ML20056G744
ML20056G744 | |
Person / Time | |
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Site: | Cooper |
Issue date: | 08/27/1993 |
From: | Milhoan J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
To: | Horn G NEBRASKA PUBLIC POWER DISTRICT |
References | |
NUDOCS 9309070112 | |
Download: ML20056G744 (16) | |
See also: IR 05000298/1993099
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>* MCg\ NUCLEdR REGULATORY COMMISSION , 'g - R EGION IV 611 RYAN PLAZA DRIVE, suite 4s0 o, * [ ARLINGTON, T E XAS 76011 8064 l << .... yyy 7 : Docket: 50-298 License: DPR-46 I Nebraska Public Power District ATTN: Guy R. Horn, Vice President, Nuclear l P.O. Box 98 i Brownville,_ Nebraska 68321 ; I SUBJECT: . FINAL SYSTEMATIC ASSESSMENT OF LICENSEE PERFORMANCE (SALP) REPORT This forwards the final SALP report (50-298/93-99) for the Cooper Nuclear Station for the period of January 19, 1992, through April 24, 1993. This ' final SALP Report includes: i 1. The cover letter for the initial SALP report (no revisions to the initial SALP report were made). 2. A summary of our July.12, 1993, meeting at the Cooper Nuclear Station security building auditorium'in Brownville, Nebraska. j Your August 11,.1993, response to the initial SALP report. l; 3. l We have reviewed your letter dated August 11, 1993, in response to the NRC ! recommendations in each of the SALP functional areas. It was noted that your ! response has identified specific-actions to improve performance in each of the l SALP. functional areas. -We will review your progress to achieve these ! improvements in inspection efforts during this SALP period. l
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The next SALP period for Cooper Nuclear Station is scheduled to last approximately 18 months, from April 25, 1993, to October 22, 1994. As identified in our letter dated August II,1993, from Mr. A. B. Beach,
. Director, Division of Reactor Projects, to Mr. G. R. Horn, Vice President, L Nuclear, the revised SALP program will be utilized.
Sincerely, 030014 y gh[ F egional Administrator ; Enclosures: :1. Cover letter for the initial SALP report 2. NRC Meeting Summary 3. Nebraska Public Power District response to the initial SALP report pD1 l i cc: -(see next page) i 9309070112 93D827 - NRC FILE PRTER COPY $DR ADOCK 05000298 PDR l
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cc.w/ enclosure: Nebraska Public Power District l ATTN: G. D. Watson, General Counsel * P.O. Box 499 i Columbus, Nebraska 68602-0499 i Cooper Nuclear Station. . ' ATTN- John M. Meacham, Site Manager - ! P.O. Box 98~ l Brownville, Nebraska 68321 :
l' l Nebraska Department of- Environmental !
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Control i' ' ATTN: Randolph Wood, Director P.O. Box 98922 Lincoln, Nebraska 68509-8922 i ; Nemaha County Board of Commissioners ! ATTN: Richard Moody, Chairman ! Nemaha County Courtbr se. ! 1824 N Street- l ' Auburn, Nebraska 68305 ! Nctraska Department of Health ! ATTN: Harold Borchert, Director . Division of Radiological Health - i 301 Centennial Mall, South l P.O. Box 95007 i Lincoln, Nebraska 68509-5007 i i Kansas Radiation Control Program Director ' ! ! : l h ! r
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_ .. - _ _ _ ___ i .. t Nebraska Public Power District -3- E 27 E I i 1 bec to DMB (IE40) i bec distrib. by RIV. 4 J. L. Milhoan- Resident Inspector l DRP . Section Chief (DRP/C) -Lisa Shea, RM/ALF, MS: MNBB 4503 MIS System DRSS-FIPS Section Chief (DRP/TSS) < RIV File . Project Engineer.(DRP/C) . l Senior Resident Inspector.- River Bend' C. A. Hackney, RSLO Senior Resident Inspector - Fort Calhoun J. T. Gilliland, PA0 The Chairman (MS: 16-G-15) . Records Center, INP0 Commissioner Rogers (MS: 16-G-15) G. F. Sanborn, E0 C. J. Gordon 0:DRP Commissioner Remick (MS: 16-G-15) RRIs at all sites , Commissioner..de Planque (MS: 16-G-15) L. J. Callan, D:DRSS l J. M. Taylor, ED0 (!!S: 17-G-21) D. D. Chamberlain, DRSS l J. M. Montgomery B. Murray, DRSS l J. Roe, NRR (MS: 13-E-4)' T. Chan, NRR (MS: 7-E-23) ! H. Rood, NRR (MS: 13-H-3) . l l RIV:DRP/C% WBJones;df C:DRP/Ci NEGagliardo , "D:DR .ABB ach ) DR J ntgomery RA YP\ JLMilhoan 8/q /93 8/,7/93 8bg/93 8/ 71/93 8g/93 l .
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Nebraska Public Power District -3- E 27 E bcc to DMB (IE40) bec distrib. by RIV: J. L. Milhoan Resident Inspector DRP Section Chief (DRP/C) Lisa Shea, RM/ALF, MS: MNBB 4503 MIS System DRSS-FIPS Section Chief (DRP/TSS) Project Engineer (DRP/C) RIV File Senior Resident Inspector - River Bend C. A. Hackney, RSLO Senior Resident Inspector - Fort Calhoun J. T..Gilliland, PA0g The Chairman (MS: 16-G-15) l Records CenterPINPO.' Commissioner Rogers (MS: 16-G-15) G. F. Sanborn, E0 C. J. Gordon D:DRP Commissioner Remick (MS: 16-G-15) RRIs at all sites Commissioner de Planque (MS: 16-G-15) L. J. Callan, D:DRSS J. M. Taylor, EDO (MS: 17-G-21) D. D. Chamberlain, DRSS J. M. Montgomery B. Murray, DRSS J. Roe, NRR (MS: 13-E-4) T. Chan, NRR (MS: 7-E-23) H. Rood, NRR (MS: 13-H-3) RIV:DRP/CN WBJones;df C:DRP/C 7D:DR DR / "] RA M NEGagli do y ABB ach JM, ntgomery JLMilhoan 8p7/93 8/r[ /93 8/) /93 8b)/93 8g/93 ..
, _ _ _ _ _ _ _ _ _ ~ -- - ENCLOSURE 1 l - p .. , m ~ Ario sr ATEs . 2: ... - NUCLE AR REGULATORY COMMISSION l : .- .. t - ;: I - REGtON av - (,e f. sn 'a v;.N PLAZA DRIVE SulT E 400 l . (I - a a u%G tOfd YE x AS 760118064 , . . . . , ~' X 2 3 NED l ! Docket: 50-298 i I Licenses DPR-46 l 1 4 l ; Nebraska Public' Power District j ATTN: Guy R.' Horn, Nuclear' Power j Group Manageri ; --- -P.O. Box 499- . Columbus Nebraska 168602-0499" '
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SUBJECT: INITIAL: SYSTEMATIC ASSESSMENT 0F' LICENSEE PERFORMANCE (SALP) REPORT f This forwards'therinitial SALP. report (50-298/93-99) for. the Cooper Nuclear . Station. The SALP Board met on May 20 and June 15, 1993, to evaluate the ! licensee's performance for thefperiod January 19, 1992,. through April 24, I 1993. The performance analyses and:resulting evaluations are documented in ~ " the-enclosed initial SALP report. In :accordance. with NRC policy, I Lhave' reviewed the SALP Board's- assessment and ' . concur'with'their ratings, as discussed below: Overall,11icensee ' performance declined in several functional' areas from the Lprevious SALP evaluation. A large' number of equipment problems occurred ! : during.the latter part of thisl appraisal period that' were' caused, in part, by the. failure'of licensee employees to. aggressively pursue the root cause of -potentially~significant equipment problems and to assume' effective ownership ' of. systems:and components. The problems were also caused by the willingness - offlicenseel personnel to live with problems rather'than thoroughly evaluate
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. degraded or potentially degraded equipment issues. . The' Cooper Nuclear Station l staff appears to be satisfied with. working around these. problems and, as a
l- result, the licensee's problem resolution process and corrective action
systems have been weak. Many of these equipment' problems were long-standing, ' and the ' f ailure to self-identify _ and correct- the problems are viewed as ~
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demonstrated fundamental weaknesses- in the oversight and self-assessment ~ functions. These concerns were most evident in the a_reas of Maintenance / Surveillance 'and Safety Assessment / Quality Verification and, as a result,.these areas were assigned-a rating'of Category 3. In Engineering / Technical: Support.Lsignificant weaknesses were observed in .p'roblem resolution.by the site engineering group. The board was concerned .with the' examples .of insufficient rigor applied to the evaluation and -resolution of'1dentified problems. The evaluations. relied heavily on verbal .information andithere was. lack of.. formality-in the approach to the resolution :of these problems.which-contributed to escalated enforcement actions. The board; assigned'a rating of Category l2 because of the performance of the corporate engineering. group'and the improvements in operations training. h . . - _ ._ _ . _ . _ . _
. Nebraska Public Power District -2- Performance in the functional area of Operations was mixed and assigned a rating of Category 2. Routine operations remained strong, but there was a lack of a questioning attitude on the part of the operating staff for some engineering operability determinations. This lack of a questioning attitude ! may have contributed to some of the plant problems identified during this ; period. The relationship between the operations and training staffs has < improved but requires some additional attention. ' 3 In Radiological Controls, performance has improved. The radiological controls staff has made major strides in improving the overall prognm. The board was l concerned, however, with the apparent lack of aggressiveness in identifying radiological performance weaknesses. Nevertheless, overall performance was ' . assigned a rating of Category 2 and was assigned an improving trend. ! ! Recurring problems in the areas of offsite notification, emergency assessment, and decisionmaking tended to offset the improvements noted in the area of , l Emergency Preparedness. The failures to follow up on previously identified : findings and tht: additional violations indicated a need for increased i management attention. This area was assigned a rating of Category 2 with a i declining trend. ; ; The area of Security continues to be a strength.and was assigned a rating of Category 1. On the basis of the SALP Board's assessment, the length of the SALP period will be'approximately 15 months. Accordingly, the next SALP period will be from April 25, 1993, to July 30, 1994 A management meeting has been scheduled with you and your staff to review the 4 results of the initial SALP report. The meeting will be open to the public j and held at the Cooper Nuclear Station security building auditorium on July 9, 1993, at 10 a.m. Within 20 days of this management meeting, you may provide , comments on and amplification of, as appropriate, other aspects of the initial : SALP report. ~ ; ; Your written comments, a summary of our meeting, and the results of my [ consideration of your comments will be issued as an appendix to the enclosed i initial SALP report and will constitute the final SALP report. 1 Sincerely, ( /)x tJA ames b. L. Milhoan Regional Administrator
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Enclosure 2
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JANUARY 19,1992
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APRIL 24,1993
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. l . l l AGENDA , l ; INTRODUCTIONS NRC NPPD I i OPENING REMARKS / JAMES L. MILHOAN ! PERFORMANCE OVERVIEW FUNCTIONAL AREA DISCUSSION A. BILL BEACH COMMENTS AND/OR QUESTIONS NPPD CONCLUDE MEETING COMMENTS AND/OR QUESTIONS PUBLIC/ MEDIA l [ ') _ . _ _ ._ _ - _ . _
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OVERVIEW OF PERFORMANCE
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; * DECLINING PERFORMANCE
- * FAILURE TO SELF-IDENTIFY PROBLEMS
* WEAK PROBLEM RESOLUTION
. l o A LACK OF A QUESTIONING ATTITUDE
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o WORK AROUND PROBLEMS
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. o WEAK ROOT CAUSE ANALYSIS
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. _ ._._ .. ._ . _ . _ .._ _ _ _ _ -. _ _ . .. _ . _ . _ _ _ . _ . . _ _ _ _ .. . _ _ _ .. _ _ _ ._ . .- PLANT OPERATIONS CATEGORY 2 PERFORMANCE MIXED * WEAKNESSES DESCRIBED IN PREVIOUS SALP RECEIVED MANAGEMENT ATTENTION * MANAGEMENT ATTENTION EVIDENT IN ROUTINE
OPERATIONS
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* HOUSEKEEPING GOOD * LACK OF QUESTIONING ATTITUDE - OPERABILITY
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DETERMINATIONS
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. - - - . - . . . - . - . . - . . . . - - - . . i MAINTENANCE / SURVEILLANCE CATEGORY 3 SIGNIFICANT DECLINE IN PERFORMANCE ' e WEAKNESSES IN TESTING AND MAINTENANCE OF EQUIPMENT .
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- o REACTOR BUILDING
! o SERVICE WATER SYSTEM i o REACTOR COOLANT PRESSURE ISOLATION l VALVES ! o CONTAINMENT ISOLATION VALVES l o STATION BATTERIES
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. - .-. . .. .- - - - ... -- . .. . .-. _. .. - . - . . _. . - - .- - .. - - _ - . .- . . .. .. . . . I SECURITY CATEGORY 1 1 ' e e. STRONG PERFORMANCE
. ! e PERFORMANCE EXCELLENT I ! .
* PROGRAMS EFFECTIVELY MANAGED -
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. . . _ _. _ _ _ _ _ . _ _ _ _ . _ _ _ _ . . _ . . . D SAFETY ASSESSMENT / QUALITY VERIFICATION CATEGORY 3 FUNDAMENTAL WEAKNESSES IN CORRECTIVE ACTION PROCESSES AND SELF-ASSESSMENT
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e INEFFECTIVE PROBLEM RESOLUTION
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e OVERSIGHT AND SELF-ASSESSMENTS DID NOT IDENTIFY WEAK CORRECTIVE ACTION PROCESSES
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IMPLEMENTED
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PLANT OPERATIONS CATEGORY 2 PERFORMANCE MIXED e WEAKNESSES DESCRISED IN PREVIOUS SALP RECEIVED MANAGEMENT ATTENTION * MANAGEMENT ATTENTION EVIDENT IN ROUTINE OPERATIONS * HOUSEKEEPING GOOD * LACK OF QUESTIONING ATTITUDE - OPERABILITY DETERMINATIONS - -- -- - _ _ _ _ - -. - - - _ _ _ - _.
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- RADIOLOGICAL CONTROLS
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CATEGORY 2
IMPROVING PERFORMANCE * STRONG MANAGEMENT SUPPORT FOR ALARA PROGRAM e EFFECTIVE EXTERNAL AND INTERNAL EXPOSURE CONTROLS * NOT AGGRESSIVE IN IDENTIFYING PERFORMANCE WEAKNESSES ' ~ _ _ _ _ . . _ _ _ _ m
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' MAINTENANCE / SURVEILLANCE C ATEGORY: 3
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- SIGNIFICANT DECLINE IN PERFORMANCE
l ! e WEAKNESSES IN TESTING AND MAINTENANCE OF
a EQUIPMENT
i ! o REACTOR BUILDING l
o SERVICE WATER SYSTEM
! o REACTOR COOLANT PRESSURE ISOLATION ! VALVES '
o CONTAINMENT ISOLATION VALVES
l o STATION BATTERIES l ! ! !
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EMERGENCY PREPAREDNESS CATEGORY 2 DECLINING PERFORMANCE * IMPROVEMENTS IN AREAS NOTED IN PREVIOUS SALP * RECURRING PROBLEMS NOTED IN OFF SITE NOTIFICATIONS, EMERGENCY ASSESSMENTS, AND DECISION MAKING * INCREASED MANAGEMENT ATTENTION NEEDED - 'o
. . . b SECURITY CATEGORY 1 t STRONG PERFORMANCE e PERFORMANCE EXCELLENT e PROGRAMS EFFECTIVELY MANAGED
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ENGINEERING / TECHNICAL SUPPORT CATEGORY 2
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ENGINEERING PERFORMANCE MIXED
* MODIFICATION PROCESS EFFECTIVE * SIGNIFICANT WEAKNESSES IN PROBLEM RESOLUTION 3 - - _ _ - _ - _ _ _ _ - _ . - _ _ _ _ __ _ ___ _ _ _ _
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' SAFETY ASSESSMENT / QUALITY VERIFICATION CATEGORY 3 FUNDAMENTAL WEAKNESSES IN CORRECTIVE ACTION PROCESSES AND SELF-ASSESSMENT * INEFFECTIVE PROBLEM RESOLUTION * OVERSIGHT AND SELF-ASSESSMENTS DID NOT IDENTIFY WEAK CORRECTIVE ACTION PROCESSES e INITIATIVES TO IMPROVE CORRECTIVE ACTIONS IMPLEMENTED
. _ _ _ _ _ _ _ _ _ - _ _ _ _ _ _ _ _ _ _ - _ _ _ _ _ _ _ _ _ _ _ _ _ - _ _ _ - _ _ _ - - _ _ _ _ _ _ _ - _ _ _ - _ _ _ _ _ _ COOPER. NUCLEAR STATION OVERALL PERFORMANCE SUMMARY RATING LAST RATING THIS PERIOD PERIOD FUNCTIONAL AREA 7/16/90-1/18/92 1/19/92- 4/24/93 2 2 PLANT OPERATIONS 2' 2 RADIOLOGICAL CONTROLS 1 3 MAINTENANCE /SURVElLLANCE
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2 2" EMERGENCY PREPAREDNESS 1 1 SECURITY 2 2 ENGINEERING / TECHNICAL SUPPORT 2 3 SAFETY ASSESSMENT / QUALITY VERIFICATION * IMPROVING TREND * * DECLINING TREND _ . . _ _ _ _ _ _ - * .O
- - ENCLOSURE 3
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GENER AL OF FfCE =~ ' P O BCx 899 COLUMBUS NEBRASKA 686024499 - Nebraska Public Power District ~'% MTATf"' __ NSD930977 Auguat 11. 1993 U.S. Nuclear Regulatory Commission Document Control Desk Washington, DC 20555 Gentlemen: Subject: Sveramarie Aasm _= =* m e of 1.i cens ee Performance (SALP) Report (inspection Report 50-928/93-vy) On July 12, 1993, Nebraska Public Power District (NPPD) management personnel met with NRC management to review the results of the SALP report for Cooper Nuclear Station (CNS) for the period January 19, 1992 through April 24, 1993. The purpose of this letter is to provide comments on the SALP report in addition to those made at the public SALP neering. NPPD wishes in emphasize its commitment to the continued safe operation of CNS. As indicated by NPPD management at the public SALP meeting, the District will be focusing intensely on the issues contained in the SALP report to improve the overall performance of Cooper Nuclear Station. The District will com:mit the resources and management attention necessary to effect the necessary improvements in the District's nuclear program. NPPD has analyzed the licensee recom:nencations identified in the SALP report and the attachment addresses the recommendations made by the NRC in each appropriate functional area. As stated during the SALP meeting, many corrective measures have been taken or are in progress to address the concerns expressed in the SALP report. The District appreciates the feedback provided by the SALP process and is committed to significant improvement in the perforznance of CNS. Sine rel , C. . /w orn N r Power Croup Manager g 2' /rg [[ ' Attachment r -yG"'
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NSD930977 August 11. 1993 Page 2 cc: Regional Administrator USNRC Region IV NRC Resident Inspector Cooper Nuclear Station i ! l l l
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. .- - , -. ' ! . t : . ! ; NSD9309',7 ! Attachement f Page 1 of 8 ! ! i : ! SALP RECOMMENDATIONS AND RESPONSES July 1993 , A. Plant Onorations , i i j HEC Race - ndation i Licensee management needs to take appropriate measures to assure that the j ' long-term issue of operator communications . during nonroutine operating activities has been included in the training process for all operators. j The licenses should implement an effective process for-the evaluation of ; deficient conditions that impact the safe operation of the facility, j ! NFPD Response Operations management has exerted considerable effort towards improvement ! of operator communications as described in the quarterly status reports of j j the 1992 SALP Action Plan. The most recent SALP report appropriately In an effort to enlist l ~ described this issue as an " ongoing challenge *. the support of those affected, Operations management will meet with the l
- supervision from each operating crew to discuss communication inadequacies l
and to solicit their input fer implement % further improvements. Topics ! currently under consideration are objecciva grading of casesunications [ during training, incenti_ves for high performance, methods for utilization j of video taping to improve communications, the retention of training l principles such that lessons learned are taken back into the plant Control l Room and increased overview by .ansgsment. l The Operability Determination process will be reviewed and revised, as , necessary, to enhance Shift Supervisor review of Operability i Determinations and Evaluations. This- enhancement will further the review , process to promote technical' adequacy and effectiveness. : r i ! , i . . . . _ _,_m - _ . , ._--- . - - . . - . _ . . . . . ,,-...
_ - _ _ . . NSD930977 Attachment Page 2 of 8 ,
B. - h diolonical Controls
NRC Reec--- dation The licensee needs to implement measures to assure that the facility staff is imore aggressive in the pursuit of issues which are to be documented in the radiological safety incident report process by site procedures. NPPD Response To upgrade the radiological . problem resolution process, the Corrective Action Program will be revised to clearly describe occurrences which meet the established initiation criteria for a Radiological Safety Incident Report (RSIR) . These criteria vill be established such that radiological incidents which demonstrate a weakness in the CNS Radiation Protection Program will receive the necessary station management attention and ; involvement to ensure timely, results-oriented corrective action. i To address less significant radiological problems, new thresholds, , comparable to the those currently established in the lower threshold l Corrective Action Program, will be developed. These thresholds will , address occurrence.s indicative of undesirable performance, with the degree 1 of radiological safety significance lower than that established by the l RSIR. Trending of radiological problems will be developed to provide a mechanism , by which Station Management is kept informed of the Radiation Protection Program performance. The procedure changes necessary to upgrade the Corrective Action Program relative to radiological problem resolution will be developed and implemented by January 1994
_ -. ._ _ . _ - _ s ! , s l NSD930977 l Attachment ) Page 3 of 8 ) l l C. Maintenance /Surve111ance j i 1 l MRC Racommandation The licensee. should review the scope and depth of maintenance / surveillance activities' to make sure that the maintenance and surveillance programs for - safety-related equipment are adequate to assure chat the equipment can and will, continue to perform its safety functions. The licenses should also increase ;the emphasis on oversight by plant w=mgement and systems engineering to . provide an increased level of technical support to the maime====ce and surveillance' activities at the plant. Management should provide additional emphasis . on generation of thorough and detailed ma?ntenance .and surveillance procedures, and on the need for mainte== nee / surveillance personnel to carefully. follow the procedures. NFFD Rappense Mainte===ce activities and programs' for all safety-related systems, structures, or components will be reviewed in conjunction with Maintenance Rule implementation. Preventive Maintenance activities and maintenance procedures will be thoroughly reviewed as a part of this process and will be revised as necessary to ensure accuracy. Maintenance craft training will continue' to stress the necessary requirements for procedural compliance and - attention to detail. Maintenance Management and supervisors will monitor performance in this area through field observation in accordance with Maintenance Procedure 7.0.4, Conduct of Maintenance.
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Tkw SALF analysis 'for the . Maintenance / Surveillance area noted that corrective actions had been initi.ated for several issues identified at the end of the SALP period which will be continued during the next period. Some of the specific programs which will ' receive additional evaluation _ include pressure isolation valve and check valve testing, local leak rate testing, and -inservice inspection and testing. In addition, the verification of the adequacy. of surveillance procedures has been included . in the Design Basis Reconstitution Program. More emphasis is being placed on system engineer _ involvement in overdi plant problems from initial I I identification through the tisaly, complete achievement of results. It . will be ' stressed with Maintensace and operations personnel to utilise the Engineering staff when problems first arise to enhance their resolution. As noted in the Engi.neering/Jachnical Support response, system engineer involvement led to the resolution of a number of longstanding and emergent " problems during the refueling outage. Engineering is also reviewing their current programs to ensure there is better utilization of their resources. 1 These actions will ensure better responsiveness and overview of plant activities. In addition. attention to the above activities and to compliance with all maintenance and surveillance procedures will be ; emphasized by Management. l
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NSD930977
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.D. Emergency Prpoaredness ! l ;
i 1RC Racemmenda): ion
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Licensee nmeds to take actions to assure that the recurring issues in
f' ' offsite notification, amer 5ency assessments, and decision making have been l
corrected.. ! ' MFFD Raanonse
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The District has installed a new ' hotline *. telephone system to remedy the recurring problems with late offsite notification. The new system is > independent of the. local telephone switching. channels and.will therefore
, be available even if . local telephone usage is heavy. The system was
successfully demonstrated during the initial notification of the recent ,
L : July 24, 1993 Notification of Unusual Event brought about by local area ,
flooding around the plant. The new system completed notification to all l ! applicable agencies within eight minutes of its initiation, well within the 15 minute criteria. Additionally, revisions have been made to plant procedures to ensure adequate cosmiunication takes place between the I Station Operations Review Committee and the Shift Supervisor on matters which may .. involve an event with an emergency classification. This ! upgraded coordination has been demonstrated to be effective on three l separate occasions in ensuring the timely declaration and notification of ! an event at' Cooper Nuclear Station. [ t I A change to the Emergency Response Organization (ERO) has been implemented to address the wa=1 mass noted in the area of emergency assessment. This [ change now has the Plant Manager remaining in the Technical Support Center ! ' (TSC) in the role as the Emergency Operations Director, rather than physically moving out to the Emergency Operating Facility. By remaining in the TSC, the Plant Manager will enhance the plant technical support and , j emergency assessment activities so that the facility can maintain a continuity of planning and implementation of the necessary support i
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activities. . In addition, ERO position specific training covering Accident [ Nanagement Techniques was conducted in March,1993 to enhance personnel . ; " knowledge and 1 consideration of emergency ' assesamant. Aspects of this training will-be incorporated into the ongoing EP training and assessment I process. .The skills acquired from this training were effectively ; demonstrated during a June 15, 1993 drill. In the area of decision ! ? making,' training has been conducted for " low threshold * core damage events 'where the indicated plant parameter are close to the threshold levels for . declaring a General Emergency. Particular emphasis han been placed on l degraded core symptoms and indicators for the potential loss of fission ! . product barriers. These ' low threshold" core damage scenarios have been In ! included into the . training program for future training and drills. l addition, practices at other nuclear facilities .in these areas are , observed . on a periodic bases by District personnel and evaluated for . incorporation into the District's program as appropriate. , i ! --- - --- ---_ _ _ . _ - _- __ _ __ ,
_ i - . 4 i NSD930977 Attachment Page 5 of 8 ! I E. Security i NRC Kecoman.ndation l l None. I I ; NFFD Resnonse I security will continue to receive strong management support with emphasis on program improvements. To enhance personnel readiness, response contingency - training and force-on-force exercises will be a priority. Additionally, training aids will continue to be assessed and upgraded, accordingly. To enhance security system readiness and response, a video capture system will be installed. Once implemented, these enhancements will be assessed to assure the ongoing effectiveness of the Security program.
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NSD930977 Attachment Page 6 cf 8 . F. heinserine/ Technical Supeort HE9 EAAREupendation The licensee needs to resolve plant problems by correcting the root cause, with the objective of closing the issue with finality, rather than by using a quick-fix approach to mitigate the insmediate sympcoma. The licensee should put more thoroughness. formality, and attention to careful documentation into the process. The licensee should also give management oversight and/or system engineering function more emphasis, with more responsibility and authority for reviewing all aspects of a problem. NPPD Resnonse
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Actions have been initiated to strengthen the Engineering / Technical Support staff in order to provide more effective support of plant operation. Increased emphasis is being placed on system engineer involvement in plant problems from the initial identification through the timely, conclusive achievement of results. Multi-disciplinary or multi- system casks assigned to the engineering staff are now being evaluated and resolved through the use of an engineering department instruction to ensure comprehensive reviews and corrective actions are performed. Job performance guidelines for system engineers will also be reviewed and clarified as appropriate to ensure management expectations are clearly defined.
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To promote the identification and correction of problems which may constitute a nuclear safety concern, Management expectations stressing the need for a questioning attitude have been effectively communicated to Engineering personnel. This has resulted in the resolution of several longstanding problems and numerous emergent problems during the recently completed refueling outage. This same attitude is being stressed to eliminate repeat equipment fs' 5res by ensuring engineering evaluations are performed in a rigorous Lnaal manner relying on confirmation of results. In addition, management is emphasizing the identification and resolution of plant problems as a positive aspect of their jobs. These changes will continue to be reinforced and supported to ensure that the practices become deeply ingrained in the engineering culture. Various policies and procedures are being evaluated to increase the efficiency and timeliness in which problems are resolved. In addition. a review has identified the need for streamlining some programmatic processes, and the redistribution of others, in order to better utilize the CNS engineering resources. Finally, managerial oversight of system engineer activitiss is being increased to ensure that appropriate levels of roeponsibility and authority are assigned for resolving all aspects of piant probisms.
___ _ __ _ _ , - - _ - - . _ . - - - - _ - - _ - - - - _ . . _ . t . NSD930977 Attachment Page 7 of 8 C. Safety Assasemarie/Ouality Verification NRC Recommendation Licenses management needs to perform a critical assessment of their corrective action processes in light of the problems identified by the NRC and correct the process to assure that the process is meeting licensee and NRC expectations. NPFD Rasnonse The District has performed a critical assessment of the Corrective Action Program through multiple approaches and means. These elements of our assessment are as follows: 1) A Corrective Action Program Overview Group (CAPOG) was found in April.1993 to ensure that problems related to nuclear safety were: a) Promptly identified b) Properly evaluated regarding their significance c) Effectively cwmicated to appropriate personnel
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d) Aggressively resolved with rigor commensurate with their
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safety significance. The CAPOG is composed of three senior personnel dedicated full time to this effort and reports to the site manager. Assessment of CAPOG's activities by Quality Assurance and an outside expert have concluded that CAPOG was effective and was helping conusunicate managements' expectations to plant personnel of a safety first and fix it right the first time culture. 2) The existing Corrective Action Program as a whole was recently evaluated by a Corrective Action Program Self Assessment Group (CAPSAG). The scope of its review was to evaluate: a) Managements' effectiveness in directing, supporting and monitoring the Corrective Action Program b) Corrective Action Program content, method and implementation c) Corrective Action Program overall effectiveness
. t i I l l 1 NSD930977 #. Attachment , ; Page 8 of 8 i ' 3) An investigative team was formJd in July, 1993 to perfona an independent assessment of enforcement issues identified in NRC ! Inspection Report 93-17. One of the objectives of this six member i ' team was to determine the adequacy of the proposed corrective actions to the identified issues and to recommend additional actions , to prevent recurrence. 4) A performance assessment project was performed in late 1992 by an ;
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outside agency at the request of senior NPG management to. ! a) identify root causes of the lack of uniform performance by District personnel b) identify changes needed to raise levels of performance [ ' up to managements' expectations '
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c) provide recoassendations to effect thema changes
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Information and conclusions of the above group's assessments of the Corrective Action Program have been taken and evaluated by NPG senior management. It has been determined that the program must be improved by:
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1) Improving the process by making it more stream lined . I
i 2) Clarification and enforcement of ownership and accountability ;
! ; ' ' 3) Improve communications at all levels to ensure all personnel get the same message ;
, 4) Establish program performance monitoring including indicators.
S 5) Increased management oversight of the corrective action process. The District believes the above efforts and the future program improvements will address the District's concerns with the Corrective Action Program. .
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