ML20080N060
| ML20080N060 | |
| Person / Time | |
|---|---|
| Site: | Cooper  |
| Issue date: | 08/15/1983 |
| From: | Schaufelberger NEBRASKA PUBLIC POWER DISTRICT |
| To: | Jay Collins NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| References | |
| EA-82-046, EA-82-46, NUDOCS 8310040348 | |
| Download: ML20080N060 (38) | |
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GENERAL OFFICE Nebraska Public Power District
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August 15. 1983 Mr. John T. Collins Regional Administrator U.S. Nuclear i.egulatory Commission Region IV g ; gfgg")
6111 Ryan Plaza Drive, Suite 1000 Arlington, Texas 76011
Dear Mr. Collins:
Subject:
Response to Order Modifying License; Management Appraisal of Corporate Management Docket No. 50-298 License No. DPR-46 EA 82-46 This -letter forwards the District's response to recommendations contained in the report of an independent appraisal of site and corporate nuclear management organizations and functions performed by LRS Consultants, Inc., of Idaho Falls, Idaho.
The appraisal was conducted during the period February through April, 1983, pursuant to the subject Order Modifying License
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Effective Immediately dated August 9,1982.
Section IV of the Order required that within 30 days of receipt of the appraisal report the District was to submit an analysis af each report recommendation, action to be taken in response to the recommendations, and a schedule for accomplishing the actions.
Your letter of June 21, 1983, extended the submittal date to August 15, 1983, in answer to our letter request dated June 9,1983.
The responses in the attachment are organized in the same functional areas presented in the LRS Report.
The recommendations are numbered as in the report and are repeated in the attachment for ease of review.
Milestone and completion dates for intended actions have been specified where possible.
l The District is committed to maintaining the superior performance record of the Cooper Nuclear Station and its operations in a safe and reliable manner.
Senior management has analyzed the Report's recommendations with this objective in mind.
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1\\lr. Johil T. Collins Paga 2 August 15, 1983 As you are aware, the District has made significant management changes, both at the Cooper Nuclear Station and at the General Office in Columbus.
Described in the attachment are further actions intended to enhance communications, support, training, operations, and management overview within the District's nuclear organization to maintain, and improve where possible, the safety and efficiency of our total nuclear program.
Progress toward completion will be closely monitored to assure the successful accomplishment of these committed tasks.
The Board of Directors and I are committed to assembling and maintaining a nuclear management team which reflects the high standards of excellence which exists within the nuclear industry.
We are confident that the steps we are taking will achiev'e this desired result.
Our efforts in this regard will continue.
We believe that this submittal completes all required actions relative to the Order Modifying License.
Now that the management evaluation and our assessment of its recommendations have been concluded, we are not aware of any reason under applicable regulations to request that the LRS Report or this submittal be withheld from public disclosure.
If you desire any other information, please advise.
Sincerely, NEBRASKA P 'BLIC POWER DISTRICT W
Don E. Schaufelb General Manage DES / gat:emzll/ 3 Attachment
ATTACHMENT ORGANIZATION, MANAGEMENT, AND PERSCNNEL o
RECOMMENDATION OM-1 The Board should develop some long-range overall Goals and Objectives for the District that could be adjusted from time to time but would survive Board member changes.
RESPONSE
The General Manager is currently meeting periodically with the Board of Directors with the express purpose of developing long-range goals and objectives for the District.
The work effort is already underway.
An initial draft will be discussed with the Board prior to the September meeting and it is expected that the final document will be approved by the Board by year-end 1983 with further efforts continuing thereafter, o
RECOMMENDATION OM-2 The-staff should develop near-term and long-term strategies, plans, and programs throughout the organization that will accomplish the Board's overall direction.
RESPONSE
The staff developed on July 15 a format and some initial goals and objectives based on anticipated overall objectives of the District.
As the Board defines and promulgates the District objectives, the specific goals of the nuclear organization will be modified, amplified, or revised to best support the Board's objectives.
A first draft of the nuclear organization's goals as agreed upon by all key managers will be submitted to the General Manager by November 15, 1983, for review and comment.
The final set of approved goals and objectives will be issued by December 15, 1983, for the calendar year 1984, o
RECOMIENDATION OM-3 The Board should consider more definitive delegation of broader authority to the General Manager thus removing itself further from operational details.
A clear job description would be necessary in this regard.
RESPONSE
The Board of Directors will consider further delegation of broader authority to the General Manager recognizing applicable limitations existing in Nebraska Statutes.
The General Manager will develop a job description by September 15, 1983.
The job description will be submitted to the Board of Directors for review at the September 1983 Board Meeting.
The job description will be finalized in October, 1983, and approved at the October 1983 Board Meeting..
ORGANIZATION, MANAGEMENT, AND PERSONNEL (Cont'd) o RECOMMENDATION OM-4 Top management needs to improve significantly its nuclear communications to the Board, which in turn needs to be receptive.
RESPONSE
The Assistant General Manager - Nuclear has instituted a practice, as important matters arise, of sending relatively brief, but informative letters to the Board to forewarn them of coming problems.
The Nuclear Power Group staff is currently considering additional mechanisms to ef fectively enhance information flow to keep the Board better informed.
Key among these is a proposed recommendation that the Board consider the establishment of a Nuclear Power Committee, which, during monthly meetings, could be briefed in detail on nuclear industry activities specifically relevant to the operation of CNS.
The Board, on the other hand, has significantly increased its attention to and awareness of nuclear matters.
As a result, the Board has been very supportive of the efforts being made to improve the District's nuclear program.
o RECOMMENDATION OM-5 Team work between the Board and canagement based on mutual trust and respect, needs to be developed.
RESPONSE
The Board and District management are dedicated individually and collectively to developing and maintaining team work in order to best support the safe and efficient operation of the Cooper Nuclear Station.
The Board President and the General Manager have as the District's top priority the forming of a strong team at NPPD that will work together to the benefit of all the District's customers.
A Board Committee is currently working with the General Manager to develop this teamwork statement.
As a result of discussions between the Board and District management, concerning the LRS audit findings, a more frank and open relationship has developed which, we believe, will result in mutual trust and respect. -
ORGANIZATION, MANAGEMENT. AND PERSONNEL (Cont'd) o RECOMMENDATION OM-6 Top management needs to make some hard and possibly unpleasant decisions to gain credibility with the Board.
RESPONSE
Top management has made some hard decisions in the very sensitive area of personnel changes.
There have been several changes at the Assistant General Manager level, including one termination, two promotions, and two reassignments.
A senior division position has been eliminated, a plant superintendent removed, and several division and departnent managers terminated, reassignede or demoted, depending on specific circumstances.
In addition, the nuclear organization has been restructured for more effective performance, efforts are being made to recruir experienced personnel for several key positions and an extensive effort has been mounted to clear up confusing organizational interrelationships.
o RECOMMENDATION OM-7 A planned program needs to be developed for assuring the continuing provision to Board members of critical nuclear information.
This should not be accomplished with pounds of documents but by carefully abstracting vital information from NRC, NSAC, INPO, NPPD and other utilities and providing approximately a one or two page summary each week.
This document might serve a useful function for senior staff also.
RESPONSE
The Assistant General Manager - Nuclear will be briefing the Board on the status of nuclear generation at each Board meeting.
This level of contact is important and effective in keeping the Board members appraised of significant nuclear matters.
In addition, the Assistant General Manager - Nuclear will provide a brief report of various nuclear topics to the Board of Directors, the General Manager, and senior staff at his discretion.
Also, the Nuclear Power Group staff is currently considering additional mechanisms to effectively enhance information flow to the foregoing. --
ORGANIZATION, MANAGEMENT, AFD PERSONNEL (Cont'd) o RECOMMENDATION OM-8 Establish the position of Assistant General Manager - Nuclear, with clearly defined responsibilities, duties, and authority.
RESPONSE
The posit. ion of Assistant General Manager - Nuclear has been established.
A draft position description has been prepared and is currently being reviewed.
The position description, with clearly defined responsibilities, duties, and authority, will be approved by October 1, 1983, o
RECOMMENDATION OM-9 Either assign an AGM - Nuclear from within the District or if no one internally is deemed qualified, select an Acting AGM and initiate recruiting efforts promptly.
RESPONSE
An individual to fill the position of Assistant General Manager -
Nuclear has been selected from within the District and has been assigned the responsibilities of the position.
o RECOMMENDATION OM-10 Consider organizing the Nuclear Operations of the District in general accordance with the attached organization charts, Figures 2-1, 2-2, 2-3, and 2-4.
RESPONSE
An organization chart of the Nuclear Power Group, including Department Manager level positions, was transmitted to NRC -
Region IV by Mr. D. E. Schaufelberger's letter dated July 1, 1983.
This organization was discussed with various NRC staff personnel at a meeting held at Region IV on July 21, 1983.
ORGANIZATION, MANAGEMENT, AND PERSONNEL (Cont'd)
-o RECOMMENDATION OM-11 4
Develop jurisdictional statements for the nuclear organization and for its components.
RESPONSE
Organizational descriptions will be prepared for the nuclear group and each subordinate division and department.
These descriptions will specify functional responsibilities and organization structure
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and will define interf ace relationships between the subordinate
. units of the group and between the nuclear group and other NPPD organizations.
These descriptions will be completed by January 1, 1984.
In the interim, the nuclear organization will function under i
general guidelines promulgated by the Assistant General Manager -
Nuclear.
o RECOMMENDATION OM-12 Develop clear-and accurate position descriptions for all key nuclear and nuclear support personnel.
-RESPONSE (Proposed)
Position descriptions for key nuclear management personnel will be written as part of the nuclear group organizational development.
These descriptions will be maintained in a central file and will be reviewed and revised as necessary at two year intervals.
Initial position descriptions for all key nuclear personnel will be produced and on file prior to January 1, 1984.
o RECOMMENDATION OM-13 Several present line and support management personnel should be 4
i considered for removal from the nuclear management structure of the District to allow'for promotions and/or new personnel.
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RESPONSE
Several line and support management personnel have been removed from the nuclear management structure of the District.
These changes at the Cooper Nuclear Station and within the nuclear support organization at headquarters have permitted the District to advance certain District ' personnel to increased levels of responsibility.
The District will consider the promotion / reassignment of existing personnel or the recruitment of new personnel to fill positions created by the establishment of the new nuclear group.
ORGANIZATION, MANAGEMENT, AND PERSONNEL (Cont'd) o RECOM!ENDATION OM-14 Active involvement of General Of fice management in the CNS must be developed.
Conversely, CNS management needs to eliminate the isolation it has established and become active participants with the General Office.
RESPONSE
Recent management changes have already resulted in an improvement in working relationships and effective communications between the General Office and the Cooper Nuclear Station.
The new nuclear group organizational descriptions will emphasize close relationships and active participation in a " team" concept among all nuclear subordinate units.
Meetings between Cooper Nuclear Station and General. Office counterparts are occurring on a routine basis.
The Division Manager of Nuclear Operations is involved in the planning and structuring of the Nuclear Power Group.
Two CNS personnel have been "on loan" to the General Office to aid in the reorganization, produce job descriptions, etc.
Additionally, General Office personnel are visiting the CNS and discussing current situations and problems with CNS personnel on a routine and frequent basis., -
. ORGANIZATION, MANAGEMENT, AND PERSONNEL (Cont'd) o.
RECOMMENDATION OM-15 Management training and development programs need to be implemented for the nuclear managers and supervisors.
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RESPONSE
Management and supervisory training, as in the past, will continue to be avai b le from the Columbus General Office Training Department to aid in the management training and development of the Nuclear staff.
At present', the Columbus Training Department is offering courses on Supervisory Skills, Interviewing Skills, Performance-Appraisal, Time Management, Motivation, Planning and Conducting Meetings, Individual Assessment - Profile, and a course on Written Communications throughout the Nebraska Public Power District's organization, including, Cooper Nuclear Station.
Training programs to be available in the near future include Equal Employment Opportunity Training, Stress Management, and a Human Values System workshop.
To enhance the scheduling and availability of these training programs to supervisor and management personnel throughout the District, the Columbus Training Department will publish a schedule of these training activities.
This schedule will be available to management throughout Nebraska Public Power District including the Cooper Nuclear Training staff and will aid in the coordination of activities between the Nuclear and Columbus General Office Training Departments, o
RECOMMENDATION OM-16 The District needs to develop a succession planning program, especially for key positions such as CNS Superintendents, division managers, and the AGM - Nuclear.
RESPONSE
The District recognizes that an overall succession program is a vital part of a smoothly functioning organization.
We believe that the development of such a program will require significant input and participation of all senior personnel in the Nuclear Power Group.
Therefore, detailed planning will be initiated as soon as practicable upon completion of the key personnel staffing.
We anticipate that the program will be functional by the end of calendar year 1984. -
ORGANIZATION, MANAGEMENT, AND PERSONNEL (Cont'd) o RECOMMENDATION OM-17 Delegation of signature authority for routine matters should be encouraged and supported at all levels of management.
RESPONSE
Several actions, relating to delegation of signature authority, have already occurred.
Some of these are as follows:
1.
The General Manager has delegated approval of travel authorizations to the Assistant General Managers.
2.
The Assistant General Manager - Nuclear has delegated approval of purchase orders, less than $20,000, which do not involve professional
- services, to the Division / Department Managers.
Furthermore, the AGM -
Nuclear has asked that the Division / Department Managers review their cperation to determine whether purchase order approval should be delegated further.
3.
The Division - Manager of Nuclear Operations (CNS) has delegated the signing of time sheets to his various departments.
The General Manager and Assistant General Manager - Nuclear will evaluate the delegation of additional signature authority to the Division / Department Managers.
This evaluation will be complete by the end of 1983.
Some signature authorizations which will be evaluated are as follows:
Payroll Change Authorizations Capital Budg_ Requests (Pila) less than $50,000 Work Orders less than $50,000 Work Order Supplements less than $50,000 above the original Work Order amount Travel Authorizations Overtime approval Some of these items may be delegated to area supervisors pending further review. -
ORGANIZATION, MANAGEMENT, AND PERSONNEL (Cont'd) o RECOMMENDATION OM-18 Management and the Board should recognize the hazards to safe and efficient operation resulting from high turnover of key personnel at CNS and take action to reverse this trend.
RESPONSE
Management and the Board of Directors do recognize the hazards to safe and efficient operation resulting from high turnover of key personnel at CNS.
Management has and will continue to implement programs that are intended to reverse this trend.
Some actions have already been taken to reverse the high attrition rate at CNS including the following:
o Station management and personnel changes District organization changes including expanded staffing o
o Improved communications between the Station and the General Office o
Development of integrated teamwork o
Improved the license bonus administration o
Filled some long existing vacancies o
Established a training organization o
Initiated review and evaluation of salary levels I
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ORGANIZATION, MANAGEMENT. AND PERSONNEL (Cont'd) o RECOMMENDATION OM-19 Recruitment of supervisory personnel with nuclear and management experience for assignment to CNS and the General Office should be a high priority effort of the District.
o RECOMMENDATION OM-22 Line nuclear management needs to work closer with the recruiting personnel to better assure neeting the staffing needs of CNS and supporting organizations.
RESPONSE
The Assistant General Manager - Nuclear is placing high priority on the recruitment of qualified and experienced personnel for assignment to positions established within the nuclear group.
He is working in close coordination with the Personnel Manager in this effort.
The Personnel Department will provide the Assistant General Manager - Nuclear a monthly report of nuclear group staff vacancies, summary of recruiting efforts, job offers made, acceptances, rejections, and other related information.
This report will be used to monitor staf fing efforts such that corrective actions can be taken where appropriate.
In addition, coordination between CNS and the General Office Personnel Department has been improved.
For example, the Recruiting Supervisor is now periodically visiting the station to gain a better appreciation of the station's needs in order to do a more thorough job of screening resumes and assisting the site in obtaining the best qualified candidates for employment.
ORGANIZATION, MANAGEMENT, AND PERSONNEL. (Cont'd) o RECOMME'..DATION OM-23 Personnel in supervisory ' or management positions that are impeding the growth potential of more productive employees, should be considered for reassignment to allow upward movement of present subordinates.
RESPONSE
. Several individuals in supervisory or management positions have been removed ~ from the management chain, thus opening up numerous j
opportunities for promotion and advancement.
o RECOMMENDATION OM-24 The staffing level and average competence / experience level of the staff needs to be increased through active - recruitment and acquisition of experienced nuclear personnel, through improved training of present personnel and through significantly reducing attrition.
RESPONSE
The Assistant General Manager - Nuclear will direct the development of a Comprehensive Personnel Staffing and Development Plan for the i
nuclear group.
This plan will include the preparation of detailed-descriptions for positions within the group and an assessment of the qualification and experience requirements for personnel filling these-positions.
Increased emphasis will be placed on meeting the nuclear group training needs through the General Office Nuclear Training Program.
While portions of this plan will be developed on a priority basis, the entire plan is expected to be in place by the end of calendar year 1984.
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ORGANIZATION, MANAGEMENT, AND PERSONNEL (Cont'd) o RECOMMENDATION OM-20 The District should assure that their compensation policy is competitive with the rest of the nuclear industry.
RESPONSE-Comparative salary data has been obtained and ef forts are underway to expedite processing the necessary upgrading of salary ranges in many key areas.,Although there will undoubtedly be further refinements required, we intend to have new salary ranges in place by the end of calendar year 1983.
o RECOMMENDATION OM -21 Benefits should be evaluated and modified, if required, to assure the ability of the District to actract new, senior nuclear personnel and to transfer present personnel as needed between the GO and CNS.
RESPONSE
The District evaluates benefits on an annual basis as requested by the Board of Directors.
Management makes requests to the Board for changes in benefits and wages usually in the month of August of each year to be initiated either October 1 or January 1.
In 1982, management submitted a proposal to pay interest differential for all new hires and transfers within the District; however, the proposal was not approved by the Board.
We believe that, since discussions held with the Board subsequent to the management audit, and pursuant to its recommendations, the merits of having a competitive benefit program is currently more fully appreciated and, as a consequence, will result in Board approval of improved benefits where warranted.
A study of industry-wide benefit programs will be undertaken as a supplementary part of our normal benefit evaluation program.
The results of this effort will be utilized in formulation of recommendations for submittal and approval by the Board of Directors.._
SAFETY COMMITTEES o
RECOMMENDATION S-1 SRAB Consideration should be given to a more formalized review of items of potential safety significance in committee.
RESPONSE
A subcommittee of SRAB recently reviewed the rvisting SRAB Charter and Procedures and produced an updated draft of these documents.
The draft was recently approved by NPPD Management.
Included in the present SRAB. Guidelines and Instructions are requirements for a more formalized review of items of potential safety. significance in committee.
These new Guidelines and Instructions will be implemented by October 1, 1983.
o-RECOMMENDATION S-2 SRAB Consideration should be given (a) to expanding the Board size to enhance the. coverage of all the necessary disciplines and technical competence required, (b) to designating members with more time to devote to the reviews, and (c) to including at least one member of SORC on the Board.
RESPONSE
A subcommittee of SRAB has recently reviewed the existing SRAB Charter and Procedures and has produced an updated draft of these documents which has been approved by NPPD Management.
SRAB membership will be expanded from five members to seven members.
In addition, a full-time non-voting SRAB Administrator will assist SRAB.
The membership of SRAB presently consists of managers with considerable line responsibility.
The draft proposes a change whereby some or all of these managers may be replaced with staff technical people or people with less line management responsibility.
This will permit SRAB members to devote more time to SRAB activities.
In order to provide needed operational input to SRAB deliberations, one member of SORC will be designated by the SORC chairman to serve as an ex-of ficio member of SRAB.
In addition, consideration is being given to having shift supervisors participate in SRAB meetings on a rotating basis to provide additional operations insight and increased intercommunications between CNS and the GO. _
SAFETY C0511TTEES (Cont'd) o REC 0m!ENDATION S-3 SRAB A training program should be developed and implemented.
RESPONSE
The present SRAS Guidelines and Instructions contain a section on SRAB training.
Essentially, this training consists of approximately 40 hours4.62963e-4 days <br />0.0111 hours <br />6.613757e-5 weeks <br />1.522e-5 months <br /> of instruction each year on SRAB duties and responsibilities,10CFR50.59 and CNS systems.
This training program will be implemented by October 1,1983.
o RECOMMENDATION S-4 SRAB Assure the active support of the General Manager to the SRAB and assure the independence of the Chairman.
RESPONSE
The revised SRAB Policy, promulgated by the General Manager, delegates the authority and responsibility for safety review activities to the Assistant General Manager - Nuclear.
The AGM -
Nuclear has designated a Chairman for the Safety Review and Audit Board to become effective October 1, 1983, to allow for an orderly transition from the current Board.
o RECOMMENDATION S-5 SRAB A review should be performed to assure that all activities specified for SRAB review or other activity (e.g., audits, witness of plant operations, procedure reviews, etc.) are being performed according to prescribed methods and schedules.
RESPONSE
Quality assurance already performs audits of SRAB activities.
The current examination and revision of the SRAB Charter and Procedures has also resulted in additional scrutiny of SRAB activities.
The new SRAB Cuidelines and Instructions and the reconstitution of SRAB membership, including a full-time SRAB Administrator, will cause SRAB activities to be performed more thoroughly and vigorously..-
1 SAFETY COMMITTEES (Cont'd) o RECOMMENDATION S-6 SRAB Consideration should be given to review by SRAB of the various industry and NRC operational event information.
RESPONSE
INPO SOER's have been routinely routed pursuant to SRAB procedures for review and evaluation.
NRC bulletins, notices, and other documents related to nuclear safety have been routed to personnel involved in the District's nuclear activities, but not pursuant to SRAB procedures per se.
SRAB routing of such documents is being implemented pursuant to revised SRAB Guidelines and Instructions.
o RECOMMENDATION S-6 SORC Consideration should be given to assuring that all items of potential safety significance are reviewed in a meeting.
RESPONSE
CNS concurs that all items of potential safety significance should be reviewed by SORC, meeting as a committee (not privately by SORC committee members as was done previously).
A new SORC Charter, which includes this requirement, will be implemented by January 1,
'1984.
o RECOMMENDATION S-7 SORC Any inconsistencies between the Administrative Procedures (i.e.,
1.18, 1.3, 1.12, 1.10, 1.13) and Section 6.2.1 of the Technical Specifications need to be rectified.
RESPONSE
A review of the documents identified in the recommendation is underway.
Inconsistencies have been found and noted and these inconsistencies will be rectified based upon the SORC reorganization.
Review and correction of the applicable administrative procedures will be completed prior to January 1, 1984 _
LICENSING o
RECOMMENDATION L-1 The corporate signature authority in transmitting official, attested information to the Nuclear Regulatory Commission should be changed from the Division Manager for Licensing and Quality Assurance to the Assistant General Manager having line management responsibility over the operation of the Cooper Nuclear Station.
While the licensing group would still play its extant role in disseminating and collecting licensing information, the official transmittal to the NRC would have the benefit of line management authority and accountabilitv.
RESPONSE
All future transmittals to the NRC, which are signed under oath or affirmation, shall be signed by the Assistant General Manager -
Nuclear.
Signature authority for correspondence other than noted above has been delegated to the Manager, Technical Staff, Nuclear Power Group.
o RECOMMENDATION L-2 A formal system should be implemented to track NRC commitments made at CNS through LER's or other documents.
RESPONSE
Within the new CNS organization structure, the position of
,Regulatory Compliance Specialist has been established.
Responsibilities of this position will include review o'f CNS correspondence to the NRC and other organizations to determine what commitments have been made.
The commitments will be tracked and closed out upon completion.
Procedures formally defining the tracking system operation will be generated / reviewed / revised by January 1, 1984 o
RECOMMENDATION L-3 Consideration should be given to expanding the licensing staff by one individual to allow proactive participation in future licensing issues.
RESPONSE
The need for additional licensing support is recognized and an evaluation was performed to determine specifically what form such support should take.
Under the new organizational structure, the Licensing and Safety Department will be responsible for various nuclear safety related functions.
An authorization for an additional licensing engineer has been approved by District management. -
ENGINEERING o
RECOMMENDATION E-1 An overall document or charter should be prepared that defines how engineering support for the Cooper Nuclear Station is to be provided.
Included in this document should be a discussion of how the configuration management of the engineering design bases and the as-built configuration of the plant are to be maintained.
In drawing up this engineering charter it is suggested that consideration be given to establishing one engineering function that reports on-site and is charged with the maintenance type engineering to maintain plant operation and an engineering group that ' reports off-site that is charged with the longer range, plant improvement projects.
As noted in the Organization, Management, and rersonnel section of this report, both engineering groups should be in organizations that report to a single Assistant General Manager - Nuclear.
RESPONSE
The AGM - Nuclear has established general guidelines regarding the charters of the site and offsite engineering organizations.
The managers of these two groups are to coordinate the development of the charters.
The AGM - Nuclear and the Technical Staff Manager will review and approve the prepared charters.
The finalized charter and interface document will be completed by September 15, 1983.
o RECOMMENDATION E-2 Active steps should be taken to provide the General Office engineering group with scheduled plant-specific systems training.
Consideration should be given to including the General Office engineers in the systems training courses being given by the Cooper Nuclear Station engineering group.
RESPONSE
A training program for General Office, nuclear work-related employees has been under development for several months.
The General Office engineers will be scheduled to take the systems training courses currently given at CNS.
This will have the immediate advantage of interaction between the two groups, development of personal relationships, ability to gain " hands-on" training when applicable and efficiency and standardization in CNS related training.
This program will be implemented subsequent to STA training.
It is anticipated the training will begin by January 1, 1984. _
ENGIliEERING (Cont'd) o RECOMMENDATION E-3 An evaluation should be conducted as to how to minimize the transportation problem caused by the remoteness of the Cooper Site.
Consideration should be given to scheduled flights from Columbus to a suitable airstrip near the CNS to maximize the on-site hours a General Office engineer could provide when working on a CNS project.
Alternatives should be considered such as moving the off-site engineering group to facilities that are closer to the Cooper Station (e.g., the EOF building or commercial space in one of the nearby towns).
RESPONSE
The problem regarding transportation of General Office engineers to Cooper Nuclear Station has been addressed several times in the past.
Informally scheduled flights between Columbus and CNS are currently provided.
An investigation of regularly scheduled aircraft use will be performed by February 1, 1984, for both outage and routine operations.
Should such use prove to be cost-effective, a program will be proposed for District management approval.
Relocation of the General Office engineering organization to facilities closer to CNS is not considered an acceptable alternative.
o RECOMMENDATION E-4 With the departure of the recent Cooper Nuclear Station Engineering Supervisor, consideration should be given to effecting personnel changes in the General Office nuclear engineering group that would more readily assist in the build-up of a healthier interface relationship.
RESPONSE
A change has already been made in the General Office Nuclear Engineering Department.
Through reorganization, the Manager of the Nuclear Engineering Department has been replaced.
It is felt that this personnel change will enchence and improve the working relationship between the CNS Engineering Supervisor and the General Office Nuclear Engineering Department, o
RECOMMENDATION E-5 A program of assignments of new General Office engineers to the Station for six to' twelve months should be considered, as should a program of interchanging engineers between CNS and the GO.
RESPONSE
Integration of the interchange program into Engineering career path development is being considered.
The Nuclear Services / Nuclear Operations Division Managers will be responsible for developing a proposed program for management review by July 1, 1984.
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OPERATIONS' i I f
o RECOMMENDATION 0-1 i
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High priority should be given to the retention of licensed operators and to the development as soon as possible of a sixth shift.
RESPONSE
A high priority is being given to the retention of licensed operators.
Recently, a license bonus was established for SR0s and R0s in order to help reduce attrition.
The necessary plans have been established to provide for sixth shift operation.
As soon as there are enough SR0s and R0s to properly man the required positions, a six shift rotation will be instituted at which time the-sixth. shift will be a training shift.
Contingent on completion of the Engineering STA Training Program and operators receiving their licenses, the rotation is scheduled to be implemented by the end of 1983.
A compensation survey has commenced.
Upon receipt of the survey results, competitive compensation levels will be established.
o RECOMMENDATION 0-2 Consider increasing the complement of Station operators, to provide a larger pool from which to draw future RO and SRO candidates.
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RESPONSE
An additional four station operators have been included as part of the proposed reorganization.
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o RECOMMENDATION 0-3 4
lf the two functions of shift supervisor and shift technical advisor are combined, specific instructions must be issued to the shift supervisor that in upset plant conditions he must stand back and exercise control
' from the broader perspective of the total plant condition.
RESPONSE
i
. Specific instructions have been issued to the shift supervisor.
o RECOMMENDATION 0-4 Incorporation of the TSC in the control room should be reevaluated.
RESPONSE
A portion of the control room which is separate from the main control staging area is presently used as the Engineering operations section of the Technical Sup' port Center.
There are no plans to further incorporate the TSC into the control room.
MAINTENANCE o
RECOMMENDATION M-1 Improvements in the area of personnel recruittent and retention mur,t be made immediately with critical attention to the I&C area.
In addition to attempting to understand and correct the causes for the high attrition rate in the I&C area, steps should be taken to expedite plant-specific training.
RESPONSE
In recognition of' the need to upgrade the I&C area, the reorganizat. ion establishes the I&C area at a higher level equivalent to the maintenance and operations organizations.
In the restructured organization, the ISC Supervisor reports directly to the Operations Manager, the positions of Foreman and Lead I&C Technician have been established and four additional technicians have been authorized.
I&C will begin systems training within the I&C group by December 1, 1983.
Additionally, the proposed Training Department includes the full time training position of I&C and Electrical Instructor.
o RECOMMENDATION M-2 Estimates should be made of expected attrition rates and a personnel acquisition program should be put in place. co provide a cadre of personnel in training to successfully counter the expected losses.
RESPONSE
The new organizational structure includes an additional eight positions in the maintenance area in order to maintain an adequate
-number of experienced personnel in view of anticipated attrition, o
RECOMMENDATION M-3
'The management structure and qualifications of incumbent personnel in the maintenance organization should be reviewed to determine if changes would improve morale and inhibit attrition.
RESPONSE
The recent reorganization has taken this recommendation into account.
Additionally, we believe that incumbent personnel qualifications will be improved through the upgraded formal training program.
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MAIKTENANCE (Cont'd) o RECOMMENDATION M-4 A review should be conducted to determine the advantage / disadvantage of changing CNS Administrative Procedure 1.7.1 to require that all work on Essential systems be covered by a Maintenance Work Request (MWR).
RESPONSE
Procedure 1.7.1 has been revised and implemented to require that all work on essential components is covered by an MWR.
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TRAINING o
RECOMMENDATION T-1 A Training Department should be organized under the leadership of a single supervisor with full responsibility-for licensed and nonlicensed on-site training.
RESPONSE
A ' Training Department is included in the CNS reorganization plan which will provide adequate staffing to meet training requirements.
l The structure includes a Training Department Manager assigned responsibility for the entire on-site training program.
At this time a Training Department Manager has been assigned.
Additionally, General Electric will provide an on-site General Electric Training Manager and two General Electric licensed
-instructors to augment the CNS training staff which consists of one 4
full' time Shift Supervisor /SRO acting as Operations Training Supervisor and one full time Education Specialist.
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o RECOMMENDATION T-2 One of the first responsibilities of the new training supervisor should be the generation of a comprehensive CNS training program detailing the training needs and the resources to carry out the program, i
RESPONSE
The Training Manager has been assigned full authority and
-responsibility for development of a comprehensive training program.
Resources to fulfill the expected program requirements have been specified in the CNS reorganization plan, r
o RECOMMENDATION T-3 1
An additional licensed instructor and training clerk to maintain records should be added to the staff along with the assignment of the present training shift supervisor full time to the Training Department.
RESPONSE
The.new training organization 'at CNS includes the above recommendation except for clerical support.
Clerical support will be provided by the CNS Administration Department.
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4 TRAINING (Cont'd) o RECOMMENDATION T-4 The Training Manual.should be upgraded and systems descriptions should be updated'to more accurately reflect the present status of the plant.
More emphasis should also be placed on balance of plant systems training.
RESPONSE
The Training Manager has been assigned full responsibility for generation of a new Training Manual written to reflect the current status of the plant.
The manual will include additional emphasis on balance of plant training.
The manual will include updated system descriptions in a lesson plan format.
The District has contracted for various training services with the General Electric Company.
As
-f part of these services, General Electric is to generate the foregoing documents during the course of the two-year contract.
o RECOMMEMDATION T-5 Consideration should be given to relocating formal training to classroom facilities at the new EOF or at another centralized location.
RESPONSE
Relocation of - the Training Department to the new EOF has been accomplished.
Additionally, accommodation of Training Department space requirements in planned warehouse facility expansion.is under consideration.
o RECOMMENDATION T-6 The sixth shif t should remain in normal rotation and dedicated to requalification training of incumbents.
RESPONSE
The sixth shift will be used specifically as an In-training Shift.
o RECOMMENDATION T-7 NPPD should review the STA training situation and determine if remedial training is appropriate for incumbent shift supervisors.
RESPONSE
The District has reassessed the STA' staffing philosophy ac CNS.
As a result, an STA training program has been implemented to qualify Station Engineers to perform the duties of Shift Technical Advisor.
This initial training will be completed by the end of December, 1983.
In the interim, the District - has determined that the
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. currently approved STA program, using qualified shift supervisors, is satisfactory.
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TRAINING (Cont'd) o RECOMMENDATION T-8 The Training Department, when established, should develop, in cooperation with operations, a formalized training program and schedule for nonlicensed Station operators.
The qualification card system should be revitalized and used as part of this training program.
RESPONSE
The training program will include formalized non-licensed operator training.
The CNS Training Department structure will provide resources to meet non-licensed operator training needs.
This is to be accomplished subsequent to full implementation of enhanced licensed operator training.
The qualification card system was reinstituted for all nonlicensed station operators starting August 1, 1983.
o RECOMMENDATION T-9 The critical needs of enchanced I&C training should be reviewed to assure that the diminution of experience in that group is countered by increased plant-specific training.
RESPONSE
The training needs of IAC have been reviewed.
An ISC and Electrical Training Instructor has been established as part of the new Training Department.
I&C plans to begin plant systems training within the I&C Department by December 1, 1983.
o RECO W NDATION T-10 Consideration should be given to expand the systems training program given by the CNS engineering group to include General Office engineers.
RESPONSE-Please refer to the response to Recommendation E-2...
EMERGENCY PLANNING o
RECOMMENDATION EP-1 A single Emergency Planning Coordinator should be appointed with full responsibility for the NPPD emergency planning.
Adequate staff support should be provided to this individual.
RESPONSE
The concept of a single EP Coordinator has been considered and rejected.
We have an Emergency Planning Coordinator at CNS and at the General Office'.
Basic division of responsibility is defined as the grotected area at CNS; i.e., inside/outside the security fence.
These individuals carry out their responsibilities in meeting overall NPPD's Emergency Planning Objectives through the normal structure of the Nuclear Power Group.
Adequate staff support will be provided on an "as required" basis.
QUALITY ASSURANCE o
RECOMMENDATION Q-1 Consideration should be given to relocating the General Office QA Department closer to the CNS.
RESPONSE
Consideration has been given for such relocation, and it has been decided that a QA Department at the General Office will be retained.
QA has been elevated to divisional status with increased staffing in both Corporate and'CNS QA Departments.
o RECOMMENDATION Q-2 Establish a routine reporting relationship of the status and adequacy of the QA Program to the General Manager.
RESPONSE
Monthly status reports of NPPD QA activities will be generated.
These activities will be identified by the QA Department Managers based upon input from GO and CNS QA staffs and will be submitted to the General Manager through the QA Division Manager.
These reports will be supplemented by periodic personal briefings for the General Manager by the QA Division Manager.
The briefing frequency shall be established by the QA Division _ Manager based upon program adequacy, i.e., any perceived problems shall be reported in a timely manner in order that direction can be provided by the' General Manager.
o RECOMMENDATION Q-3 Increase the CNS QA staff by at least two people as soon as possible.
RESPONSE
One new position has been authorized and the position offer accepted as of June 3, 1983.
This individual reported to CNS on July 1, 1983.
The second position authorization is currently being processed.. _.
QUALITY ASSURANCE (Cont'd) o RECOMMENDATION Q-4 Identify the Essential and non-Essential structures, systems, and components that require QA involvement.
RESPONSE
Structures and systems have been identified and classified.
Component identification and classification has been a continuing effort for several; years.
Finalization of the entire classification
- program, which is estimated to include approximately 50,000 components, will be completed by July 1,.1986.
Interin milestone schedule dates and system component priority establishment will be developed by November 6, 1983, in accordance with Generic Letter 83-28, Salem ATWS Events.
o RECOMMENDATION Q-5 Initiate a QA training program for General Office management personnel who are involved with the CNS.
RESPONSE
A QA Training Program has been in place for several years and has been-utilized to train GO engineering and support personnel.
This training has been incorporated into the recently established General Office Nuclear Training Program for all appropri.ce corporate personnel involved in nuclear support activities.
o RECOMMENDATION Q-6 A coordinated corrective action program that includes LER's, NCR's, MWR's, SRAB items, audit and surveillance findings and ISE findings should be developed.
This should include a program to analyze trends of significant conditions adverse to quality.
RESPONSE
CNS has established the position of Regulatory Compliance Specialist (NIS) to track the status of action items initiated by LER's, ECR's, audit and surveillance findings and I&E findings.
This program is now in effect.
An Action Item Tracking System has been developed (similar to system G.O.
Li ensing currently utilizes) and an Equipment History Trend Analysis system will be implemented.. In addition, the Nuclear Plant Reliability Data System (NPRDS) will be l
implemented on the Prime computer.
Additionally, procedures defining the operation of the above trackings systems will be generated, reviewed, and revised as required to insure that all corrective action commitment completions are reported to the NIS.
QUALITY ASSURANCE (Cont'd) o RECOMMENDATION Q-7 Careful consideration should be given to determining those systems, structures, and components that have some significant importance to safety and therefore should require some level of QA program application.
Examples of those that should be reviewed are:
Post-accident sampling system, radwaste system, security system, fire protection system, chemistry instrumentation, meteorological monitoring equipment, and the HVAC systee.
RESPONSE
It is recognized that the classification of "important to safety" is receiving considerable industry and regulatory attention at this time.
We will participate in support of the effort to further define "important to safety" systems, structures, and ccmponents as part of our ongoing BWR Owner's Group activities.
I RADIATION PROTECTION AND ALARA o
RECOMMENDATION RP-1 Formalized training of HP technicians could be improved, including plant-specific systems training.
' RESPONSE The Training Department has been assigned the responsibility to establish a formalized Health Physics and Chemistry training program.
Included will be plant specific systems training.
Chemistry and Health Physics training material has been procured from General Physics.
The recently approved Training Department struccire includes a full time Chemistry and Health Physics Instructor.
The Chemistry / Health Physics Department reorganization includes sufficient personnel to provi'de for the increased training commitment.
Initially, a General Electric Chenistry and Health Physics Instructor has been contracted to provide basic and technical training.
This individual will develop a Chemistry and Health Physics training program including documentation on equipment operation and sampling techniques as well as integration of the General Physics training material into the program.
o RECOMMENDATION RP-2 The ALARA program being formulated should be implemented this year with a single individual designated as the ALARA coordinator.
RESPONSE
An ALARA procedure has been drafted and is in its final review within the Chemistry and Health Physics department.
It is anticipated this procedure will be approved and implemented by January 1, 1984.
Also, the position of ALARA Coordinator is part of the CNS reorganization. The individual in this position will review Work Items, MWR's and routine functions for dose tracking and evaluate methods of exposure reduction.
o RECOMMENDATION RP-3 An annual physical examination including blood cell count for radiation workers should be considered.
RESPONSE
The blood cell count examination will be included as part of the annual physical examination for CNS employees in the 1984 cycle.
RADIATION PROTECTION AND ALARA (Cont'd) o RECOMMENDATION RP-4 Consideration should be given to installation of a hand-and-foot counter for additional protection against unoetected surface contamination.
RESPONSE
Consideration has been given to the installation of hand and foot counters at Cooper Nuclear Station.
In our opinion, however, the currently available units would not provide a significant improvement in the detection of surface contamination over methods presently in use at the station.
The District will continue to monitor industry directions in this area and will take appropriate action when more ef fective equipment becomes available.
RADk'ASTE MANAGDENT No recomendations made.
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CHEMISTRY o
RECOMMENDATION C-1 The vendor training course should be supplemented with lesson plans specific to the Cooper plant design.
Training of technicians should be formalized and implemented expeditiously.
RESPONSE
The new Training Department structure includes a full-time Chemistre and Health Physics. Instructor.
Training material has already been procured from General Physics Corporation.
A General Electric Chemistry and Health Physics Instructor has been contracted for, to provide basic and technical training.
He will develop a Chemistry and Health Physics training program including documentation on equipment operation and sampling techniques and will integrate the General Physics training material into the program..
ENVIRONMENTAL o
RECOMMENDATION EV-1 NPPD should consider developing the capability of doing its own meteorological assessment since experience at other sites shows this to be cost beneficial.
RESPONSE
NPPD is in the process of developing the in-house capability to perform the meteorological assessments which are now being performed by outside consultants.
The transition verification phase is expected to occur in 1984 and use of consultants for this activity terminated at the end of 1984 o
RECOMMENDATION EV-2 A program should be adopted to reduce liquid releases.
RESPONSE
Efforts are in progress to reduce liquid releases.
These efforts include:
reduction of the number of leaks responsible for a portion of liquid releases and the operation of the Augmented Liquid Radwaste System on a daily basis.
Additionally, the new CNS Engineering Organizational Structure includes a full-time Process Control Engineer.
A primary responsibility of this Engineer will be to review, evaluate, and propose design improvements necessary to further reduce liquid releases, j
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PROCUREMENT, INSPECTION, AND STORES o
RECOMMENDATION P-1 Increase the involvement of quality assurance in the early review of purchase requisitions that may relate to Essential structures, systems, and components.
RESPONSE
CNS Administrative Procedure 1.11, Revision 19, " Requisitioning, Receiving, Storage of Essential Parts, and Components," requires that " prior to submitting" an essential or essential " commercial grade" purchase order to the department supervisor for initialing, the CNS QA Department will perform an independent review of the purchase order, to insure that all the necessary quality requirements have been specified.
CNS Quality Assurance has routinely performed a quarterly review of nonessential purchase orders since August, 1981, which has revealed no adverse trends in purchase order classification.
Additionally, this review requirement will be formalized by incorporation into QAP 1400 " Procurement and Control of Essential Spare Parts and Equipment" by October 1, 1983.
o RECOMMENDATION P-2 Improve purchase order information to allow complete receipt inspection by a quality control inspector.
RESPONSE
The CNS Quality Assurance Department has established a training course covering proper receipt inspection.
This course will become required training for all engineers beginning January 1, 1984.
This training will provide the engineer with the knowledge necessary to improve purchase order information to allow proper receipt inspection.
o RECOMMENDATION P-3 Upgrade information on MWR's to allow complete inspection by an inspector who may not be intimately f amiliar with the work rad enforce the requirement to complete all portions of the form.
RESPONSE
CNS Administrative Procedure 1.7.1, Revision 4, " Work Item Tracking
- Corrective Maintenance," has been revised to include a more detailed QC/ Testing Checklist and also requires a Level II QC Inspector to review the overall work package for content and completeness prior to work item closeout. _,,
PROCUREMENT, INSPECTION, AND STORES (Cont'd) o RECOMMENDATION P-4 Improve the storage and control of weld rod and the identification of Essential spare parts.
RESPONSE
As part of the CNS organization, new positions have been added to better control storage of warehouse material and spare parts acquisition.
These positions include Inventory Control Coordinator, Warehouse Foreman, Material Controller and Material Data / Spare Parts Analyst.
Identification of es.sential spare parts will be performed as action to satisfy LRS Recommendation Q-4 o
RECOMMENDATION P-5 Consider increased senior management attention to the nuclear fuels activity including review of the NPPD/Mommsen Associates / Energy Fuels Exploration Company relationships.
_ RESPONSE, With the establishment of a Nuclear Power Group nuclear technical activities, including nuclear fuel management, will receive increased overview.._
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RECORDS MANAGEMENT AND DOCUMENT CONTROL o
RECOMMENDATION RM-1 Expedite changeover from the Zytron to the PRIME 650 systen at CNS.
RESPONSE
Authorization for replacement of the CNS Zytron system with a Prime computer has been obtained and the procurement and changeover will occur expeditiously in 1983.
o RECOP3ENDATION RM-2 The two-year basis for microfilming the active records in the GO should be enforced.
RESPONSE
Procedures concerning the subject of quality records, their definition, storage and retention requirements, will be reviewed and revised as necessary.
Following this review, training will be conducted to insure that nuclear group personnel are aware of nuclear records requirements.
This procedure review and training will be completed during the first quarter of 1984.
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