ML20115G321
| ML20115G321 | |
| Person / Time | |
|---|---|
| Site: | Cooper  |
| Issue date: | 04/11/1985 |
| From: | Schaufelberger NEBRASKA PUBLIC POWER DISTRICT |
| To: | Martin R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| References | |
| EA-82-046, EA-82-46, NUDOCS 8504220169 | |
| Download: ML20115G321 (15) | |
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Nebraska Public Power District
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S April 11,1985
}[H @ M OV/[2 Mr. Robert D. Martin Regional Administrator APR I 61985 U. S. Nuclear Regulatory Commission Region IV I
Gil Ryan Plaza Drive Suite 1000 Arlington, Texas 76011
Dear Mr. Martin:
Subject:
Status of District's response to LRS Nuclear Management Appraisal Report
Reference:
- 1) Letter from L. G. Kunct to R. D. Martin dated March 13,1985, on above subject.
LRS has recently reviewed the status of the District's response to its' Nuclear Management Appraisal Report of April,1983.
Per Reference 1, a copy of this review is forwarded.
Appendix A of the attachment lists the recommendations with a brief title and
.provides the status of each.
The review is being evaluated by District management and all remaining open items are being vigorously pursued to completion.
Following the next scheduled Board of Directors meeting at which the results of this review will be discussed, any further developments regarding the remaining open items will be forwarded.
It is anticipated this additional information will be forwarded to you during the week of April 29, 1985.
Sincerely, NEBRASKA PUBLIC POWER DISTRICT
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s Don E. Schaufe erger General Manog
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APPENDIX A Status of NPPD Responses to LRS Appraisal Report Recommendations OM-1 District Long Range Goals and Objectives The District did embark on a program to develop long range goals and objectives.
However, the initial overall goals had limited substance.
OM-2 Strategies to Accomplish the Board's Overall Direction Based on understandings as to the Board's desires each of the AGM's did develop goals and objectives for his division.
No evaluation was made of the strategies, plans and programs in divisions other than Nuclear, where a good start has been made in establishing and meeting specific goals.
OM-3 More Definitive Delegation of Authority by the Board to the General Manager This item is being worked on.
It has been tangled up with legal ramifications and does not appear to have had high priority and is not complete.
4 OM-4 Board / Management Nuclear Communications This item is ongoing and being accomplished.
OM-5 Board / Management Team Work Needs Development This item is ongoing and there are clear signs of improve-ment despite some obvious continuing friction.
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OM-6 Top Management Needs to Make Some Hard Decisions This item related to the need for staff buildup, reorganiza-tion and District-wide personnel actions, which were in fact accomplished.
OM-7 Provision of Nuclear Information to the Board This item is ongoing and is being accomplished.
OM-8 Establish Position of AGM-Nuclear with Position Description The AGM-Nuclear position was established promptly and a position description was developed.
Although formal approval has been withheld pending completion of OM-3, the responsibilities duties and authority have been de facto implemented.
Subordinate position descriptions in the nuclear organization have been developed and implemented in line with that of the AGM-Nuclear.
OM-9 Assign an AGM-Nuclear Completed.
OM-10 Nuclear Operations Organization Completed.
OM-ll Jurisdictional Statements for Nuclear Organization Divisions Completed.
OM-12 Position Descriptions for Key Nuclear Management Positions Completed.
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OM-13 Nuclear Management Personnel Actions Completed.
OM-14 GO Management Involvement in CNS and Elimination of the Isolationist Attitude of CNS Management There has been much accomplished here and efforts continue to show improvement.
OM-15 Management Training This is an ongoing effort and is being accomplished.
OM-16 Succession Planning Program This program was initiated ~in the nuclear organization in March, 1985 on a formal basis but can only be considered to be embryonic at this point in time.
OM-17 Delegation of Signature Authority Some delegation has occurred at the AGM and Division Manager levels.
More should be considered.
The intent of the recommendation has been met.
OM-18 Board and Management Must Reverse High Turnover at CNS Several actions have been taken over the preceding two years to reduce the turnover rate.
Some of these actions (notably in I&C) are too recent to show results yet.
The intent of the item is being met although action has not always been as prompt as would be desirable.
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OM-19 Recruitment of Experienced Supervisory Personnel for CNS and the GO With the exception of R. Wilbur, L. Berry, D. Reeves and G. Horne, it does not appear that the District has been able to recruit experienced nuclear individuals.
Either acquiring such experienced personnel has had too low a priority or the District is not competitive.
More action is required in this area.
OM-20 Competitive Compensation Policy This is an ongoing effort.
Significant improvements have been made.
The effort needs to continue.
OM-21 Benefit Program and Permanent Transfer Policy The District reviews benefits annually, but no significant improvements have been made in the last two years.
As discussed in E-5, a temporary transfer policy has been established for GO/CNS transfers.
OM-22 Line Nuclear Management / Personnel Department Cooperation in Recruiting l
i Ongoing and being accomplished in excellent fashion.
i OM-23 Reassignment of Some Existing Nuclear Supervisors and Managers l
Completed.
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OM-24 Increase Staffing Level and Experience Level through Acquisition, Training and Retention This is an ongoing effort with slow, but good strides made to date and more underway.
The intent is being met.
S-1 More Formalized Review in Committee by SRAB Completed.
S-2(a) Expand SRAB Size to Enhance Discipline Coverage Completed.
S-2(b) Designate Members with Time to Spend on Necessary Review Completed.
S-2(c) Include At Least One Member of SORC on SRAB Completed very recently.
S-3 SRAB Training Program Completed.
S-4 Assure Active Support of the SRAB by the General Manager and Assure the Independence of the SRAB Chairman ongoing and being accomplished.
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S-5 Assure SRAB Review Activities are being Performed as Required ongoing and being accomplished ~.
S-6 Review by SRAB of Operational Event Information ongoing and being accomplished.
S-7 Upgrade of SORC Charter on Discussion in Committee of Safety Issues This recommendation has not been implemented.
There is no SORC Charter as such; rather, the duties of SORC are outlined in Technical Specification paragraph 6.2.1.A and Station Procedure 0.3, " Station Operating Review Committee".
Neither the Technical Specification paragraph nor the Station Procedure have been revised to require review of items of potential safety signif-icance.
Although the Compliance Specialist's tracking system has a signed form from the Station Manager saying a Technical Specification change. had been implemented, the referenced change did not pertain to this subject.
S-8 Inconsistencies Between Administrative Procedures Regarding SORC All administrative procedures were upgraded by Stone &
Webster under contract to the District.
This was completed in July, 1984.
The S&W procedure updating activity was engaged in
" creating new/ revised procedures relating to Administrative Services and Station Policy, to rewriting the MDC procedure, to incorporate the expanded role and membership of SORC".
This activity was intended to respond fully to this recommendation.
However, S&W apparently did not do a thorough job.
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although the intent of the recommendation has been met, the substance of the recommendation was not met.
L-1 Corporate Signature Authority for NRC Correspondence Completed.
L-2 Formal Commitment Tracking System A formal commitment tracking system was established at the CNS site and is administered by the Compliance Specialist.
However, any system is only as good as the input data, which in this case leaves much to be desired.
The intent of the recom-mendation in establishing a formal commitment tracking system has been met.
However, management attention must be directed to the quality of the input data to the system.
L-3 Expand Licensing Staff Completed.
E-1 Engineering Interface Agreement Between CNS and GO Engineer-ing Groups Completed.
E-2 Plant Systems Training for GO Engineers GE was contracted for and did provide a CNS plant specific training course at Columbus for GO engineers.
The intent of this recommendation has been met.
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E-3 Resolution of Transportation Problem Between GO and CNS Completed.
E-4 Personnel Changes in GO Engineering Completed.
E-5 Assignment of GO Engineers to CNS and Interchange of Engineers At the present time large numbers of GO engineers are on assignment to CNS to work on various outage related activities.
A transfer policy has been worked out and one transfer has already occurred.
This item is ongoing and is being accomp-lished.
O-1 Operator Retention and Six Shifts License bonuses have been increased and retention of operators has improved.
Staffing up with plant equipment operators to promote to and fill the ranks of licensed operators has not been given the high priority required.
O-2 Increase Number of Station Operators The numbers were increased, but not sufficiently.
There-fore, the intent of this item was not accomplished.
O-3 shift Supervisor and STA Functions Completed.
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O-4 Reevaluation of the TSC in the control Room Completed.
M-1 Attrition of and Plant Specific Training for I&C Technicians The intensive plant specific training portion of this recommendation was met by providing an intensive 35 day systems training course for the I&C technician group.
Obviously, it was not until the recent salary restructuring effort was accomplished in February, 1985, that the intent of the recommendation to identify and eliminate the principal cause of high attrition was met.
Therefore, the intent of the full recommendation has finally been met.
M-2 Personnel Acquisition Program to Counter Anticipated Attrition Completed.
M-3 Maintenance Structure and Problems with Supervisors Completed.
M-4 All Essential System Work to be Covered by an MWR Completed.
T-1 Training Department Established and Manager Assigned Completed.
T-2 Generation of a comprehensive CNS Training Program The intent of this recommendation has not been met.
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T-3 Additional Licensed Instructor and Records Keeping At the time of the LRS audit the training group consisted of one full time individual and 1/2 time of a shift supervisor.
The initial staffing plan brought Training up to 12, including one clerk.
The present program is to increase the size of the group to 35, including 6 clerical.
The intent of the recommendation is being met.
T Upgraded Systems Descriptions This is being accomplished by contract with GE.
Completion date is August 1, 1985 and it is now in the final stages.
The intent of this recommendation is being met.
T-5 Transfer Training classrooms to the EOF Completed.
T-6 Use of Sixth Shift for Training Dependent.upon 0-1 and therefore not yet completed.
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~T-7 STA Training l
Completed.
T-8 Non Licensed' Training l
A program is in place and a revamped qual card system is I
being used.
plans are to eventually upgrade the qual card system.
However, the intent of this recommendation has been met.
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T-9 Enhanced I&C Training This recommendation is the same as the training portion of M-1 and the intent of this recommendation has been met.
T-10 Systems Training for GO Engineers This recommendation is similar to E-2 and the intent of the recommendation has been met.
A nuclear trainer has been hired into the GO Training Department to assure continuation.
EP-1 Appoint a Single Emergency Planning Coordinator This recommendation was rejected and two coordinators were appointed, one at CNS and the other at the GO.
The intent of this item has been accomplished.
Q-1 Relocation of the GO Quality Assurance Department to Vicinity of CNS Recommendation rejected.
Q-2 Establish a Routine Reporting Relationship Between QA and the General Manager This item has not been accomplished.
Q-3 Increase the QA Staff i.
Completed.
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Q-4 Enhanced O List A contract was let to EPM Inc. to upgrade the Q list based on an accident progression analysis of the accidents defined in the USAR.
EPM is on schedu.e and should make the July, 1986 commitment date.
A review of the work EPM did on the response to Generic Letter 83-28, Salem ATWS Event, indicates they will do a good job.
The intent of this recommendation is being met.
Q-5 OA Training for GO Personnel This is ongoing and being accomplished.
Q-6 Corrective Action Program and Trend Analyses An integrated corrective action tracking program to handle NRC commitments, bulletins, INPO evaluations, EP punch lists, LER's, SORC items, etc. has been established.
QA is trending and analyzing trends of NCR's.
Audit findings are now being added to the trending program.
The intent of this item has been accomp-lished.
Q-7 Determination of Systems, Structures and components Import-ant to Safety Completed.
RP-1 Plant Specific Training for HP Technicians This recommendation has not been met.
Present plans call for HP plant systems training to be conducted after the com-pletion of the current pipe replacement outage sometime in the summer of 1985.
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RP-2 Implement ALARA Program and Designate a Coordinator Completed.
RP-3 Annual Physical Examination Completed.
RP-4 Hand-and-Foot Counter Recommendation rejected.
However, NPPD is monitoring the industry for availability of better equipment.
C-1 Chemistry Training Program Efforts to upgrade the chemistry training program and to train technicians is ongoing.
The intent of this recommendation has not been met as yet.
EV-1 Meterological Assessment Completed.
l EV-2 Program to Reduce Liquid Releases I
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Completed.
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P-1 QA Review of Purchase Requisitions I
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completed.
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P-2 Improve Purchase Order Information for QC Receipt Inspection Completed.
P-3 Improve MWR Information to Allow Complete Work Inspection Completed.
P-4 Improve the Storace and control of Weld Rod Completed.
P-5 Increase Senior Management Attention to Nuclear Fuels Activity Completed.
RM-1 Expedite Changeover from Zytron to Prime 650 i
completed.
RM-2 Enforce Two-Year Basis for Microfilmina Active Records l
l Completed and ongoing.
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