ML20117N560

Engineering Self Assessment 960205- 23

ML20117N560
Person / Time
Site:	Cooper
Issue date:	02/23/1996
From:	NEBRASKA PUBLIC POWER DISTRICT
To:
Shared Package
ML20117N554	List: ML20117N551 ML20117N560
References
NUDOCS 9609190273
Download: ML20117N560 (163)

Text

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Xebraska Public Power Di. strict Cooper Nuclear Station ENGINEERING SELF ASSESSMENT February 5 - 23,1996 I$0"$0$cd$I0ooS9s PDR R

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EX EC UTI VE S UM M A RY . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . I 1

1 1.0 P U R P O S E . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5 i 1

2.0 0 BJ E CTI V ES . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5 1 3.0 B A C K G RO UN D . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5 l

4.0 ASSESSMENT APPROACH AND METHODOLOGY . . . . . . . . . . . . . . . . . . . . . . . . . 6 l 4.1 O V E RV I E W . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6 4.2 A SS ES S M E NT A P P RO AC H . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 7 4.2.1 Ho rizont al R evi ew . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 7 4.2.2 Vert ical R eview . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .......... 8 4.2.3 Post-Reorganization Effectiveness . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 8 .

1 4.3 TEAM COMPOSITION AND RESPONSIBILITIES . . . . . . . . . . . . . . . . . . . . . . . 9 t 4.3.1 Assessment Team Comnosition and Responsibilities . . . . . . .............. 9 4.3.2 Response Team Comnosition and Resnonsibilities . . . . . ........ ........ 9 4.4 H ANDLING OUESTIONS AND ISSUES . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 10 4.5 B AC K UP DOCUM ENTATION . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 10 5.0 OVERALL ASSESSMENT RESULTS . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . I 1 i 5.1 ST R E NG T H S . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . I 1 )

5.2 CA US AL FACTOR FIN DING S . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. 12 l 5.3 P E RFORM ANCE I SS U ES . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 15 l 5.4 PERFORM ANCE ENHANCEMENTS . . . . . . . . . . . . ..................... 21  !

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6.0 ABILITY TO RESOLVE OPERATIONAL ISSUES . . . ................... 23 6.1 S CO P E/S U M M A RY . . . . . . . . . . . . . . . . . . . . . . . . . . . . . ................... 23 6.2 ST R E N GT H S . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 24 6.2.1 Simulator Fidelity .......................................... ... 24 6.3 F I N D I N G S . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . ..... ................... 24 6.3.1 Attention to Detail . . . . . . . . . . . . . . . . . . . . ....................... 24 6.3.2 Inaccurate Proced ures . . . . . . . . . . , . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. 25 6.3.3 Operability Assessments . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 25 6.3.4 Backlog Prioritization/ Low Value Work . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 26 6.3.5 Safety Evaluations . . . . . . . . . . . . . .......... .. ................... 26 6.3.6 Interdenartmental Communications . . ... ....... ................... 26 l

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I TABLE OF CONTENTS 6.3.7 Roles and Resnonsibilities . . . . . . . . . . . . . . . . . . . . . . . . . ....... ..... 27 6.4 AREAS FOR IM PROVEM ENT . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 27 .

I 6.4.1 Field Change /MWR Interface ..................... ...... ........ 27  !

6.4.2 Training / Plant Knowledge . . . . . ... . .......................... . 27 6.4.3 EOP/OPL Process . . ..................... ....... .............. 28 6.4.4 S i m ul at o r Trai ni n g . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . ..... 28 7.0 M AINTENANCE SUPPORT . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 28 7.1 S U M M A R Y . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2 8 7.2 SCO P E A N D M ETilO DO LOG Y . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 29 7.3 ST R E NG T H S . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2 9 1 7.3.1 Customer Satisfaction imnroved . . . . . . . . . . . . . .... . ... ..... 29 l 7.3.2 Work Ethics .. ................................... ... ....... 29 )

7. 4 F I N D I N G S . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3 0 7.4.1 Management Exnectations and Accountability . . . . . . . . . . . .. .......... 30 7.4.2 Roles and Resnonsibilities . . . . . . . . . . . . . . . . . . . ..................... 31 7.4.3 Work Control Process Ownershin . . . ...... ..... .. .............. 31 7.4.4 Wo rk Pri o ri t i za t i o n . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . ...... .... 32 7.4.5 Incomplete Understandine of Corrective Action Program . . . . . . . . . . . . . . . . 33 7.5 A R E A S FO R I M P RO V E M E NT . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 34 i 7.5.1 Ineffective Internal communications . . . . . . . . . . . ...... ............. 34 i 7.5.2 Ineffective External Communications . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. 35 1 7.5.3 The Replacement Comnonent Evaluation (RCE) nrocess . . . . . . . . . ....... 36 )

7.5.4 Document /Information Availability . . . . . . . . . . . . . . . ....... ... ..... 36 i 7.5.5 Engineering Involvement in MWR Prenaration . . . . . . . . . ............. .37 7.5.6 Vendor Bulletins / Letters . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3 7 7.5.7 Performance Indicators . . . . . . . . . . . . . . . . . . . . . . . . .... ............ 38  ;

7.5.8 The Eauinment Data Field (EDF) ........ . ............ .. . ..... 38 l 7.5.9 The Preventative Maintenance Program . . . . . . . . . . . . . . . . . . . . . . . . . . ... 38 7.5.10 The Predictive Maintenance Program . . . . . . . . . . . . . . . . . . .. ......... 39 7.5.11 Maintenance Rule /PSA Understanding . . . . . ...... ............ .. 40 l 7.5.12 Procedural Noncomnliance . . . . . . . . . . . . .... .... . .. ..... 40 i 7.5.13 Desk Ton Guides . . . . . . . . . . . . . . . . . ... ..... ......... ...... . 41 l 7.5.14 Low Value Work . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. 42 l

8.0 SYSTEM ENGINEERING EFFECTIVENESS ........... ............ .... 43 8.1 S U M M A RY . . . . . . . . . . . . . .. ..... .......... ..... .............. 43 8.2 SCO P E A N D M ETIIO DO LOG Y . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4 3 l

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TABLE OF CONTENTS 8.3 STRENGTilS ................ ............................. ........ 44 8.4 FI N D I N G S . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 44 8.4.1 Ineffective Use of System Engineering Resources . . . . . . ...... ........ 44 8.4.2 Management involvement . . . . . . . . . ..... . ....................... 44 i 8.4.3 Design Basis Knowledge . . . . . . . . . . . . . . . . . . . . . . . . . . ...... ....... 46 8.4.4 Preventive Maintenance (PM) Prouram . . . . . . . . . . . . . . .............. 46 8.4.5 Performance Monitoring . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4 8 8.4.6 Training Oualifications . . . . . . . . ........ .... .................... 49 8.4.7 System Maintenance / Modification Priorities . . ... ................... 50 8.4.8 Work l oa d . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 51 8.4.9 To ol s . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5 3 t 8.4.10 System Engineering Walkdowns . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 54 8.4.11 Reactor Engineering . . . . . . ....... .. ... ...... ............. ... 55 8.4.12 OPL: An owner for the OPL nrocess is needed . . . . . . . . . . . . . . . . . . . . . . 57 8.5 A RE AS FOR IM PROVEM ENT . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 58 8.5.1 System Encineer Review of 0SCRs . . . . . . . . ............... . ... .. 58 l l

9.0 PLANT MODIFICATIONS . ... .................... ................... 60 i 9.1 S U M M A RY . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 60 9.2 SCO P E A N D M ET H O DO LOG Y . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 60 )

9.3 ST R E N GTil S . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . ...... 61 )

9.3.1 Organizational structure . . . . . . . . . . . ..............................61 l 9.3.2 B acklog R ed u ct ion . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 61 9.4 F I N D I N G S . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 61 9.4.1 Design / Configuration Control . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 61 l 9.4.2 Calculation Control . . . . . . . . . .. .... ............ . .. ... 64 i 9.4.3 Modification Process . . . . . . . . . . . . . . .............. ............... 64 l 9.4.4 Wo rk Prio ri t i zat i o n . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6 5 l 9.4.5 I ack of Clear and Effective Exoectations . . . . . . . . . . . . ................ 66 9.4.6 Unauthorized Modifications . . . . . . . . . . . . . ......... ..... ......... 66 9.4.7 I ack ofIntegration of Design Basis Infom1ation . . . ... .............. 67 1

9.4.8 Onerability Assessments . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .... ....... 68 l 9.4.9 Document Accessibility . . ...... ............. . .. .... ..... .. 69 9.4.10 Inadeauate Knowledge / Training . . . . ...... .. ..... .... ....... 69 9.4.11 Ineffective /Inanoronriate communications . . . . . . . . . . . ................ 70 9.5 AREAS FOR IM PROVEM ENT . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 71 9.5.1 Design Basis / Configuration Control . . . . . . . . . . . . . . . . . . . . .. .... .. 71 9.5.2 Modification Process . . . .. . .. ................ ...... ....... 72 l

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l TABLE OF CONTENTS 9.5.3 Lack of 0wnershin . . . . . . . . . . . . . . . . . . . . . . ...... ..... ......... 72 9.5.4 Proced ure Compliance . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . ............ 73 9.5.5 Procedure Inadequacies and Lack of Detail . . . . . . . . . . . . . . . . . . . . . . . . . 73 l 9.5.6 ConDicting Procedure Guidance . . . . . . . . ..........................74 9.5.7 Cumbersome Processes . . . . . . . . . . . . .... ..... ... .............. 74  ;

9.5.8 InefHelent Processes . . . . . . . . . . . . . . . . . . . . ........... ........ .. 75 l 1

10.0 ENG I N E E RI NG P ROG RAM S . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 76 10.1

SUMMARY

....................................................76 10.2 SCO P E AN D M ETH O DOLOG Y . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 76 10.3 ST R E N G T H S . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 7 7 1 10.3.1 Program Imnrovements . . . . . . . . . . . . . . . . . . . . . . . . . . . . .............. 77 I 10.4 FINDINGS..................................... ............... 78 10.4.1 Exnectations: .............. .. ....... .......... .... . . ... 78 l 10.4.2 Planning . . . . . . . ... .................. .......... ........... 78 l 10.4.3 Design Basis Integration . . ........ ... . . ..... .... .......... 79 10.5 A REAS FOR IM PROVEMENT . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 80 10.5.1 Communication . . . . . . . . ....... . .... . . .... .. ... ...... 80 10.5.2 Procrams Needing Immediate Attention . . . . .........................81 10.5.3 Ownershin . . . . . . . . . . . . . . . . . . . . . . . . ................... ........ 82 10.5.4 I nd ust ry In volvem ent . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 8 2 I 10.5.5 Feedwater Nozzle Monitoring . . . . . . . . . . . . . . . . . .......... ......... 82 l 10.5.6 Lubrication Program . . . . . . . . . . . . . . . . . . . . ...... ................ 82 10.5.7 Design Criteria Document Updates . . ...............................82 10.5.8 Table 1: Engineering Programs Health Matrix . . . . . . . . . . . . . . . . . . . . . . . . . 83 1 1

l 11.0 V E RTI CA L S L I C E . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. . . 8 7 l 11.1

SUMMARY

.....................................................87 i 11.2 SCOPE AND M ETIIODOLOGY . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 87 11.3 ST R E N G T H S . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .88 11.3.1 The lST Basis Document . . . . . . . ................. ...... ..... ... 88 11.3.2 Safety Evaluation for Modi 6 cation 93-050 ..... ........... .. . ... 88 11.3.3 Maintenance Engineer Took Charce . ... ......... ..... ... ...... 88 11.3.4 The Prooosed Part 21 Procedure . . . . . . . . . .... ....... ............ 88 11.4 FINDINGS . . . ................ .. . .. ........ .. .... ......... 88 11.4.1 Design Basis Integration . ..... ..... .. ................... . .. 88 11.4.2 Operabilitv Assessments . . . . . . . . . . . ..... .. .. ... .... ....... 89 11.4.3 Configuration control . . . . . . . . . . . . . . . .. .......... .... ....... 89 Nebraska Public Power District Cooper Nuclear Station IV Engineering Self Assessment

TABLE OF CONTENTS 11.4.4 Corrective actions . . . . . . . . . . . . . . ........ ........ . ............. 90 11.5 AREAS FOR IM P ROVEM ENT . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .... 90 11.5.1 Design Criteria Documents . . . . . ......... ........................ 90 1 1.5.2 Cal c u l a t i o n s . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. 91 1 1.5.3 Setooints . . . . . . . . . . . . . . . . . . . ........ .............. ..... .. .. 91 11.5.4 System Operating Procedures . . . . . . . ..... .. .. .. . ........ 91 11.5.5 Maintenance Work Requests . . . . . . . . . . . . .... ....... ............. 91 11.5.6 Condition Reports . . ......................... ........ ....... 92 11.5.7 Modifications . . . ......................... ............. ... .92 11.5.8 Safety Evaluations . . ........................................92 11.5.9 Procurement . . . . ............ ............. ...... . ...... 92 11.5.10 Material Condition . . . ........ ........................ ........ 92 11.6 AREAS NOT OBSERVED . . . . . . . . . . . . . . . . . . . ..... . ... ... 93 12.0 APPENDIX A - TEAM MEMBER EXPERIENCE

SUMMARY

. . . . . . Page 1 of 4 13.0 APPENDIX B - MATRIX OF QUESTIONS / OBSERVATIONS TO IP 37550

.......... .. ........................................ ..... Page 1 of 15 14.0 APPENDIX C - AREA ASSESSMENT PLANS . . . . . . . . . . . . . . . . . . Page1of43 15.0 APPENDIX D - MATRIX OF OBSERVATIONS TO CONDITION REPORTS

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14.0 APPENDIX C- AREA ASSESSMENT PLANS 4

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i I FEBRUARY 5 - 23,1996 i

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Cooper Nuclear Station Page1of43 Engineering Self Assessment

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ENGINEERING SELF ASSESSMENT Appendix C

' TABLE OF CONTENTS  ;

EX ECUTIVE S U M M A RY . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. . . . . . . . . . . . . . . . TAB 1  ;

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- I NTRO D U CTI ON . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. . . . . TAB 2  :

l A SS ES S M ENT OVERVI EW . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . TAB 3 -

l.0 Assessment Team Composition and Responsibilities -

2.0 . Assessment Objectives  :

3.0 Handling Questions \lssues 4.0 Response Team Composition and Responsibilities 5.0 Assessment Plan Overview 6.0 - Expected Results IIORIZONTAL ASSESSMENT PLAN . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . TAB 4 ENGINEERING ABILITY TO RESOLVE OPERATIONAL ISSUES . . . . . . . . . . . . . . TAB 4.1 MAINTEN ANC E SUPPORT . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . TAB 4.2 SYSTEM ENGINEERING EFFECTIVENESS . . . . . . . . . . . . . . . . . . .. . . . . . . . . . . . . . TAB 4.3 PLANT MODIFICATIONS . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . TAB 4.4 ENGIN EERING PROGRAMS . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . TAB 4.5

~. w VERTICAL ASSESSMENT PLAN . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . TAB 5 QUESTION / OBSERVATION FORMS . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . TAB 6 FI E L D N OTES . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . TAB 7 l CRITICAL ASSESSMENT ATTRIBUTES . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . TAB 8 l

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SUMMARY

OF PAST PROBLEMS / ISSUES . . . . .. . . . . . . . . . . . . . . . . . . . . . . . . . . . . TAB 9 -

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l ENGINEERING SELF ASSESSMENT Appendix C EXECUTIVE

SUMMARY

This Engineering Self Assessment consists of " horizontal" and " vertical" reviews of the major engineering processes and products. The areas identified for horizontal reviews include: 1) Ability to resolve operational issues; 2) Maintenance Support; 3) System Engineering effectiveness; 4) Plant Modification; and 5) Engineering Programs. Key aspects of the processes involved in each of the assessment areas will be evaluated for the effectiveness of Engineering performance, using document reviews, customer and engineering personnel interviews and in-process observations. One key aspect of the horizontal review will be to identify specific significant examples of performance in each area during the past year. These examples will be followed through to final resolution. At various points during the process, in-depth reviews of performance, technical accuracy and completeness ofinputs and products, communications, processes and customer satisfaction will be evaluated. This process review in conjunction with conventional reviews of a sample of Engineering products in each area will provide a more complete picture of Engineering performance. A detailed l assessment plan was developed for each assessment area by the assigned task team leader. The Task l Team Leader in each area is one of the CNS engineers assigned to the team. The entire team met and reviewed and adjusted these assessment plans.

The vertical review will consist of a classic safety system functional inspection (SSFI) type of vertical slice review. Two systems, liigh Pressure Coolant Injection and the Diesel Generators, were chosen as the subject for the vertical review. These two systems cover both electrical and mechanical systems. Both of these systems had major modifications performed on them during the 1995 outage, both are important safety systems and are risk significant, and both have had some l major concern or deficiency identified during the past year. This vertical review is expected to provide an in-depth technical review of most aspects of the technical work perfeimed by Engineering on these two systems. With the vertical and horizontal components of the self assessment, l

Engineering expects to achieve a complete picture of the Divisions performance with respect to regulatory compliance, as well as process, personnel, management and organizational efTectiveness.

l The Self Assessment Team is made up of one Engineering line manager (Team Leader), four l Engineering line supervisors, one senior engineer and several outside consultants and loaned utility employees. Three of the team members are long time CNS engineers, and three are new engineers.

The consultants include one INPO evaluator, one recently retired senior engineering manager, one management consultant. Another consultant who has recently performed numerous NRC SSFI, EDSFI and other inspections was added to the team to lead the vertical assessment. Two senior engineers have been assigned to assist full time in the vertical assessment. In addition, to provide a customer orientation, one senior utility Operations Manager from a similar BWR is participating on the team. This team composition will provide the balance of CNS specific experience and outside perspective to provide a thorough assessment.

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ENGINEERING SELF ASSESSMENT PLAN Appendix C INTRODUCTION

1.0 Background

The Cooper Nuclear Station Engineering Division completed a major reorganization in 1995.

This reorganization involved a complete re-engineering of the organizational structure, personnel needs and location of the CNS Engineering Division.

All Nuclear Power Group engineering personnel were consolidated at CNS in mid-1995, which -

involved relocating approximately 80 positions from the Columbus General OfHee. The entire organizational structure of the Engineering Division was revised and consolidated under a Senior Engineering Manager on June 1,1995. The management and supervisory structure was revised and new expectations for each group and department in Engineering were established.

Based on the new expectations for each department, the consolidated location and the clearly changed focus of the organization, the number and type of engineering personnel needed was assessed and revised. Through a thorough interviewing, screening and placement process, most of the previously existing staff was placed in the new organization according to individual abilities and organization needs. This resulted in nearly all new personnel at the manager / supervisor level. Also, as a result of the number of existing staff that chose not to relocate from the CGO and the talent deficiencies identified in the old organization, approximately 34 new engineering personnel have been added to the Engineering Division, including several new supervisors.

The new Engineering Division has been in place for approximately one year. This one year included the completion of a major refueling and maintenance outage. The purpose of this Self Assessment is to evaluate the effectiveness of the Engineering organization, staff and processes,-

after its first year of existence, to assess the success of the reorganization effort. The results of this assessment will be used to identify any weaknesses or deficiencies and recommend corrective actions.

In addition to the original purpose of the Engineering Self Assessment, which was to determine

. the effectiveness of the organization and make mid-course corrections, it was realized that the NRC planned an Engineering and Technical Inspection in February, at about the same time as the self assessment. Based on new NRC guidance in Inspection Procedure (IP) 40501, which allows licensees to request the use of self assessments in lieu of NRC inspection, Engineering suggested that NRC also take advantage of the self assessment. The NRC agreed to follow the self assessment, and ifit is performed satisfactorily, to use it to focus NRC efforts. This resulted in NRC not scheduling an Engineering and Technical Inspection for February 1995. NRC will, instead, have inspectors follow the self assessment. NRC has made it clear that this will not reduce inspection man-hours for CNS Engineering, since the current SALP rating is a 3.

However, it will permit the NRC to focus available inspection hours on areas requiring further Nebraska Public Power District Cooper Nuclear Station Page 5 of 43 Engineering Self Auenment

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. ENGINEERING SELF ASSESSMENT PLAN Appendix C INTRODUCTION attention, rather than a general inspection like the Engineering and Technical Inspection. I I

2.0 Purnose  !

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The purpose of the Engineering Self Assessment is to determine if the changes in the i

Engineering Division have made a significant improvement in the capabilities and effectiveness  ;

of engineering support at Cooper Nuclear Station. J 3.0 Obiectives i

l The objectives of the Engineering Self Assessment are:

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1) To assess the post-reorganization effectiveness of the Engineering Division to perform routine and emergent site activities, including the identification and resolution of technical issues and problems. .

2) To identify areas needing further improvement.

3) To further develop Engineering self assessment capabilities.

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ENGINEERING SELF ASSESSMENT PLAN Appendix C ASSESSMENT OVERVIEW l.0 Assessment Team Comnosition and Resnonsibilities 1.1 Composition and Resnonsibilities The Engineering SelfAssessment Team and their associated responsibilities are as follows:

Michael Boyce Team Leader Ole Olson Task Leader - Resolution of Operational Issues Paul DiRito Task Leader - Maintenance Support James Salisbury Task Leader- System Engineering Effectiveness James Flaherty Task Leader- Plant Modifications Fadi Diya Task Leader- Engineering Programs Michael Shlyamberg Task Leader- Vertical Assessment Kenneth Thomas Vertical Assessment Evaluator Roger Moberly Vertical Assessment Evaluator Ted Hough Team Facilitator Robert Godley Licensi'ig Liason David Bremer Operations Liason Thomas Carson Maintenance Liason John Oswald QA Liason 1.2 Team Member Expectations Each team member is expected to conduct a thorough and complete evaluation of the area assigned. It is the mission of this evaluation to identify any concerns with engineering or CNS compliance with regulatory requirements, and to identify any weaknesses or areas needing further improvement.

Any plant operability, safety or regulatory issue must be identified promptly to the Team Leader to ensure that station management is informed and to ensure that the issue is addressed expeditiously.

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ENGINEERING SELF ASSESSMENT PLAN Appendix C ASSESSMENT OVERVIEW 2.0 Assessment Obiectives 2.1 Overall Objectives The overall objectives of the Engineering Self Assessment are as follows:

1) To assess the post-reorganization effectiveness of the Engineering Division to perform routine and emergent site activities, including the identification and resolution of technical issues and problems.

2) To identify areas needing further improvement.

3) To further develop Engineering self assessment capabilities.

2.2 Post-Reorganization Effectiveness

. The effectiveness of Engineering is divided into two parts. Part one is the ability to meet l regulatory requirements. This includes such items as technically correct and complete  !

engineering designs, operability assessments and problem resolutions; proper configuration control; accurate and accessible design basis information; and compliance with the license, appropriate codes, standards and commitments. j Part two of assessing Engineering effectiveness involves an evaluation of more subjective i areas. These areas include such items as ownership and accountability; process l i

effectiveness; effective use of resources, prioritization of work, and responsiveness; value added products; customer satisfaction; organizational effectiveness; staff qualifications and -

capabilities; communications; and management and supervisory effectiveness. These areas ,

are not black and white. However, without continuous improvement in these areas, regulatory compliance will slip. To assess these areas, it is necessary to not only review documents, but to interview engineering personnel and engineering customers, and to perform subjective evaluations of processes, people and functions. Tab 8 provides more i information on the critical a aibutes that are fundamental to this assessment.

3.0 Ilandling Ouestions and Issues A process for handling questions and issues has been identified for this assessment. The following definitions are used in this process:

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ENGINEERING SELF ASSESSMENT PLAN Appendix C ASSESSMENT OVERVIEW Question -

Any request for information or documentation provided to the response team.

Observation - A weakness or strength identified by the Assessment Team. Weaknesses will typically result from an unanswered or inadequately answered question.

These will be identified to the response team, reported to management and discussed in the report, unless resolved.

Finding . -

A fundamental underlying strength or weakness in one of the critical assessment attributes or some area of compliance, usually resulting from a e

number of data points due to observations by the team in more than one area

} of the assessment. These will be identified to management and discussed in j the final report.

! Questions will be documented on the form in Tab 6. These will be provided to the response t team and a copy will be provided to the Team clerk for entry into a database and filing. The l Response Team will be expected to respond within 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> to the question originator. The originator will then assess the response and either close the question, request additional information, or determine that a observation exists.

If the question is adequately answered, the criginator will so indicate on the original or a copy of the Question Form and provide it to the Team Clerk, along with any supporting documentation. The Team Clerk will then ensure that the database is updated and the closure documentation is filed.

If the originator is not satisfied with the response, and it is not a matter of obtaining additional information, he/she shall document the Observation on the appropriate form in Tab 6. Prior to presenting the Observation to the Response Team, the originator shall bring the Ob'servation to a Team Meeting and discuss it with the Team. Team Meetings will be held at Noon each day of the first two weeks of the Assessment and at 1600 the last week. The Team shall discuss all l

Observation, and upon the concurrence of the Team Leader, the Observation shall be presented to the Response Team and to Management, j Documented Observations will also be provided to the Team Clerk for entry into the database and filing of the concern along with any associated documentation.

At the Team Meetings, copies of all Team Members' Observations shall be distributed in advance and discussed. This will allow any potential Findings to be evaluated and formulated, based on similar or related Observations in different areas of the assessment. Also, it will serve Nebraska Public Power District Cooper Nuclear Station Page 9 of 43 Engineering Self Assessment

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ENGINEERING SELF ASSESSMENT PLAN Appendix C j ASSESSMENT OVERVIEW j to focus the assessment in other areas, toward items of concern from Observations in other areas, in order to validate the Observation and determine if a Finding exist.

Findings identified during Team Meetings will be determined based on the consensus of the members.- Once determined to be an Finding, the Team Leader shall discuss the issue with management and track the Finding for inclusion in the final report.

Some synergistic effects of different Team Member Observations may not be easily or readily identifiable. For this reason, the Team has set aside the afternoon of Wednesday of the second week of the assessment to systematically assess the identified Observations on the whole. A method similar to the INPO " yellow sticky" method will be used to spot related or synergistic  ;

observations that may be issues requiring further validation during the remaining one and one-half weeks of the assessment.

At any time during the assessment, a Team Member may identify a Observation that appears -

to be an item of noncompliance, an operability issue, a safety concern, a procedural violation or any other significant condition adverse to quality (SCAQ). These issues will be promptly identified to the Assessment Team Leader. Upon his evaluation of the potential impact of the

' Observation, the Observation will be promptly relayed to the Response Team Leader, not waiting for a Team Meeting. The Response Team will be notified that the concern is being considered to be a potential SCAQ and will be required to respond to the concern within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. if the response team does not believe the concern can be resolved within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, the response team shall initiate a Condition Report, and take whatever action is required by appropriate CNS procedures. The Response Team shall provide the action taken to the originator within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. If an SCAQ is identified, the Assessment Team will follow the handling of the problem as a part of the assessment, but will not participate in the resolution.

The assessment will continue regardless of the issues.

4.0 Resnonse Team Cemnosition and Resnonsibilities The composition and responsibilities of the Response Team are:

Daniel Buman - Response Team Leader Mark Unruh - Response Team - Vertical Slice Glen Seeman - Response Team - Plant Modification Todd Hottovy - Response Team - OperationalIssues Mick Spencer - Response Team - Programs John Swanson - Response Team - System Engineering Scott Freborg - Response Team - Maintenance Support I

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a ENGINEERING SELF ASSESSMENT PLAN Appendix C .

ASSESSMENT OVERVIEW )

- The Response Team is expected to perform the following during the Assessment:

1) Respond to Questions and Concerns within 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br />.

2) _ Respond to Observations that are Significant Conditions Adverse to Quality within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.

3) Upon discovery of an SCAQ that cannot be answered within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, have a Condition Report initiated.

4) Any SCAQ that requires operability assessment, reportability assessment, immediate or compensatory actions or other procedural action, assure it is taken.

5) If a Question or Observation leads the Response Team to the discovery of a further concem or a separate unrelated concern, it shall be identified to the Assessment Team for further validation and evaluation.

The Assessment and Response Teams are not adversarial in nature. They are all part of one larger Engineering Team performing the best possible assessment of the effectiveness i of the Engineering Division. All known information will be shared between the two parts j of the assessment team. Any Question, Observation or Finding will be shared as promptly j as possible with the Response Team, to allow them to provide information or insight into j the problem. Likewise, any information discovered by the Response Team will be shared I i

with the Assessment Team, so that it may be factored into the overall assessment.

5.0 Assessment Plan Overview 5.1 Overview ,

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The Engineering Self Assessment will consist of both a " horizontal" and a " vertical" I review. The horizontal review consists of five major areas of engineering performance.

The five areas are: 1) Ability to Resolve Operational Issues,2) Maintenance Support,3) ,

System Engineering Effectiveness,4) Plant Modification, and 5) Engineering Programs.

The horizontal review is a review of the programs and processes that make up the  !

engineering function. The vertical review is a classic vertical slice assessment of the ~ l

. technical products associated with two systems. The two systems chosen were: the High  ;

Pressure Coolant Injection System and the Diesel Generators.  ;

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Cooper Nuclear Station Page11of43 Engineering Self Aueument

l ENGINEERING SELF ASSESSMENT PLAN Appendix C ASSESSMENT OVERVIEW The original Assessment Outline, submitted to the NRC in letter NLS950211, dated l

November 3,1995, identified a sixth horizontal assessment area. This sixth area was i Engineering Document Control. An Assessment Plan was developed for this area. I Ilowever, it was determined that this area overlapped significantly with the other 5 ,

assessment areas. Therefore, the Engineering Document Control Assessment Plan was l rolled into each of the other horizontal assessment areas. Thus, document control will be '

assessed within each of the plan areas instead of as a separate plan area.

1 5.2 Horizontal Review i The five areas chosen for this review were chosen based on a review of the summary of issues in the engineering area from past major evaluations of Cooper Nuclear Station.

Since one of the primary objectives is to assess post-reorganization effectiveness, an j evaluation of the areas of concern prior to the reorganization will identify whether progress l

is being made. l Within each of the five areas, the horizontal review will review products, conduct interviews of engineers and customers and follow in-progress activities. One other key aspect of the horizontal review will be to select examples of recent events which are representative of the important functions within that area. The event will be followed through the process to determine engineering effectiveness at each step. At key points in the process, the '.ssessment Team will " dig" vertically into the inputs and outputs of the process. TR ril provide a thorough assessment of the technical adequacy and regulatory compliance ' Engineering products, as well as an assessment of organizational, process, personnel and management effectiveness of the Engineering Division. ,

1 An assessment plan has been developed by the Team for each of the five areas. Tab 4.1 l through l ab 4.5 contain the individual assessment plans.

5.3 Vertical Review The vertical review is a classic Safety System Functional Assessment of two systems. The two systems chosen were the fligh Pressure Coolant Injection System and the Diesel Generators. These two systems were determined to be appropriate for the following reasons:

1) Address both electrical and mechanical systems.

2) Both systems had major modifications during the 1995 outage.

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ENGINEERING SELF ASSESSMENT PLAN Appendix C ASSESSMENT OVERVIEW

3) . Both systems are important safety systems and both are risk significant.

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4) Both systems have had deficiencies identified in the past year.

A consultant with significant experience performing vertical slice inspections has been added to the Team to lead this portion of the assessment. The NRC Inspection procedure and Temporary Instruction will be used as guidance for this part of the assessment. Tab 5 contains the assessment plan for the vertical review.

l 6.0 Exnected Results The Engineering Division expects to a thorough, in-depth evaluation of the effectiveness of the new organization to handle routine and emergent work, including identification and resolution of problems. The results expected are a set of weaknesses, issues and possible noncompliances, and recommendations of areas for future improvement.

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ENGINEERING SELF ASSESSMENT Appendix C l l

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HORIZONTAL ASSESSMENT  !

PLAN l

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ENGINEERING SELF ASSESSMENT Appendix C Evaluation of Engineering's Ability to Resolve Operationalissues January 31,1996 Evaluation Obiective Provide a " horizontal review" of the Cooper Nuclear Station engineering staff's ability to perform routine and reactive activities required to support plant operational issues.

Evaluation Reauirements

1. Evaluate Engineering's ability to meet operational expectations while performing design change l activities. This includes- 1 Prioritization of Design Changes with respect to Operation's expectations Appropriate identification of Operator Training requirements Control of critical Control Room drawings that are affected by design changes Communication of partial completions of modifications to the Operations Department Appropriate identification of post modification testing of Design Changes to ensure that system / components are operable prior to closeout Communication of on the spot changes to the Operations Department Modifications evaluate impact on simulator hardware and software

2. Evaluate Engineering's ability to meet Operational expectations while performing Plant Temperary Modification activities. This includes:

Communication ofinstallation of removal of PTMs to the Operations Department j Control of critical Control Room drawings that are affected by PTMs  :

Engineering's responsiveness to operational concerns created by PTMs installed for long periods of time (9-12 months)

Engineering'r. responsiveness to PTMs requested by the Operations Department l

Evaluation of the impact PTMs have on plant operations and safety

3. Evaluate the extent and quality of Engineering's involvement in operational activities. This includes:

Effectiveness of Engineering communications with the Operations staff  !

Engineering's involvement in the resolution of operational issues Engineering's responsiveness to operational " work arounds" and red arrow open items The ability to identify operational concerns into the prioritizing engineering work l Timeliness of engineering resolutions of operational concerns

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ENGINEERING SELF ASSESSMENT Appendix C  !

Evaluation of Engineering's Ability '

to Resolve Operationalissues  !

January 31,1996 ,

Willingness of operations to request engineering involvement in addressing issues Availability and use of the PRA in the decision making process while evaluation  !

operationalissues Engineering's ability to identify the Operations Department as a customer f Reactor Engineering's effectiveness in responding to operational issues Engineering's effectiveness during Refuel Outage 16 l Overall change in the responsiveness to operational issues following the Engineering reorganization Accuracy of calculations that support the EOPs Engineering's involvement in changes to EOPs, via procedural requirements. ,

4. Evaluate major issues that stem from the evaluation of the above requirements.

Evaluation Plan

1. Interview Operations Management to determine their opinion of Engineering's ability to meet their expectations.

2. Interview an Operations Crew, a member of Operations Support and a member of Operations Training to determine their opinion of Engineering's ability to meet their expectations. l

3. Interview Engineering Management to determine how operational goals and expectations are communicated to the Engineering staff. I l

4. Prepare a questionnaire and interview 4 Engineering's to obtain input on the ability ofengineers to meet operational expectations.

5. Review a Design Change that impacted the Control Room and/or operational routines against the following criteria. l Operator training requirements were identified.(03.01d)

Critical Control Room drawings were revised as required by procedures in a timely manner.

Post modification testing was focused on the installed changes and procedures were  !

reviewed and approved. (03.0lk)

Post modification testing was evaluated and deviations were resolved.(03.0ll)

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1 ENGINEEklNG SELF ASSESSMENT Appendix C Evaluation of Engineering's Ability to Resolve OperationalIssues January 31,1996 Post modification testing ensured that equipment and systems were operable prior to returning to service.(03.01k,03.01i(6),03.01m))

OSCs received required operations review.

Design Changes were properly released for work.

Simulator changes were properly incorporated into the modification.

Prioritization of modifications include consideration for safety significance (03.03f(l))

6. Review 2 PTMs and assess their ability to address the following criteria.  ;

l Appropriate functional testing is performed after installation or removal of a PTM.(3.02e) l Control Room personnel are aware ofinstalled and removed PTMs.

Critical Control Room drawings were revised as required by procedures in a timely manner.(03.02h)

' l Plans exist to eliminate PTMs that have been installed for greater than 9-12 i months.(03.02g) l PTMs address impact on plant operations and safety l l

7. Identify 2 surveillances assigned to the Engineering Department and review the results against i l the following criteria.

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Evaluation of results were performed in a timely manner, l Proper release for performance of the SP was obtained.

Resolution of discrepancies were provided.

Engineering identified and supported resolution of operability issues.(3.06a)

8. Identify 2 Operational Assessments that required engineering l

, input and evaluate the OA against the following criteria. I Assessments considered USAR and Technical Specification requirements Generic implications were addressed if appropriate Conclusion were clear Appropriate references and supporting documents were identified (03.03b)

The root cause of the condition was determined.(03.03b)

Records of the OA were properly maintained.(03.03d4))

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ENGINEERING SELF ASSESSMENT Appendix C Evaluation of Engineering's Ability j to Resolve OperationalIssues l January 31,1996 i

9. Identify 2 closed Condition Reports that were evaluated by Engineering and evaluate the Condition Reports against the following criteria.

Probabilistic risk assessment was used if appropriate to evaluate the impact of the condition.(03.03a)  !

The evaluation of the CR clearly identified the problem, root cause and corrective actions i required to prevent recurrence. (03.03b)

Procedural requirements were met. i Appropriate modes of system and plant operation were addressed.

Evaluations were made in a timely manner.(03.03d(5))

Part 21 evaluations were done when appropriate. (03.03e(3))

Ability of engineering to initial identify the concerns of the CR.(03.06a(1))

Management involvement was at the proper level.(03.06a(2))  ;

Adequate root cause evaluations were completed. (03.06a(3))

Adequate operability assessments were completed. (03.06a(4))

Corrective actions were identified and implemented in a timely manner.(03.06a(5))  ;

Evaluations considered generic implications, procedures and human performance inadequacies.(03.06a(6))

CR Backlogs are tracked and managed.(03.03f(3))

10. Evaluate 2 safety evaluations using the following criteria.

Evaluations were technically accurate.(03.0lf)  ;

-. Evaluations consider applicable modes of operation Evaluations address applicable accidents and transients Engineering involvement was at the appropriate level. (03.03e(2))

Personnel involved met training requirements.(03.07a)

11. Evaluate an Engineering Judgement using the following criteria.

Evaluations were technically accurate.(03.01f)

Evaluations consider applicable modes of operation Corrective actions were identified and implemented in a timely manner.(03.06a(5))

Evaluations considered generic implications, procedures and human performance inadequacies.(03.06a(6))

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y ENGINEERING SELF ASSESSMENT Appendix C Evaluation of Engineering's Ability to Resolve OperationalIssues January 31,1996 l

12. Evaluate responses to an infonnation notice, a SOER and a vendor bulletin using the following criteria. (03.03d(l)(2)(3)) l Evaluations are performed in a timely manner.(03.03d)

Records of the evaluations are maintained and retrievable.(03.03d)

Evaluations are technically accurate.

Corrective actions are identified and implemented in a timely manner.

13. Review a Design Change or PTM that required partial closure and detennine if operability and 50.59 requirements were appropriately considered.(03.01h)

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- 14. Perform further evaluation of additional scope identified by the above reviews but not identified I by the original evaluation requirements.

15. Provide and obtain daily feedback from the Engineering Self Evaluation Team to ensure consistency during assessment.

j Evaluation Products  !

I Findings will be generated by drafling a final report including all CNS documents reviewed and field documents generated. The report will be in the fonnat adopted by the Engineering Self Assessment Team.

References i 1

1. NRC IP 37550 I

2. INPO 90-015

3. NLS950211

4. NRC IP 40501

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ENGINEERING SELF ASSESSMENT Appendix C IIorizontal Review of Maintenance Support Assessment Plan -

January 24,1996 Scope i

To review specific recent cases of Engineering support for specific maintenance activities or programs and assess Engineering performance. These activities or programs should include troubleshooting, corrective maintenance, planned maintenance on selected systems, use of Risk Analysis to support outages and the Maintenance Rule Program. From this review, strengths, weaknesces or areas in need of further improvement will be identified. Immediate corrective action and action to prevent reoccurrence will be taken or recommended as appropriate.

Method of Assessment WEEK 1: Initial Data Gathering Phase (Feb 5,1996 to Feb 11,1996)

1. Obtain recent examples of the following documents to review for effectiveness and compare to respective procedure for compliance:

a. Review 3 instances where Engineering provided troubleshooting assistance.

1) Review to ensure troubleshooting guidance did not constitute a PTM nor l required a 50.59.

2) Review for conformance with procedure 7.0.1.7.

3) Review Engineering troubleshooting assistance for adequacy, appropriateness and timeliness. [03.03c.(4)]

4) Review adequacy of proUem identification, Root Cause failure analysis and corrective actions. [03.03b], [03.06a.(1)], [03.06a.(3)]

b. Review 3 examples of where System Engineers helped develop work instructions or MWR package.

1) Assess adequacy of Fire Protection related Engineering support. Does the MWR meet National Fire Protection Association Standards for PMT.

2) Assess the adequacy of the coordination with the System Engineer, Program Engineer, MOV Engineer, CV Engineer, and EQ Coordinator.

3) Assess the adequacy of Program instructions for the MWR.

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ENGINEERING SELF ASSESSMENT Appendix C Horizontal Review of Maintenance Support Assessment Plan January 24,1996 l

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4) Review the MWR for and address adequacy of:

PMT per 7.0.5 Unisolable River flooding Program requirements Control Room human factors MOV control and PMT Potential to drain Reactor Engineering Support Procedures Potential to drain Fuel Pool

! STP/SP Requirements Consider preconditioning l Potential Temporary Modificmiors Pretesting Required l Breach of Control Room Envelope Configuration Changes l Breach of Primary or Second ny Containment l

l 5) Review MWR for adequacy of prior ty and scheduling.

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Engineer could have done to assist.

l 7) Review PMT for adequacy in meeting Pressure Testing, IST and Welding j requirements / acceptance criteria.

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l 8) Was a technical walkdown performed for any Special Instructions that were generated  !

per procedure 7.0.1.5. Were procedures circumvented by the Special Instructions.

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9) Review for conformance with procedures 3.6.1,0.40,7.0.1.2, and 7.0.1.4.

10) Review for conformance with EQ and Essential program requirements.

l 11) Evaluate backlog of work and timely review performed on MWRs.

l 12) Evaluate formality of the process, consistency and efficiency of performance. l l 13) Was initial problem identification, root cause analysis, corrective action l l implementation and equipment trending information adequately incorporated into MWR packages. [03.03b], [03.03c.(1)], [03.06a.(5)]

14) Were Vendor Bulletins, NRC Generic Communications and SOERs adequately incorporated into MWRs in a timely manner. [03.03d.(1)], [03.03d.(2)], [03.03d.(3)],

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c. Review 3 examples of where Engineering assisted in generating a PMT.

1) Was the PMT process was modified by plant or industry operating experience. l

2) If the Maintenance was a result of a component failure, did the PMT adequately  !

address the failure root cause.

3) Assess the preparation and performance of PMT based on Codes, Standards, Tech Specs, Vendor recommendations and analysis. l l_ 4) Was the PMT generated in accordance with procedure 7.0.5.

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5) Did the PMT adequately address everything in the MWR.

6) Did the PMT clearly and accurately identify the acceptance criteria. [03.03c.(3)]

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d. Assess appropriate Engineering involvement in determining and changing PM requirements on plant equipment.

1) Review 2 recent PM changes to determine if the appropriate engineers reviewed and concurred with the changes. Verify that a basis currently exists for the 2 PMs.

2) Evaluate the process for PM generation to ensure proper engineering involvement in analysis of equipment problems and recommendations for revisions to the PM program. [03.03c.(2)]

3) Evaluate whether Engineering is properly involved in the resolution of problems encountered during PMs.

4) Does design change information get properly incorporated into the PM program per 3.4.11. [03.01g]

e. Review a sample of recent RCEs for the followmg

1) Procedural requirements for preparation, review, and approval were followed. I

2) Personnel signing the RCE were qualified and of the appropriate level.

3) Assess ownership of the process. >

4) Assess procedure 3.25 for work flow issues.

5) RCEs were not used to make design modifications to the plant.

6) Controlled original RCEs are maintained in a retrievable location.

7) Status ofin-progress and complete RCEs is tracked.

8) Closure of RCEs are timely.

9) ' Documents affected by RCEs are updated in a timely fashion.

f. Review the Special Test and Special Procedure process for the following:

1) Were special procedures generated for non-routine maintenance. Was the special procedure appropriate or should a Maintenance procedure have been used/ generated.

2) Were special tests and special procedures generated in accordance with procedure 3.5.

3) Determine if STP/SP's are stored properly.

4) Determine if the status ofin-progress, approved and completed STP/SP's is tracked.

5) Determine if STP/SP's are closed out in a timely manner.

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g. Review a recent example of where an Engineering Manager reviewed an essential  ;

component minor maintenance item. i

1) Was the review performed in accordance with procedure 7.0.1.6.  ;

2) Was it clear what needed to be reviewed and what accountability was associated with the review.

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ENGINEERING SEL.F ASSESSMENT Appendix C llorizontal Review of Maintenance Support Assessment Plan January 24,1996

h. Review 3 examples of CGI paperwork processing from package generation to acceptance plan implementation.

1) Assess adequacy of a CGI dedication package per procedure 3.22

2) Assess completeness of technical evaluation / adequacy of Engineering involvement of CGI dedication packages per procedure 3.22.1. [03.01a], [03.03c(5)]

3) Assess the adequacy of the CGI dedication package Action Plan and Action Plan implementation per procedure 3.22.2 and 3.22.3.

4) Does the process encourage short cuts to be taken by Maintenance individuals.

5) Assess whether inputs to the dedications are applicable to CNS.

6) Evaluate whether original controlled CGIs are stored properly.

7) Assess ownership of the CGI program.

8) Review qualifications of the originators, reviewers, and approvers.

i. Review the Setpoint Log process as follows:

1) Assess ownership of the Setpoint Log.

2) Review procedures 3.26,3.26.1,3.26.2, and 3.26.3 governing the Setpoint Program.

3) Determine the basis for at least 3 important setpoints and verify that the basis is an approved calculation or analysis.

4) Verify that the approved Setpoint for 3 entries in the Setpoint log are accurately reflected in the appropriate operating procedures.

5) Verify that adequate procedural guidance exists to ensure that setpoints are maintained current. .

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Review 3 current essential Vendor Manuals to verify the following:

1) Vendor Manuals contain information pertinent to the equipment, currently installed in the plant (via EDF or nameplate).

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2) Choose at least 2 important vendor recommended preventative maintenance activities.

Verify a PM or surveillance exists to implement the vendor recommendations or that ,

a valid technicaljustification exists.

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3) Choose at least 2 important vendor design values and verify via comparison with other documents (DCDs, drawings, procedures, etc.) That the appropriate design basis  ;

has been maintained.  !

4) Assess ownership of the Vendor Manual Control Program. Review procedures 3.11, 3.11.1, and 3.11.2 for the Vendor Manual Control Program. Determine if the vendor manual update process tracks the status of vendor manual changes.

Nebraska Public Power District Cooper Nuclear Station Page 23 of 43 Engineering seir Assessment

ENGINEERING SELF ASSESSMENT Appendix C j llorizontal Review of Maintenance Support Assessment Plan January 24,1996

2. Perform field observations in the following areas to observe Engineering support of Maintenance:

! a. Observe MWR initial review by Engineering.

1) Assess adequacy of Fire Protection related Engineering support. Does the MWR ,

meet National Fire Protection Association Standards fo PMT.

2) Assess the adequacy of the coordination with the System Engineer, Program l Engineer, MOV Engineer, CV Engineer, and EQ Coordinator.

3) Assess the adequacy of Program instructions for the MWR. ,

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4) Review the MWR for and address adequacy of:

PMT per 7.0.5 Unisolable River flooding ,

Program requirements Control Room human factors MOV control and PMT Potential to drain Reactor Engineering Support Procedures Potential to drain Fuel Pool STP/SP Requirements Consider preconditioning Potential Temporary Modifications Pretesting Required Breach of Control Room Envelope Configuration Changes Breach of Primary or Secondary Containment

5) Review MWR for adequacy of priority and scheduling. '

l 6) Review MWR for adequacy of obtaining materials, was there more that the System Engineer could have done to assist.

7) Was a technical walkdown performed for the instructions. l 1

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b. Observe MWR closeout review by Engineering.

1) Assess adequacy of Fire Protection related Engineering support. Does the MWR .

meet National Fire Protection Association Standards for PMT. l

2) Assess the adequacy of the coordination with the System Engineer, Program Engineer, MOV Engineer, CV Engineer, and EQ Coordinator.

3) Assess the adequacy of Program instructions for the MWR.

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. Nebraska Public Power District Cooper Nuclear Station Page 24 of 43 r2.gineering seir Assessment l

ENGINEERING SELF ASSESSMENT Appendix C

! IIorizontal Review of Maintenance Support j Assessment Plan January 24,1996

4) Review the MWR for and address adequacy of:

PMT per 7.0.5 Unisolable River flooding Program requirements Control Room human factors MOV control and PMT Potential to drain Reactor Engineering Support Procedures Potential to drain Fuel Pool STP/SP Requirements Consider preconditioning Potential Temporary Modifications Pretesting Required Breach of Control Room Envelope Configuration Changes Breach of Primary or Secondary Containment

5) Review MWR for adequacy of priority and scheduling.

6) Review MWR for adequacy of obtaining materials, was there more that the System l Engineer could have done to assist. .

7) Review PMT for adequacy in meeting Pressure Testing, IST and Welding requirements / acceptance criteria.  !

8) Was a technical walkdown performed for the instructions.

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c. Observe Procurement process involvement by Engineering.

1) Review Procurement documents to establish / document part requirements, how to procure and receipt. Review for compliance with procedure 3.15.

2) Do procedural requirements ensure the appropriate specifications are provided for essential P.O.'s. Evaluate the procedural guidance for preparing P.O.'s.

3) Evaluate technical receipt inspection requirements.

4) Does Engineering have the appropriate level of review.  ;

d. Observe an actual plant issue being resolved by Engineering that requires interface between Engineering and Maintenance.

3. Formulate questions to ask for each respective group in Engineering and Maintenance that either provides or receives Maintenance support from Engineering. Questions should be formed based on discrepancies identified in paperwork review, observations, verification of performance of key activities and investigating into issues previously identified above. The following areas should also be addressed:

• Communications and interfaces between Engineering and Maintenance. Evaluate timeliness and quality. Do postjob meetings evaluatejob performance.

Resolution of technical issues. Evaluate timeliness and appropriateness.

Nebraska Public Power District Cooper Nuclear Station Page 25 of 43 Engineering Self Assessment

ENGINEERING SELF ASSESSMENT Appendix C IIorizontal Review of Maintenance Support Assessment Plan January 24,1996 Evaluate necessity of reviews being performed. Are the appropriate groups performing the review or should the review be performed by another group. Are there ownership / accountability issues present.

Are there MWRs that are actually modifications. Ilow clear is the difference, is it understood, what perceptions exist about the distinction.

Backlogs should be evaluated for acceptability and plans to eliminate.

StalTmg levels and experience of Engineering staffinvolved.

Engineering organizational structure is clearly defined.

Clearly delineated responsibilities, training, procedures.

Determine if a procedure, program owner and quality check points exist for each process or program.

Are procedures adequate and being followed. Address from compliance and common sense points of view.

Assess problems with the Vendor Manual control process. Are Vendor manuals accessible and maintained up to date.

Routine and reactive response capability and performance.

Appropriateness of post maintenance testing. Is it clear who owns the PMT.

Use of PRA in decision making in on-line and outage maintenance. [03.03a]

Knowledge of Maintenance Improvement programs and Maintenance Rule Programs: 1 concerns addressed or understanding adequate for current level of development.  ;

Use of Maintenance Rule program for equipment trending and PM revision. [03.03c.(1)], l

[03.03c.(2)]

• Adequacy of documentation of resolutions.

• Are set points adequately controlled in calibration or maintenance activities. '

Engineering involvement in predictive maintenance program adequate and outages adjusted based on Engineering input per procedure 7.0.14.  ;

• Avelable performance indicators ofequipment reliability /few maintenance related failures.

Engineering involvement in PMTs, troubleshooting, procurement, MWR approval, and i ensuring maintenance is not bypassing the modification process.

Replacement parts available or fabrication support adequate per procedure 3.21. Does maintenance feel they are on their own to get parts. Are parts shelf ready.

• What should be Engineering involvement in obtaining parts from customer / benchmark i i at of view. Who owns this process. Should Maintenance be more involved in i obtaining / verifying correct parts. l Is there or should there be any consolidation of parts lists from various manufacturers.

Use of vendor information or NRC bulletins

• Prioritization of work, identification of work safety significance.

Nebraska Public Power District Cooper Nuclear Station Page 26 of 43 Engineering Self Assessment

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ENGINEERING SELF ASSESSMENT Appendix C IIorizontal Review of Maintenance Support Assessment Plan January 24,1996 Contract engineering reliance and effectiveness.

Use of QA to improve Engineering support of Maintenance.

Quality of support of Maintenance on both Tech Spec and non-Tech Spec systems.

Does Engineering Management take an active role in job performance. Are high performance standards for Engineering support activities established, communicated and reinforced.

Individual accountability and morale ofindividuals involved. Is developing improved methods of meeting safety, quality and productivity goals encouraged.

Maintenance satisfaction with Engineering service and what further Engineering support is needed by Maintenance.

Review Engineering and I&C interface during surveillances.

4. Conduct interviews with Engineering and Maintenance individuals to evaluate effectiveness of key activities and probing into issues identified above. Conduct at least a 10% representative sample interview from each responsible group in Engineering that supports Maintenance or in Maintenance is the recipient of Engineering support including supervision

5. Identify 3 to 5 specific recent examples for further investigation based on interviews. Examples should be based on relative importance of the issue and value to be gained by further investigation.

WEEK 2: Detailed Assessment of Problem Areas (Feb 12,1996 to Feb 18,1996)

6. Perfonn investigation into specific events of concem identified in item 5 by reviewing applicable documentation and interviewing individuals involved in previous investigations.

Evaluate the following in the review of the CRT report:

a. Evaluate the root cause assessment.

b. Evaluate whether the corrective actions addressed the original problem and prevent recurrence. Evaluate backlogs and overdue items.  ;

c. Evaluate whether generic /other train /other component evaluations were adequate.

d. Review the number and type of Level 1 assessment extensions in the Engineering division.

e. Assess attitudes in Engineering toward the CAP program in interviews with Engineers.

7. Develop a list of strengths, weaknesses and findings from results of investigation. Each strength, weakness or finding should have at least 2 or 3 facts listed to support the conclusion.

Weaknesses and findings should have proposed corrective action.

Nebraska Public Power District Cooper Nuclear Station Page 27 of 43 Engineering Self Assessment

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ENGINEERING SELF ASSESSMENT Appendix C llorizontal Review of Maintenance Support Assessment Plan January 24,1996 WEEK 3: Generic Implications Assessment (Feb 19,1996 to Feb 25,1996)

8. Incorporate findings from Engineering support of Maintenance with other areas of self assessment to determine generic strengths, weaknesses and findings.

WEEK 4: Report Writing / Submission (Feb 26,1996 to Feb 29,1996)

9. Write / consolidate the Engineering Self Assessment into a final report and brief senior management /NRC.

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i ENGINEERING SELF ASSESSMENT Appendix C Evaluation of System Engineering Effectiveness Scope: 1 Review of performance of specific system engineers in such areas as:

l (a) Improving and maintaining system materiel condition.  ;

(b) Trending system and component performance.

(c) Customer service.

l Evaluation plan: )

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The evaluation of this area will consist of procedure reviews, interviews, record reviews, performance indicators, and observations. The teams support is requested to support the various )

interviews outlined in this plan.

(a) Improving and maintaining system material condition. j

1. Choose several major evolutions on three systems and determine system engineers involvement.

Ilow are the system engineers involved informed of the resolution of all CR with respect to their l system assignments? Review CRs in the CRG in the past year and determine system engineer involvement and awareness.

2. Interview four engineers and determine the methods used to improve and maintain system materiel condition. Tour the system with the system engineer to determine system knowledge level. These interviews should include questions identified in Attaclunent 1.

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3. Interviews with the program owners for the programs indicated below to determine involvement i of the system engineer. l Surveillance program.

FAC program.

ISI program.

IST program.

MOV program. '

Check Valve program.  ;

Appendix J '

Fire Protection.

Oil analysis.

Tliermography.

INebraska Public Power District Cooper Nuclear Station Page 29 of 43 Engineering self Assessment

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1 ENGINEERING SELF ASSESSMENT Appendix C j Evaluation of System Engineering Effectiveness

4. Review the PM program and the recently implemented PM reduction program. Determine the .

adequacy of system engineering involvement.

5. Review seural vendor manuals and determine if vendor recommended PMs are in place or have been evaluated as a deviation to the vendor recommended program. Ilow many unreviewed open vendor manuals exist? What is the mechanism used to review updated vendor manuals. I Does this review include updating PMs as required?

6. Review any real time events that may occur during the evaluation period.

7. Review past assessments to identify unchanged and unimproved trends.

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8. Evaluate engineers support of maintenance windows and maintenance equipment performance.  ;

9. Evaluate the system engineer use the DCD on a regular basis and what is the method of f updating the DCD when discrepancies are identified? l (b) Trending system and component performance.

This evaluation will specifically investigate the effectiveness of the performance monitoring program. The evaluation will include a review of the routine monitoring, collection, trending, and analysis of the performance data for equipment important to plant reliability. In addition, managements commitment to the performance monitoring program will be reviewed.

1. Review the existing program?

a. Does it include all equipment important to plant reliability?

b. Does the program include review of equipment performance with respect to the following parameters:

Vibration.

Heat exchanger performance.

Heat determination and analysis.

Monitoring of major equipment such as:

DGs.

Station batteries.

HPCI and RCIC.

RHR and CS.

c Nebraska Public Power District Cooper Nuclear Station Page 30 of 43 Engineering Self Assessment

ENGINEERING SELF ASSESSMENT Appendix C Evaluation of System Engineering Effectiveness Monitoring of major equipment such as (continued):

RR pump and M/G set.

Pump performance tests.

Valve stoke timing.

Oil analysis.

Thermography of electrical equipment.

c. Does a document exist that documents what equipment and performance characteristic may need to be monitored?

d. Are test results reviewed in a timely manner?

e. Is the frequency of each test documented?

f. Is the optimal perfomiance levels documented in order to properly evaluate test results and trends?

g. Does the CR4T program provide input to the performance monitoring program?

h. Is clear management involvement included in the program?

i. Ilow is the owner of the program? i

2. Interview four engineers to determine the adequacy of the performance program. These interviews should include questions identified in Attachment 2:

(c) Customer senice.

This section will consist of determine if the primary customers are adequately satisfied with the product provided by system engineering.

1. Review the survey results of the recently performed engineering survey entitled: RE16 Outage Customer Service Survey - Engineering Organization. Incorporate tl.ese comments into the customer service evaluation questionnaire to determine the cause of poor and excellent performance.

Nebraska Public Power District Cooper Nuclear Station Page 31 of 43 Engineering Self Assessment

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k ENGINEERING SELF ASSESSMENT Appendix C Evaluation of System Engineering Effectiveness  ;

2. Perform one on one interviews to determine the level of satisfaction with regard to system engineers. One on one interviews with the following personnel are recommended:

Operations Supervisor.

Operations Support Group Supervisor.- i Several Shift Supervisors. l Several Control Room Supervisors. I Several Control Room Operators.

l Several Station Operators. 1

- Plant Engineering Manager.

Maintenance Supervisor.

Maintenance Planning Supervisor.

Mechanical Supervisor.

Several engineering Supervisors..

Several Engineers.

Several Chemistry technicians.

Several RP technicians.

The interviews must consider the following:

Does the customer feel comfortable in requesting support and does he/she believe his request will be resolved without followup?

Does the Customer know who is the system engineering contact?

Are expectations consistent?

Do expectations reflect EP 3.2, System Engineering Program ?

Evaluate and document interdepartment communication.

3. The following interviews are recommended following the completion of a majority of the above interviews and assessment ofinterview results.

Maintenance Manager. I Operations Manager.

Senior Engineering Manager.  !

Plant Manager.

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4. Review the observation program in the past year to determine adverse trends in the engineering department.

l Nebraska Public Power District Cooper Nuclear Station Page 32 of 43 Engineering Self Auessment

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~ Attachment 1 Appendix C 1mproving and Maintaining System Material Condition Interview Questions for Section (a) 2

a. Involvement of system engineering in the PM process?

b. Ilow are IE, OER, and vendor manuals used to improve and maintain system materiel condition?

c. Are system walkdowns performed on a periodic basis?

d. What specific guidance is used during these walkdowns?

e. What are the results of these walkdowns?

f. Do engineers understand their primary function is to improve and maintain system materiel condition?

g. Is the system engineer familiar and involved with major maintenance activities and design  ;

changes for his system? What equipment is awaiting modification? What PTM is installed to enhance equipment performance?

h. Is the system engineer adequately involved in the programs identific d in a3 above?

i. What inspection or equipment monitoring technique is not being perfonned that should be?

j. What does training provide to the system engineer to help him/her achieve the above duties?

Is the trrining performance based?-

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k. Provide examples ofimprovements to the systems materiel condition provided by the system )

engineer. What program supported this improvement? )

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1. What long term problems are currently being resolved? What problems is the system engineer )

aware of that do not have a improvement plan in place? Why, if any?  ;

' m. Is the system engineer aware of any poor maintenance practice that are contributing to poor availability? I

n. Does the system engineer maintain a system notebook? If yes, what type ofinformation is included in the notebook?

Nebraska Public Power District Cooper Nuclear Station Page 33 of 43 Engineering Scif Assessment

1 Appendix C Improving and Maintaining System Material Condition Inten'iew Questions for Section (a) 2 ,

o. Ilow many systems is the system engineer assigned? Is this an insufficient or excessive workload?

p. Does the system engineers priorities match those of the Operations department?

q. Ilow does management support the systems engineers efforts to improve and maintain system materiel condition? . Are they supportive in resolving this improvements and maintenance activities, (i.e., support budgets resources, E.T.)?

r. What is managements expectation with regard to the system engineers involvement in improving and maintaining system materiel condition?

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s. What is the involvement of the system engineer in the maintenance rule?

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t. Does the system engineer have adequate time to perform his function? What work if any is distracting the engineer from performing his duties?

u. Are the roles and responsibility of the system engineer clearly defined? Are the system engineers aware of the requirements and are they being implemented?

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Nebraska Public Power District Cooper Nuclear Station Page 34 of 43 Engineering self Assessment

, Appendix C Trending System and Component Performance Interview Questions for Section (b) 2

a. Do the engineer s use the performance program and how?

b. Do the engineer s routinely change the program to make it more effective. What specific action has been initiated as a result of the program? If so provide specific examples.

c. Can examples of plant equipment failures be identified that could have been identified by the performance program but were not.

d. Is the program consistently used by the engineer and can it be used by other plant personnel?

e. Do engineers have ideas on improvement and can not get the changes implemented?

f. Is the Surveillance program used to trend equipment performance effectively?

g. What equipment is not included in the performance monitoring program and should be?

h. Of the equipment currently being trended, what equipment is currently trending in the degraded condition?

i. What is management s involvement in the performance program?

j. What performance indicator provides the engineer with an overall health of the system?

k. . Does the Maintenance or Operations department solicit the system engineers advice as it relates to their system?

1. Is the system engineer actively involved with the chemistry department as it relates to their system?

Nebraska Public Power District Cooper Nuclear Station Page 35 of 43 Engineering Self Assessment I

ENGINEERING SELF ASSESSMENT Appendix C PLANT MODIFICATION January 31,1996 Objectives:

1. Select several cases of Design Changes, Temporary Design Changes, Minor Modifications, Replacement Component Evaluations, Drawing Change Notices, Setpoint Changes, and Component Dedications

2. Assess Engineering performance considering:

a. Process effectiveness and procedural adequacy

b. Managerunt of resources

c. Planning and management of the work

d. Technical adequacy of the results

e. Configuration and design control

f. Effectiveness of the organization intemal to Engineering and within the Nuclear Power Group

3. Incorporate consideration of the following issues - NRC IP 37550, DSAT, SEO, CAL, INPO 90-015, inspections (Cooper and other stations), Manager knowledge, Industry issues, Existing issues pending resolution (corrective action program, etc.)

Work Plan: l

1. Select five safety significant design changes and/or minor modifications, four temporary design

]

changes, live plant temporary modifications, five replacement component evaluations, and two .

each relief and instrument setpoint changes for review and evaluation.  !

2. Evaluate the effectiveness of each process, the adequacy of the engineering procedures in providing a quality product, the technical adequacy of the results, and configuration and design control. I

a. Approved procedures and knowledgeable qualified personnel are used to generate, review, I and approve the modification. Assess training process for qualification of personnel and plans for upgrading.

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b. Evaluate inputs to the modification such as procurement specifications for dedication of '

parts used, use of correct assumptions and design inputs to calculations, and review of codes, standards, and regulatory requirements committed to by CNS (e.g., EQ, ISI/IST,  ;

seismics) to ensure appropriate for the modification. Did A/Es have access to most current i documentation? Were all applicable reviews and approvals of modifications and i

Nebraska Public Power District Cooper Nuclear Station Page 36 of 43 Engineering Self Assessment

1 ENGINEERING SELF ASSESSMENT Appendix C PLANT MODIFICATION January 31,1996 calculations performed in accordance with procedures? Verify appropriate licensee documentation was reviewed for effect, such as vendor manuals, DCDs, USAR, and Technical Specifications. Evaluate the 10CFR50.59 process as follows: l

i. Identify the owner of the process.

ii. Review the procedure for work flow. I lii. Evaluate the 50.59's associated with the selected modifications and five not associated l with modifications.

iv. Evaluate the storage of 50.59 records.

v. Evaluate the technical adequacy of 50 59 evaluations to verify they meet the ,

regulatory requirements, consider appropriate USAR sections, does not affect Tech I Specs, and the quality of how well the 7 questions evaluations document that the issue is not an unreviewed safety question.

c. Operating experience information like NPRDS, condition reports, plant events, and maintenance history is considered in the d<; sign.

d. Modifications consider requirements for installing, verifying installation, inspecting, and testing and the installation also accotnts for ALARA and ease of constructibility, testability, operability, and maintainability. Did any modification comments packages nel get reviewed by the submitter following resolution, e.g., QA or individuals not on the SORC signature page?

e. Qualified personnel are used to design, review, approve and implement the modification including technical verification and independent reviews. Identify training and adequacy of training provided to design engineers and A/Es.

f. Post modification testing confirmed that the required functional aspects of the installed equipment were adequately tested and the testing was reviewed to ensure any deviations were evaluated and resolved prior to equipment being placed back in service.

g. Special design activities, such as computer programs and unique calculation techniques, are verified, validated, and approved prior to use.

h. On-the-spot changes (OSCs) receive technical reviews and approvals equivalent to the original modification package. Consider the number of OSCs against the reasons for them to evaluate quality of the modification.

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ENGINEERING SELF ASSESSMENT Appendix C PLANT MODIFICATION January 31,1996 t c

i. Status reports for both partially and completely implemented modifications ensure that I

appropriate documentation is updated in accordance with procedures prior to operation of the system as necessary to support system operation, tagouts, and maintenance. Verify any '

temporary documents submitted are being used unless permanently replaced and evaluate  :

effectiveness of the existing interim processes. Verify completion reports of available . I modifications being closed out ensure appropriate documentation is being updated:

. i. Operating procedures. ,

ii.- EOPs. l iii. Drawings.

iv. Calculations. j

v. Engineering Data File.

vi. Setpoint log.

.' vii. Operator training manuals.

viii. USAR. i ix. DCDs.

x. PMs. '{

xi. ISI/IST programs. j

-j. : Installed hardware conforms to the post-modification drawings. Perform field walk down of selected modifications with Operations Department staff.

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k. For backlogged completion reports, reviews are conducted to ensure appropriate preventive  ;

maintenance and testing is performed. Identify how/why large backlog was created. l

1. Specific to PTMs and setpoint changes, do controls exist to ensure necessary training and document updates are performed prior to placing a system back in service.

m. Specific to setpoint changes, procedural controls equivalent to the modification process exist to ensure appropriate inputs and reviews.

3. Evaluate configuration control and the management of engineering resources, planning and management of the work, and the effectiveness of the organization internal to engineering and within the Nuclear Power Group.

n. - The engineering organization has clearly defined responsibilities and procedures regarding the modification control processes, commercial grade item dedications, drawing control process, design criteria document process, equipment data file / classification process, calculation review and approval, and generation of modifications by architect / engineer Nebraska Public Power District  !

Cooper Nuclear Station Page 38 of 43 Engineering Self Assessment

l ENGINEERING SELF ASSESSMENT Appendix C PLANT MODIFICATION January 31,1996 firms. Verify DC/ mms and other engineering related quality documents are stored and controlled properly.

o. The staffing requirements are adequate, number of vacancies are low, and engineering qualifications are acceptable to provide flexibility within the organization. Utilization of the staff minimizes the amount of overtime required, use of architect / engineers and other technical support personnel, backlog is low and work prioritization is effective.

p. Prioritization of modifications is based on a clearly defined process and included cost / benefit criteria such as safety significance, regulatory impact, and reliability improvements, as appropriate.

q. Specific to PTMs, actions exist to ensure periodic review (9-12 months). Evaluate whether timely action was taken to review, identify, and resolve problems which have been long-standing (>l2 months) and which could have been corrected during RE16.

r. Evaluate the availability and accessibility of engineering specifications as follows:

i. Do appropriate engineering specifications exist and are they accessible (e.g., piping specifications, lubrication, materials, adhesives, etc.).

ii. Are appropriate engineering personnel involved in preparation, review, and approval of engineering specifications.

iii. Do engineering specifications have appropriate owners and are they kept up to date.

s. Evaluate available performance indicators for OSCs, backlog of Engineering Work Request / Engineering Project Requests (EWR/EPRs), timeliness of completion report  ;

submittals and closeouts, timeliness of plant temporary modification closeouts. Identify negative trends to determine management awareness.

t. The effectiveness of the permanent and temporary modification processes is periodically )

evaluated and the results used to make program improvements. Evaluate if PTMs are l circumventing the modification process.

u. Methods exist to evaluate the effectiveness ofinstalled modifications after a period of use to ensure customer satisfaction and to make program improvements. Methods exist and evaluations are being performed to evaluate the number of modifications initiated to correct problems with earlier modifications. Feedback from QA activities, NAIT actions, outage critique comments, engineering surveys, etc. is used to improve engineering processes and in a timely manner.

Nebraska Public Power District Cooper Nuclear Station Page 39 of 43 Engineering Self Assessment

ENGINEERING SELF ASSESSMENT Appendix C PLANT MODIFICATION January 31,1996 i

v. Management perceives Engineering performance and capabilities to be effective and engineering initiatives have demonstrated improved performance regarding the modification processes. Evaluate the results of the recent engineering survey sent out l requesting feedback from all levels of management.

w. Evaluation if design engineers can describe and fully understand management's expectations regarding the modification process.

x. Evaluation of customer input to the engineering survey will identify potential strengths and weaknesses in the engineering organization regarding effectiveness during the RE16 )

refueling outage.  !

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y. Outage critique comments provide potential strengths and weaknesses in the engineering organization regarding effectiveness during the RE16 refueling outage.

4. Conduct interviews.

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ENGINEERING SELF ASSESSMENT Appendix C ENGINEERING PROGRAMS January 27,1996 Assessment Objective:

Review engineering programs for effectiveness.

Assessment Plan First Week

1. Consolidate a list of all engineering programs. Possible sources are past related assessments, interviews with affected engineering personnel, existing lists of engineering programs, Utilities Services Alliance (USA) engineering and technical support capabilities matrix, etc...

2. Interview affected engineering personnel. These interviews will focus on the following areas:

a. Owner of the Program

b. Reason for the Program

c. Program Definition / Basis Document

d. Action Plan for the Program

e. Procedures

f. Internal and External Commitments

g. Training

g. Interfaces

i. Program Interface with Design Change Process

j. Program Interface with Work Control Process

k. Added Value

1. Program vs. Industry

m. Sources for Updating the Program

n. Independent Assessment of the Program

o. Health of the Program

p. Long Term Goal - Transition from One Owner to the Rest of the Organization

q. Personnel Executing the Program

r. Contractors Supporting the Program Nebraska Public Power District Cooper Nuclear Station Page 41 of 43 Engineering Self Assessment

ENGINEERING SELF ASSESSMENT Appendix C ENGINEERING PROGRAMS -

January 27,1996 Second Week i r

3. . Interview selected customers. These interviews will focus on the following areas:

a. Timeliness

b. Effectiveness

c. Added Value

d. Customer Involvement

e. Customer Satisfaction -

4. Review the program in comparison to its purpose. The purpose of the program should be based -

on the needs of the station as well as regulatory commitments.

5. Review management of engineering resources and staffing. This review will focus on the l following areas: l

a. Adequacy of Staffing

b. Adequacy of Resources Management Third Week

6. , Write the assessment report. The report will have 11 e following outline:

a. Description of Scope

b. Strengths and improvements

c. Findings and Need for Further Improvement

d. Immediate Corrective Action / Action to Prevent Recurrence i

Nebraska Public Power District Cooper Nuclear Station

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ENGINEERING SELF ASSESSMENT Appendix C APPROACII TO VERTICAL SLICE ASSESSMENT January 30,1996 -

1.0 Goals -

The overall goal of the safety assessment of the specific systems is the determination of the ability (of the selected systems) to perform the intended function in accordance with the ,

licensing basis for the plant. The goal of the vertical slice approach in the assessment process is to use the assessment results (of the individual systems) as indicators of the overall plant performance, capability of plant departments and the efTectiveness ofinterdepartment interfaces.

The latter is the most important products of the vertical slice.

Additionally, the vertical slice can be used for:

Determination if the design organization established and communicated system margins, their limits and interrelations to the appropriate plant organization.

Determination if the plant organization incorporated this a ormation in plant procedures and established clear references in these procedures to design calculation.

Determination of the system (s) margins. This activity has a substantial payback potential.

2.0 Approach The vertical slice inspection will be wnducted by review of the selected documents from the following broad categories (for each of the selected systems).  !

1. Flow Diagrams 7. System Operating Procedures )

2. Design Criteria Documents 8. Maintenance Work Requests

3. IST Basis Documents 9. Condition Reports

4. Specifications 10. Plant Modifications

5. Calculations 11. 50.59 Reviews

6. Setpoints Nebraska Public Power District Cooper Nuclear Station Page 43 of 43 Engineering Self Assessment

ENGINEERING SELF ASSESSMENT 15.0 APPENDIX D - MATRIX OF OBSERVATIONS TO CONDITION REPORTS OBSERVATION CR SERIAL CR NUhlBER OPERABILITY NUhlBER NUh1BER ASSESSNIENT?

O-00I l-20317 CR3 96-0103 N 0-008 1-21111 CR4R 96-0098 N 0-013 1-14239 CR4R 96-0119 Y O-O15 1-15430 CR4R 96-0126 N 0-016 1-15842 CR4R 96-0115 N 0-016 1-15843 CR4R 96-0116 N 0-016 1-15845 CR4R 96-0117 N 0-016 1-15846 CR4R 96-0118 N 0-018 1-14666 CR4T l-14666 N 0-019 l-20148 CR4R 96 0112 N 0-034 1-09243 CR4R 96-0125 Y O-078 l-21383 CR3 96-0137 Y O-101 1-21148 CR4T l-21148 N 0-103 1-20549 CR4R 96-014I N 0-116 1-15438 CR3 96-0139 Y O-152 1-20159 CR3 96-0163 N 0-234 1-2055i CR4R 96-0151 Y O-235 1-13393 CR4R 96-0165 N Nebraska Public Power District Cooper Nuclear Station Page1 of2 Engineering Self Assessment

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ENGINEERING SELF ASSESSMENT 15.0 APPENDIX D - MATRIX OF OBSERVATIONS TO CONDITION REPORTS (continued)

OBSERVATION CR SERIAL CR NUMBER OPERABILITY NUMBER NUMBER ASSESSMENT 7 O-24i ' l-20766 CR4R 96-0150 N 0-261 1-18636,1-8638 CR3 96-0140 Y,N 0-295 l-20158 CR4R 96-0164 N Nebraska Public Power District Cooper Nuclear Station Page 2 of 2 Engineering Self Assessment

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EXECUTIVE

SUMMARY

l The Nebraska Public Power District Nuclear Power Group embarked on a three phase  !

performance improvement plan in November 1994. Phase 1, completed February of 1995, I involved activities necessary to restart Cooper Nuclear Station following a nine month shutdown )

under a Confirmatory Action Letter. Phase 2, completed June of 1995, included a complete I reorganization of the Engineering Division and relocation of the corporate Nuclear Engineering Department to the site. Phase 3 is the long term performance improvement plan, scheduled for completion in early 1997.

The " Engineering Division Reorganization Phase 3 Transition Plan" (Transition Plan), Revision 0, dated August 3,1995, was developed as a part of the Phase 3 Performance Improvement Plan.  !

Part A of the Transition Plan provided the focus for the Engineering Division from July 1,1995 through February 28,1996. As anticipated, the emphasis of Part A of the Transition Plan was less on Phase 3 improvements and more on preparations for Refueling Outage 16 (RE-16), which commenced on October 14,1995. The final activity in Part A of the Transition Plan directs the performance of an Engineering Self Assessment in February 1996. The Transition Plan further states that Part B, covering the period March 1,1996 through June 1,1996, will be expanded ,

based on the results of the Engineering Self Assessment. l 1

Major accomplishments were made under the Phase 2 Performance In1provement Plan and Part A of the Engineering Transition Plan between January and December 1995. These included: ,

i 1

. restructuring the Engineering organization;  ;

development of position profiles for all Engineering positions;  ;

. selection of managers, supervisors and staff; 1

. relocation of corporate Engineering to the site;

. recruiting 34 new engineers and supervisors;

• major improvements in Engineering support during the outage; and

. selected process improvements.

The objectives of the Engineering Self Assessment were:

. To assess the post-reorganization effectiveness of the Engineering Division to perform routine and emergent site activities, including the identification and resolution of technical issues and problems; j

. To identify areas needing further improvement; and

. To further develop Engineering self assessment capabilities.

The results of this self assessment indicate that theie have been some substantial improvements j in Engineering performance. In particular, responsiveness to Engineering's primary customers j I

Nebraska Public Power District Cooper Nuclear Station 1 Engineering Self Assessment 4

1 i

EXECUTIVE

SUMMARY

-t (Operations and Maintenance) has shown significant improvement, as reflected in comments made in many of the interviews conducted by the Assessment Team. Also, program and process improvements are evident in selected areas, such as the MOV Program and Inservice Inspection and Inservice Testing. Further, Engineering was viewed by most organizations on site as substantially more successful at supporting plant needs during RE-16 than in any previous I outage. The Assessment Team concluded that most of these improvements are due to the efforts to consolidate Engineering on site, allowing more effective interaction and integration with the plant. However, the assessment results also indicate that the details of the Engineering reorganization and the transition toward meeting the new Engineering mission identified in the i Transition Plan are incomplete and several areas need further significant improvement.

The assessment team identified eight areas in which significant improvement in Engineering 1 performance is needed. The team also identified five causal factors that have been major I contributors to less than desired performance. The team concluded that these five factors must be given the highest priority and that addressing these causes will improve Engineering I performance substantially. The team also identified three areas where improvements would  ;

enhance Engineering effectiveness and facilitate the other improvements. l The highest priority areas, that require significant immediate improvement, are the following five (5) underlying causes ofless than desired performance:

The Engineering management team has not clearly defined, communicated and reinforced roles, responsibilities and interfaces for engineers, supervisors and managers.

The Engineering management team has not established clear expectations for supervisors and staff and is not holding them accountable for performance.

. The Engineering management team has not established effective lines of communication within Engineering and with external customers and support organizations.

l The Engineering managers and supervisors are not effectively prioritizing work, leading to ineffective use of resources and important tasks not being performed. l

. The Engineering management team has not established effective integrated planning and  ;

scheduling of Engineering work. I Nebraska Public Power District Cooper Nuclear Station .

2 Engineering Self Assessment

EXECUTIVE

SUMMARY

i l

The five underlying causes identified above have led to the following eight areas where  !

Engineering performance is in need of significant improvement:

. System Engineers are not performing the nost important functions that must be the focus of  !

theirjob responsibilities, including sy stem problem identification and resolution, performance monitoring and trending, becoming the primary source of system knowledge, and providing oversight of system maintenance and surveillance testing.

. Engineering performance on operability assessments and safety evaluations needs improvement.

. Engineering performance in plant design and configuration control is inconsistent and in need of significant improvement.

. Plant design basis information is not readily accessible, design and licensing basis knowbdge  ;

is limited and is not well integrated into plant processes. l l

. = Engineers and supervisors (particularly in Plant Engineering) are expending significant time .

and resources on low value work activities.  !

1

. Many engineering programs are in need of significant attention to establish clear ownership, expectations, plans and performance monitoring.

. Management and supervision have not reinforced the need for attention to detail and greater consistency in the area of procedural compliance.

. The transition of findings and observations from the Diagnostic Self Assessment Team (DSAT) and NRC Special Evaluation Team (SET) Reports to long term performance improvement plans is incomplete.

The self assessment also identified three areas where improvements would facilitate and enhance Engineering effectiveness:

. Many Engineering processes are unnecessarily cumbersome and time consuming.

. Training and qualineation need to be enhanced in sewral specific areas, including: use of site

'and Engineering processes (how we do be 'es:;), integrated and specific system knowledge (particularly for System Engineers), the nue of qualified Reactor Engineers and the overall level of engineering certifications (system experts, SROs, SRO certification, STE qualification).

Nebraska Public Power District Cooper Nuclear Station 3 Engineering Self Assessment

l l

EXECUTIVE

SUMMARY

j 1

l

. Tools, resources and support in such areas as document availability and retrieval, databases, l and design basis information need to be improved for more efficient use of engineer's time.

With respect to the objectives of the Engineering Self Assessment, the Assessment Team has {

concluded that, while some progress has been made in Engineering effectiveness, significant immediate improvements are needed in several performance areas and in several fundamental areas.  !

l The report is organized as follows: l 1

Section i describes the Purpose of the assessment l

Section 2 presents the Objectives of the assessment Section 3 provides some Background information about Engineering, Section 4 discusses the Assessment Approach,and Section 5 presents the Overall Assessment Results and findings, and supporting examples, in I terms of: l

. S9veral Strengths,  ;

• Five Causal Factors, '

i

. Eight Perfonnance Issues, and

. Three Performance Enhancements. l l

Sections 6 through 11 provide the detailed results and observations from each of the areas of the assessment:

Section 6 Ability to Resolve Operational Problems ,

Section 7 Maintenance Support l Section 8 System Engineering Effectiveness Section 9 Plant Modification Section 10 Engineering Programs Section 11 System Assessments Appendices provide additional details:

Appendix A Team Member Qualifications, Appendix B Matrix Comparing the Assessment Questions / Observations to Inspection Procedure 37550, Appendix C Individual Area Assessment Plans,and l Appendix D Matrix of Questions / Observations to Condition Reports.

l l

l Nebraska Public Power District Cooper Nuclear Station i 4 Engineering Self Assessment l

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1.0 PURPOSE The purpose of the Engineering Self Assessment, as stated in the " Engineering Division Reorganization Phase 3 Transition Plan," Revision 0, dated August 28,1995,is:

Perform an Engineering Division Self-Assessment to determine organi:ational effectiveness. Include an assessment ofthe effectiveness ofthe System Engineering Program. Part B [ofthe Plan] will be expanded to cover the actions needed to address the improvement items identified by the Engineering Division Self-Assessment scheduled to be performedin February 1996.

2.0 OIMECTIVES The objectives of the Engineering Self Assessment are:

- To assess the post-reorganization effectiveness of the Engineering Division to perform routine and emergent site activities, including the identification and resolution of technical issues and problems.

. To identify areas needing further improvement.

To further develop Engineering self assessment capabilities.

3.0 BACKGROUND

The Cooper Nuclear Station Engineering Division completed a major reorganization in 1995.

This reorganization involved a complete re-engineering of the organizational structure, personnel needs and location of the CNS Engineering Division.

All Nuclear Power Group engineering personnel were consolidated at CNS in mid-1995, which involved relocating all Corporate Nuclear Engineering positions from the Columbus General Office (CGO). The entire organizational structure of the Engineering Division was revised and consolidated under a Senior Engineering Manager on June 1,1995. The management and supervisory structure was revised and new expectations for each group and department in Engineering were established.

Based on the new expectations for each department, the consolidated location and the clearly changed focus of the organization, the number and type of engineering personnel needed was assessed and revised. Through a thorough interviewing, screening and placement process, most of the previously existing staff was placed in the new organization according to individual abilities and organization needs. This resulted in assignment of different I

i Nebraska Public Power District i Cooper Nuclear Station 5 Engineering Self Assessment

l individuals to most manager / supervisor positions (although most came from within the NPG). Also, as a result of the number of existing staff that chose not to relocate from the

CGO and the talent deficiencies identified in the old organization, approximately 34 new engineering personnel were added to the Engineering Division, including several new i j supervisors. Restaffing to the 90% level was completed in September 1995.

The new Engineering Division has been in place for approximately seven months. This ,

seven month period included the completion of a major refueling and maintenance outage.

{

The purpose of this Self Assessment is to evaluate the effectiveness of the Engineering  ;

4 organization, staff and processes after its first seven months of existence and to assess the l j effectiveness of the reorganization effort. The results of this assessment will be used to  !

! identify any weaknesses or deficiencies needing corrective actions, t

In addition to the original purpose of the Engineering Self Assessment, which was to  !

determine the effectiveness of the organization and make mid-course corrections, it was realized that the NRC planned an Engineering and Technical Support Inspection in February, j at about the same time as the self assessment. Based on new NRC guidance in Inspection

Procedure (IP) 40501, which allows licensees to request the use of self assessments in lieu of  ;

. an NRC team inspection, Engineering suggested that NRC also take advantage of the self  !

j assessment. The NRC agreed to follow the self assessment, and ifit is performed satisfactorily, to use it to focus NRC efforts. This resulted in NRC not scheduling an Engineering and Technical Support Inspection for February 1995. NRC, instead, had an  ;

NRC inspector perform a mid- assessment oversight. NRC has made it clear that this will not  !

reduce inspection man-hours for CNS Engineering, sincube current SALP rating is a 3. l Ilowever, it will permit the NRC to focus available inspection hours on areas requiring l further attention, rather than perfonning a general inspection like the Engineering and Technical Support Inspection. Appendix B contains a matrix showing the questions and observations which address the Engineering and Technical Support Inspection Procedure 37550 areas.

4.0 ASSESSMENT APPROACH AND METHODOLOGY 4.1 OVERVIEW The Engineering Self Assessment Team devoted more than 1500 man-hours to this assessment, from 8 senior engineering personnel and 5 consultants and loaned employees.

The Team conducted approximately 100 interviews, reviewed countless documents and ,

observed numerous in-process work activities. The effort resulted in over 150 formal  !

documented questions and approximately 300 documented observations during the three week assessment, j Nebraska Public Power District Cooper Nuclear Statior. 1 6 Engineering Self Assessment l l

At the mid-way point of the assessment, the Team spent two one-half day sessions assessing progress against the plan, identifying potential significant findings for validation and focusing the efforts of the remaining one and one-half weeks of the assessment, i

The Team used a series of systematic methods to synthesize the final findings of the assessment from the large amount of data gathered during the three week assessment. These included the INPO " yellow sticky" method, stream analysis and causal factor charting. The final findings resulted in 5 causal factors,8 performance issues and 3 areas for enhancement. l l

4.2 ASSESSMENT APPROACil The Engineering Self Assessment consisted of both a " horizontal" and a " vertical" review.

The horizontal review consisted of five major areas of engineering performance. The five areas were: 1) Ability to Resolve Operational Issues,2) Maintenance Support,3) System Engineering Effectiveness,4) Plant Modification, and 5) Engineering Programs. The horizontal review was a review of the programs and processes that make up the engineering function. The vertical review is a classic vertical slice assessment of the technical products associated with two systems. The two systems chosen were the High Pressure Coolant Injection System and the Emergency Diesel Generators.

The original Assessment Outline, submitted to the NRC in letter NLS950211, dated November 3,1995, identified a sixth horizontal assessment area. This sixth area was Engineering Document Control. An Assessment Plan was developed for this area. However, it was determined that this area overlapped significantly with the other 5 assessment areas.

Therefore, the Engineering Document Control Assessment Plan was rolled into each of the other horizontal assessment areas. Thus, document control was assessed within the other plan areas instead of as a separate plan area.

4.2.1 Horizontal Review l

The five areas chosen for this review were chosen based on a review of the summary ,

ofissues in the engineering area from past major evaluations of Cooper Nuclear i Station. Since one of the primary objectives is to assess post-reorganization effectiveness, an evaluation of the areas of concem prior to the reorganization will l identify whether progress is being made, j Within each of the five areas, the horizontal assessment reviewed products, conducted interviews of engineers and customers and followed in-progress activities. One other key aspect of the horizontal review was to select examples of recent events which are representative of the important functions within that area. The event was followed through the process to determine engineering effectiveness at each step. At key Nebraska Public Power District l Cooper Nuclear Station

! 7 Engineering Self Assessment

points in the process, the Assessment Team " dug" vertically into the inputs and outputs of the process. This provided a thorough assessment of the technical adequacy and regulatory compliance of Engineering products, as well as an assessment of organizational, process, personnel and management effectiveness of the Engineering Division.

An assessment plan was developed by the Team for each of the five areas. Appendix C contains the individual area assessment plans.

4.2.2 Vertical Review The vertical review is a classic Safety System Functional Assessment of two systems.

The two systems chosen were the liigh Pressure Coolant Injection System and the Diesel Generators. These two systems were determined to be appropriate for the following reasons:

1) Address both electrical and mechanical systems.

2) Both systems had major modifications during the 1995 outage.

3) Both systems are important safety systems and both are risk significant.

4) L30th systems have had deficiencies identified in the past year.

A consultant with significant experience performing vertical slice inspections was added to the Team to lead this portion of the assessment. The NRC Inspection Procedure and Temporary Instruction were used as guidance for this part of the assessment. Appendix C contains the vertical assessment outline.

4.2.3 Post-Recreanization Effectiveness l The effectiveness of Engineering is divided into two parts. Part one is the ability to meet regulatory requirements. This includes such items as technically correct and complete engineering designs, operability assessments and problem resolutions; j proper configuration control; accurate and accessible design basis information; and i compliance with the license, appropriate codes, standards and commitments.

Part two of assessing Engineering effectiveness involves an evaluation of more subjective areas. These areas include such items as ownership and accountability; process effectiveness; effective use of resources, prioritization of work, and responsiveness; value added products; customer satisfaction; organizational effectiveness; staff qualifications and capabilities; communications; and management and supervisory effectiveness. These areas are not black and white. Ilowever, without continuous improvement in these areas, regulatory compliance will slip. To Nebraska Public Power District Cooper Nuclear Station 8 Engineering Self Assessment

assess these areas, it is necessary to not only review documents, but to interview engineering personnel and engineering customers, and to perform subjective evaluations of processes, people and functions.

4.3 TEAM COMPOSITION AND RESPONSIBILITIES 4.3.1 Assessment Team Comnosition and Resnonsibilities The Engineering Self Assessment Team and their associated responsibilities were as follows:

Michael Boyce Team Leader Ole Olson Task Leader - Resolution of Operational Issues Paul DiRito Task Leader - Maintenance Support  ;

James Salisbury Task Leader - System Engineering Effectiveness James Flaherty Task Leader - Plant Modifications Fadi Diya Task Leader - Engineering Programs l Michael Shlyamberg Task Leader- Vertical Assessment I Kenneth Thomas Vertical Assessment Evaluator Roger Moberly Vertical Assessment Evaluator Ted Hough Team Facilitator Robert Godley Licensing Liason David Bremer Operations Liason i Thomas Carson Maintenance Liason John Oswald QA Liason Consultants: J. Mason (PRISM) G. Welsh (INPO) l G. Goering (Goering Consulting) J. Wyrick (WNP-2) l M. Shlyamberg (NUENERGY)

A summary of the Team Member's experience is included in Appendix A.

4.3.2 Resnonse Team Composition and Responsibilities The composition and responsibilities of the Response Team were:

Daniel Buman - Response Team Leader Mark Unruh - Response Team - Vertical Slice Glen Seeman - Response Team - Plant Modification Todd Hottovy - Response Team - Operational Issues Mick Spencer - Response Team - Engineering Programs Nebraska Public Power District Cooper Nuclear Station 9 Engineering Self Assessment

John Swanson - Response Team - System Engineering Scott Freborg - Response Team - Maintenance Support The Response Team performed the following during the Assessment:

1) Responded to Questions and Concerns within 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br />.

2) Addressed Observations that were Conditions Adverse to Quality within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.

3) Upon discovery of a condition adverse to quality that could not be addressed within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, initiated a Condition Report, and followed CNS procedures for operability and reportability assessments.

4.4 HANDLING OUESTIONS AND ISSUES A process for handling questions and issues was identified in the assessment plan, contained in Appendix C.

It was recognized that at any time during the assessment, a Team Member may identify an observation that appeared to be an item of noncompliance, an operability issue, a safety concern, a procedural violation or any other condition adverse to quality. These issues were promptly identified to the Assessment Team Leader and prornptly relayed to the Response Team for appropriate action in accordance with the Corrective Action Program. In cases where a clear condition adverse to quality was identified, the Assessment Team generated the condition report. The Response Team was responsible for follow-up to ensure that operability evaluations, reportability evaluations and immediate corrective actions were undertaken in accordance with CNS procedures.

The Self Assessment resulted in over 20 Conditions Reports being generated, including several requiring operability assessments. Each of these conditions was handled on a real time basis, and the Assessment Team did not identify any cases where the Response Team failed to take action or follow the Corrective Action Program. Appendix D contains a matrix of and observations that resulted in Condition Reports.

4.5 BACKUP DOCUMENTATION The individual questions asked by the Assessment Team and the responses from Engineering were documented on a form and entered into a database. The original hard copy questions and responses are maintained on file and the database is preserved on disc.

In addition, the observations of the Assessment Team were documented on a form and entered into a database. liard copies and the database are likewise maintained on file.

Nebraska Public Power District Cooper Nuclear Station 10 Engineering Self Assessment

The Assessment Team also maintained field notes documenting interview results, document reviews and observations ofin-process work. Copies of the field notes are available for review. Each Task Team Leader for the five horizontal review areas prepared a notebook which contains Assessment Results Forms that identify the activities completed in accordance with the area assessment plan and the associated field notes. These notebooks cross-reference the Area Assessment Plans to the activities completed. The notebooks are also available for review.

5.0 OVERALL ASSESSMENT RESULTS This Section of the report provides the overall summary of the most significant findings of the Engineering Self Assessment. The primary underlying causes ofineffective performance are identified as the first five findings. Findings 6 through 13 identify the most important areas where Engineering performance is at less than desired levels and significant improvement is needed. Findings 14 through 16 identify enhancements that would be beneficial to improving overall Engineering performance effectiveness.

More specific findings and areas for improvement, as well as more details on the overall findings, are contained in the specific area assessment results in Sections 6.0 through 11.0.

5.1 STRENGTIIS There were several notable areas ofimprovement in the Engineering Division. First, customers indicated in interviews that support and responsiveness were greatly improved in l

the past year. Engineering is clearly providing more timely and better responses to l Operations and Maintenance issues than prior to the reorganization.

Engineering has also made numerous improvements in selected programs and processes. I One program of particular note was the MOV Program. This program conducted a tremendous scope during the 1995 refueling outage, with very few schedule hold-ups, l resolved several complex technical issues very effectively, and managed to turn around a l program that less than one year ago was in dire straights. Also notable were the ISI/IST Programs and the new Minor Modification process.  ;

One additional area of significant improvement is Engineering performance during the 1995 outage. While far from perfect, customers and engineers all agreed that the Engineering Division support during the outage was far superior to any previous outage. Comments such as " Engineering showed ownership," " Engineering took a tough stance on important issues,"

and positive comments about Engineering's work ethic and around-the-clock support indicated that Engineering has made great strides in performance since the 1994/95 forced outage.

Nebraska Public Power District Cooper Nuclear Station 11 Engineering Self Assessment

a More specific areas of strength are identified in Sections 6.0 through 11.0.

5.2 CAUSAL FACTOR FINDINGS Finding 1: The Engineering management team has not clearly defined, communicated and reinforced roles, responsibilities and interfaces for engineers, supervisors and managers. I i

Example 1: Several important Engineering Programs and processes have no owner, including the Erosion / Corrosion Program, OPL-3 inputs and the 10 CFR 50.46/ Appendix K analysis.

Example 2: Interviews with engineering personnel and customers concluded that the System Engineers are not performing the responsibilities that are viewed as most important, such as system walkdowns, equipment performance monitoring and trending, system problem identification and resolution, understanding system functions and design basis, and preventive maintenance and surveillance testing involvement.

Example 3: Interviews with Maintenance and Engineering personnel indicate that the division of responsibility between System Engineering and Maintenance Planning is not clear, including which group should write MWR instructions, the practice of engineers reviewing all MWRs and the requirement for an Engineering Manager to sign all minor maintenance activities.

Finding 2: The Engineering management team has not established clear expectations for supervisors and staff and is not holding them accountable for performance.

Example 1: There is a wide variation in the level of development and performance of i I

Engineering Programs. Many do not have program description or basis documents, improvement plans, plans to self assess, or performance indicators. Only those that have received special management attention or were driven by regulatory requirements have met some level of higher performance.

Example 2: Several examples were identified where Condition Reports were not written to document minor conditions that were within the threshold for a CR. These included the lack of CR on work performed by a vendor on Condensate Booster Pump oil pump that came back wired incorrectly, the lack of CR on a l differential pressure control valve installed backwards on B Condensate Pump, and many process and procedure problems identified in interviews, for which no CRs ever were appropriately generated, l

Nebraska Public Power District i Cooper Nuclear Station 12 Engineering Self Assessment

Example 3: Although many people interviewed felt they knew what System Engineers should be doing, they have not been doing those things.

Finding 3: The Engineering management team has not established effective lines of communication (both horizontal and vertical) within Engineering and with external customers and support organizations.

Example 1: Several times over the three weeks of the self assessment, team members observed poor translation of day-to-day plant priorities to the responsible engineer. These communications problems resulted in lack of feedback to the customer, untimely response, lack of understanding of the real issue by the responsible engineer and inefficient use of the System Engineer's time attempting to determine the action required. Examples included the problems concerning filling the Z Sump loop seal, operation of SBGT system following painting, concerns with the KAMANs and performance of a HPCI surveillance.

Example 2: One example of poor performance in responding to an NRC Senior Resident Inspector question was observed. This involved a simple question on the seismic qualification of a hoist. It took approximately one week to respond.

The SRI indicated that CNS Engineering typically has problems with establishing ownership and communicating a complete detailed response or evaluation to the NRC. ,

Example 3: Numerous communications problems were noted between Maintenance Planners and System Engineering and one example of Scheduling miscommunication with Procurement Engineering was observed.

Maintenance Planning felt that System Engineering did not have the knowledge to add value to the MWR process, but is required by procedure to i review and approve. System Engineers felt that Maintenance Planners were too dependent on them for MWR instructions. Procurement Engineers were ,

not aware that Scheduling felt that "Q" Numbers were one of the biggest parts problems and hold-ups during the outage.

Finding 4: The Engineering managers and supervisors have not been effectively prioritizing work, leading to ineffective use of resources and important tasks not being performed.  !

l Example 1: In intersiews with System Engineers, several low value activities routinely l assigned to them are cited as the reason they are not able to perform more important functions, such as system walkdowns, equipment performance 1 Nebraska Public Power District Cooper Nuclear Station 13 Engineering Self Assessment i

monitoring and trending. These activities include Category 4R Condition Reports to correct system drawings; review of all surveillances (even those with satisfactory results) and review of operator logs.

Example 2: During the assessment, in a weekly management meeting attended by all Engineering Managers and Supervisors, the need to drive down Corrective Action Program backlogs was discussed for two hours. This effort is being driven by performance indicators that track the number of backlog Level 1 CAP items greater than 60 days old, Level 3 items greater than 1 year old and any item extended more than 2 times. These performance indicators drive Engineering to work these items according to due data, regardless of the safety significance of the items. This meeting resuited in several groups in Engineering shifting all resources to CAP item closure, despite the other more important work that was in progress.

Example 3: Backlogs in some key areas such as Red Arrows in the Control Room, DCNs (including Control Room Drawings), safety classification, modification closure packages and MWR closecuts reflect Engineering's focus on many l

internal backlogs instead of some important plant support backlogs.  ;

Finding 5: The Engineering management team has not established effective integrated planning and scheduling of Engineering work.

Example 1: While a few of the Engineering Program owners have developed plans and l strategies for their programs, a large majority of the program owners have not, ,

even though they recognize weaknesses and gaps in their programs. I Example 2: Important milestones have slipped in the review of EPR/EWRs. The original completion date was 1/31/96. As of 2/23/96, this project is not complete.

This impacts the ability to prepare and schedule for the next refueling outage.

It is uslear what has prevented completion of this project, since it is not i possible to determine what higher priority work superseded the EPR/EWR j reviews.

Example 3: It was identified in several interviews with engineers that assignments were made to individual engineers with due dates without consulting the individual j or his supervisor. This resulted in the individual being overloaded and going l overdue, without any method to influence his work load. In one case, an engineer was assigned to be a CRT leader for a Category 2 Condition Report, had numerous EPRs assigned for review and was assigned Phase 3 actions.

Nebraska Public Power District Cooper Nuclear Station l 14 Engineering Self Assessment

4 5.3 PERFORMANCE ISSUES Finding 6: System Engineers are not performing the most important functions that must be the focus of theirjob responsibilities, including system problem identification and resolution, performance monitoring and trending, becoming the primary source of system knowledge, and providing oversight of system maintenance and surveillance testing.

Example 1: Interviews and observations of work indicate that System Engineers are aware that Maintenance performs data gathering for predictive maintenance, such as vibration data, but few System Engineers use this information.

Example 2: System Engineers' time is driven by performance indicators which recognize only arbitrary due dates and numbers of extensions, without regard to safety significance or what other more important work may be planned.

Example 3: Interviews indicated that many System Engineers are not certain what the design and licensing basis of their systems are, where to find them or what the difference is; many do not have copies of their system DCDs, do not know how to maintain the documents, have never had training on the DCDs and are not satisfied with the content of the DCDs.

Example 4: The performance monitoring and trending program has no owner, has little guidance on its use, and is not understood and used consistently by System Engineers. 1 l

Example 5: There is no required System Engineer involvement in the Preventative Maintenance (PM) Program. Several examples were identified where vendor ,

recommended PMs are not being performed. System Engineers are not aware j of the basis for the PMs on their systems.

]

Finding 7: Improvements are needed in the performance of Operability Assessments and 50.59 safety evaluations.

1 Example 1. The drawing change and classification change procedures (3.7 and 3.13) do l not require a 50.59 screening when changes are made that are not associated with a modification. (Note that prompt corrective action was taken to correct this.)

Example 7 An Operability Assessment was identified where no documented basis was included for an engineering judgement provided on the DG muffler bypass valves.

Nebraska Public Power District Cooper Nuclear Station 15 Engineering Self Assessment

4 e

i

i. Example 3: An example of an Operability Assessment was identified where an engineer not certified on his system performed an OA.

Finding 8: Engineering performance in plant design and configuration control is inconsistent and in need of significant improvement.

! Example 1: It was discovered that USAR Chapter VI still references the 1977 LOCA

{

l Analysis. This has been updated at least twice, including under Design :l j Change 94-332.

}

} Example 2: The vendor manual change process has been changed'such that only the Procurement Engineers review vendor manual changes for effects on other documents and changes required in the plant. This may not be an appropriate level of review to ensure configuration control.

Example 3: The component identification code (CIC) used in the EDF is not consa.

• with the CICs used in procedures and drawings.

Example 4: Thirteen unauthorized modifications were observed as identified on Condition Reports sent to the CRG between January 9, and February 14,1996, during the assessment. No process exists for evaluating these unauthorized mods to determine the acceptability of the design conduct a 50.59 safety evaluation, or ensure configuration of other documents (such as EDF and PMs) are maintained.

J Example 5: No process exists to ensure Design Criteria Documents are updated following the revision of a program, such as the ISI/IST Program or Appendix J Program.

Example 6: Two examples ofincomplete or inadequate post-modification testing were identified, involving SW-MOV-89A/B and Diesel Generator Starting Air.

Example 7: No process exists to control outstanding Engineering Judgements (EJs) that are posted against a calculation, such that everyone is aware of how many are effective and what the combined effects are. Also, there is no requirement to maintain EJs as quality records. One example was identified where 13 EJs i were outstanding against the 125VDC and 250 VDC load calculations.  ;

During the 1995 outage, the 125V and 250V battery discharge test load profile  !

was established without cognizance of the 13 EJs using only the approved  ;

calculation. The 13 EJs did affect the load, but fortunately the load profile established was conservative enough to bound the EJs. (Note CR written, Nebraska Public Power District Cooper Nuclear Station 16 Engineering Self Assessment l

.I; I

immediate evaluation completed.)

Example 8: There are approximately 24,000 calculations on record, with no means of determining which is the latest revision, which are superseded, and which have been modified. Also, there is no cross-reference that ties calculations to l output documents (e.g., procedures). [

Example 9: Examples of the use of an MWR revision to revise a modification to allow '

machining of the pressure boundary parts of a valve were identified. While I the vendor was contacted and the design authority on the component )

concurred with the change, several configuration control issues were raised.  ;

- No method exists to capture these pressure boundary part changes on a l

' drawing, specification, etc., and no safety evaluation was performed on the modification before the work.  ;

Finding 9: Plant design basis information is not readily accessible and design and licensing basis knowledge is limited and is not well integrated into Engineering processes.

Example 1: Design Basis information is not readily available and accessible to engineers.

This includes lack of controlled copies of USARs, Technical Specifications, .

DCDs, and integrated databases containing design basis information. For example, Design Engineering and Engineering Support only have one copy of the USAR and TS available to them. System Engineers do not have the DCD for their systems in their offices. No accurate, accessible way exists to <

! identify and retrieve design basis calculations.

t Example 2:

Several observations indicate a lack of design basis knowledge on the part of R I engineers throughout Engineering. These include: 1) failure to include HPCI-

CV-10CV and 1 ICV in the IST basis document as performing a safety l function in the closed position,2) a submittal routed for signature during the

) assessment contained misleading information concerning the 10 CFR l 50.46/ Appendix K analysis, but there was no knowledge of this analysis in

)

l Engineering,3) the assessment team questioned the basis for the OPL-3

requirement for the turbine bypass valves to open in 0.3 seconds for the feedwater controller failure transient and it was discovered that no testing was performed to verify this, which was not questioned by Engineering.

Example 3: The 50.59 safety evaluation process limits reviews to the USAR and Technical Specifications. These are only part of the licensing basis of the j i

plant. This is not well understood . The difference between the licensing and Nebraska Public Power District Cooper Nuclear Station 17 Engineering Self Assessment

design basis of the plant is not well understood. It was noted that some calculations reference the USAR as a design basis reference.

Example 4: Interviews with numerous engineers indicate that the DCDs do not contain all of the information needed to do theirjobs effectively .

Finding 10: Engineers and supervisors (particularly in Plant Engineering) are expending significant time and resources on low value work activities.

Example 1: Engineers continue to monitor diesel generator fuel consumption rates to i verify that actual rates are bounded by design basis calculations. This has  !

been ongoing for a significant period, even though the measured value has never fallen outside the calculation.

Example 2: System Engineers continue to conduct reviews of all surveillance testing, 1 including those with all satisfactory results, even though the process was ,

changed in the Phase 2 plan to eliminate this requirement.

Example 3: System Engineering continues to review all MWRs on both the front end after Maintenance Planning and on the back end after Operations. Many interviewed felt that this was not necessary for all MWRs. Several engineers and planners believed that with a little guidance, the planners could handle the  ;

great majority of the MWRs.

l Finding i1: Many engineering programs are in need of significant attention to establish clear ownership, expectations, plans and performance monitoring.

Example 1: Several engineering programs and processes were identified as having no assigned owner, including the Erosion / Corrosion and Microbiologically Induced Corrosion (MIC) Programs, OPL inputs, and the 10 CFR 50.46 Analysis. I Example 2: The MOV Program Plan has not been revised to reflect the latest changes to the organization and program. l Example 3: The Check Valve Program had a Condition Report / Audit finding due to failure to resolve long standing INPO concerns.

Example 4: The Maintenance Rule and PSA Programs have not been communicated to the organization and no training has been performed on application of these two important programs.

Nebraska Public Power District Cooper Nuclear Station 18 Engineering Self Assessment

q Finding 12: Management and supervision must reinforce the need for attention to detail and greater consistency in the area of procedural compliance.

Example 1: Signs prohibiting removal of the single controlled copy of vendor manuals from the TSC were ignored. Numerous manuals had been checked out for over a month.

Example 2: Several Engineering Procedures, including 3.11 and 3.4, still represent the old Engineering organization.

Example 3: Numerous examples were noted where minor procedural requirements for PTMs and Operability Assessments were not followed.

Example 4: Examples were noted where RR-1 and weld checklist forms were not properly i signed.

Finding 13: The transition of the findings and observations from the Diagnostic Self  !

Assessment Team (DSAT) and NRC Special Evaluation Team (SET) Reports to long term perfonnance improvement plans is incomplete. Several DSAT and SET identified technical issues could not be found to be addressed in the  !

Phase I,11 or 111 Performance Improvement Plans, or in any other plan. Also, i some fundamental problems identified in Engineering, that were identified by i the DSAT and SET, appear to remain after a significant period of time, with l no existing plan and schedule to resolve the concern. '

Example 1: The DSAT and SET Reports both identified that there are 24,000 calculations on record, with no way to identify which ones are current, which ones have been superseded and which have been modified. Also, calculations do not  ;

cross-reference one another or other documents. The response to inspection Report 95-01 stated that this would be addressed in the long range plan. This i issue could not be found in any plan.

Example 2: DSAT Section 2.3.5 identifies lack of clearly defined roles and responsibilities and failure to monitor and assess effectiveness ofimplementation of management expectations as the cause of Engineering's failure to conduct important System Engineering duties and complete important planned activities (such as precess improvements) in other Engineering areas. The self assessment found that there still exists a lack of clearly defined roles and responsibilities in Engineering, and no plan exists to correct this deficiency.

Example 3: DSAT Section 2.3.l(4) identifies lack of design basis knowledge on the part Nebraska Public Power District Cooper Nuclear Station 19 Engineering Self Assessment

of many engineers. Interviews with engineers during the self assessment indicate that this is still a concern. Phase III Plan training focuses on how to use Design Criteria Documents, rather than defining what design basis information is and improving engineer's capabilities to find and understand it.

Example 4: DSAT Section 2.3.i(3) identifies inadequate control and interface with General Electric regarding fuel reload analysis and control of the design information necessary to support reload, accident and transient analyses. The self assessment identified that this continues to be a concern, in that CNS had problems with the core design during startup from the 1995 outage (i.e., not able to obtain 100% power quickly) do in part to limited consideration of plant operations in the core design and no owner was identified for the OPL-3,4 and 5 documents which provide the inputs to the accident and transient analyses.

Example 5: DSAT Section 2.3.3.l(1) identifies that a growing backlog of problem reports (CAP NAIT items) is challenging the station to work on the important issues and avoid being distracted by the number of CRs on events or conditions having lesser significance. DSAT identified that work on backlog may not be appropriately prioritized. Although the backlog has steadily decreased, and is significantly lower than it was at the time of the DSAT, System Engineers identified that one of the reasons that important duties were going undone is that an apparent artificial importance was being placed on the backlog of NAITs.

Example 6: DSAT Section 2.3.1(4) identified that the design basis for the interaction between the RIIR and the Fuel Pool Cooling System, and the 150 degree F fuel pool limit was not understood by Engineering. Ilad this issue been followed up, the crisis during the 1995 refueling outage may have been avoided. Note that no formal tracking or plan to investigate and resolve the issues that resulted from this event currently exists.

Example 7: Several specific Special Evaluation Observations (SEO) were identified that there does not appear to be any plan to correct in existence: 1) SEO ltem 8.3JT describes inadequacies in the surveillance test program. The SEO action plan surveillance program changes to be implemented as a part of the Improved Standard Technical Specifications (ISTS). Ilowever, the Phase III Plan on ISTS does not mention Surveillance changes; 2) SEO ENG-15 was closed based on the conclusion that Engineering training programs were in place as of 5\2\95. The Phase 11 Plan calls for a review of the Engineering training program by 12\22\95; 3) SEO PJP-11 indicates that management will ensure a Nebraska Public Power District Cooper Nuclear Station 20 Engineering Self Assessment 1

clear definition of the relationship between IST and the preventive maintenance program. This item was transferred to the Maintenance Rule Program. The Phase III Plan on Maintenance Rule does not include this item;

4) SEO JT-9 indicates that PTMs are not performed in accordance with the 2.0.7 procedure. A PCN was produced to clarify the procedure, however, the current procedure owner is not aware of the concern and continuing problems i with the PTMs were identified during the self assessment; and 5)SEO JT-11 .

indicates that several OD/OEs were not in compliance with procedures and were narrow in scope. This same concern was identified during the self assessment. .

Example 8: A review of Phase I PIP, Appendix J," Cross Reference of DSAT Field Notes and Phase I Plan," identified that approximately 33 of the DSAT engineering I area observations were excluded from the Phase I Plan. While this was by l design, it was intended that these items would be included in the Phase III Plan, and this effort was incomplete.

5.4 PERFORMANCE ENHANCEMENTS Finding 14: Many Engineering processes are unnecessarily cumbersome and time consuming.

Example 1: The Replacement Component Evaluation process was cited in many interviews as a problem process. This process is very limited in that it only i permits equivalency for obsolete components and requires 5 Engineering l signatures to approve a simple equivalency replacement.  ;

Example 2: The OSCR process used during the outage permitted work to be eliminated from the outage scope without System Engineer knowledge. Examples were the RW-AOV-10 through 13. '

Example 3: There are several aspects of the PTM process that have not been routinely followed, including the requirement to eliminate PTMs greater than 6 months old by making them permanent designs.

Example 4: The vendor manual change process is currently being conducted in a manner different from the procedure in order to effect a more streamlined process.

Finding 15: Training and qualification needs to be enhanced in several specific areas ,

including: use of site and Engineering processes (how we do business),

integrated and specific system knowledge (particularly for System Engineers),

Nebraska Public Power District Cooper Nuclear Station 21 Engineering Self Assessment

the number of qualified Reactor Engineers and the overall level of engineering certifications (system experts, SROs, SRO certifications, and STEs).

Example 1: Interviews with System Engineers and customers indicate that integrated system knowledge is weak and process knowledge is weak. System Engineers are not given training on these subjects prior to being assigned to a system.

Many System Engineers are not certified on their specific systems.

Example 2: There is only one certified Station Nuclear Engineer in the Reactor Engineering Group.

' Example 3: Engineers have not been provided adequate training on the contents and use of the DCDs or on how to maintain the DCDs.

Finding 16: Tools, resources and support in such areas as document availability and retrieval, databases, and design basis information need to be improved for more efficient use of engineer's time.

Example 1: The information management system is inefficient. Too much engineering time is spent retrieving documents. For example, there is only one drawing :

print machine on site. Also, it is difficult to obtain a hard copy of controlled procedures. No database exists which shows the currently effective design basis calculations.

Example 2: System Engineers interviewed do not believe that the current equipment monitoring and trending program that is available is adequate for its intended purpose. The program is not frequently used.

Example 3: There is only one set of controlled vendor manuals on site.

Example 4: The CMDC database is inadequate. It cannot be used to determine the currem number ofopen modifications.

Example 5: Tools have not been provided to capture significant technical issues, that while not conditions adverse to quality, require additional engineering evaluation. Several examples were identified of previously known issues

where Engineering had not performed any additional evaluation and was not L tracking the issues. These included the Reactor Building to torus vacuum breakers design under loss ofinstrument air, spent fuel pool cooling redundancy and linear fuel bundle off-load limits, Service Water effluent rad monitor problems from RE-16, and the design of the Z Sump. Note that the l

I h Nebraska Public Power District

! Cooper Nuclear Station

22 Engineering Self Assessment

RilR shutdown cooling crosstie to spent fuel pool cooling design basis was a DSAT question that was not tracked and resolved and caused significant delays and manpower during RE-16.

6.0 ABILITY TO RESOLVE OPERATIONAL ISSUES 6.1 SCOPE /

SUMMARY

The horizontal review of Engineering's ability to resolve operational issues included input from over thirty interviews with operations, training and engineering staff members. It also included document reviews of such engineering products as plant temporary modifications, design changes, minor modification packages, operability assessments, condition report evaluations, OER responses, surveillance procedures, safety evaluations and engineering judgements.

The results of this review indicate that the CNS Operations staff has observed noted improvement in Engineering's ability to respond to issues since the Engineering reorganization. Ilowever, the overall assessment found several areas that required focus by the Engineering Division. Operations personnel desire a "one stop shopping" approach when a need for engineering involvement arises and expect the System Engineering area to fulfill this need. This need is understood by the Engineering Staff, but is not being met because the role of the System Engineer is not well defined and the performance oflow value work does not allow System Engineers to interface with Operators. Engineering's support of Operability Assessments was found to be oflow quality. Review of Engineering products found several examples of failure to follow procedures. Procedures were also noted as inconsistent in some areas. Safety evaluations required much more documented detail in the areas of accident and transient applicability, as well as the consideration given to different modes of operation.

Existing Operations Department processes were not well known or utilized by the System Engineer. This included no engineering interface with the Operations Department system '

experts and no engineering participation in operations system training provided during SRO/RO license classes.

In addition to the above findings, several areas for improvement were identified. On the Spot Changes used to revise modification packages are not routed through the responsible maintenance planner. This results in the potential to omit post maintenance testing requirements. Additional training within System Engineering is needed to strengthen the understanding of CNS processes and to improve integrated plant knowledge. Design Engineering lacks the knowledge of the contents of EOP calculations and OPL processes and requires training to ensure modifications do not invalidate EOPs or OPL conclusions.

Finally, current engineering training does not utilize the control room simulator as a leaming tool.

Nebraska Public Power District Cooper Nuclear Station 23 Engineering Scif Assessment

6.2 STRENGTIIS 6.2.1 Simulator Fidelity: The moi.ification process incorporates required changes to the control room simulator in an expedient manor. Good communication between the simulator group and Engineering was noted during the assessment.

Example 1: Minor Modification 95-184 was an emergent modification performed at the end of the Cycle 16 Refueling Outage. This modification was initiated and completed within one back shift. Though the potential to overlook minor details such as simulator updates was great due to the expedition of the modification, corresponding simulator modifications were completed to allow operator training prior to startup from the refuel outage.

Example 2: Interview with the Simulator Supervisor found that Engineering kept the simulator group informed of modifications that affect control room panels. This was further ensured by procedural controls.

6.3 FINDINGS 6.3.1 Attention to Detail: Review of various engineering products has resulted in observations of missing required signatures, incomplete work and procedural violations. These observations indicate the CNS Engineering staff's lack of attention to detail in the area of procedural compliance.

Example 1: Review of PTM 96-03 and 95-19 revealed the following deficiencies:

1) Drawings not identified for update when the PTM expected duration was greater than 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> (CNS Procedure 2.0.7, Step 8.1.5).

2) The ALARA Coordinator review was not obtained (CNS Procedure 2.0.7, Stem 8.1.11).

3) Caution tags were not hung when required (CNS Procedure 2.0.7, Step 8.4.1.11).

4) The Shift Supervisor's approval signature block was not signed by the Shift Supervisor (CNS Procedure 2.0.7, Step 8.4.1 and 8.5.1).

5) Attachments to PTMs were not included (CNS Procedure 2.0.7, Step 8.1.7.1).

Nebraska Public Power District Cooper Nuclear Station 24 Engineering Self Assessment

Example 2: Review of the opeability assessment for CR 96-40 revealed the following deficiencies:

1) Parts of Attachment 2 to operability assessment were not completed.

2) The basis for operability contained an Engineering Judgement without reference to any supporting basis as required by CNS Procedure 0.5.

3) The Engineer that performed the OA was not certified to the training requirements of TPD 509.

Example 3: Review of the Engineering Judgement (EJ) log found that 20% of the EJs logged out for initial performance were not documented as completed. The CNS calculation procedure requires assessment of all EJs against the effected calculation to ensure design margins aren't effected. The incomplete log does not allow this assessment.

6.3.2 Inaccurate Procedures: Review of CNS procedures found instances of errors and contradictions within the procedures. This impacts the ability of procedure users to meet procedural compliance expectations.

Example 1: Section 2.5 of the CNS Safety Evaluation Procedure infers that performance of maintenance activities that change or remove plant components are acceptable if accompanied by a Safety Evaluation. By definition, the design change process is the appropriate mechanism to use to modify the facility and it is not appropriate to allow maintenance activities to change or remove plant components. Thus, this j section of the Safety Evaluation Procedure contradicts defined CNS processes. i Example 2: Conceptional Design Document (CDD) Procedure 3.4.2, Section 2.2 states that ]

the CDD's originator's supervisor should determine if a CDD is required. 1 However, Section 4.2 of the same procedure states that the same determination is the Design Engineer's responsibility.

6.3.3 Onerability Assessments: Operability Assessments supported by the Engineering i Department were not thorough. Assessments lacked the detail required to j determine operability. Assessments failed to identify use of design basis information and licensing basis information.

Example 1: Operability Assessments for CR 96-40 and CR S/N 1-06559 contained operability assessments performed by Engineering that had no reference to design basis or functional requirements. Follow-up discussions with System Engineers found Nebraska Public Power District Cooper Nuclear Station 25 Engineering Self Assessment l

that DCDs were not used and that the DCDs did not contain needed information.

Assessment conclusions were difficult to validate until the performers of the assessments were consulted.

Example 2: Engineers are required to be certified to Training Program Description (TPD) 509 prior to performing operability assessments. CR 96-040 was performed by an engineer that was not certified to TPD 509. Lack of training and certification is considered a contributor to the noted poor quality of operability assessments.

6.3.4 Backlog Prioritization/ Low Value Work: Currently System Engineers are not able to dedicate resources needed to meet operational expectations because priority is placed on reduction of existing backlogs and performance oflow value work.

Example 1: Interviews with System Engineers found that little or no performance monitoring or MWR prioritization is being performed by System Engineers. Ilowever, interviews with Operations personnel found that both performance monitoring and MWR prioritization are expectations.

Example 2: Observation of daily morning briefings found that though emergent plant issues were discussed, they were not given the same priority as completion of backlog items. Follow up throughout the day within System Engineering validated this fact.

Example 3: Operations personnel expects a "one stop shopping" response to operational

.,4iries. Examples were provided to the Self Assessment Team that detailed Engineering's inability to meet this expectation. The priority placed on the backlog and low value work contributes to this inability.

6.3.5 Safety Evaluations: Safety evaluations lack the detail required to document thoroughness.

Example: Review of the Safety Evaluations performed for DC 95-44-2 and Minor Modification 95-184 found no documentation on the identification of the accidents and transients evaluated. Modes of operation considered by the evaluation were not documented.

No reference to the Nuclear Safety Operational Analysis (NSOA) was made. Review of the CNS Safety Evaluation Procedure found no requirements to utilize the NSOA.

6.3.6 Interdenartmental Communications: Existing operational activities are available to improve interdepartmental communications, but are not being utilized by the Engineering Department.

Nebraska Public Power District Cooper Nuclear Station 26 Engineering Self Assessment

Example 1: The Operations Department has assigned various operators as system experts.

This assignment is controlled by CNS procedures which recommend regular interfaces with associated System Engineers. Interviews with Operations and System Engineers found that this interface is not occurring on a regular basis.

Example 2: Interviews with the Operations Training Supervisor found that System Engineers are not taking advantage of attending License classes when their particular system is discussed. This attendance was encouraged by the Training Supervisor duri~;

the interview to strengthen communication 3 with Operations personnel and enhance the system knowledge of the engineer.

6.3.7 Roles and Resnonsibilities: Engineering's reorganization is not well understood by the Engineering Staff. Roles defined by the reorganization do not match activities being performed in the field.

Example 1: A majority of engineering supervision was unaware of the contents of the reorganization phm and the Engineering Transition Plan.

Example 2: A review of the roles defined in the reorganization plan found that many of the responsibilities outlined for the Engineering Support Department were being performed by the Plant Engineering Department.

Example 3: Through interviews of Engineering personnel, it was apparent that the role of the Maintenance Engineer was not well understood.

6.4 AREAS FOR IMPROVEMENT 6.4.1 Field Change /MWR Interface: No process exists to coordinate On the Spot Changes for modifications with the MWR planning process.

Example 1: DC 95-044-2 was revised by an OSC to require performance of a snubber inspection procedure. This OSC was not provided to the Maintenance Planner and was, therefore, not included with the other hanger inspections listed as post maintenance test requirements. Review of the CNS OSC procedure found that there is no requirement to provide OSCs to Maintenance Planning.

6.4.2 Training / Plant Knowledge: Training on CNS processes and integrated plant knowledge must be emphasized for System Engineers.

Example 1: Interviews with Operations personnel found consistent statements on the need for training of System Engineers on CNS processes and integrated plant knowledge.

Nebraska Public Power District Cooper Nuclear Station 27 Engineering Self Assessment

Example 2: Several instances were noted where System Engineers were not aware of procedural requirements while involved in CNS processes. L i Example 3: System Engineers recently hired at CNS were immediately assigned activities prior to completing training. >

t 6.4.3 EOP/OPL Process: Design Engineering has no expertise in the areas of EOP

calculations or OPL processes. Training is required to ensure that design j activities do not invalidate EOPs or OPL conclusions. However, this training has

] not been provided.

Example 1: Design Changes are assessed to determine if EOPs are impacted via a checklist in

, CNS Procedure 3.4.6. EOP calculations are complex in nature and specific i knowledge of these calculations is required to accurately complete the EOP checklist. No expertise on EOP calculations resides within Design Engineering to provide input to this process.

Example 2: Design Changes and Minor Modification procedures contain no requirements to address effects on OPL conclusions. No expertise on the OPL process could be found within Design Engineering.

6.4.4 Simulator Training: Review of Engineering training identified that the simulator is not being used as a training tool within the Engineering Department.

Interviews with the Simulator Supervisor found that the simulator is available for use and is encouraged as a training tool.

7.0 MAINTENANCE SUPPORT 7.1

SUMMARY

The horizontal review of Engineering Maintenance Support found that Maintenance on the whole had seen an improvement in the responsiveness of Engineering. However, the lack of clear expectations, accountability and defined roles and responsibilities within Engineering hampered Engineering from working efficiently and focusing on appropriate priorities. In particular, focus and ownership by System Engineering in the Work Control Process need improvement to ensure the appropriate scheduling priorities are made from an Engineering perspective. Several instances were also observed that questioned Engineering's ability to evaluate technical issues from a generic or process point of view and to make appropriate root cause determinations.

Nebraska Public Power District Cooper Nuclear Station

, 28 Engineering Self Assessment l'

A number of areas for improvement were also identified in the Maintenance Support horizontal review. A few low value activities, such as reviewing MWRs and cumbersome processes such as the RCE process still need to be adhessed. Ilaving the l appropriate tools, such as documents and vendor manuals available was also an issue. l Procedure control and adherence concerns were identified. Many of these issues would be appropriately dealt with by addressing Engineering roles, responsibilities and priorities as discussed above.

7.2 SCOPE AND METHODOLOGY The scope of this portion of the Engineering Self Assessment was to review specific recent cases of Engineering support for specific maintenance activities or programs and assess Engineering performance. These activities or programs included troubleshooting, corrective maintenance, planned maintenance on selected systems, use of Risk Analysis to support outages and the Maintenance Rule Program. The assessment plan that was developed for this horizontal area was completed during the self assessment. From this assessment, strengths, findings and areas for improvement were identified. Immediate corrective action was taken as appropriate.

7.3 STRENGTHS 7.3.1 Customer Satisfaction Improved: Engineering has undergone a major.

reorganization and supported a refueling outage and yet customers of Engineering still feel that Engineering has improved in stepping up to issues and being more responsive to their needs.

Example 1: Interviews with scheduling supervision felt that around the clock outage i coverage by Engineering was excellent. Engineering showed signs of system ownership starting to take root.

Example 2: Interviews with Maintenance Supervision felt that Engineering is more receptive to the Maintenance point of view and acknowledged maintenance experience.

Example 3: QA individuals felt Engineering had made a significant turnaround during the outage in stepping up to difficult issues and making tough decisions.

7.3.2 Work Ethics: liigh work ethics in Engineering has on occasion made up for lack of CNS experience.

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29 Engineering Self Assessment

i Example 1: An observation was made where a newly hired System Engineer assisted I&C personnel to resolve a procedural discrepancy in a timely manner.

Example 2: Interview with Scheduling supervision indicated that they felt high work ethics made up for Engineering inexperience during the outage.  ;

Example 3: The Engineering Coordinator for Scheduling is an individual from l

Engineering support who fulfills this responsibility along with his regular l duties. This was positively commented on by both Engineering and Maintenance Planners.

1 7.4 FINDINGS 7.4.1 Management Exnectations and Accountability: Lack of clear expectations and  !

accountability in Engineering has resulted in an organization that does not work I well together as a team.

Example 1: Interviews with 4 System Engineers,3 Engineering Support Engineers and 3 Design Engineers indicated that management expectations are not clearly l identified for any of the 3 Engineering departments. I Example 2: All Engineering Project Requests (EPRs) were scheduled to be reviewed for RE-17 by January 31,1996. By February 2,1996 only 350 of 600 EPRs had ,

been completed. No guidance had been given to Plant Engineering Manager I on available budget funding for RE-17. It was also unclear how PED supervisors would be utilized in screening EPRs. Prioritization criteria established may be too simplified.

Example 3: A Design Engineer was assisting in troubleshooting concerns on DG-2 muffier bypass valve. The Engineer spent 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> developing troubleshooting guidance per procedure 7.0.1.7 based on direction from Maintenance '

supervision. After starting troubleshooting, the activity was halted because Maintenance Planning and the Maintenance Manager felt a STP was required.

l&C backed out of the troubleshooting procedur:: while the Design Engineer went to develop the STP.

Example 4: In an interview with an A/E who worked on the DG modification during the outage, his opinion was that manpower resources allotted to the DG modification was minimal for the first half of the DG-1 modification implementation. IIe felt CNS did not account for the fact that most A/Es, even in large engineering firms, are composed of office engineers with no Nebraska Public Power District Cooper Nuclear Station 30 Engineering Self Assessment

l

. )

field experience. Ilaving only one CNS person on site who was knowledgeable of the modification and did not have the project as his primary job, especially since it was a complex modification, was unsatisfactory in his estimation.

7.4.2 Roles and Resnonsibilities: Interviews with Engineering personnel and Customers indicated roles and responsibilities are not clearly identified for Engineers to allow them to focus appropriately, i

l . Example 1: DSAT 2.3.5 identified a lack of clearly defined roles and responsibilities for System Engineers as a cause of Engineering failure to improve. Little or no improvement has been demonstrated in the past 18 months.

f Example 2: Numerous interviews with Engineering personnel resulted in a consensus that

j. System Engineers are not performing adequately the responsibilities they view as most important.

i Example 3: Scheduling feels Maintenance Planning is telling System Engineers what PMs j to perform. System Engineers are felt to have a passive role in PMs.

Example 4: The Engineering Support Department Manager and Reliability Engineering supervisor have tried for 6-8 weeks to get System Engineering invohement in Maintenance Rule implementation.

- Example 5: An owner of the DG muffler bypass concern was not assigned until the issue was near the crisis stage.

7.4.3 Work Control Process Ownership: Ownership by System Engineers of the Work Control Process is not clearly established.

Example 1: Interviews with Engineering personnel indicated the division of responsibility and interface between Engineering, Maintenance and Maintenance Planning is not clear. Individuals agreed that involvement was necessary, but did not agree on the degree ofinvolvement.

l Example 2: Maintenance Planning interviewees do not believe Engineering is aware of plant priorities. Appear to be insensitive to MWR packages priorities.

Emergent items have to be hand carried by Maintenance Planners to receive j attention.

l Nebraska Public Power District Cooper Nuclear Station 31 Engineering Self Assessment e

J

, . . - - . . , , . . .~

1 Example 3: A meeting on a Reactor Building. Demineralized Water System Outage did not result in consensus on who should coordinate the evolution. The Operations representative thought it should be the System Engineer, but he did not acknowledge nor accept.

Example 4: Interviewed individuals felt Engineering often perfonned support work / troubleshooting in the field that could be perfonned by Maintenance individuals.

Example 5: A Scheduling Supervisor expressed frustretion that when he pressed a Plant Engineering Department supervisor to name an evolution coordinator from his group, the supervisors response was "OK, but don't let this become a habit".

7.4.4 Work Prioritization: The cyclic prioritization of backlog reduction appears to be more prevalent than the prioritization of process improvements that would climinate the backlog generation.

Example 1: For the past 2 SALP periods (report 4/93 and 8/95) the NRC identified that System Engineers are not perfonning their most important duties, including:

1) system walkdowns,2) equipment and system trending,3) system problem identification,4) system health / reporting,5) system knowledge / expertise. So far,6 months into the current SALP period, it appears that little or no action I has been taken to correct this concern.

Example 2: DSAT section 2.3.3.1 (1) identified that a growing backlog of problem reports (CAP, NAITs) was challenging the station to work on the important issues and avoid being distracted by the number of CRs on events or conditions having )

lesser significance. Work on backlog items may not have been appropriately  ;

prioritized. This appears to continue to be true nearly 18 months af ter the l DSAT.

Example 3: At a Plant Engineering morning meeting on 2-16-96, it was unclear what the l top priorities were for the day based on the following statements: 1)

Discussion on Sr. Engineering Manager MS-mali item on CAP backlog was identified as an item that "need to keep in front of everybody",2) stated that his top priority was to address Engineering Self Assessment j Response Team items,3) At the end of the meeting the i stated that priorities for the day were NAITs and EPR screens,4) Resolution of a DG muffler bypass valve concern, which had the potential to make both  :

DGs inoperable was not identified as a top priority. l I

Nebraska Public Power District Cooper Nuclear Station 32 Engineering Self Assessment

1 l

Example 4: In an interview with a System Engineer, the System Engineer was unaware of the reason that NAITs were an issue as a result of the previous weeks priority shift. There appeared to be a lack of communication from management concerning the System Engineering workload priorities.

Example 5: In an interview, a newly hired System Engineer was asked what his top priorities were.11is response was 1) EPR/EWR screening for the next outage,

2) NAIT items review,3) Training and closing out items from RE-16,4) Daily fire drills (which become #1 when emerge). When asked what his i responsibilities were, he stated he had gotten ajob description in his offer i letter, but otherwise they weren't discussed much. He felt other work such as testing, performance monitoring and procedure review were not getting enough emphasis.

7.4.5 Incomnlete Understanding of Corrective Action Program. Several observations j were made that indicated an incomplete understanding of the Corrective Action Program requirements and Root Cause Analysis.

1 Example 1: CR l-16002 was written due to multiple failures of C Main Condensate Booster Pump oil pump cover gasket. An existing MWR was revised to fix  !

(MWR 95-4576). A Systerr Engineer involved in troubleshooting, knew that i the oil pump rotated backwards, blowing out the gasket, due to wiring changes made to the overhauled motor by a contractor in Connecticut. This was not documented on CR l-16002 nor MWR 95-4576, because according to the System Engineer, "there was not any point in investigating too deep", because he was "otherwise happy with work"(from contractor), he was " Doubtful any useful information" could be obtained and we are "done with them for a good ,

long while" CR 95-1458 was latter written to address the pump being wired backwards. It was assigned to Maintenance who stated the problem was that Operations wouldn't allow them to bump the pump for rotation because they were concerned about breaker damage on high starting current. This was viewed as a communication issue between Operations and Maintenance.

Example 2: MWR 95-4567 found a seal water outlet DP control valve installed backwards i on the B condensate booster pump. The System Engineer was involved in j troubleshooting and correction. No CR was generated to address / investigate 1 the root cause.

Example 3: CR 95-1102 was written due to 4160V bus IF transfer to emergency while performing procedure 7.3.16. A CAT 2 CR identified the root cause as personnel error by the Engineer providing test instructions. Procedure 7.3.16 Nebraska Public Power District Cooper Nuclear Station 33 Engineering Self Assessment i

was also reviewed by a Shift Supervisor. Procedure 7.3.16 also appears inadequate in its review requirements for installing a temporary modification (which is what caused the bus transfer) compared to procedure 2.0.7 for installing a Plant Temporary Modification (PTM). Would appear that more than one barrier (the engineer) broke down in this process.

Example 4: CR 95-1205 addressed multiple problems with DG-1 acceptance testing. Each individual problem found had a root cause identified, but no generic root cause was determined. CR 95-1241 was written by QA due to lack of effective and timely resolution of approximately 140 discrepancies for DG-1 using the CAP program. This CR assured that the DG-1 discrepancies were adequately addressed to ensure DG-1 could be declared operable and lessons i were adequately applied for maintenance on DG-2. The root cause was identified as lack of ownership / project management for mods and maintenance. Long term actions were to establish expectations for project )

owners and to further critique RE-16 DG issues. Appears that process i problems were deferred, ignored or diluted. Many process problems were identified in discussions with involved individuals that have not been addressed.

Example 5: CR l-16981 found that procedure 14.20.5 did not provide for calibration of Recire MG set Indicators if they were found out of calibration. CR l-16981  ;

calibrated B Recire MG set and CR 1-19238 calibrated A Recire MG set. i Discussion with involved I&C Tech revealed that nothing had been done to i prevent reoccurrence. System Engineer who reviewed / signed the package J completion did not remember the issue when questioned.  ;

7.5 AREAS FOR IMPROVEMENT 7.5.1 Ineffective Internal Communications: Ineffective internal communications were observed between Engineering Managers and subordinates.

1 Example 1: System Engineer recommended to the to to stop monitoring F sump. Direction given by the was that wanted 4 day averages to be taken. No further discussion occurred. When individually questioned, the System Engineer still believed that no value was added by taking 4 day averages, but since could easily be done, didn't object.

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Nebraska Public Power District Cooper Nuclear Station 34 Engineering Self Assessment l

Example 2:

asked if Fuel Floor ropes had been removed.

When a negative response was received the issue was dropped. Was unclear if this was still desired, no completion date was discussed.

Example 3: asked about a rumor he had heard about when personal performance plans were due. '

admitted the information heard in the rumor was true.

Example 4: A discussion was held in the Morning Engineering Meeting about who presents and what to present in EPR screens on 2-16-96. These screens were to have been completed Jan 31,1996.

Example 5: A communication gap exists between site Senior Management and Engineering supervision regarding the status of the Engineering reorganization. Senior Management expressed that progress on the reorgenization was "on plan" while Engineering groups expressed uncertainty with the status of the reorganization and frustration that the reorganization was not operating more efficiently and effectively.

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/.5.2 Ineffective External Communications: IneITective or miscommunications was l observed to occur between Engineering and organizations external to Engmeermg.  ;

1 Example 1: During RE-16 preoutage preparations, design Engineering did not interact well in maintaining not only design Engineering's status of modifications but  !

also Maintenance Planning. This resulted in many unnecessary calls to '

Maintenance Planning to determine their status.

Example 2: Interviews with Maintenance Supervision indicated A/E's working on design changes did not understand CNS expectations due to having to send packages back several times before they were right.

Example 3: Interviews with A/E working on DG modification indicated that there was not enough up-front craft involvement, or only received sketchy reviews. Also felt Maintenance was leery of making decisions when they were the most knowledgeable. Frequently Maintenance deferred to Engineering for decisions, who exercised consensus decision making due to their lack of experience. This sometimes resulted in overly conservative decisions.

Example 4: Procurement Engineering was not aware of any delays caused by Q numbers.

Scheduling felt Q numbers were the biggest part critique item from the outage.

Nebraska Public Power District Cooper Nuclear Station 35 Engineering Self Assessment

Example 5: stated he was not clear what Construction's role was.

Believes Maintenance should always get first shot at every job. Construction believes they should have specialty contracts for difficultjobs. Construction does not believe they are working well at t'ie Manager level.

7.5.3 The Replacement Comnonent Evaluation (RC El nrocess: The RCE process was identified by both Engineering and Engineer ag customers as a cumbersome and inefficient process.

Example 1: Maintenance personnel interviewed telt the RCE process was a manpower killer for easyjobs. Gave example of an RCE being required to replace a $10 drain valve in the Water Treatment system. Felt this was discouraging maintenance from doing an easyjob. RCE processes addresses everything as essential.

Example 2: Observed planning meeting to replace demineralized water valves in the Reactor Building. System Engineer felt valves should be replaced by rubber seated valves to stop leakage. Same valves were replaced last year and anticipate will have to replace again next year because ofinstalling what we have in stock, versus the rubber seated valve. System Engineer felt compelled to take this approach because of a cumbersome RCE process.

Example 3: RCE 95-12 was written by a staff augmentation engineer and received the required 5 Engineering review signatures. It was discovered during this assessment that the RCE specified the wrong component for the application.

Appears that the complexity of the process had diluted any sort of i accountability and had not involved the appropriate individuals (an electrical maintenance engineer).

Immediate Corrective action taken: CR SN 1-21463 was written to address the concern. l Since the RCE provides a TIS that is currently inoperable for the SW Quad IIV and is not used in the EOPs, there is no immediate operability concern.

7.5.4 Document /Information Availability: Obtaining documents and information in a timely manner were noted as a major Engineering roadblock.

Example 1: Only one controlled copy of USAR and Tech Specs exists for all of Design j and Eng Support Departments. This information is not available on the LAN.  :

Example 2: Operating Procedures for Design and Eng Support are only available on the  !

computer and are difficult to access.

Nebraska Public Power District Cooper Nuclear Station 36 Engineering Self Assessment

Example 3: - Limited access to film readers and only one controlled set of Vendor Manuals currently exist on site.

Example 4: Computer Information Management is not user friendly, is not compatible between data bases nor do new Engineers receive any training on them.

Viewed as a major time waste trying to access required information to perform theirjobs by newly hired Engineers.

7.5.5 Engineering Involvement in MWR Preparation: Engineering needs to provide Maintenance Planners with adequate tools to enable them to perform MWR package preparation without direct involvement by Engineering.

Example 1: Maintenance Planners interviewed felt that they could perform ASME XI, MOV, ISI, IST, Appendix J, Fire Protection, Check Valve, Erosion / Corrosion and Protective Relay reviews without Engineering reviews if given the proper training and procedural guidance.

. Example 2: An engineer felt that if Maintenance Planners had a controlled copy of the relief valve setpoint log they could perform the first half of the relief valve setpoint test form without Engineering involvement.

Example 3: The Plant Engineering Manager felt that MWR reviews could be minimized if-Maintenance Planners were given the appropriate guidance. The MWR Engineering signatures were established when Maintenance Planning was first set up and were inexperienced. This has changed and the process has not changed with the experience level.

7.5.6 Vendor Bulletins /L etters: No effective means ofincorporating Vendor Bulletins and letters into the OER screening process.

Example 1: Interviews with OER personnel indicated they entered Vendor information into the NAITs data base if the information was forwarded to them. Program has been in place since early 1995, at which time a letter was forwarded to all i personnel notifying them of the program implementation. There has not been j any training on the process since. Procedure does not specify how Vendor I infoimation is supposed to be sent to the OER group.  !

l Example 2: OER Group learned of a Part 21 concern from the DG manufacturer only by reviewing NRC correspondence. They made several CNS internal phone calls to find that the System Engineer had received the respective Part 21 - ,

notification from the vendor.  !

Nebraska Public Power District l Cooper Nuclear Station ,

37 Engineering Self Assessment  !

7.5.7 Performance Indicators: Performance Indicators used by the station tend to track backlogs versus providing a mechanism of determining a specific systems health or providing trending.

Example 1: An interview with a Maintenance Supervisor indicated that he felt performance indicators should be more predictive of systems or equipment status. Current performance indicators trend backlogs.

1 Example 2: System Engineers perform INPO Monthly and Quarterly system performance l reviews. This report records the number of system demands, failures, planned )

and unplanned unavailability. Other than being very manpower intensive for l the System Engineer, it does not appear to have any impact on station l operation. Could be made more visible for trending information.

Example 3: There is not a routine process for specific system health to be presented to the i station in an interactive manner. Process should allow issues to be identified, l escalated and questions focused at system owners.

7.5.8 The Eauinment Data Field (EDF): The EDF needs to be updated and consistently  ;

used to ensure configuration control can be maintained.

l Example 1: Not all Fire doors are in the EDF or are coded correctly in the EDF. Fire Seals l were in the EDF, but were taken out in 1989 and have not been put back in yet. Approximately 100-200 Fire Seals have been identified through Appendix R which were never classified.

Example 2: The Component Identification Code (CIC) shown in the EDF is supposed to be the goveming CIC for the equipment. This CIC is not consistently used in i l

procedures and drawings and there does not appear to be a systematic plan to upgrade the procedures and drawings.

Example 3: A review of spare parts and Engineering specifications revealed that no guidance exists which requires Procurement Engineering to update the EDF when vendor material changes are made.

7.5.9 The Preventative Maintenance Program: The Preventative Maintenance Program has not received adequate prioritization by Systera Engineering in addressing longstanding issues.

Example 1: In discussions with Maintenance personnel, it was identified that Maintenance has ownership of the program, but past philosophy was if equipment was Nebraska Public Power District Cooper Nuclear Station 38 Engineering Self Assessment

PM'd more often it will work better. This was never verified and they believe Engineering should look at the value added by all the PMs that are performed.

PM optimization that was proposed in the past from Engineering did not work. This is viewed as a weak spot in System Engineering, for Maintenance believes major cost savings could be realized. Cited an example of where in one week performed 91 PMs and 18 cms. This is out of balance.

Example 2: Scheduling believes that Maintenance Planning is controlling which PMs get performed. Engineering is believed to have too passive a role. QA indicated that Maintenance is too cavalier in their attitude towards PMs and are not being held accountable for performance. This is resulting in an ever increasing PM backlog.

Example 3: Procedure 7.0.2 does not require Engineering review or oversight of the PM program. Maintenance is directed in the procedure to discuss PM changes with Engineering "when needed", no signature from Engineering is required.

Example 4: Interviews with System Engineers indicated that their is no System Engineer involvement in the PM process. PMs are usually changed without Engineering knowledge. There is no program to provide guidance on periodically performing PM reviews or to evaluate and modify the PM frequency. The PM program is currently done hard copy only and is difficult to track. It is also handled on a shop to shop basis, which makes it inconsistent.

i 7.5.10 The Predictive Maintenance Procram: The Predictive Maintenance Program has not received adequate attention from System Engineers.

Example 1: Maintenance supervision felt the Predictive Maintenance program was underutilized and compared to other utilities we were " missing the boat".

Maintenance currently takes a lot of data, which is available and could be better utilized. Maintenance feels Engineering is not aware of current capability and they have lost interest in pushing the issue.

Example 2: In an interview with the Plant Engineering Manager, he felt the System Engineers should own the Predictive Maintenance program, but felt this was a j future project and that this expectation was not known among System Engineers. He was also concerned that the Predictive Maintenance program was not documented as to what is performed and why.

i Nebraska Public Power District Cooper Nuclear Station 39 Engineering Self Assessment

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t Example 3: In discussions with the thermography program owner, it was revealed that the l program was almost non-existent and needs development. The development l of the program was being delayed due to other priorities.  ;

Example 4: Under the lubrication program, a lot ofoil sampling has been done to date, but there is no process set up for trending of data. A data trending process is still i in the planning stage by the program owner. l 7.5.11 Maintenance Rule /PSA Understanding. Many misconceptions or lack of understanding of the Maintenance Rule Program /Probablistic Safety Assessment j currently exist. Insufficient training / indoctrination has been conducted on site on these Reliability Engineering programs.

Example 1: Several Engineering customers questioned about Maintenance Rule knew that somehow it was going to improve equipment reliability, but had misconceptions about what the program was about. Some thought it was a

. PM optimization program or that it would require an Air Operated Valve  ;

program to be first established. Others admitted that they were not sure what '

the impact of the Maintenance Rule program would be.

Example 2: In an interview with the Reliability Engineering Supervisor, it was revealed

- that there are many planned applications of the CNS PSA that'are planned that would benefit multiple areas of the plant. These applications have not yet been formally communicated to the site.

Example 3: Training has been planned by Reliability Engineering to bring SAIC on site to conduct training on the PSA for both users and owners, since very little actual expertise exists on site. It was planned to have training personnel also attend  ;

this training to incorporate into CNS training programs. This proposal has stagnated due to lack of funding.

7.5.12 Procedural Noncomoliance. Several examples were observed of proceoural noncompliance due to incomplete procedural documentation or signatures. j Example 1: The Safety Evaluation and GE Summary of Repairs for Electrical penetrations performed under Special Procedure SP 95-114 stated that repairs on electrical penetrations would be performed by GE field personnel to ensure preservation of original design (GE stated the process was only valid if performed by GENE personnel). Ilowever, rework performed on X101C was done by CNS personnel. This was done by marking over the initial SP with additional J Nebraska Public Power District Cooper Nuclear Station 40 Engineering Self Assessment

signatures and lining out old ones, which does not appear to comply with procedure 3.5, Special Test Procedures /Special Procedures. Required GE signatures for the rework on SP 95-114 were annotated as "N/A".

Immediate Corrective Action Taken: CR SN 1-09243 was written and the Operability Assessment determined that while GE certification may not cover the CNS personnel performed repair, the qualification is not atTected since the same process, methods, materials, etc were used. Additionally, the repairs performed by CNS personnel passed the procedural acceptance criteria. A memo was also generated to document the qualification of the CNS personnel who had performed the qualification.

l Example 2: Attachment 5 of RCE 95-063, which replaced the existing motor on CS-MO-MO128, specified that no calculations required revision for the RCE.

110 wever an EJ for RCE 95-063 discussed that NEDC 94-242, the pipe stress analysis for the valve, did not have the correct weight for the valve per an Anchor Darling drawing.

Immediate Corrective Action Taken: Design Engineering identified that the EJ was in error in that the correct valve weight had been used in the calculation, but that the NEDC had not been appropriately updated. The NEDC will be revised at the next major revision. 1 Example 3: On 2-6-96 it was observed that IIPCI vendor manual 003 was signed out 12 95 and IIPCI vendor manual 72 vol I was signed out 1-12-96. A sign on the TSC library door states the manuals may be signed out for a maximum of 14 1 days. Eight other sign out cards were checked for a total of 10 checked. 4 of I the 10 had been signed out greater than 14 days. l Example 4: The documentation of actual work completed under essential Mmor i Maintenance 96-00433 could have been more specific on what work was performed. Paperwork stated that " adjusted packing gland as per procedure 7.2.20". Procedure 7.2.20 packing adjustment section allows tightening the gland nuts, adding packing or repacking the valve if required. Documentation of actual work performed would aid in future maintenance.

Example 5: Closure of completed STP/SPs and RCEs by System Engineering is not timely. There are 7 open STP/SP. There are 36 open RCEs,14 of which have been open for more than one year.

7.5.13 Desk Ton Guides: Written expectations for the use of Desk Top Guides is not available and control of them is weak. Observations were made where work performance is not in compliance with Desk Top Guides.

Nebraska Public Power District Cooper Nuclear Station 41 Engineering Self Assessment

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, . Example 1: Scheduling Supervisor identified that we are not following desk guides in l T existence. An Engineering Desk Top Guide requires an Engineering i Coordinator position. Currently this is being performed by an Engineering

! Support individual on a part time basis. The Scheduling desk guides requires

Engineering to bring scheduling a prioritized list of work they want to achieve

in their respective system windows. This is not happening and even the

. Scheduling supervisor acknowledged that this was probably not realistic. l Example 2

Written management expectations for the use of Engineering Desk Top guides is not available and configuration control of the guides is weak. The

{

!. Engineering Desk Guide covering Engineering interface with the work control  !

!' process is contained in the back of the Engineering Department Instruction -

j Manual rather than in the Engineering Desk Guide Manual. One Engineering j supervisor was unaware of the existence of one of the guides. An other '

Engineering supervisor was unsure where desk guides were headed, whether they would be eliminated or made into procedures. One supervisor referred to the guides as workarounds due to the difficulty in changing existing site

administrative documents.

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[ 7.5.14 Low Value Work: Several processes still have low value reviews bemg  ;

performed by Engineering. j

! l Example 1: Reviews performed by System Engineers on MWRs provides low value as _ .

l l viewed by System Engineers, Maintenance and observed in progress. New I

System Engineers do not feel their review adds much to the process. Some

- feel Maintenance Planners should be given adequate guidance to not l necessitate Engineering review. Maintenance feels program reviews are l~ process driven and they could do without Engineering reviews in at least

2/3'rds of all MWRs reviewed. An observation of an MWR by Engineering i~ indicated no substantial value added Information the Maintenance Planner l needed from Engineering was obtained by a phone call.

j Example 2: A review of an Essential Minor maintenance package received the review of 1 j the Scheduling Manager, Maintenance Manager and Plant Engineering ]

l Manager. It was unclear why these individuals had to review the package or if-

! any value was added. Procedure 7.0.1.6 does not specify what the reviews are L for. The job reviewed was to tighten packing on an REC valve.

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[ Nebraska Public Power District j Cooper Nuclear Station l

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8.0 SYSTEM ENGINEERING EFFECTIVENESS 8.1

SUMMARY

The purpose of the of this portion of the assessment is to evaluate the effectiveness of the ,

System Engineering organization. l The engineering self assessment Mam has concluded that the System Engineer's are marginally effective and functional almost exclusively in a reactionary mode. The problem areas identified by the team include poor management of engineering resources, weaknesses in the use of design basis information, minimal involvement in the preventive maintenance program, inadequate trending of plant equipment and systems, and inadequate planning of system maintenance. The heavy workload of the System Engineers is preventing them from  !

performing System Engineer duties. Weaknesses in the training and qualification of System l Engineers, inadequate tools, and unclear prioritization of work were identified. The i consistency and content of System Engineering 'valkdowns performed by the System i Engineer also needs improvement.

It was also noted that the workload assigned to the Reactor Engineering group exceeds the available resources for both short term and long term operation and there is a lack of an i owner ibr the OPL process. Another area identified as needing improvement is the OSCR process needs to include a System Engineer review / approval. ,

l 8.2 SCOPE AND METHODOLOGY J

The System Engineering assessment plan included three typical areas of review that were ,

included in the assessment plan:

i. Improving and maintaining system material condition.

i ii. Trending system and component performance.

4 iii. Customer Services. )

i

. This review consisted of a horizontal review of the System Engineering function. j Documentation reviews and interviews with both System Engineers and customer interviews  !

4 were performed as part of this assessment plan. Additional emphasis was placed on specific areas when potential weaknesses were identified by team members.

All findings and areas ofimprovement were based on the results of the System Engineering assessment plan and other observations provided by the remaining team members.

1 Nebraska Public Power District Cooper Nuclear Station 43 Engineering Self Assessment

8.3 STRENGTIIS None.

8.4 FINDINGS.  ;

8.4.1 Ineffective Use of System Engineering Resources. A lack of specific roles and I responsibilities is resulting in the ineffective use of System Engineers resources.

As a result, improvements in design basis knowledge, reviews of PMs, plant equipment performance monitoring, and the planning of system maintenance are not being effectively performed. This problem exists due to the heavy workload involving an excessive corrective action backlog and an over involvement in the planning of maintenance work packages. Contributing to this problem are inadequate training, inadequate tools, and unclear prioritization of work. l 8.4.2 Management involvement: The lack of management attention has contributed to the ineffective use of System Engineering resources.

Example 1: The roles and responsibilities of the engineers has not been effectively documented, disseminated, or reinforced in the engineering and non-engineering organizations. As a result, both the engineering and non-engineering organizations are unclear who has the primary responsibility for various subjects.

Example 2: Management has not effectively addressed the performance issues identified in past evaluation reports as it relates to the System Engineering function.

Examples are provided below:

a. For the past two S ALP periods, the NRC has identified that the System Engineers are not performing their most important duties including system walkdowns, equipment and system trending, system problem identification, system health monitoring, ands system knowledge and expertise. So far,6 months into the current SALP period, it appears that little or no action has been taken to correct this situation.

b. The April 1995 INPO report identified weaknesses in the management of engineering resources and prioritization of workload. These were identified as causes of System Engineering not performing their key walkdowns, trending etc. Little to no action has been taken to resolve this issue.

Nebraska Public Power District Cooper Nuclear Station 44 Engineering Self Assessment

c. The 1994 DSAT identified lack of clearly defined roles and responsibilities and failure to monitor and assess effectiveness ofimplementation of a management expectation as the cause of engineering's failure to conduct important System Engineering duties. The self assessment has seen a continued failure after 18 months in this area with little or no improvement.

d. The 1995 INPO evaluation and 1993 and 1995 SALP reports indicate that specific action will be taken to correct the problem that System Engineering is not focusing on important duties. CNS made a commitment to correct these

. problems, including a commitment to clearly identify management expectations. Little action has been taken to date.

Example 3: The prioritization of work needs improvement. Observation of normal station meetings and individual interviews indicate that System Engineers are driven by management priorities of the week and due dates set by the CAP process that do not recognize emergent issues or the groups integrated workload.

Supervisors are unable to adjust priorities due to managements focus on formal performance indicators. This focus on performance indicators does not recognize emergent issues and the need for system interaction by the System Engineer.

Example 4: No overall plan to assist System Engineering. Although one of the stated purposes of the engineering reorganization was to establish the Engineering Support Department and Backlog Reduction Transition Team to relieve some of the burden of the System Engineer, this relief has not been totally successful. Backlog Reduction Transition Team has been disband and Engineering Support Department has their own work. The Operations.

Support group of Engineering Support Department do not have sufficient resources relieve System Engineers. The Operations Support Engineering Group is too small to and is currently working on Engineering Support Department backlog. In addition, the Emergency Response Organization has six qualified electrical engineers, two from System Engineering. The engineering organization has the capability to add 10 more qualified electrical engineers to the Emergency Response Organization to reduce the burden on the current six engineers. This has not been done to date.

Example 5: The reorganization goal was that System Engineers were to spend no more than four hours on a single task. This has not been implemented resulting in the lack of a proactive and real time intrusive System Engineering organization.

Nebraska Public Power District Cooper Nuclear Station 45 Engineering Self Assessment

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8.4.3 Desien Basis Knowledge. Based on interviews, the System Engineers' design basis knowledge for his/her assigned system is questionable.

Example 1: One operating crew indicated that many engineers do not understand the i interrelationship between systems, even though they are knowledgeable of )

their systems. One example is the flange gasket replaced on the NBI level

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3A condensing chamber. The lack of engineer knowledge of system l interrelationship and the breakdown of other barriers resulted in the loss of i

SDC during the last outage (reference CR95-1380).

Example 2: Many System Engineers do not understand what constitutes the design and licensing basis of the plant. There is significant confusion over what they are and where to find them. Very few System Engineers have had past SRO or STE certifications. i l

Example 3: The DCD was provided to the System Engineer with no training or guidance concerning its use. The System Engineer was unaware of the method of using or updating the DCD. Several of the System Engineers did not have a  !

copy of the DCD for their system and were concerned with the lack of )

information in the DCDs.-  !

8.4.4 Preventive Maintenance (PM) Program: The System Engineer has little or no j direct involvement in the PM program that may be contributing to a poor PM i program. Examples of a poor PM program are provided below. Reference section 7.5.10 for more information:

Example 1: A review of four Vendor Manuals was performed to determine if vendor recommended Preventive Maintenance (PMs) are being implemented. The results of this are provided below:

a. The vendor manual for the Price Pump Company pump REC-P-BP recommends re-lubrication of the sleeve every 6 to 12 months or as indicated on the motor. No PM exists. Since the pumps installation in 1990, the pump has seized twice.

b. VM 0075 recommends the annual inspection of the RCIC-TU-TURB governor gear drives. No PM was identified to perform this inspection.

c. There is currently no PM to inspect REC-RV-18RV on an annual or any periodic basis as recommended by VM 1635.

Nebraska Public Power District Cooper Nuclear Station 46 Engineering Self Assessment

t l d. PMs and their frequency as recommended by VM 1635 are not being implemented for TEC-P-BP. PM 07595 exists for this pump to change the oil only,

e. The calibration of the Ratio 2000 Turbidimeter is recommended every six months. No PM exists for this instrument.

l Example 2: Inattention to the PM program may be resulting in the performance of excessive PMs. A major overhaul of each CW pump is required every four years. The System Engineer indicates that if sufficient emphasis and p resources were placed on the PM program, the engineer could improve the l performance monitoring of the pump. These improvements may result in the reduced PM overhaul frequency from every 5 years to 10 years.

j Example 3: The PM reduction project initiated during the outage consisted of a ,

contractor reviewing PMs to delete them from the outage scope. The  !

System Engineer did not have input into the scope of the review nor did the l System Engineer have adequate time to review the results. Many System l Engineers did not approve the changes recommended as a result of a lack of

!' PM basis. 'The current PM optimization project also has little or no System l Engineering involvement.

l l Additional Supporting Information:

Example 4: Involvement in the Preventive Maintenance (PM) program was discussed l- with the System Engineers with the following observations:

I

a. - The engineer has no direct involvement in the PM program. . The PM procedure does not require System Engineering review of new or revised

! PMs.

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l- b. The initiator of a PM change sometimes requests the System Engineer to  !

! review the change, however, this is not true all the time.

c. There is no program or management encouragement to prompt the engineer

'to review the PMs in his system or to evaluate and change its frequency.

d. The PM reduction program implemented during the outage resulted in a total of 10 PMs being deleted from one system. This was at a cost of 60 man-hours of review time. The engineer estimates the elimination of these PMs saved 10 l

man-hours during the outage.

} Nebraska Public Power District Cooper Nuclear Station 47 Engineering Self Assessment -

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e. The engineer has no direct involvement in the PM optimization program currently in progress. Predicted by the engineer high benefits would be gained from the PM optimization program.

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f. One engineer indicated the PM program should be a big part of the System l

Engineers duties but it is not at this time,

g. Many of the PMs do not have an easily accessible basis and a lot of time is required to determine that basis.

l 8.4.5 Performance Monitoring. System Engineers indicate they do not routinely trend - 1 important system parameters nor is there a management commitment to perform I this trending.  !

Example 1: Three System Engineers were questioned concerning their knowledge and action related to components on the IST increased test frequency list. There )

is currently no emphasis or priority in removing equipment from this list.

In addition, management is not emphasizing the importance of the resolution ,

of components being placed on the IST increased test frequency list.  ;

Subsequently there are currently 10 components on the list. l Example 2: Based on interviews with several System Engineers, the following observations are provided- l I

a. One System Engineer does use the Performance monitoring program, j however, the engineer performs this work on his own without the guidance i i

of a program document or management involvement. The program has no owner that he is aware.

b. One System Engineer is knowledgeable that the maintenance department monitors component vibration, he has never seen the resulting data.

c. The engineers could recall only one time when a CR was written to resolve a concern identified by the Performance Monitoring program,

d. Various engineers indicate they rarely use the current program,

e. Updates, deletions, and knowledge of the basis for the trends in the program are minimal for nonexistent.

1 Nebraska Public Power District l Cooper Nuclear Station l 48 Engineering Self Assessment

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f. There is minimal management involvement in the performance monitoring 5

program.

g. An overall health indicator of the system is not available. The health is y determined by the engineer thorough engineer's perception.

Example 3: Lubrication and thermography results data continues to be provided and is not

- being trended by the responsible engineer.

i j 8.4.6 Training Oualifications: System Engineers do not receive adequately training for i their position.

[ Example 1: The DCD was provided to the System Engineer with no training or guidance i

concerning its use. The System Engineer was unaware of the method of using the DCD.

Example 2: Only one of the Reactor Engineers is currently qualified to perform reactor engineering duties independently. The staff has been augmented by one contractor who is currently not qualified as a reactor engineer or System Engineer.

Example 3: Many engineers do not understand the interrelationship between systems, even though they are knowledgeable of their systems.

l Example 4: The engineers have received no training on the PRA process or the maintenance rule. The engineers lack training on the processes of engineering. This includes areas such as processes, expectations for communication and reporting, priority of responsibility, interface with other groups, and use of databases. 1 Additional Supporting Information:

Example 5: New systems engineers are assigned systems before they are trained and familiar with the CNS processes. Many times the operators must dedicate an operator to assist and train the System Engineer in what is required to resolve plant technical issues. For instance, the operator may need to provide an overview of the operability assessment procedure. .

Example 6: One engineer has been at Cooper for 17 months without the benefit of any industry training programs.

l Nebraska Public Power District Cooper Nuclear Station 49 Engineering Self Assessment

8.4.7 System Maintenance / Modification Priorities: System maintenance / modification priorities are not being effectively established by System Engineering.

Example 1: Lack of System Engineering involvement in the review and approval of OSCRs resulted in the deletion of work from the outage scope without System Engineer reviews. Several examples follow:

a. An OSCR was initiated to remove PMs from the outage scope to replace the packing in RMV-AOV-10AV thru 13AV The initiator requested input from the System Engineer as to the acceptability of these changes. The System Engineer opposed the deletion indicating that the valve manufacturer would not agree with an increased PM frequency to above 18 months. The System Engineer followed the conversation up with a memo to document the position. The OSCR was later approved to delete the work from the outage -

scope without the System Engineers knowledge. A copy of the memo was later attached to the approved OSCR. The Engineer was not aware of this work had been deleted from the outage scope until after the plant start-up -

and cannot be performed during power operation.

b. MWR 95-2237 replaces EE-REL-ASDR in accordance with PM 05738. This PM replaces this EQ component on a RE6 replacement frequency. This MWR was deleted from the outage without proper justification or documented system or EQ engineering knowledge. (OSCR 95-0150)

c. RF-CV-16CV was also deleted from the outage scope without System Engineer knowledge or approval. The engineer was aware that the ability of this valve to pass LLRT testing during the next refueling outage (RE-17) with the age of the existing soft seat was poor. The engineer was not aware of the valve work had been deleted from the outage scope until later in the outage. An OSCR was initiated, approved, and the work added back to the outage scope at that time.

d. Approximately 10 MWRs were added back into the outage scope after the System Engineer discovered they were missing from the Revision 0 schedule. (OSCR 95-0217)

e. A Minor Modification (MM) to replace the unloader valves on the TGF skid was deleted from the outage without System Engineers documented concurrence. The MM was later OSCR'd back into the outage scope.

(OSCR 95-0089)

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Example 2: The Operation Manager indicated the prioritization of MWRs and PMs by the System Engineer is currently not being performed and does not meet the Operation Manager's expectations. This was confirmed through various observations.

Example 3: EWRs are not being reviewed for the CRD systems in the RE group to meet the January 31 due date as a result of the heavily assigned workload. '

8.4.8 Workload

IIeavy backlog, inefficient processes, and undefined role of the System Engineer prevents them from performing duties typically expected of ,

CNS System Engineering.

I Example 1: System Engineers indicate that the current primary work function of System i Engineering is the resolution of NAIT items and the support of MWR package planning. There are currently 293 open NAIT items assigned to the Plant Engineering Department. Based on interviews of System Engineers and the maintenance planning organization, SE review of MWRs is low value added work.

l Example 2: Ineffective tools as indicated in Section 8.4.9 below is resulting in the  !

inefficient use of System Engineering resources.

Example 3: The Plant Manager indicated the Operations and Maintenance department currently have a high reliance on the Engineering department. Examples given include the engineer's review of MWRs packages and Surveillance procedures. In addition, several examples of work in the field were provided that should have been resolved by maintenance alone. Instead an engineer was requested to support the trouble shooting effort.

Example 4: The following items where identified as items that hinder the engineer from performing his System Engineering duties:

a. Excessive micro-managing which result in frequent priority changes. These priority changes are resulting in System Engineer interruptions and inefficiencies,

b. Resolving an excessive number of NAITs with many NAITs having little value added.

c. Researching information for other departments.

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d. One engineer gets approximately 50 questions a week, many of them from maintenance planners.

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e. Trivial CR4R items are assigned to the engineer that could more appropriately be performed by a process such as: 1

. Drawing change requests. '

Requesting CICs for existing unmarked equipment.

Request for tags for CICs. Why are the engineers involved?

CRs that identify that a procedure is incorrect and a PCN is required.

f. Excessive meetings are draining the System Engineer resource.

Additional Supporting Information:

Example 5: Several other inefficient processes that require no value added work as indicated below:

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a. The RCE process (replacement part equivalency evaluation) requires the

, component to be obsolete before the process can be use. The process also

requires the Managers approval. The procedure requires a review by a total of five engineers, supervisors, and managers. This appears excessive.

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b. A generic equivalency evaluation or RCE process does not exist for the same replacement of components. An example is the replacement of small bore Crane valves with Vogt valve which is a common occurrence and an new RCE is required in each case.

c. System Engineers are required to review and sign all Surveillance procedures despite a change to the Surveillance program procedure to a reduce System Engineer involvement in the surveillance program.

Example 6: Three processes have been identified that relate to outage work that resulted in the inefficient use of the System Engineer's time:

a. The SRB process resulted in SE inefficiencies. There was no formal guidance during SRB presentation. Very few notes were taken to document the discussion. As a result, many SRB approved items were not placed on the outage schedule. This required the System Engineer to review the SRB approved items from his notes and compare this with the schedule. Missing work was OSCR'd back into the outage schedule.

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b. The method to add or delete work from the outage schedule was also a concern. There was no System Engineer review and no feedback to the '

originator if an OSCR'was approved or disapproved. The engineer was also i concerned that work may have been deleted from the outage schedule without his awareness. This occurred in several situations. As above. ,

c. The SOAC process consist of a committee to verify system readiness for i operability. The committee is chaired by an operations representative and  !

consist of representatives from Design Engineering, Technical Staff, Maintenance, Plant Engineering (System Engineer), Work Control Center - I Test File (reference OP 2.0.11). In the System Engineers case, the engineer l performed a large majority of the functions without much support from the '

committee.

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Example 7: Inappropriate assignment of CRs to the System Engineering group results in inefficient use of System Engineering resources. The following examples l were provided:

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) a. A CR was assigned to engineering to evaluate and resolve a condition of a sign being removed from the transformer yard. The engineer will request a new sign to be made and posted. Evaluating why the sign was missing will

be the difficult task.

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b. A CR was written to generate a memo to the NRC when the SW radiation monitor was INOP for greater than 30 days. A question from CRG was directed to the System Engineer if the windmilling of the pump was related to the rad monitor being INOP. Instead of calling the engineer, the CR was assigned to him instead of Licensing. The engineer is now responsible to 1 ensure a letter is written by Licensing and submitted to the NRC. The i engineer can also return the CR to CRG and justify why it should be assigned to another department. However, this function is also a time l consuming task. i

8.4.9 Tools

The tools used by System Engineers needs improvement.

Example 1: The effectiveness of the engineering group is greatiy limited as a result of the unavailability of, or knowledge of, information such as the following:  ;

a. In general, plant information retrieval uses excessive System Engineering resources. For example, One System Engineer could not find a SIL file and what the response has been to these vendor documents.

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b. Terminal block and cable ~ database are available but their existence is unknown.

c. The USAR or Technical Specification is not available in the engineering offices or library. At the present time the USAR is available on the computer, however, it is awkward to use and locate information. The computer version does not contain illustrations. The Technical Specifications are currently not available on the computer.

d. System Engineers knowledge on the use of PMIS and RONAN is limited.

e. EPRI books in the library are available but there is no reference index.

f. IEEE documents should be available in the library but are not.

g. The INTERNET and EPRI-NET are available but not utilized effeedvely.

Example 2: The System Engineer does not have a copy of the DCD for his system. He is aware they exist in the control room but he does not have a controlled copy at his office. The engineer has received no training on the use of the DCD at CNS. The System Engineer was also concerned with the lack of

information in the DCDs.

j- Example 3: The System Engineers do not maintain a system notebook nor is it required.

C This resulted in some major inefficiency in the review of past problems with the system and in turning over the system to a new engineer. The later was experienced last year on several system turnovers. ,

Additional Supporting Information:

Example 4: Reactor engineering is struggling due to the lack of tools such as 3-D monicore.

Example 5: A health indicator for each system is not available.

8.4.10 System Engineerine Walkdowns: The consistency and content of System Engineering walkdowns performed by the System Engineer needs improvement.

Example 1: Although System Engineers are performing system walkdowns, the content and frequency of these walkdowns is inconsistent between engineers.

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l Example 2: EDI 91-03 provides guidance on an annual walkdown but does not provide guidance for frequent walkdowns and its content. Engineering management has provided no other expectation concerning system walkdowns to the System Engineers.

8.4.11 Reactor Eneineering: The workload assigned to the reactor engineering group exceeds the available resources for both short term and long term operation. As a result, both the reactor engineering and System Engineering duties of the group are not being effectively performed. This problem exists because the 1995 engineering reorganization did not adequately address the resources versus workload issue.

Example 1: A recent survey of reactor engineering staff for BWR plants of the same size and type as CNS indicates the Reactor Engineering group size versus duties at CNS are disproportionate. Monticello, which is normally considered a lean and well operated plant have similar responsibilities including similar system assignments as Cooper, but are staffed with 8 engineers. Another plant with similar responsibilities is Peach Bottom. This plant has 2 units and 13 reactor

, engineers. The CNS Reactor Engineering Group has only 4 engineers.

Example 2: The Reactor Engineering group must be certiF:d as both System Engineer and Reactor Engineer. The reactor engineering group has 4 approved positions plus 1 Supervisor. One position is vacant at the time and has been vacant for over five months. The three remaining reactor engineers including the Supervisor require training. Only one of the reactor engineers is currently qualified to perform reactor engineering duties independently. Again, a lack of resources has minimized the ability of the group to obtain adequate training. The staff has been augmented by one contractor who is currently not ,

qualified as a reactor engineer or System Engineer. ,

i Example 3: Additional duties have already been added to the Reactor Engineer (RE) group. These duties include the responsibility for.

a. Core reload design change (normally performed by the fuels group). l

b. OPL and Reload licensing items (normally performed by the licensing group).

c. FME of the fuel pool.

d. Technical Specification upgrade reviews (phase 3)(1 man-year).

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e. 3-D monicore installation and training. (8 man-months).  ;

Item d and e will require 30 percent or more of the total reactor engineering i groups resources. In addition, once 3-D momcore is mstalled, additional time t is required to make use ofit. .

i Example 4: Reactor Engineers indicate that the implementation ofinnovative thinking in  ;

the reactor engineering group is being minimized as a result of the excessive i workload. The examples below contributed to the plant slow startup _  ;

follcwing the RF016 outage. l

a. I Continuous rod pulls as performed by other plants instead of group notch.

Group notching also effectively bypasses the RBM system. ,

b. ARTS /ELLLA was purchased to allow operation above the 108 percent rod line. However procedures continue to limit operations to less than 108 i percent. Resources to justify the change are currently inadequate. l l

Example 5: EWRs are not being reviewed for some systems in the' Reactor Engineer group l to meet the January 31 due date as a result of the heavily assigned workload.  !

Some Reactor Engineer duties such as the review of core data on a daily basis t as expected by the Reactor Engineer Supervisor are not being adequately l performed as a result of System Engineer duties.

Additional Supporting Information: l 1

Example 6: In the past year,4 reactor engineers have left the group. This leaves only one  !

CNS experienced and qualified reactor engineer in the group. ,

l Example 7: There is no division of duties and responsibilities of the RE group from the System Engineering organization. 1 Example 8: The group is currently experiencing problems filling the open position in reactor engineering. Approximately 6 prospective reactor engineers have been interviewed for the position in the past 5 months with no offers accepted. - The group was not fully staffed before the reorganization nor since.

Example 9: Full power operation was not achieved as rapidly as expected during the startup from the RE16. This was due in part by the core not being designed from an operational standpoint. The core was designed to minimize MCPR and not to equalize all thermal limits. The reactor engineering group was not I

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aware of this approach to fuel core design nor had any input into the design process. ,

l Example 10: Integration of the Reactor Engineering group with Operations personnel may be restricted. The current procedure 2.0.3 " Control Room Access, Conduct, and Staffing Requirements" restricts the reactor engineer from access to the >

control room as a result of their status as a part of the engineering organization. This restricts the reactor engineers ability to evaluate core parameters on a routine basis and tc " integrate" with the operators.  ;

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8.4.12 TL: An owner for the OPL orocess is needed. Lack of clear ownership of the process is creating a situation were proper verification and identification of l changes to the OPL may be omitted from the Reload Licensing process. I Example 1: The Feedwater Controller Failure - Maximum Demand, Event #32, is described in the USAR, Chapter XIV Section 5.1.6, page XIV-5-7 and Figure XIV-5-3a and 3b. It is also described in the Supplemental Reload l Licensing Report for Cooper Reload 16 Cycle 17. This Abnormal )

Operational Transient results in a scram and the need for RPV pressure j relief. This pressure relief is provided immediately by main steam bypass l valves (BPV). l The model used by GE in the Reload Licensing Report requires the BPVs to open to 80% of capacity within a specified time frame after initiation of the turbine trip. This time was reported to GE in OPL-3 as 0.3 seconds.

The BPVs have been modified several times since plant start-up. It is not apparent that CNS has verified the response of these valves to be less than 0.3 seconds following the modification of these valves. A study is currently being performed to determine if these changes effected the response time of these valves.

Example 2: The OPL data review process does not have a procedure to control OPL limits. The Reactor Engineering Group, Configuration Management, and the Licensing department all have an input into the OPL data review process with no one person or department coordinating the effort.

Example 3: The design process does not ensure a change to OPL parameters will be  !

adequately identified or evaluated. Neither the Design Input Guide or the attachments to EP 3.4.6, Design Input Checklist, direct the Design Engineer l l

to evaluate changes to the OPL design basis. The only exception is if the Nebraska Public Power District Cooper Nuclear Station j 57 Engineering Self Assessment

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j design change requires a set point change.

Additional Supporting Information:

1 Example 4: Thee are currently no process barriers that would initiate action to review a l

change to OPL limits. A typical scenario that would not result in an

{

adequate review of the OPL and Reload Licensing Analysis (RLA) is provided below;

a. Final feedwater temperature is increased by 5 degrees as a result of a design change to the secondary plant equipment.

b. In the mean time, the OPL-3 data is verified twelve months ahead of the outage. To verify final feedwater temperature the engineer will review the table in the USAR and will find it to be the same as it was last cycle.

c. The reload analysis is performed using the old final feedwater temperature.

d. The design change package will revise the table in the USAR to reflect the expected change in final feedwater temperature. This change is not implemented until the outage the modification is being performed and after the OPL-3 has been verified.

e. Unless a knowledgeable design or licensing engineer is involved in the change, the plant operates outside the bounds of the RLA.

8.5 AREAS FOR IMPROVEMENT 8.5.1 System Engineer Review of OSCRs: The OSCR process needs to include a ,

System Engineer review / approval. Without the input from the System Engineer, j some critical work may have been deleted from the 1995 outage without proper  !

justification.

Example 1: During the 1995 refueling outage, removal of Preventative Maintenance work from the outage required the initiation of a OSCR form. This form does not required System Engineering review or approval. During interviews with several System Engineers, two situations have been identified where work was deleted from the outage scope without the System Engineer approval as discussed below:

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a. An OSCR was initiated to remove PMs from the outage scope to replace the packing in RMV-AOV-10AV thru 13AV. The initiator requested input from the System Engineer as to the acceptability of these changes. The System Engineer opposed the deletion indicating that the valve vendor would not agree with an increased PM frequency to above 18 months. The System Engineer followed the conversation up with a memo to document the position. The OSCR was later approved to delete the work from the outage scope without the System Engineers knowledge. A copy of the memo was later attached to the approved OSCR. The Engineer was not aware of this work being deleted from the outage scope until after the plant start-up and cannot be performed during power operation.

b. RF-CV-16CV was also deleted from the outage scope without System Engineer knowledge or approval. The engineer was aware that the ability of this valve to pass LLRT testing during the next refueling outage (RE-17) with the age of the existing soft seat was poor. The engineer was not aware of the' valve work had been deleted from the outage scope until later in the outage. An OSCR was initiated, approved, and the work added back to_the outage scope at that time.

Example 2: As a result of the above interviews, a brief review of 450 OSCRs was performed. The following results are provided below:

a. PM 07613 rebuilds HPCI-TP-SA59. This PM was deleted from the outage as a result of its potential replacement during the RE-017. In addition, HPCI-TP-SA59 was also deleted from the PM as a result of its notential replacement. (OSCR 95-0056)

b. MWR 95-2237 replaces EE-REL-ASDR in accordance with PM 05738. This PM replaces this EQ component on a RE6 replacement frequency. This MWR was deleted from the outage without proper justification or documented system or EQ engineering knowledge. (OSCR 95-0150)

c. MWR 95-1339 was issued to eliminate leakage from the CS-P-A mechanical seal. The MWR was deleted from the outage with the justification that the System Engineer will trend leakage this operating cycle. This MWR was deleted from the outage without documented System Engineer confirmation or that a trend would be performed. (OSCR 95-0216)

d. Many non-essential relays were deleted from the outage scope without documented System Engineering review.

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e. Approximately 10 MWRs were added back into the outage scope after one System Engineer discovered they were missing from the Revision 0 schedule. (OSCR 95-0217)

f. A Minor Modification (MM) to replace the unloader valves on the TGF skid  ;

was deleted from the outage without System Engineers documented concurrence. The MM was later OSCR'd back into the outage scope.  ;

(OSCR 95-0089).

1 9.0 PLANT MODIFICATIONS 5

9.1

SUMMARY

t i There have been several improvements in the area of Plant ModiDeations. Strengths were noted in reducing plant temporary modiDeation backlogs, outage support and overall 3 organizationel structure. Overall, design and configuration control were being performed  ;

adequately, however, much of the process is too informal and requires far too much i engineering time and resources. l I

There is need for substantial improvement in design control and co:ifiguration control. Some { '

l- specific areas for improvement are control of unauthorized modifications, particularly, once l identified, the as-built configuration must be evaluated for design adequacy and a safety l

evaluation performed. No process exists for this evaluation. Stand alone Drawing Change l Notices (DCNe) and Component Evaluation Packages (CEPs) not connected to a modification do not currently require a 50.59 safety evaluation. Inadequate control of Engineering Judgements, lack of a process for updating Design Criteria Documents after program changes, and use of the USAR and Technical Specifications as design inputs were all areas needing improvement. The calculation control program is inadequate and no cross reference exists from calculations to design output documents, such as procedures. Concerns ,

also exist in the configuration control associated with MWRs used to implement modifications.

9.2 SCOPE AND METHODOLOGY The Plant Modifications area assessment pian was developed considering the previous findings of the Diagnostic Self Assessment Team, the NRC Special Evaluation Team, previous INPO Evaluations and other NRC and QA audits. In addition, Inspection Procedure ,

37550 was used to ensure that the scope of the NRC Engineering and Technical Support  ! '

Inspection was covered. Finally, the knowledge of the team members was used to identify areas where suspected weaknesses may exist, based on problems identified in Condition Reports and the recent refuelmg outage entique. j

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I Nebraska Public Power District t Cooper Nuclear Station 60 Engineering Self Assessuent l

The methodology of this horizontal area assessment was to review Engineering products, interview engineers and customers and observe in-process work, to evaluate the effectiveness of processes, supervision and management, human performance, the organizational structure, and technical skills and abilities.

9.3 STRENGTIIS 9.3.1 Organizational structure. It appears that the organizational structure and staffing levels are appropriate.

Example 1: One of the outside consultants, with significant utility management experience, observed that the existing organizational structure of the CNS Engineering Division is one of the best he had ever seen.

Example 2: In interviews with managers and supervisors, staffing levels were generally seen as adequate, provided some level of outsourcing is permitted until the backlogs are reduced.

Example 3: Interviews with customers indicated that Engineering was more successful in supporting plant needs during the recent refueling outage than in any previous outage.

9.3.2 Backloe Reduction: Design Engineering Management has taken some aggressive steps to reduce specific backlogs and improve customer support in specific areas.

Example 1: The Simulator Support Supervisor was complimentary of the way that design modifications interface with simulator hardware changes. MM95-184 was an example of a fast turn-around emergent modification where the simulator staff was kept well informed and the hardware was changed expeditiously to match the plant.

Example 2: Design Engineering has an aggressive plan in place to convert all plant temporary modifications (PTMs) to permanent modifications, with a goal of l completion of February 29,1996. Significant progress has been made toward l achieving these goals.

9.4 FINDING.S I i

1 9.4.1 Design /Conficuration Control: Design and configuration control performace is i in need of significant improvement. l l

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l Example 1: It was discovered that USAR Chapter VI still references the 1977 LOCA Analysis. This has been updated at least twice, including under Design Change 94-332.

Example 2: The vendor manual change process has been changed such that only the Procurement Engineers review vendor manual changes for effects on other documents and changes required in the plant. This may not be an appropriate level of review to ensure configuration control.  !

Example 3: The component identification code (CIC) used in the EDF is not consistent with the CICs used in procedures and drawings.

Example 4: Thirteen unauthorized modifications were observed as identified on Condition J Reports presented to the CRG between January 9 and February 14,1996, )

during the assessment. There is no process for evaluating these unauthorized-modifications to determine the acceptability of the design, conducting a 50.59 safety evaluation or ensuring that configuration control is maintained by updating documents other than the drawing (e.g., PMs and EDF).

Example 5: No process exists to ensure Design Criteria Documents are updated following the revision of a program, such as the ISI/IST Program or Appendix J Program.

Example 6: Two examples ofincomplete or inadequate post-modification testing were identified, involving SW-MOV-89A/B and Diesel Generator Starting Air.

Example 7: No process exists to control outstanding Engineering Judgements (EJs) that are posted against a calculation, such that everyone is aware of how many are effective and what the combined effects are. Also, there is no requirement to -

maintain EJs as quality records.

Example 8: There are approximately 24,000 calculations on record, with no means of determining which is the latest revision, which are superseded, and which have been modified. Also, there is no cross-reference that ties calculations to output documents (e.g., procedures).

i Example 9: Calculation NEDC 91-083D references MP 7.0.11 as a source document. MP j 7.0.11 does not reference the calculation.  !

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i Example 10: Calculation NEDC 94-261, approved on 6/6/95 to validate the results of i Surveillance Procedure 6.3.1.2. This surveillance was superseded on 5/30/95 by 6PC503.

Example 11: Procedure requirements in submittal of status report information is unclear. It I has been interpreted such that only essential and EQ PM, EDF, etc. updates need to be submitted. This could cause significant delays in important nonessential updates.  !

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Example 12: DC 93-050-1 drilled holes in the downstream disc of several valves. This i information was not captured in the DCDs or on any drawing or specification.

No guidance is provided as to when this kind ofinformation should be added.

Also, changes to DCDs affecting the design basis of the plant is accomplished by procedures that are not SORC approved.

Example 13: An example from TDC-94-086 was identified where de EDF was not updated to reflect the long term temporary modification.

Example 14: During implementation of DC 93-050-1, machining of RCIC-MOV-MO21 bonnet was determined to be necessary. The vendor was contacted and a record of conversation was written agreeing to the modification. This was accomplished by a revision to the MWR, without any safety evaluation. No controls are in place to capture the fact that 0.015" was milled off of the bonnet on this valve and nothing would prevent further machining of this 4 bonnet in the future, even though the vendor only authorized machining I 0.020".

Example 15: Operations personnel were required to continually pursue interim drawings from Engineering in order to keep Control Room drawings up to current configuration.

Example 16: The Design Engineering Department could not produce two recent relief valve setpoint calculations requested by the assessment team. Also,it was identified j that instrument and relief valve setpoint calculations are not identified as quality records in Procedure 1.9.

l Example 17: Identification of piping specifications require considerable research and tribal knowledge. There has not been a controlled updated specification maintaining i current the configuration of the piping as it has been modified over the years.

Current methods require starting with the original contract (E69-4) and l researching modifications to find current design.

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i Example 18: It took excessive time and paperwork to determine if the addition of a hose bib ,

on a fire protection drain in the Learning Centerjanitor's closet required a

modification. Procedures do not clearly define the extent of design controls '

l and the boundaries of modifications.

9.4.2 Calculation Control: The Calculation Control Process is in need of significant improvement.

Example 1: The DSAT identified that there are 24,000 calculations on record with no way l to determine which ones are the latest revision, which have been superseded, l l

and which have been modified. No actions have been taken to correct this j problem. j Example 2: The 125 and 250 VDC load calculations had 13 engineeringjudgements l

pending against them. There was no controlled method to determine this.

During RE-16, when the load profile for the battery discharge test was developed, the engineer had no way to know about these EJs and used the latest approved version he could find on film, which did not take into account the changes made by EJS. (A condition report was written, and the load profile used was bounding, even after considering the EJs).

Example 3: No method exists to cross-reference calculations that provide the design basis l for the final design to the appropriate design output documents (e.g.,

procedures, USAR, etc.) or to other calculations that may use the calculation as input.

9.4.3 Modification Process: The Design Change Process is known to be cumbersome and ineffective in some areas, leading to work-arounds, failure to correct plant problems and inefficient use of resources, but other work has been prioritized above correcting these deficiencies.

Example 1: The design change process contains no provision for follow-up to assess the effectiveness of the modification in resolving the original plant problem. This has led to at least one instance where maintenance man-hours are wasted with continuous repairs of recently installed equipment. The example is the NBI-F-11, continuous reference injection filters.

Example 2: IIaving the installation section included in the modification package has caused numerous serious delays in the field during implementation, as well as the use of extensive engineering man-hours, when Maintenance and Construction Management can perfbrm these functions more efficiently.

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Example 3: The poorly defined threshold for a modification continually requires the use of a modification for maintenance or " equivalency" replacements.

Example 4: The testing section is the responsibility of the design engineer, when it is well known that this function should be a separate function. Two examples of inadequate post-modification testing were identified: SW-MOV-MO89A/B and DG Starting Air.

9.4.4 Work Prioritization: Inappropriate prioritization of workload has led to backlogs that are difficult to close out and problems implementing configuration control.

Example 1: Experience with the Backlog Reduction Transition Team project demonstrated the inefficiencies associated with not closing out modifications quickly after installation. To date only 8 DCs/ mms Completion Reports out of 51 from the RE16 outage modifications have been completed. 35 of the 51 MWRs issued for station modification for assembling closure packages or in Engineering for final MWR signatures are still in WIT. Almost all 35 were completed over 2 months ago, including acceptance testing with many over 3 months ago.

There is no time frame given to ensure timely closure of the MWRs.

Example 2: The original schedule for review of the EWR/EPRs to define the scope for RE-17 was to complete the reviews by 1/31/95. As of February 23,1995, the reviews are not complete. This activity affects the schedule for preparations for RE-17. No way to tell what more important work was placed ahead of this project.

Example 3: There has been considerable emphasis placed on working on Engineering backlogs, such as NAIT items. However, some very important plant support i backlogs have not been pursued, such as Red Arrows and DCNs (including Control Room Drawings). Also, no effort has been placed on reducing or controlling the amount of work input to Engineering.

Example 4: Turnover files from NED are still being stored in various locations and most have not been assigned to, nor reviewed by, the current staff for outstanding issues even though the reorganization of Engineering occurred about nine months ago.

Example 5: There is evidence that the various improvement initiatives that were identified in past assessments by the DSAT, NRC and INPO are not being prioritized, tracked and, in some cases, are not identified as open items. Action plans with identified owners are not available in most cases and progress on many issues Nebraska Public Power District Cooper Nuclear Station 65 Engineering Self Assessment

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is not occurring. An integrated plan with an estimate of needed resources to l

address these engineering initiatives is not available.  !

t 9.4.5 - Lack of Clear and Effective Exnectations. There has been a lack of clear and i effective expectations for ownership of plant issues and problems concerning l design and configuration control. j Example 1i The root cause investigation for CR 95-1241 identified the root cause for the I deficiencies during the DG-1 modification during RE-16 as " lack of clear i ownership / project management". There were no effective corrective actions l taken in this CR. The same concerns were observed to occur during the I assessment conceming the DG muffler bypass issue.

Example 2: . CR 95-1239 identified the root cause as a lack of management process and l

" lack of management expectations" regarding the continuing problems with-  !

plant configuration control. No effective corrective action was taken under this CR to address this root cause.

Example 3: The use of a Record of Conversation is standard practice used by design i engineering to support modifications. No formal vendor concurrence is obtained consistently. Also, no process exists to capture on a drawing or specification the changes made to the configuration.

Example 4: Several of the existing plant temporary modifications are greater than 6 l months cid, which is in violation of the procedure. (Note that aggressive

! action is being taken to resolve this).-

9.4.6 ' Unauthorized Modifications: Numerous Una'uthorized Modifications identified in a review of CRG Meeting Minutes from January 9,1996 to February 14,1996.

No process exists to ensure that these unauthorized modifications are evaluated l

for acceptability of the design as-is, that design inputs are not invalidated (seismic Appendix J, fire protection, EQ, etc.), and that control of configuration is maintained, such as PM and EDF updates.

Example 1: CR 96-0017 identified a one Watt resistor was replaced with a two Watt i resistor on the RRMG set voltage regulators.

1 Example 2: CR 96-0020 identified that the as-built configuration of the plant differs from j the drawing in that the Feedwater steam side drain line has two valves instead ofone.

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[ Nebraska Public Power District t Cooper Nuclear Station 66 Engineering Self Assessment l

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Example 3: CR 96-0036 identifies that SWBPs have petcocks instead of caps and plugs as j shown on the drawings.  :

Example 4: CR 95-0097 indicates Air Compressor C has wrong size heater installed.

There were a total of 13 unauthorized modifications identified in the CRG minutes from 1/9 to 2/14,1996. i 9.4.7 Lack ofIntegration of Design Basis Information. Several observations were  ;

made that indicate a lack ofintegration of design basis information exists to ensure plant configuration changes are adequately reflected in CNS documents.

j Example 1: The design analysis and safety evaluation for DC 93-24 did not adequately f reference the specific design basis requirement of the Diesel Generator DCD .j section 5.0, step 5.5.3.1, which requires the check valves to support the air a receivers in storing sufficient air volume to independently start the engine at  !

least five times with a minimum of ten seconds per start. The Augmented ISI I program is also not referenced in the design analysis or safety evaluation  !

which would have ensured consideration of program requirements. i Example 2: The design change process does not ensure a change to OPL parameters e.re j adequately identified and evaluated. The Design Input Guide and the i attachments to EP 3.4.6, Design Input Checklist also do not direct the Design j Engineer to evaluate changes to the OPL design basis. The only exception to this was noted to be if the design change requires a set point change.

Example 3: The transfer of DC emergency load profile information for use in surveillance {

testing was performed by memo between the Design Engineer and the System J Engineer with no independent verification. No formal method exists or is l being used to transfer " quality" information as required by ANSI N45.2.11.

Example 4: In a review of minor modification package 95-073, "SW-MOV-MO89A,B Throttling Trim Modification", it was noted that the only calculations referenced for the modification were NEDC 91-255, rev. 4 and NEDC 91-250A, rev. 4. In the modification package, the statement was made that the design Engineer should verify that these two calculations were modified to reflect the new valve trim. In the modification package, there is not a reference to the system flow calculation. The system flow cale should be referenced to verify the new valve trim does not significantly change the flow characteristics of the system. In the information presented for this modification, there is no indication of a review of the effects of the new valve trim on the overall system flow characteristics. In addition, the modification i Nebraska Public Power District 1 Cooper Nuclear Station  !

67 Engineering Self Assessment l i

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package indicates the design requirements for the system include the ability of the valve to pass 8,000 gpm of flow if two service water booster pumps are operating. There is no reference to indicate where this design information is contained.

Example 5: USAR Chapter VI still references NEDO 24045 CNS LOCA Analysis dated August 1977. DC 94-332 revised the LOCA Analysis in October,1994, but did not update the licensing basis contained in USAR Chapter VI. There was at least one other update of the LOCA Analysis in 1992 related to the 125 VDC failure.

9.4.8 Onerability Assessments. Inadequate Operability Assessments and Safety Evaluations instances were observed where documentation provided to justify Operability Assessments and Safety Evaluations were inadequate or too generic to be of value.

Example 1: An Operability Assessment provided to the Shift Supervisor in response to CR S/N 1-06559 lacked documented evidence to support Engineeringjudgements stated in the OA. The same OA was previously provided in response to CR S/N 1-15732. Procedure 0.5 requires documented evidence to support engineeringjudgements made in OAs.

Example 2: During the review of an operability assessment for CR 96-0040, it was noted that the basis for operability contained an engineering judgement without reference to supporting documentation. In addition, no supervisory reviews were obtained even though the System Engineer was new to CNS and the llPCI system.

Example 3: Calculations NEDC 95-143 and NEDC 95-160 were performed by a contractor and reviewed by DED. The assumptions were reasonable and the analytical methods appropriate.110 wever, the design inputs used the USAR and TS, which are licensing documents, and not technical input documents.

Inputs for this cale should have come from DCDs or component design specifications.

I Example 4: Safety Evaluations reviewed by the Vertical Slice Team found that while as a whole the safety evaluations were adequate, some safety evaluations provided generic responses to questions. The wording of the responses to the questions could be clearer in showing that the result of the proposed changes would have no effect on the radiological consequences of an accident. The Safety Evaluation and 50.59 procedure (EP 3.3) also limits the review oflicensing Nebraska Public Power District Cooper Nuclear Station  !

68 Engineering Self Assessment

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documents to the USAR and TS. These documents are only part of the licensing basis, NRC SERs should also be included. The Safety Evaluation for DC 93-050 was an excellent example of how to perform a good safety evaluation.

9.4.9 Document Accessibility. The inability of Engineering to easily access and use required documents hampers their ability to efficiently and accurately perform their work.

Example 1: Engineering Dept. Instructions, Desktop Guides, CNS/NPG/NPPD Directives, USAR and Tech Specs are not readily available to the Engineers in performing their daily work. Only one controlled copy of USAR and Tech Specs exists in the trailer complex for ESD and DED departments and neither is available or easily searchable when available on ZY-Search.

Example 2: The DSAT and SET Reports identified that there are 24,000 calculations on record with no way of determining which ones are current, superseded or modified. No action has been taken to address this issue and it is not a part of the Phase 3 plan.

Example 3: During informal discussions with various engineering personnel, it was noted that the identification of piping specifications for plant systems require considerable research and tribal knowledge to obtain. Current methods require starting with the original contracts and then researching the various design changes implemented or discussing with plant personnel to more quickly find the proper piping specification.

Example 4: The electrical design group procured a copy of EDSA (a software program to perform electrical load studies and circuit analyses)in March of 1995. The program disks have never been installed, and CNS has already received an update on the disks. Because this program is not in use, major electrical calculations are only updated once per operating cycle using engineering judgements to evaluate minor electrical load additions and later reconcile these with the analysis. The last reconciliation of engineering judgements took approximately six man-months.

9.4.10 Inadeauate Knowledge /Fraining. Observations were made during the Self Assessment where inadequate knowledge or training has contributed to Engineering ineffectiveness.

Nebraska Public Power District Cooper Nuclear Station 69 Engineering Self Assessment

Example 1: DSAT Section 2.3.1 (4) identified a lack. of design basis knowledge with many Engineers. This same observation has been made in interviews with 10 different Engineers in all three departments. Insufficient action has been taken to resolve this issue.

Example 2: The provided a MS-mail document providing guidance for System Engineers on how to perform a consistent quality review of EPRs/EWRs for RE17. No training was provided on this guidance nor does the MS-mail guidance provide effective instructions on estimating total costs associated with generating a modification.

Example 3: Activities for training Engineering personnel focused on the use and ,

maintenance of the design criteria documents rather than providing training on  :

the information that constitutes the plant design basis. For example, the activities do not include actions to evaluate the adequacy of the calculation  ;

index, the availability of system design specifications, and the relationship of the design information to the licensing basis. The lack of training and understanding of design basis information was identified as a finding in the DSAT.

Example 4: In an interview with a System Engineer it was noted that the Engineer is TPD 502 and 509 certified but not specific system certified. Operability  ;

assessments and 50.59 screens and analysis are performed on a regular basis 1 even though the Engineer is not certified to this specific system. The engineer has also received no training on the use of the DCD at CNS.

9.4.11 Ineffective /Inanpropriate Communications. Several observations were made that indicate ineffective or inappropriate communications exist both within Engineering and between Engineering and Engineering customers.

Example 1: Procedure 2.0.2, Operations Logs and Reports, requires that short term and temporary information for the shifts be communicated in the Night Order Log.

From interviews it appears that Engineering sends memos and notes directly to the operating shifts rather than using the established Night Order Log process.

Example 2: Neither the Maintenance Engineer responsible for the 7.2.35, Relief Valve Set Point Test, or the Relief Valve Engineer responsible for EP 3.17, Safety &

Relief set point control, knew that the code for valve testing was being changed on March 1,1996 from PTC 25.3-1976 to OM Part 1,1987. Neither Engineer was involved in reviewing the proposed changes to procedure 7.2.35.

Nebraska Public Power District Cooper Nuclear Station 70 Engineering Scif Assessment

Example 3: From interviews with plant personnel the general consensus is that NRC Region management is confident and comfortable with the site team's improvement plan and progress regarding Engineering. From an interview with the senior resident, satisfaction with the progress in improvement of the site's Engineering support was marginal at best. It was believed that CNS does not have a concept of how to efTectively communicate with the resident inspectors. The NRC in many instances needs to prompt integrated investigations and complete evaluations ofissues. Residents must seek out -

positive initiatives for inclusion in their inspection reports. There is not a routine meeting to disceu Engineering issues with the residents.

Example 4: The design change process improvement team activities have not been well communicated throughout the Engineering organization. The understanding of a number of Engineering supervisors was that the design change process improvement activities would review the overall design change processes in use at CNS, with an emphasis on streamlining the related processes. From discussions with members of the design change process improvement team, it is evident that the scope of the activity is limited to removing the installation and testing requirements from the design change packages.

9.5 AREAS FOR IMPROVEMENT 9.5.1 Design Basis / Configuration Control. Interviews with station personnel and review of records indicated that roles and responsibilities are not clearly defined for Engineering to ensure design basis and configuration processes are properly controlled.

Er.:npic 1: Through a review of the OPL data process and interviews with Reactor Engineering it was noted that no clear owner exists to ensure a change to OPL parameters will be adequately identified or evaluated.

Example 2: There is no owner for the 10CFR50.46/ Appendix K/ECCS/LOCA Analysis.

There is loose ownership of some input documents (OPL-3,4,5) but no single owner of this important regulatory required analysis.

Example 3: DSAT 2.3.l(3) identifies inadequate control and interface with GE regarding the fuel reload analysis and control of the design information necessary to support the accident and transient analysis. Several observations indicate that no action has been taken to address this issue.

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9.5.2 Modification Process. Interviews with station personnel and reviews of station modifications indicated that the roles and responsibilities are not clearly i established regarding the modification process.

l Example 1: Operations noted that during the conceptual design phase a design package, Operations is not included until the conceptual design is ready for approval.

The process could be more effective if other plant members are included from the start.

Example 2: Engineers are required to perform a preliminary review to determine if the modification effects EOPs and EOP calculations. Operations personnel currently perform the calculations because no training is provided to . l Engineering on EOP calculations.

Example 3: From a review of minor modification MM 95-073, the writing of the installation and testing information by the design engineer may contribute to )

problems during the installation process.

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Example 4: The current process of turnover of plant modifications tot Operations does not l recognize the various specific needs of Operations and provide for specific  !

sign off acceptance. These sign offs need to indicate acceptance of the system i modification of Operations with the listed exceptions on an attached punch list.

9.5.3 Lack of Ownership regarding issues which effect plant design.

Example 1: CR.95-1241 deficiencies identified during the DG-1 modification root cause analysis identified a lack of clear ownership / project management for modifications and maintenance as the root cause of the deficiencies. The  ;

current issue with the DG exhaust bypass valve suffered from the same lack of I ownership until the issue became a crisis.

Example 2: From interviews and observation of an NRC exit it is apparent that l

establishing clear single point ownership and responsibility for emerging j issues is a problem at CNS. Roles and responsibilities have not been established and communicated adequately to allow the organization to operate in automatic in this regard.

Example 3: A review of Procedure 7.2.35 and 3.17 on relief valve setpoints and controls indicates no clear ownership of which engineer, maintenance, design, system, or Relief Valve Program, should generate the setpoint test sheet nor where to N*raska Public Power District Cooper Nuclear Station 72 Engineering Self Assessment

find the information. While procedure classification is appropriate, it also indicates roles and responsibilities are not clearly defined. l 9.5.4 Procedure Compliance. A review of modification packages and personnel interviews identified that personnel errors continue to occur regarding procedure compliance.

Exam 3h 1: The SORC Chairman failed to check the box indicating whether a SRAB review was required for modification nor was the error caught by the design engineer during his final review prior to implementation.

Example 2: Sections of DC 95-101 were not marked up reflecting the changes resulting from OSC #3 as required by Procedure 3.4.10.

Example 3: Procedure 3.4.5 requires that a copy of the EPR be attached to the minor modification package, however, no copy was attached. In addition, Attachment 1 of Procedure 3.4.5 was not updated in accordance with the procedure when it was determined that ESPI changes were required.

9.5.5 Procedure Inadequacies and I ack of Detail. A number of examples were identified where a lack of detailed information in procedure contributed to errors, inadequate maintenance of configuration control, or potential work delays.

Example 1: During implementation of DC 93-050-1, machining of the bonnet area was necessary. The vendor authorized .020" to be machined via a Record of Telecon. There are no procedural controls in place to specifically prevent J future machining of this valve bonnet from exceeding the vendor specified limit, nor are there generic controls in place to capture similar events. There is also no procedural guidance for controlling Records of Telecon.

Example 2: Observations were made when reviewing design packages that minimal ,

guidance exists for identifying when not only changes to DCDs is required, i' but also when additions should be made to the DCDs.

Example 3: During a review of relief valve setpoint change packages it was identified that Procedure 1.9 did not identify the setpoint change packages as quality records which are required to be maintained per ANSI.N45.2.9. Procedure 1.9 doesn't list calculations or instrument setpoints to be controlled as quality records either.

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Example 4: During a review of two plant temporary modifications (PTMs) it was identified that Procedure 2.0.7 has no requirement to perform functional tests following installation / removal of the PTMs.

Example 5: An interview identified that a vendor had provided a comparable replacement made of aluminum to replace a brass component. All design specifications and part number were the same and the recommendation was made to store in the same bin. No procedural guidance exists for storage of components with equivalent specifications. Nor does the procedure require updating ESPI when material changes occur. This could prevent unnecessary work delays in the field.

9.5.6 Conflictine Procedure Guidance. Numerous reviews identified the need for clarification of procedures and that outdated or conflicting guidance in procedures was contributing to very inefficient work processes.

Example 1: The status report for DC 93-024 did not include EDF changes for downgrading the air compressors from essential to nonessential due to a misinterpretation of the status report wording by the design engineer.

Example 2: Minor modification Procedure 3.4.5 provides poor guidance on what constitutes the difference between Attachment 3 - Minor Modification Documents List and Attachment 4 - Configuration Documents List.

l Procedures 3.4.5 and 3.4.11 conflict on the guidance required to be submitted i in the status report for minor modifications.

Example 3: Numerous engineering procedures contain outdated information such as pre-reorganization references.

Example 4: Procedure 3.4.7 provides weak guidance for evaluating the cumulative effect i of engineering judgements on calculations.

l Example 5: Procedures 3.17 and 7.2.35 on relief valve control is in need of clarification  ;

regarding responsibilities of effected individuals.

9.5.7 Cumbersome Processes: The complexity of the existing engineering procedures and processes, and the lack of others, have significantly contributed to the cost of modifications and the occurrence of work arounds and unauthorized modifications in the plant.

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Example 1: A review of CRG meeting minutes from January 9 to February 14 identified 13 unauthorized modifications installed in the plant. The contributing factors l were the lack ora broad component equivalency procedure versus the RCE Procedure, and the need for a simplified modification procedure.

Example 2: The temporary design change process was initiated to allow for plant temporary modification installations greater than six months. It added another labor intensive requirement which could be alleviated through other means, e.g., returning PTM's to SORC for periodic review.

9.5.8 Inefficient Processes. A review of the engineering procedures identified a number of requirements with questionable value which contribute to inefficient work practices.

l Example 1: Construction Management has the only Controlled Copy stamp which requires l

significant work delays and wasted effort in processing modifications and field changes (OSCs) through the Planning Department. This appears to be a carry over from the old offsite design organization.

Example 2: Numerous condition reports were generated due to craft missing the duplication of signatures required between the installation and testing sections of modification packages and the maintenance procedures that were called out for use by the Planning Department. The modification procedures were not kept current with changing plant practices, procedures and organization.

Example 3: Several of the modification packages prepared by the A/E's required significant rework up front and several exceeded cost estimates primarily due to the detail required by the writers guide and the modification procedures.

Example 4: A review of several design changes identified there is significant duplication ofinformation in the design change, e.g., between the description, justification and design analysis sections versus the equivalent write up in the safety evaluation and secondly between the references and document change sections of the package.

Example 5: A review of several calculations identified that the poor control of the calculation process has contributed to significant frustration and wasted manpower in identifying and obtaining the most recent calculation package applicable to a task.

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10.0 ENGINEERING PROGRAMS I 1

10.1

SUMMARY

The health of thirty one (31) Engineering Programs was assessed. In general, Engineering

- Programs were adequate. About 42% of the programs were healthy and on the improving

trend. Others needed improvement.

During the assessment of Engineering Programs, it was evident that the programs that had regulatory commitments, had management's attention, and became healthy. The remaining .

programs were either in the early development stages or had taken a back seat to other l priorities (i.e., emergent issues, CAP backlog, EPR/EWR reviews, etc...).

l 10.2 SCOPE AND METHODOLOGY i The scope of this assessment was to review the health of Engineering Programs. Thirty One (31) Engineering Programs were assessed. These programs were assessed through personnel interviews and selected document reviews. The following steps were taken to perform the assessment:

i i 9 A list of Engineering Programs was consolidated. This list was consolidated based on the true meaning of a program, past related assessments, interviews with affected

Engineering personnel, existing lists of Engineering Programs, and Utilities Services Alliance (USA) Engineering and Technical Support Capabilities matrix.

9 Twenty one (21) Engineering personnel were interviewed. These interviews focused on the following areas:

O . Owner of the Program O Reason for the Program O Program Definition / Basis Document O Action Plan for the Program O Procedures O Internal and External Commitments O Training O Program Interface with the Design Change Process j O Program Interface with the Work Control Process O Added Value O Program vs. Industry O Sources for Updating the Program O Independent Assessment of the Program Nebraska Public Power District Cooper Nuclear Station 76 Engineering Self Assessment

O IIealth of the Program O Long Term Goal- Transition from One Owner to the Rest of the Organization O Personnel Executing the Program i

O Contractors Supporting the Program O Resources Management and Adequacy 9 Eleven (11) customers were interviewed. These interviews focused on the following areas:

O Timeliness O Effectiveness O Added Value O CustomerInvolvement O Customer Satisfaction G Selected documents were reviewed. Some of these documents were selected based on output of personnel interviews. These documents consisted of program plans, program procedures, past assessments, and NRC Inspection Reports. Programs were reviewed in comparison to their purpose.

Engineering Programs health is .,marized in Table 1.

10.3 STRENGTIIS l 10.3.1 Program Imnrovements: As a result of Engineering management paying attention to Engineering Programs with regulatory commitments, these programs have gone j through significant improvements.

I Example 1: The Motor Operated Valve (MOV) Program is proactively and aggressively l following up on issues related to MOVs. Several old issues identified by CNS l and NRC where a thorough and timely effort has been undertaken by the l MOV team to technically resolve the issue and document the resolution. The  !

MOV Program ownership and direction are clearly defined. The program has l adequate resources. This program is now healthy and on the improving trend. l l

Example 2: In-service Inspection (ISI) and in-service Testing (IST) Programs are very l extensive programs. To ensure the continued health of these programs, three l people were assigned as the owners of these programs. One owner was i assigned to both the ISI Boundary Basis Document and the IST Testing Basis Document. One owner was assigned to ISI implementation and another owner was assigned to IST implementation. These programs have adequate resources. These programs are healthy and on the improving trend.

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L Example 3: Fire Protection Program is a program that has had significant issues in the

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past. This program was assigned two owners. One for the program itself and

, the other for implementation. A lot of effort went into resolving the issues.

{ This program is now on the improving trend.

t Example 4: IST team has taken aggressive actions to reduce and maintain the number of pumps on IST increased test frequency due to vibration. The DSAT/ SET reported nine (9) pumps on increased frequency. Currently, only three (3) pumps are on increased frequency and a plan exists to correct the problems and eliminate the need for increased frequency.  ;

'10.4 FINDINGS  !

10.4.1 Exoectations: Management's expectations for Engineering Programs are not I defined and effectively communicated to program owners. This created a wide variation in the level of development and performance of Engineering Programs.

Example 1: Engineering Programs owners are not consistent in the way Engineering Programs are developed and maintained. Through conversations with program owners, each program owner had a different understanding of what the  !

expectation were. This created a wide variation in the level of development and performance of Engineering Programs.

i Example 2: No expectations have been set for Engineering managers and supervisors to oversee programs. Engineering managers and supervisors should have a number of means (day-to-day coaching, planning, periodic reviews,' setting expectations, and the performance management process) to oversee programs for which they are responsible.  !

Example 3: Erosion / Corrosion (E/C) Program does not currently have an owner. ,

Engineering Programs supervisor has an open position and is actively seeking to fill this position. Until an E/C owner is assigned, interim actions need to be taken to prepare for the upcoming refueling outage in 1997. ,

10.4.2 Planning: Many Engineering Programs do not have an action plan or a strategy (vision). This created lack of direction, focus and accountability. This, in turn, ,

made it easier for the program owner to ignore the program an.1 get involved in j emergent activities. l i

Example 1: While some examples of planning activities for programs exist in Engineering,

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Nebraska Public Power District Cooper Nuclear Station 78 Engineering Self Assessment

programs. Program owners should have a clear idea of requirements and station needs, a vision, an understanding of gaps, and a plan for their programs.

Example 2: MOV Program plan has not been updated to reflect the latest changes. This '

plan was last revised on January 21,1995. Since then, the program has gone through significant improvements, enhancements, and changes. These changes have not been reflected into the plan.

Example 3: Check Valve Program was audited by QA during Refueling Outage 16 (RE16). QA wrote a condition report since old INPO concerns have not been resolved yet. The program owner is preparing a response. It was very evident that this program had no plan or a strategy (vision).

10.4.3 Desien Basis Integration: Engineering Programs related discrepancies raise questions on the integration effectiveness of the Design Basis into Engineering Programs.

l Example 1: IST Basis Document, Revision 1, Page 176, Item HPCI-CV-10CV and HPCI-CV-11CV, states "these check valves do not perform an active safety function in the closed position". However, DCD-2, Revision 3, HPCI Design Criteria Document, Appendix B, Section 2.2.18, indicates that these valves do have an active safety function in the closed position. These valves need to have an active safety function in the closed position. CR 96-0103 (SN 1-20317) was initiated to capture the required IST Program changes.  ;

Example 2: Vendor Manual Control process has effectively been changed since July 10, j 1995. However, procedures have not been changed. Vendor Manual Change l Form (VMCF) has also been changed to only require Procurement Engineering to implement changes to Vendor Manuals based on discussions  !

with affected groups. While this significantly streamlines the process, it is  ;

unclear whether adequate configuration control is maintained. '

Example 3: NRC Inspection Report IR 95-12 identified that the ASME Code boundaries in Procedure 6.3.10.28 disagree with controlled drawings.

Example 4: NRC Inspector, identified two ISI/IST boundary concems during a recent NRC inspection.

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Example 5: A review of calculation NEDC 91-083D, Revision 4, approved 1/4/95, shows that Procedure MP 7.0.11, Revision 2, is referenced as a source document.

However, Procedure MP 7.0.11, Revision 5, dated 9/29/95, does not include a reference to the calculation (calculation is for MOV settings for IIPCI-MOV-M017 and IIPCI-MOV-M058). This appears to be generic from a stand point of not providing a ready reference to applicable calculations for the MOVs.

Example 6: NEDC 92-050BD,IIPCI-REL-K33/43 Setpoint calculation takes credit for specific equipment to calibrate the timers. Ilowever, that equipment is no longer used. No method currently exists to control the use of Measuring and

' Testing Equipment (M&TE) to support design basis documents. l&C/ Design Engineering Group is re-designing the Instrument Setpoint Program but is not yet in place.

Example 7: Concern raised over classification of Fire Doors and Fire Seals within the Equipment Data File (EDF). Not all Fire Doors are in the EDF or are coded in the EDF correctly. Fire Seals were in the EDF, but were taken out in 1989. An attempt was made to put them back in around one and a half years ago, but they all need new 3.13 paperwork. Also, approximately one hundred (100) to two hundred (200) new Fire Seals have been identified through Appendix R which were never classified.

Example 8: The responsible Maintenance Engineer used an uncontrolled copy of an approved setpoint change request to complete the applicable 7.2.35 Data Sheet. This information should have been taken directly from the controlled Relief Valve Setpoint Log. A CR (Serial No. 1-21148) was issued to address this item.

Example 9: Design Change DC 93-024 did not test / justify the starting of the Diesel Generators without the air compressors, but DGSA-RV-10RV thru 13RV i were deleted from the IST Program, and DGSA-CV-14CV thru 17CV were i changed to test closect only. This was the result ofinadequate interface '

between the IST Program and the Design Change process. CR 96-0151 (Serial No.1-20551) was issued to address this item.

10.5 AREAS FOR IMPROVEMENT 10.5.1 Communication: Engineering Programs owners, responsibilities, definition, and changes are not effectively communicated to Engineering personnel and customers. This has created confusion and wasted valuable time in trying to find out who to contact for issue resolution.

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Example 1: ' Engineering " System and Program Assignments Matrix" is a good tool to communicate system and program ownership to Engineering personnel and customers. This matrix is not complete and is not commonly used. It was very evident that, in most cases, Engineering personnel and customers were not aware of who to contact.

Example 2: The term programs is used to refer to a wide range of things: programs (Fire Protection), processes (Procurement), activities or responsibilities related to components (Snubbers, Check Valves), other sets of activities or responsibilities (Configuration Management). More clearly defined definitions-for these " things" may help with communication and accountability for assignments and expectations for owners.

Example 3: Neither the Maintenance Engineer responsible for the 7.2.35 Relief Valve Setpoint Test, or the Relief Valve Engineer responsible for Engineering Procedure 3.17, Safety and Relief Setpoint Control, knew that the code for valve testing was being changed on March 1,1996 from PTC 25.3-1976 to OM Part 1,1987. Neither engineer was involved in reviewing the proposed changes to Procedure 7.2.35.

Example 4: An Engineering customer expressed a concern that changes to Engineering Programs (i.e., ISI/IST boundary, etc...) are not effectively communicated to Engineering customers and personnel.

Example 5: Significant improvements / changes were made to the Probabilistic Safety

. Assessment (PSA) model in the later part of 1995. Additional improvements are being planned for 1996. The PSA process as well as how it can help CNS has not been officially communicated. Therefore, Engineering customers are not aware and not taking advantage of the PSA. The same t.pplies to the Maintenance Rule Program.

' 10.5.2 Programs Needing Immediate Attention: Even though all programs including >

healthy ones, need continual attention and improvement. The following programs need immediate attention and improvement:

O Air Operated Valves O Check Valves O Fatigue Monitoring O Instrument Setpoints O Lubrication O MaintenanceImprovement O Microbiologically Induced Corrosion (MIC) Monitoring and Mitigation Nebraska Public Power District Cooper Nuclear Station '

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= . _ . . -- - -.- - - . - - .. . .. - . - - . - . _ - - - . - - . _

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O Painting and Coatings

.O Protective Relay Setpoints O Relief Valve Setpoints O Severe Accident Management  ;

' O - Solenoid Operated Valves O Thermography j 0 Vibration '

10.5.3 Ownership:. The Following Programs Need Owners: l O ' Erosion / Corrosion

! O MIC Monitoring and Mitigation l

10.5.4 Industry Involvement: Engineering Programs Owners appear to be involved in the industry in the interest of keeping their programs up to date. However, it is not j' {

evident that industry information is fully utilized. Engineering Programs owners l- need to take full advantage ofindustry information in updating their programs.

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10.5.5. Feedwater Nozzle Monitoring: Engineering Procedure 3.20 " Reactor Pressure l i

Vessel Thermal Transient Review", requires the monitoring of Feedwater (FW) i nozzle leakage. Monitoring is accomplished through the use of PMIS and i

GEIEMS data. This data is collected on a regular basis. However, interpretation of

- this data is not done on a regular basis. Procedure 3.20 does'not specify a  ;

monitoring frequency. Data obtained to date does not indicate FW nozzle leakage j that exceeds the administrative limits set in Section 6.2 of Procedure 3.20. CR 96-j '- 0150 (Serial No. 1-20766) was issued to address this item.

) Procedure 3.20 needs to be revised to address monitoring frequency. Also, y interpretation of PMIS and GEIEMS data needs to be performed on a more

! frequent basis. A permanent owner needs to be assigned to this monitoring activity. ,

!' 10.5.6 Lubrication Program: Under the Lubrication Program a lot of oil sampling has ,

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been done to date. There is not a process set up for trending of data. Trending can ,

lead to significant enhancements in the program which, in turn, can lead to

l. significant cost reduction. A data trending process needs to be set up under the

Lubrication Program.

L i 10.5.7 Desien Criteria Document Uodates: There Are No Procedural Requirements to

, revise affected DCDs if the program documents (i.e., IST Basis Document, etc...)

< are revised.

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10.5.8 Table 1: Engineering Procrams Health Matrix Program - Program 1 Oflicial . Official Program Industry Overall Health

' Owner Program . Program . Procedures / Involvement

' Document Action . . Desk

~ Plan Instructions (Yes/No) - (Yes/No) - (Yes/No) (Yes/No)-

Air Operated Valves No No No Yes Early development stages - needs improvement.

Appendix J No Yes Yes Yes Healthy program - has management's attention.

Check Valves Yes No Yes Yes Program is weak - needs improvement. Responding to QA audit - INPO concerns haven't been resolved yet.

Environmental No No Yes Yes llealthy program - needs additional people trained -

Equipment Qualification needs management's attention - no EQ DCD.

Erosion / Corrosion No Owner Yes No Yes No llealthy program - needs an owner.

Assigned Fatigue Monitoring No No Yes Yes Early development stages - needs improvement.

Fire Protection Yes Yes Yes Yes Improvog program - strong ownership - needs management's continual attention.

Instrument Setpoints No No Yes Yes Existing program is weak - plans for new program -

needs development and management's attention.

Individual Plant No No No Yes Improving program - using a lot of contractor's help -

l Examination for Extemal needs management's contim.al attention.

Events (IPEEE)

Nebraska Public Power District Cooper Nuclear Station 83 Engineering Self Assessment

Program Program Official OfUcial Program Industry Overall Health -

Owner Program Program Procedures / Involvement Document Action Desk Plan Instructions

! (Yes/No) (Yes/No) (Yes/No) (Yes/No)

In-Service inspection Yes Yes Yes Yes Ilealthy program - strong ownership - needs (ISI) management's continual attention.

In-Service Testing (IST) Yes Yes Yes Yes llealthy program - strong ownership - needs management's continual attention.

Lubrication No No Yes Yes Needs improvement - needs sample trending database.

hiaintenance Rule Yes Yes No Yes Owner is active in developing the program - needs management's continual attention - needs to be communicated to CNS.

hiaintenance No Yes Yes Yes Early development stages - needs improvement.

Improvement Meter Banding No No Yes No Adequate program - plans to revise the procedure -

needs database to track scope.

MIC Monitoring and No Owner No No No No Program almost non-existent - no owner.

Mitigation Assigned Motor Operated Valves Yes Yes Yes Yes - llealthy program - significant improvement - strong owner- has management's attention - using a lot of contractor's help.

Nuclear Plant Reliability Yes Yes Yes Yes llealthy program - minimal backlog - strong owner.

Data System (NPRDS) Does it need to be owned by Engineering?

Nebraska Publie Power District Cooper Nuclear Station 84 Engineering Self Assessment

. . - _ - ~ _ . - . - . . - . . . . . . ~ . .

[

I Program ~ Program Official OfTicial Program . Industry ' Overallllealth ,

- Owner Program - Program . - Procedures / Involvement Document ' Action - J Desk .;

Plan ' Instructions [

r (Yes/No) - (Yes/No) (Yes/No) (Yes/No) .

I Painting and Coatings No No Yes Yes Early development stages - needs improvement.  !

Protective Relay No No Yes Yes Early development stages - needs improvement -

Setpoints developing a setpoint log. 3

'i Relief Valve Setpoints No No Yes No Needs improvement - Maintenance Planners need a [

controlled copy of the loo Repairs / Replacement No Yes Yes Yes liealthy program.

Severe Accident No No No Yes Early development stages - needs improvement.

Management i

' Shelf Life Yes No Yes Yes liealthy program - efforts are underway for enhancements and big S savings.  ;

Snubbers No Yes Yes Yes Ilealthy program. j i

Solenoid Operated No No No Yes Early development stages - needs improvement. l Valves Seismic Qualification Yes No Yes Yes liealthy program - using a lot of contractor's help. t Utilities Group (SQUG) s Thermography No No Yes No Needs development.

I Nebraska Public Power District Cooper Nuclear Station 85 Engineering Self Assessment i t

F

Program Program . ' Ofracial . . Official - . Program - . Industry - . Overall Healthi Owner. ' Program Program . - Procedures / . .: Involvement

- Document ' Action' . .. Desk -

Plan Instructions (Yes/No) (Yes/No) .

.' (Yes/No) ' .- (Yes/No)

Vendor Manual No No Yes Yes Healthy program - needs management's continual attention - good efTort in reducing backlog - only one controlled set of Vendor Manuals is available.

Vibration No No Yes Yes . Being developed - needs improvement.

Welding No No Yes No Program established - needs management's attention -

needs enhancement.

Nebraska Public Power District i Cooper Nuclear Station 86 Engineering Self Assessment ,

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11.0 - VERTICAL SLICE I1.1

SUMMARY

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1 The results of the vertical slice of HPCI and Emergency Diesel Generator systems l indicated that each of these systems can perform its intended function in accordance' I with the licensing basis. However, the licensing bases are not clearly defined.

Both the Design and System Engineering organizations are in need ofimprovement, i and departnient and plant interfaces are weak.

The design organization does not appear to have effective control of design and licensing bases and configuration issues. Until these issues are resolved, the system margins, their limits and interrelations cannot be established and communicated to the appropriate plant organizations.

The plant organization did not consistently incorporate design and licensing basis information in plant procedures and established clear references in these procedures to design calculations.

i 11.2 ECOPE AND METHODOLOGY  !

'Ihe vertical slice inspection was conducted by review of the selected documents from the following broad categories (for each of the selected systems).

Flow Diagrams, Design Criteria Documents, USAR, Technical Specification & 1 IST Basis Documents. (See Questions: 004, 010,'013,018,023, 024,033,092,  !

l39,140 & Observations: 001,004,018,023,045,057,070,151,187,188,190, 191).

. Calculations. (See Questions: 018, & Observations: 062,180,232,235)

. Setpoints (See Questions: 013,035,069,092,130,139,140 & Observations: 070, 101,102,121,232,233).

. System Operating Proc e~ dures. (See Observations: 233).

. Maintenance Work Requests. (See Questions: 019 & Observations: 013,019).

. Condition Reports._ (See Questions: 019 & Observations: 199,201).

Nebraska Public Power District Cooper Nuclear Station 87 Engineering Self Assessment

Safety Evaluations. (See Observation 100).

Procurement (See Questions: 024,117,118).

I1.3 STRENGT11S 11.3.1 The IST Basis Document provides a very good description and clear references to support the IST program requirements (Observation 286).

I1.3.2 Safety Evaluation for ModiEcation 93-050 provides an excellent example on how to perform good safety evaluations (Observation 100).

I1.3.3 Maintenance Engineer Took charge and pro-actively assisted I&C to resolve problem with RiiR-REL-K121 A (Observation 018).

I1.3.4 The Pronosed Part 21 Procedure provides better guidance for evaluation of potential Part 21 issues (Observation 199).

11.4 FINDINGS l

11.4.1 Design Basis Integration: Design basis information is not being effectively integrated into Plant procedures, programs, and activities on a routine basis.

Example 1: IST Basis Document, Revision 1, Page 176, item liPCI-CV-10CV and IIPCI-CV-11CV, states "these check valves do not perform an active safety function in the closed position". Ilowever, DCD-2, Revision 3, liPCI Design Criteria l l Document, Appendix B, Section 2.2.18, indicates that these valves do have an

active safety function in the closed position. These valves ned to have an active safety function in the closed position. Design basis information not correctly integrated into IST Basis Document. CR 96-0103 (S/N 1-20317) was initiated to capture the required IST Program changes (Observation 001, CR S/N 1-15429).

1 Example 2: Calculation NEDC 94-261, Rev. O, was approved on 6-6-95 to validate the acceptance criteria in Surveillance Procedure 6.3.1.2. This surveillance procedure was superseded on 5-30-95 by 6.PC.503, Rev 0. The calculation was prepared on 1-3-95 but was not reviewed for over 4 months, the reviewers  !

did not check the status of the referenced procedure. The surveillance ,

procedure does not reference the calculation that validates the acceptance '

criteria. Use of unapproved design basis information and a lack of control over design basis information (Observation 062).

Nebraska Public Power District Cooper Nuclear Station 88 Engineering Self Assessment l

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Example 3: Control of M&TE to support Design Basis. NEDC 92-050BD, IIPCl-REL-K33/43 Setpoint calculation takes credit for specific equipment to calibrate ,

time delay relays. However, that equipment is no longer being used. No  ;

method currently exist to control the use of M&TE to support design basis j documents (Observation 232).  ;

Example 4: One of the purposes of modification DC 93-024 was the reclassification of the l starting air compressors as non-essential. The acceptance testing for this modification does not verify the ability of the starting air system to make multiple starts of the diesels without the air compressors. There is no analytical basis in the design package that would justify not performing a test of the capability of the diesel air start system to function without the compressors. Post modification testing not verifying design basis. Note: l since the compressors and associated valves are yet to be reclassified the operability of the air start system is not in question. (Observation 234)  ;

Example 5: Confusion continually exists over the safety classification of HPCI-LS-90 indicating a weak or unclear design basis (Observation 151). l 1

11.4.2 Operability Assessments: Operability Assessment performance by Engineering is in need ofimprovement.

l Example 1: Operability Assessment provided to Shift Supervisor in response to CR S/N 1-  !

06559 lacked documented evidence to support Engineeringjudgements stated in the assessment. The same Operability Assessment was previously provided in response to CR S/N 1-15732, also without supporting documentation.

Station Procedure 0.5 requires supporting documentation for any Engineering i judgements (Observation 116, CR S/N 1-15438). l Example 2: An Operability Assessment to support CR 96-040 was performed by an Engineer that was not certified to TPD 509. Additionally, no documentation was provided to support the assessment and there was no supervisor review.

Certification to TPD 509 qualifies an Engineer to perform Operability Assessments (Obsen ations 078,061).

I1.4.3 Configuration control: Configuration control is in need of significant improvement.

Example 1: Procedure 3.7, DRAWING CllANGE NOTICE, Revision 8.1, does not require a 50.59 screening for drawing changes submitted which are not associated with a modification. Note: Procedure 3.7 has since been revised to require a 50.59 screening for non-modification drawing changes (Observation 016 CR S/N 15845).

Nebraska Public Power District Cooper Nuclear StaPon 89 Engineering Self Assessment

Example 2: A significant backlog of Engineering Judgements (EJs) against calculations exists. Twelve EJs are pending against NEDC 87-131C and ten EJs are pending against NEDC 87-131D. No effective method exists to track outstanding EJs pending against calculations. (Observation 235, CR S/N 1-13393).

Example 3: No process exist to ensure Design Criteria Documents are updated following a revision of a program, such as ISI/IST Program or Appendix J Prot, ram (Observation 191).

Example 4: Inconsistencies exist between the IST Basis Document, Revision 1, and Design Criteria Documents. The IST Basis Document states that HPCI-MOV-MO58 is not within the scope of Appendix J requirements (page 198) yet DCD-2, Appendix B, Section 2.2.9, states that it is (Observation 191).

I1.4.4 Corrective actions: Corrective actions are not consistently effective or are not being carried out to completion.

Example 1: MWR 95-4257 was written to install a voltage suppressor on DG-REL-DG2(14S3) per drawing G5-262-743, sheet 16 which was subsequently canceled because the Design Engineer could not detennine whether it was required. No CR was generated to follow up nor was any documented investigation performed to determine if the same relay installed on DGl was missing a suppressor (Observation 013).

Example 2: The root cause identified in CR 95-1241 was a lack of clear ownership / project management during the DG modification process. The DG muffler bypass valve problem suffered from the same lack of ownership until the issue became a crisis. The lack of ownership identified in the diesel generator modification has not been effectively addressed (Observation 251).

11.5 AREAS FOR IMPROVEMENT 11.5.1 Design Criteria Documents. Flow Diagrams, USAR, Technical Specification &

IST Basis Documents.

. DCDs do not provide clear system function description; safety related status designation; nor do they identify specific licensing basis. Not all safety related equipment is identified in DCDs.

Nebraska Public Power District Cooper Nuclear Station 90 Engineering Self Assessment

Information in DCDs overlaps with the information in IST basis but some of the requirements are (for the same equipment) different.

I1.5.2 Calculations.

Use of Engineering Judgement (EJ). There is no clear requirement to document any decrease in margin, irrespective of the magnitude.

The calculation procedure does not provide a requirement to consider a potential for a design change being introduced by the calculation (or its revision), especially for calculation not associated with any design change packages.

11.5.3 Setnoints  !

l

. Set point calculations are not referenced in DCDs. l Set point calculations are not referenced in plant surveillance procedures. A change to the procedure could alter the assumptions in the calculation.

Furthermore, the procedures have been rewritten with new numbers assigned.

These new procedure numbers are not referenced in the supporting calculations.

The design and maintenance engineers involved in relief valve set point i testing were not aware that the test method was being changed to OM-1 for the third ten-year interval Inservice Test Program.

There is not sufficient documentation to address that it is acceptable that the l Emergency Diesel Generator day tank 6 hour6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> level alann setpoint is below the minimum required.

I 11.5.4 System Onerating Procedurcs. '

There is no formal periodic verification that the EDG day tank level is maintained above the minimum required value after the EDG test completion. (The ,

Emergency Diesel Generator day tank 6 hour6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> level alarm setpoint is below the 1 minimum required).

I1.5.5 Maintenance Work Reauests.

Maintenance Work Requests were not closed out in a timely manner to support submittal of the ASME XI Repair / Replacement Report.

Nebraska Public Power District Cooper Nuclear Station 91 'agineering Self Assessment

11.5.6 Condition Renorts.

The disposition of some CRs focused too narrowly on resolving the specific problem. The generic implications are sometimes overlooked.

I1.5.7 Modifications.

There is an inadequate understanding of the differences between the functional / process requirements and safety requirements Better documentation of all of the design inputs and considerations is needed. After the solution to the immediate problem is found, the effects of this solution on other components, systems, structures, plant, environment,  ;

etc. are not addressed (documented). j 11.5.f, Safety Evaluations.

Responses to the questions are not specific, and do not addrcss the actual l change.

Responses to the consequences questions are not limited to the radiological consequences only.

Improvement of reliability is used as a means to justify that there is no impact on the probability. {

i l1.5.9 Procurement.

There is a weakness in spare parts in that existing parts are not re-evaluated promptly when the parent component is recirssified as essential. While this condition does not affect safety, it could potentially affect plant availability.

(Procurement Engineering is aware of this issue and plans to address it during 1996.)

11.5.10 Material Condition.

Several oil leaks were noted in both Diesel Generator rooms and the HPCI room which appeared to be accepted conditions. Ladders and tool boxes were found unrestrained. A spool piece in the llPCI room was inadequately restrained to prevent its interference with HPCI piping.

Nebraska Public Power District Cooper Nuclear Station 92 Engineering Self Assessment

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- 11.6 AREAS NOT OBSERVED.

In general areas identified in IP 37550 that were not evaluated during the vertical assessment had no recent activities or issues in these areas for the systems selected  ;

for the vertical slice. Additionally, these areas were adequately observed in the j 2

horizontal assessments. See the Matrix cross-referencing the 37550 areas to the 1 l Vertical Slice Assessment contained in Section 11.7.

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l Nebraska Public Power District Cooper Nuclear Station 93 Engineering Self Assessment

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ENGINEERING SELF ASSESSMENT  !

)

12.0 APPENDIX A -TEAM MEMBER EXPERIENCE

SUMMARY

l MICIIAEL T. BOYCE Assessment Team Leader Manager, Engineering Support Department, Cooper Nuclear Station

• B.S. Nuclear Engineering, University of Cincinnati, Cincinnati,011 14 years nuclear power plant experience )

Design Basis Supervisor, Design Basis Reconstitution, Cooper Nuclear Station

• Senior Licensing Engineer, Cooper Nuclear Station Startup Test Engineer, Clinton Power Station Consulting Engineer, providing support in the areas of Piping and Support Design and Installation

• Fires llazards Analysis

• Probabilistic Risk Assessment, LaSalle

• SRAB Staff Engineer, Duane Arnold

• Mechanical and Nuclear calculations and analysis 1

1 l

PAUL J. DiRITO Assessment Team Member

• Senior Reliability Engineer, Engineering Support Department, Cooper Nuclear Station

• B.S. Mechanical Engineering, US Naval Academy, Annapolis, MD

• 16 years nuclear power plant experience

• SRO Licensed at Oyster Creek and Peach Bottom Atomic Power Station

• Previous Self-Assessment experience at Peach Bottom Atomic Power Station

• Former Operations Manager, Cooper Nuclear Station FADI DIYA Assessment Team Member i

• Supervisor, Civil / Structural, Design Engineering Department, Cooper Nuclear Station

• M.S. and B.S. in Civil Engineering, Bradley University, Peoria, IL Registered Professional Engineer

• Over 10 years of Nuclear Design Engineering experience

• Performed Self-Assessment of Configuration Maintenance for Palo Verde Nuclear Generating Station

• Chairman of Subcommittee ACI 349-4," Low Level and liigh Level Radioactive Material Repository Structures" Page 1 of 5

ENGINEERING SELF ASSESSMENT 12.0 APPENDIX A -TEAM MEMBER EXPERIENCE

SUMMARY

(continued)

JAMES R. FLAHERTY Assessment Team Member Supervisor, Mechanical, Design Engineering Department, Cooper Nuclear Station

• 13.S. Mechanical Engineering, University of Nebraska, Lincoln, NE 18 years nuclear power plant and engineering experience Formerly held positions of System Engineer through Plant Engineering Manager

• Former Corrective Action Program Supervisor

• Shift Technical Advisor,7 years

• Participated in 3 INPO Assist Visits GERARD T. GOERING Assessment Team Member

• Independent Consultant 13.S. Mechanical Engineering, Iowa State University, Ames, IA 32 years of nuclear power plant and engineering experience

• Past PWR Licensed SRO Past Chairman Onsite Review Committee, Westinghouse Owners Group Steering Committee, Westinghouse Owners Regulatory Response Committee, and served on NUMARC and INPO working groups Past Manager Nuclear Technical Support and Design Engineering (Prairie Island and Monticello)

Member of New York Power Authority Safety Review Committee for Indian Point -

111 and Fitzpatrick TED E. IIOUGH Assessment Team Facilitator

• Independent Review Group Advisor, Cooper Nuclear Station

• B.S. Electrical Engineering, University of Nebraska, Lincoln, NE

• Post-Graduate studies in Nuclear Engineering, University of Washington, JCGS, Richland, WA

• 25 years nuclear power plant and engineering experience, ( 9 Commercial Nuclear Plants)

Qualified Naval Operator, Lead Engineer in: Electrical Engineering, I & C Engineering, Piping and Supports Engineering

• Acting Site Manager, Nc;bar Engineering Department, Cooper Nuclear Station

• Corrective Action Progrsa Evaluator, Cooper Nuclear Station l

• Past Certification as ANSI Level III Electrical Inspector and Lead Q A Auditor Page 2 of 5

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l ENGINEERING SELF ASSESSMENT 12.0 APPENDIX A -TEAM MEMBER EXPERIENCE

SUMMARY

(continued)

DR. JOllN II. MASON Assessment Team Member

• Principal Consultant, PRISM Consulting, Inc

• Ph.D. and M.S. Nuclear Engineering, MIT, Boston, MA

• M.S. in Management from the Sloan School of Management 29 years of nuclear plant operation and engineering experience Line Manager (to President) for several nuclear engineering design and service organizations Participant in nuclear plant operations and engineering organization assessment, performance improvement, and re-organization engagements for: Carolina Power &

Light's Brunswick Nuclear Station, Carolina Power & Light's Nuclear Engineering Department, Washington Public Power Supply System's nuclear power organization, Entergy's River Bend Nuclear Station, Nebraska Public Power District's Cooper Nuclear Station, Nebraska Public Power District's Nuclear Engineering Department, Entergy's Grand Gulf Nuclear Station, Public Service Electric & Gas's Salem Nuclear Station, Department of Energy's Savannah River Plant, Commonwealth  !

Edison's Nuclear Training Department l

ROGER W. MOBERLY Assessment Team Member

• Senior Electrical Engineer, Design Engineering Department, Cooper Nuclear Station l B. S. Electrical Engineering, University of Missouri, Columbia, MO l

• 13 years nuclear power plant and engineering experience (9 years CNS)

• Qualified Shift Technical Advisor,4 years

• 8 years as System Engineer, Electrical Equipment (Distribution) System OLE II. OLSON Assessment Team Member

• Supervisor, Core Cooling Systems, Plant Engineering Department, Cooper Nuclear I Station

• B.S. Electrical Engineering, Iowa State University, Ames, IA

• 12 years experience in Engineering Support of BWR power plants

• SRO Duane Arnold Energy Center

• Past Supervisor ofI&C Engineering

• Past Supervisor of Predictive Maintenance Engineering

• Participation on Self-Assessment teams for NRC IP 37550 and INPO evaluations Page 3 of 5

ENGINEERING SELF ASSESSMENT 12.0 APPENDIX A-TEAM MEMBER EXPERIENCE

SUMMARY

(continued)

JAMES K. SALISBURY Assessment Team Member Supervisor, TG/ BOP Engineering, Plant Engineering Department, Cooper Nuclear Station B.S. Mechanical Engineering, Wichita State University, Wichita, KS l

• 14 years nuclear industry experience Qualified Shift Technical Advisor,7 years '

• INPO Loaned Employee, performed assessments and evaluations of various Nuclear plants in the United States and Taiwan  !

Former Reactor Engineer and Lead Performance Engineer l

MICIIAEL SIILYAMBERG Assessment Team Member

• President, Principal Engineer, NUENERGY, Inc. Richboro, PA B.S. Mechanical Engineering, Polytechnical Institute, Lvov, USSR 20 years nuclear power plant and engineering experience Consultant to US NRC for 19 inspections (6 E&TS,11 SWSOPI,2 EDSFI)

Supervising Engineer Discipline Engineer, UE&C

• Lead Systems Engineer, UE&C

• Project Engineer, ATES,Inc

• Sr. Power Engineer, SWEC Nuclear Design Engineer, CANDU, Ontario Hydro i

KEN B. TIIOMAS Assessment Team Member

• Senior Staff Engineer, Engineering Programs, Cooper Nuclear Station B.S. Nuclear Engineering, University of Tennessee

• 22 years nuclear power plant and engineering experience

• Past BWR Licensed SRO Member ASME XI Working Group, Inspection of Systems and Components

• Control Point Manager, Design Basis Reconstitution, NMP1

• Superintendent, Site Licensing (Niagara Mohawk)

• Chairman of the EPRI Committee on Implementation of ASME Code Case N-483

• Consulting Engineer, providing support in the areas of:  ;

Insen' ice Inspection Insen' ice Testing Local and Integrated Leak Rate Testing Page 4 of 5

ENGINEERING SELF ASSESSMENT 12.0 APPENDIX A -TEAM MEMBER EXPERIENCE

SUMMARY

(continued)

GARY C. WELSII Assessment Team Member

• BWR Section Manager, Events Analysis Department, INPO

• B.S. Civil Engineering, Georgia Institute of Technology

• 18 years of nuclear power plant and engineering experience

• Registered Professional Engineer

• SRO certification, CE, PWR, April 1989

• Assistant Team Manager, Special Projects Department, INPO

• Assistant Team Manager, O & A Department,INPO Senior Evaluator, Design Engineering, Technical Support, and O & A Departments, INPO

+

Assistant Manager, Nuclear Station Engineering Department, Illinois Power Company, Clinton Power Station

• Quality Assurance Engineering Support Supervisor, Georgia Power Company, Edwin I. Ilatch Nuclear Plant JOliN WYRICK Assessment Team Member

• Assistant to WNP2 (Washington Nuclear Plant) Plant General Manager, Washington Public Power Supply System

• SRO License on WNP2, Washington Public Power Supply System

• Nuclear Training Manager, Washington Public Power Supply System

• Outage Manager, Washington Public Power Supply System

• Manager of Maintenance Engineering and Planning, WPPSS i

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Page 5 of 5

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ENGINEERING SELF ASSESSMENT 13.0 APPENDIX B - MATRIX OF QUESTIONS / OBSERVATIONS TO IP 37550 ITEM 37550 DESCRIPTION OF 37550 SECTION PLAN / QUESTION OBS SECTION SECTION NO. NO 1 02.01 Evaluate several safety significant design changes and plant mods to verify Plant Mod No question compliance with applicable installation and testing requirements. Work Plan Q-015

, Item I Q-020 8

2 02.02 Evaluate several safety significant temporary plant mods to verify Same as above Q-006 conformance with the applicable requirements 3 02.03 Evaluate the extent and quality of engineering involvement in site activities. 1. Operational Issues , Q-027 O-018 Evaluation Requirement items 0-028 1-3 0-036

2. Maintenance Support, Plan 0-041 Items 2 and 3 0-042 0-061 0-068 O-083 0-146 4 02.03a Evaluate the extent and effectiveness of the site engineering communications Operational Issues, Evaluation 0-009 with the other departments such as maintenance, ops, etc. Requirements Items 1,2 and 3 0-010 Maintenance Support item 3 0-018 C 024 O-025 O-028 O-033 O-046 O-062 0-102 0-158 Nebraska Public Power District Cooper Nuclear Station Page1 of15 Engineering Self Assessment

ENGINEERING SELF ASSESSMENT 13.0 APPENDIX B - MATRIX OF QUESTIONS / OBSERVATIONS TO IP 37550 (continued)

DESCRIPTION OF 37550 SECTION PLAN / QUESTION OBS.

ITEM 37550 SECTION NO. NO SECTION Evaluate the engineering involvement with the resolution of technical issues Operational issues Evaluation Q-035 O-023 5 02.03b selected from recent plant events or routine work documents. Requirements item 3 and Q-070 0-129 Evaluation Plan items 5,8,9 Q-072 0-154 and 12. Q-074 O-200 Q-075 Q-076 Q-080 j

l 6 02.03c Evaluate the extent of backlogged engineering work. Plant Mods Q-063 0-040 Work Plan Items 2.k. 3.b and Q-084 0-067 l

3.f Q-095 O-099 l Q-112 0-123 i

O-126

! O-229 O-240 7 02.04 Determine the degree to which engineering maintains the plant design bases Plant Mods Q-001 0-151 current for selected safety systems and verify that the regulatory requirements Work Plan Item 3.e Q-003 0-153 and commitments are properly implemented in the performance of Q-020 0-161 engineering activities. Q-022 0-162 l

Q-036 O-235 Q-037 O-259 I

Q-123 0-261

! O-303 Q-137 8 02.05 If performance problems are identified, evaluate the relative capabilities of the NA site and corporate engineering organizations. All NPG Engineering is on site.

Nebraska Public Power District  :

Cooper Nuclear Station l Page 2 of15 Engineering Self Assessment ,

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ENGINEERING SELF ASSESSMENT 13.0 APPENDIX B - MATRIX OF QUESTIONS / OBSERVATIONS TO IP 37550 (continued)

ITEM 37550 DESCRIPTION OF 37550 SECTION PLAN / QUESTION OBS.

SECTION SECTION NO. NO 9 02.06 Evaluate the effectiveness of the controls and self assessment programs related Eng. ProgramsAssessment Q-127 O-088 to engineering activities. Plan item 2.0 Q-128 Q-129 Q-132 10 02.06a Evaluate the appropriateness and timeliness of controls in identifying, 1. Operational Issues, Q-002 0-004 resolving and preventing problems caused by such areas as corrective action Evaluation Plan Items 8 and 9 Q-019 O-149 program, root cause analysis, safety committees, and self assessment in the 2. Vertical Assessment Item Q-020 0-154 engineering area. 2.10 Q-044

3. Maintenance Support item Q-059 1.a.4 Q-086 11 02.06b Evaluate the effectiveness of controls by reviewing pertinent issues, events, or . Example: DG MufTier Bypass Q-035 0-228 problems identified during the inspection. Valve issue Q-036 O-223 Q-092 Q-042 12 02.06c Detsrmine whether there are strengths or weaknesses in the controls for Not part of the Plan, but was Q-022 0-013 identifying and resolving reviewed issues that could enhance or degrade plant done in evaluation stage. Q-035 O-051 operations or safety. Q-079 O-072 0-073 0-074 O-075 O-076 13 02.07 Evaluate the overall efTectiveness of the independent safety engineering group NA a-d (ISEG) No ISEG equivalent Nebraska Public Power District Cooper Nuclear Station Page 3 of 15 Engineering Self Assessment

ENGINEERING SELF ASSESSMENT 13.0 APPENDIX B - MATRIX OF QUESTIONS / OBSERVATIONS TO IP 37550 (continued)

ITEM 37550 DESCRIPTION OF 37550 SECTION PLAN / QUESTION OBS.

SECTION SECTION NO. NO 14 02.08 When design changes and modifications have been made to the systems Not assessed. No a-f installed as a part of the NRC regulations 10 CFR 50.62,10 CFR 50.63, and modifications have been supplement I to NUREG 0737 for RG l.97 instruments and SPDS, evaluate perfonned recently in these these mods to ensure that the original design basis and margins for the areas. These areas have been applicable systems / components have not been compromised. inspected many times in past years.

15 03.01 Select 5 mods and evaluate for the following: Plant Mods, Work Plan item 1 Q-027 Q-099 Q-028 Q-138 Q-053 0-146 Q-097 16 03.0lr Engineering involvement in determining procurement specs. l. Plant Mods, Work Plan item Q-024 O-084 2.b Q-025 O-272 2.Maint. SupportAssessment Q-056 Plan items 1.h and 2.c Q-087 Q-117 Q-ll8 Q-139 Q-140 17 03.0lb DCs and mods reviewed by on-site and off-site organizations as required by . Plant Mods Q-104 Tech. Specs. Work Plan item 2.a,2.b and 2.e 18 03.01c Mod packages identified operating procedure and EOP changes. Plant Mods Q-103 0-145 Work Plan item 2.i Q-135 Q-136 Nebraska Pubhc Power District Cooper Nuclear Station Page 4 of 15 Engineering Self Assessment

ENGINEERING SELF ASSESSMENT 13.0 APPENDIX B - MATRIX OF QUESTIONS / OBSERVATIONS TO IP 37550 (continued)

ITEM 37550 DESCRIPTION OF 37550 SECTION PLAN / QUESTION OHS.

SECTION SECTION NO. NO 19 03.01d DCs identified and implemented appropriate operator training program 1. Plant Mods revisions. Work Plan Item 2.i

2. Operational Issues Evaluation Plan Item 5 20 03.0le Markups of revisions to controlled plant documents were distributed to critical 1. Plant Mods 0-208 personnel. Work Plan Item 2.i and 2.j O-270

2. Operational Issues O-300 Evaluation Plan item 5 21 03.01f Appropriate USAR changes were identified and technically accurate 50.59s 1. Plant Mods Q-014 0-034 were included. Work Plan Item 2.b Q-020 0-053

2. Operational Issues Q-138 O-100 Assessment Plan Item 10 Q-146 O-271

3. Vertical Assment item 2.11 0-303 22 03.01g PMs, ISI and IST changes were included in mod package. l. Plant Mods Work Plan item Q-121 0-001 2.i O-059 2.Maint Support item 1.d.4 0-081 0-102 0-191 0-286 O-303 23 03.0Ih For partially implemented mods, the effects of partial implementation was 1. Plant Mods 0-281 adequately considered and considered in the 50.59. Work Plan Item 2.b

2. Vertical Slice item 2.11

3. Operational Issues Assessment Plan Item 13 Nebraska Public Power District Cooper Nuclear Station Page 5 of15 Engineering Self Assessment

_ _ _ _ _ _ _ _ _ _ _ . _ _ _ _ _ _ . _ _ . _ _ _ _ _ . _ _ _ _ . _ _ _ _ . . ._.____m. _. ___ ._ _ _ _ . _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ . . _______J

ENGINEERING SELF ASSESSMENT 13.0 APPENDIX B - MATRIX OF QUESTIONS /OHSERVATIONS TO IP 37550 (continued)

ITEM 37550 DESCRIPTION OF 37550 SECTION PLAN / QUESTION OBS.

SECTION SECTION NO. NO 24 03.01i DC calculations, analyses and design output documents ensure: 1. Plant Mods Q-009 O-019

1. technical review, design verification and independent design review. Work Plan Items 2.a,2.b,2.f. Q-031 0-134

2. Correct usage of design info develooped by one group and used by another. 2.1 and 2m Q-034 0-180

3. Appropriate design inputs from codes, standards and relevant design 2. Vertical Assessment item 2 Q-036 criteria. 3.OperationalIssues Q-037

4. Cale and analytical methodology complied with regulatory requirements, Assessment Plan item 5 Q-038 licensee design guides, commitments and industry practices. Q-039

5. Calc assumptions were technically reasonable. Q-053

6. Post-mod testing acceptance criteria adequately verified all aspects of Q-057 implemented dei Q-120

7. Open or items ;. y verification in calcs were satisfactorily resolved or Q-121 tracked for future closure . Q-124

8. Design requirements such as 50.59, EQ, cable separation and seismic Q-138 criteria were considered.

25 03.Olj The as-modified plant was left in a configuration consistent with regulatory Plant Mods Work Plan items 0-161 requirements, and licensee commitments. Any deviations were communicated 2.d,2f and 2j. O-162 to NRC.

26 03.0lk Post-mod test procedures focused on the installed changes, changes to Operational Issues 0-137 procedures were reviewed and approved per the plant program. Assessment Plan item 5 O-162 0-163 0-200 0-234 27 03.011 Test results that didn't meet acceptance criteria were addressed, deviations Operational issues 0-257 were dispositioned by engineering and appropriate retesting was performed. Assessment Plan item 5 Nebraska Public Power District Cooper Nuclear Station Page 6 of15 Engineering Self Assessment

ENGINEERING SELF ASSESSMENT 13.0 APPENDIX B - MATRIX OF QUESTIONS / OBSERVATIONS TO IP 37550 (continued)

ITEM 37550 DESCRIPTION OF 37550 SECTION PLAN / QUESTION OBS.

SECTION SECTION NO. NO 28 03.Olm Testing criteria and results demonstrated performance of the installed SSCs in Operational Issues Q-102 0-137 accordance with the License Amendment application, if applicable, and the Assessment Plan Item 5 Q-119 O-162 design documentation. O-163 0-234 29 03.0ln Evaluate timeliness, and technical adequacy of safety evaluations on field Plant hfods Q-067 O-016 changes (OSCs) as well as the number and reason for field changes. Work Plan items 2.h and 3.f O-161 0-163 0-257 30 03.0lo Installed hardware conformed to the as-built drawings. Plant h1ods Work Plan Item 0-161 2.j 0-260 0-302

- 31 03.02 Select 5 temporary modifications (including mechanical, electrical and I&C) Plant Mods Work Plan Item I Q-006 O-012 and review for the following:

32 03.02a The review and approval process for temp mods. Plant Mods Work Plan item 2 0-031 and 2.1 0-283 O-284 33 03.02b The procedure for installing temp mods. Plant Mods Work Plan Item 2 0-283 and 2.1 34 03.02c The formal record for tracking the status of temp mods, lifted leads, jumpers, Operational Issues Evaluation temp strainers and temp trip set points of control equipment. Plan Item 6 35 03.02d The independent verification, where appropriate, ofinstallation and removal Plant Mods Work Plan item O-281 of temp mods. 2.d Nebraska Publie Power District Cooper Nuclear Station Page 7 of 15 Engineering Self Assessment

ENGINEERING SELF ASSESSMENT 13.0 APPENDIX B - MATRIX OF QUESTIONS / OBSERVATIONS TO IP 37550 (continued) r ITEM 37550 DESCRIPTION OF 37550 SECTION PLAN / QUESTION OBS.

SECTION SECTION NO. NO 36 03.02e Functional testing of equipment following instaillation or removal of the temp 1. Plant Mods Work Plan item O-031 mod. 2.d, and 2.f

2. OperationalIssues Aevaluation Plan Item 6 37 03.02f Correct installation of the temp mod. 1. Plant Mods Work Plan item 2.f and 2.j

2. Operational Issues Evaluation Plan Item 6 38 03.02g For temp mods that have been installed for a long period (9-12 mos.) The 1. OperationalIssues 0-012 cause of the delay and the overall effect of the temp mod. Evaluation Plan item 6

2. Plant Mods Work Plan Item 3.d 39 03.02h The affected control room drawings relect the temp mods installed. 1. Plant Mods Work Plan item O-031 2.1 0-282

2. Operational Issues Evaluation Plan item 6 40 03.02i The method ofidentifying the temp mod at the equipment. Not Evaluated 0-031 41 03.02j Pertinent design change and plant mod attributes from 03.01 have been Plant Mods Work Plan Items O-282 considered. 2 and 3.

Nebraska Public Power District Cooper Nuclear Station Page 8 of15 Engineering Self Assessment

ENGINEERING SELF ASSESSMENT 13.0 APPENDIX B - MATRIX OF QUESTIONS / OBSERVATIONS TO IP 37550 (continued)

ITEM 37550 DESCRIPTION OF 37550 SECTION PLAN / QUESTION OBS.

SECTION SECTION NO. NO 42 03.03 Identify recent plant nonconformances or deficiencies from CRs, recent SALP OperationalIssues Evaluation Q-017 Repons, LERs, Part 21 Reports and 50.72 notifications and Bulletin, GL and Requirements item 3 and Q-044 IN responses and evaluate for significant issues requirirng Engineering A ation Plan Items 5,8,9 Q-052 involvement. Request additional info on those selected and conduct and 12.

interviews and document reviews to assess Engineering performance in resolving the issue. During these reviews and interviews, consider the following:

43 03.03a The Engineering Group's use of PSA in decision making. 1.OperationalIssues 0-044 Evaluation Plan item 9 O-221 2.Maint Support Item 3 0-244 44 03.03b Technical issues are resolved by Engineering arriving a a sound technical Q-035 O-013 solution based on appropriate technical basis. Extent of condition, root cause Q-036 O-034 and actions necessary to prevent recurrence are appropriately considered. Q-037 O-078 Includes assessment and disposition of deficiencies from ISI Program and Q-047 O-096 responses to operational matters such as LERs, set point changes and Q-071 0-108 unanticipated system responses during normal operation or an evant. Q-123 0-116 Q-125 O-119 O-144 0-149 O-154 O-156 Nebraska Publie Power District Cooper Nuclear Station Page 9 of15 Engineering Self Assessment

ENGINEERING SELF ASSESSMENT 13.0 APPENDIX B - MATRIX OF QUESTIONS / OBSERVATIONS TO IP 37550 (continued)

ITEM 37550 DESCRIPTION OF 37550 SECTION PLAN / QUESTION OBS.

SECriON SECTION NO. NO 45 03.03c Engineering supports maintenance in the analysis of equipment performance Maintenance Support Items I Q-022 0-008 trending data and recommends changes to PM schedules. The ultimate and 2 Q-026 O-029 measure is w hether the equipment runs reliably, with few maintenance related Q-07I O-032 failures. Engineering should identify PMT requirements and acceptance Q-109 O-050 criteria, troubleshooting of complex problems, develop specifications for the Q-134 O-064 procurement of commercial grade parts, and ensure that unauthorized mods Q-143 0-080 are not performed without proper review (50.59) and approval under MWRs. Q-144 0-081 Q- 14 '- O-152 Q-146 O-183 0-258 O-266 46 03.03d Engineering evaluates external information, such as vendor bulletins, SOERs, Operational Issues Evaluation Q-026 0-112 and NRC generic communications in a timely manner and maintain records. - Plan Item 12 Q-048 O-215 Q-050 Q-126 Q-131 47 03.03e Evaluate the degree of Engineering involvement with procedure revisions, Not part of the plan 0-199 50.59s, Part 21 evaluations and Tech Spec and USAR amendments.

48 03.03f The work prioritization process, safety significance of specific work activities, l. Plant Mods Work Plan Q-041 0-037 and the system for tracking backlogged items. The size and shape of the items 2.k,3.b, and 3.f, . Q-043 0-039 Engineering backlog is not as important as the management of the backlog. 2.Maint Support item 1.b.1I Q-059 O-040 Q-061 0-052 Q-084 O-069 Q-095 O-110 0-124 Nebraska Publie Power District Cooper Nuclear Station Page 10 of15 Engineering Self Assessment

ENGINEERING SELF ASSESSMENT 13.0 APPENDIX B - MATRIX OF QUESTIONS / OBSERVATIONS TO IP 37550 (continued)

ITEM 37550 DESCRIPTION OF 37550 SECTION PLAN / . QUESTION OBS.

SECTION SECTION NO. NO 49 03.04 Licensee configuration managen'ent should ensure that design basis Plant Mods Work Plan item Q-001 0-057 documentation is consistent with regulatory requirements, licensee 2.b,2.j,3.a and 3.e Q-023 0-062 commitments and the as-built facility. Q-031 0-131 Q-033 0-132 Q-043 0-133 Q-050 50 03.04 For plant modifications reviewed, there must be assurance that SSCs will Plant Mods Work Plan items Q-120 Para.2 perform their intended safety functions. Consider the following: 2.d,2.f, 2.j and 3. II 51 03.04a Design basis documentation (e.g., design criteria. licensing commitments, and Plant Mods Work Plan item Q-060 0-014 calculations of record) was available and utilized in conjunction with the 2.b Q-073 0-030

' generation of the engineering analyses to support DCs and Mods Q-091 0-038 Q-130 0-060 Q-137 O-063 0-090 0-141 0-151 0-274 O-292 52 03.04b Documents containing design basis information are controlled and updated to Plant Mods Work Plan It'.m Q-031 0-014 ensure they remain current. 2.i Q-073 0-015 Q-113 0-045 O-136 Nebraska Public Power District Cooper Nuclear Station Page 11 of15 Engineering Self Assessment

ENGINEERING SELF ASSESSMENT 13.0 APPENDIX B _ MATRIX OF QUE5TIONS/ OBSERVATIONS TO IP 37550 (continued)

ITEM 37550 DESCRIPTION OF 37550 SECTION PLAN / QUESTION OBS.

SECTION SECTION NO. NO 53 03.04c System design requirements (e.g., system ? ;criptions, calculations and Plant Mods Work Plan item O-070 analysis, component specifications, and drawings) reflect as-built condition of 2.i and 2.j 0-187 the plant and are consistent with the regulatory requirements and 0-233 commitments.

54 03.05 If significant weaknesses are identified in the engineering organization, Were included in plan consider pertinent engineering elements listed below:

55 03.05a Clearly defined responsibilitiesthat are understood by management and staff. l. System Eng Effectiveness Q-016 O-039 The engineering staff understands and implements engineering procedures and Attachment 1, items a-u Q-049 O-097 programs. Consider the overlap and interface between engineering groups. 2. Plant Mods Work Plan item Q-110 Consider the extent and effectiveness of communications between 3.a 0-005 organizations (Ops, Maint and Eng.) Associated with a specific mod package. 3. Eng. Programs Plan items .

2a. 2b,2c,2f, and 2i 56 03.05b Review the distribution of responsibilities between site and corporate NA - All NPG Engineering is NA - All NPG engineering. on site Engineering is on site 57 03.05c Review the extent and reliance on contracted engineering organizations 1. Engineering Programs item O-082 Consider the timeliness and adequacy of followup on concerns identified by 2.s 0-140 the contractors. Determine the degree of ownership of contractor products 2. Plant Mods Work Plan Item and monitoring of contractor work. 2.b and 3.b Nebraska Publie Power District Cooper Nuclear Station Page 12 of15 Engineering Self Assessment

ENGINEERING SELF ASSESSMENT .

13.0 APPENDIX B - MATRIX OF QUESTIONS / OBSERVATIONS TO IP 37550 (continued)

ITEM 37550 DESCRIPTION OF 37550 SECTION PLAN / QUESTION OBS.

SECTION SECTION NO. NO 58 03.05d Review the role of system engineers and their knowledge of system System Engineering Q-016 O-009 requirements and plant design bases. Review SE involvement in activities on Effectiveness Plan (entire Q-029 O-010 their systems, including planned maintenence, mods, surveillance testing, plan) Q-062 0-026 temp mods, operability determinations and disposition of condition reports. . Q-064 O-030 The length of time system engineers havew had system responsibility may Q-105 0-032 affect system knowledge. If this is a problem, evaluate their training. Q-106 O-033 0-036 O-047 O-079 O-094 O-095 59 03.05e Evaluate staffing and utilization to accomodate workload through such 1. Plant Mods Work Plan Item Q-042 0-245 indicators as ability to respond to plant needs within required time frame, 3.b amount of overtime worked, backlog and prioritization, and number of 2. OperationalIssues staffing vacancies. Consider the qualifications of personnel. Evaluation Requirements item 3

60 03.05f Review the adequacy of formal and infomal training programs. In particular 1. Plant Mods Work Plan item Q-065 O-011 review 50.59 training. Also, root cause and operability determination training. 2.b Q-066 O-027

2. Operational Issues Q-107 O-071 Evaluation Plan items 8 and Q-133 10, Q-147 Nebraska Public Power District Cooper Nuclear Station Page 13 of15 Engineering Self Assessment

ENGINEERING SELF ASSESSMENT 13.0 APPENDIX B - MATRIX OF QUESTIONS / OBSERVATIONS TO IP 37550 (continued)

ITEM 37550 DESCRIPTION OF 37550 SECTION PLAN / QUESTION OBS.

SECTION SECTION NO. NO 61 03.05g Review the adequacy of design control procedures, design guides, design Plant Mods Work Plan items 0-016 specifications, engineering administrative control procedures, and 2 and 2.a 0-056 organizational interface control procedures. O-087 O-125 O-128 O-188 O-235 O-256 62 03.06 Review recent evaluations by internally and externally conducted technical 1. Operational Issues Q-045 O-061 audits, such as SSFis. These reviews should assess the depth of technical Evaluation Plan items 7,8,9, Q-046 O-185 reviews performed and issues identified by the licensee and adequacy of and 12. Q-068.

li:ensee resolution of those issues. 2.Maint Support items 1.a.4, Q-082 Adequacy of controls may be assessed by determining how effective the 2.a and 2.d Q-127 licensee performs the following: 3.Eng Programs item 2.0 Q-128

1. Initial identification of the problem. 4. The results of 1995 irs,

2. Elevation of problems to the proper level of management for resolution. SET and 1995 SALP were

3. Root cause analysis. included as TAB 9 of the

4. Disposition of any operability issues. Assessment Plan.

5. Implementation of corrective actions.

6. Expansion of scope of the corrective actions to include applicable related system, equipment, procedures, and personnel actions.

63 03.06 When evaluating engineering activities, consider the timeliness of resolving Plant Mods Work Plan Items. Q-028 O-070 Para 3 engineering findings and the number of repeat findings. Consider the number 3.f,3.g, and 3.h O-124 of mods issued to correct problems with previuos mods. Consider engineering 2. OperationalIssues 0-144 reliance and use of QA and feedback to improve Engineering. Evaluation Plan item 9 O-298 64 03.07 Assess ISEG NA - No ISEG equivalent Nebraska Public Power District Cooper Nuclear Station Page 14 of 15 Engineering Self Assessment

ENGINEERING SELF ASSESSMENT 13.0 APPENDIX B - MATRIX OF QUESTIONS / OBSERVATIONS TO IP 37550 (continued)

ITEM 37550 DESCRIPTION OF37550 SECTION PLAN / QUESTION OBS.

SECTION SECTION NO. NO 65 03.08 Assess programs and process to maintain systems and equipment not in Tech Not in plan Specs, such as RG 1.97 (other than Cat. I and Type A), ATWS, Station Blackout and sollware, available and operable.

Nebraska Public Power District Cooper Nuclear Station Page 15 of15 Engineering Self Assessment

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