ML20137C753

Constitutes Utils Response to SALP Insp Rept 50-298/97-99 & Outlines Focus for Improved Performance

ML20137C753
Person / Time
Site:	Cooper
Issue date:	03/19/1997
From:	Graham P NEBRASKA PUBLIC POWER DISTRICT
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
NLS970054, NUDOCS 9703250107
Download: ML20137C753 (10)

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P.O. DOX W ILL NEB SKA 68321 Nebraska Public Power District "E&7affi""

x NLS970054 March 19,1997 U.S. Nuclear Regulatory Commission Attention: Document Control Desk Washington, D.C. 20555-0001 i Gentlemen:

Subject:

Response to the Systematic Assessment of Licensee Performance (SALP) Report NRC Inspection Report No. 50-298/97-99 Cooper Nuclear Station, NRC Docket 50-298, DPR-46

Reference:

1. Letter to G. R. Horn (NPPD) from L. J. Callan (USNRC) dated February 14, 1997, " Systematic Assessment of Licensee Performance (SALP) Report 50-298/97-99"

2. Letter to G. R. Horn (NPPD) from L. J. Callan (USNRC) dated August 2, 1995, " Systematic Assessment of Licensee Performance (SALP) Report 50-298/95-99" NRC Inspection Report 50-298/97-99 (Reference 1) provided the NRC's assessment of safety ,

performance at Cooper Nuclear Station (CNS) for the period of July 9,1995, through January 11, 1997. This letter, including Attachment 1, constitutes Nebraska Public Power District's (District) reply to the SALP Report and outlines the District's focus for improved performance.

As a result of the 1995 SALP Report (Reference 2), numerous actions were initiated to focus the station on operations, and place Operations in a stronger leadership role. These actions resulted in noted improvements, including the installation of a more conservative operating philosophy.

The District acknowledges that continued improvement is needed in procedural adherence,  :

operator training, command and control, and supervisory oversight. The process that will lead to desired levels of perfo;mance has been initiated by Operations management, and includes establishing and enforcing higher standards of performance for not only Operations, but the entire station. Further, while progress has been made in maintaining a good questioning attitude and corrective action program implementation, increased management attention will assure desired improvement is achieved. To address procedural adherence during stressful situations, changes have been made to require abnormal operating procedures be in-hand once immediate actions have been taken and verified. To address training weaknesses, Operator training in the simulator jD has been shifled from an evaluative to an interactive methodology. This philosophical shift wi .

also facilitate improved communication of management expectations on topics such as procedural l 9703250107 970319 PDR G ADOCK 05000299 @,5 lE!E!B,5lERE * '

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9 NLS970054 March 19,1997 Page 2 of 3 adherence, command and control, and supervisory oversight during operator training. The effectiveness of these changes will be monitored during Control Room and training observations and performance assessments by Operations and Training staff.

The District is pleased with the StafTs recognition ofimproved performance in the Maintenance category. Many of the improvements noted are a direct result of the Performance Improvement Plan developed and implemented during the May 25,1994, forced outage restart efforts.

While some changes, such as the surveillance testing program, have met with success, others, such as work scheduling / planning, have yet to meet management's expectations for improved performance. Consequently, work scheduling / planning is one of six key organizational alignment issues for 1997, and is receiving increased management attention. Improvement plans include implementation of the Life Cycle Maintenance concept. Under this concept, Maintenance, Engineering and Operations activities are integrated to increase reliability and availability of plant equipment and systems, while addressing concerns with schedule challenges to the operating crews.

Improvements have been achieved in Engineering through focused, deliberate management attention to correct and improve the station's engineering infrastructure. Although the rate of progress at times has been frustrating to the Engineering organization, and Staff, it has been steady and concentrated in those areas and activities associated with the organizational foundation essential to long term continuous improvement. Details for continued performance improvement in this category are provided as Attachment I to this letter, and more detailed information will be provided by mid-April.

In the area of Plant Support, the District acknowledges both the areas ofimproved performance and the weaknesses noted by the Staff. Program improvements in Radiological Protection implemented in response to the 1995 SALP Report resulted in the lowest total person-rem exposure in plant history being achieved during 1996; and performance in the physical security program remained superior. These achievements are balanced by less than superior performance in the areas of Emergency Preparedness and Fire Protection. Accordingly, management attention continues to be focused on improvements needed to support improved performance during the next SALP period.

To address the site-wide issue of procedural adherence, this topic was added as the sixth key alignment issue for resolution during 1997. Immediate actions have been taken to establish and communicate management's expectations to site personnel. Additionally, follow-up actions are in place to monitor progress and assess the effectiveness of actions taken. CNS management considers this a significant issue hindering overall improved performance.

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NLS970054 March 19,1997

Page 3 of 3 In general, the District views the recent SALP period as a transitionary phase in the plant's history. Under new management, numerous fundamental weaknesses were identified, Performance Improvement Plans implemented, and foundational corrections made to the organizational infrastructure necessary to achieve and maintain continuous performance improvement. With the closure of the Phase 3 Performance Improvement Plan at hand, this transitionary phase of Cooper's history will also come to a close. Sustained and directed performance improvement will be accomplished through the Nuclear Power Group Business Plan. Using this management tool, alignment goals will be established and specific supporting initiatives, projects, and improvements targeted to achieve the stated goals. To assess the rate of performance improvement, performaru ,ndicators will be developed where needed. Progress will be monitored frequently, reported to senior management regularly, and adjustments made rapidly in any area deemed not to be resulting in the expected improvement.

As the District is committed to maintaining an open and candid dialog with the Staff, CNS management will continue to provide objective, accurate and timely progress reports on a iegular basis through day-to-day contact and periodic management meetings. The CNS management team and staff are confident ofits ability to improve the station's performance, and reach the desired level of safety margin and performance necessary for long term station operation.

Sincerely, PMx P. D. Graham Vice President - Nuclear

/crm Attachment cc: Regional Administrator USNRC - Region IV Senior Project Manager USNRC - NRR Project Directorate IV-1 Senior Resident Inspector USNRC NPG Distribution

Attachment I i

to NLS970054 Page 1 of 6 3

CNS SALP REPORT 50-298/97-99 l PLANS TO ACHIEVE PERFORMANCE IMPROVEMENT IN THE ENGINEERING CATEGORY Cooper Nuclear Station (CNS) has identified four primary areas from the February 14,1997, Systematic Assessment of Licensee Performance (SALP) Report, to address in this response. The four areas are: System Engineering Performance; Design Basis and Configuration Control; Roles,-

Responsibilities and Expectations; and Corrective Actions. For each of these four areas discussed below, the CNS management view of current performance is described and a brief overview of the actions planned or in process is provided. i System Engineering Performance 4

There has been much improvement in System Engineering since performance of the February 1996 Engineering Self Assessment. In particular, many improvement efforts have shown positive results and progress since the Engineering Self Assessment Follow-up conducted in October  ;

1996. Management recognizes that continued aggressive involvement and emphasis is required to achieve our desired level of performance. However, recognition of performance improvements

,J and completed actions is necessary in order to accurately assess the actual improvement being achieved and the acceptability of the rate ofimprovement.

Major improvements within System Engineering include, or are reflected in:

Enhanced ability to monitor system health. l Increased quality and number of training certifications.

4 Improved day-to-day involvement and resolution of plant operational issues.

Volume and quality of inter- and intra- departmental communications.

Elimination ofinappropriate or low value work activities.

Increased involvement in Life Cycle Maintenance and Maintenance Rule.

Improved access to and knowledge of system design basis information Time spent walking down systems.

Participation in system testing and system maintenance scheduling.

Some accomplishments of note in these areas are described below.

3 A System Health Monitor report for 49 systems is now on the CNS Intranet. This computer report includes information about the major equipment, operability, design and Maintenance Rule issues affecting the system. Additional software has been purchased to permit electronic access to system trend and monitoring data and easier manipulation and display of that data. This additional capability will be installed and in use by September 1997.

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l Attachment I to NLS970054 Page 2 of 6 i

Day-to-day involvement and resolution of operational and maintenance issues has dramatically

improved since February 1996 as indicated by Engineering's customers. System Engineers have been relieved of many low value activities, or activities better performed by others. Two of the most important examples are Nuclear Action Item Tracking (NAIT) Items and MWR reviews. A staff augmentation consultant was hired to assist with backlog reduction. During this effort, the majority of backlog NAIT items were redistributed from System Engineering to the other engineering groups and the consultant. The number of NAITs in System Engineering has  ;

remained relatively constant since that time. Review of each MWR before implementation and I following completion has been eliminated. The Maintenance Planners and System Engineers now work together to set guidelines for when System Engineer involvement is needed.

Life Cycle Maintenance will be implemented following the 1997 Refueling Outage. This has required significant System Engineering participation in Preventative Maintenance Optimization, component PM Standard development, development of functional equipment groups, l establishment of on-line system outage windows and review of preventive, corrective and 1 predictive maintenance to schedule the appropriate work during established system windows.

With the exception of one newly hired System Engineer, all System Engineers have completed the Engineering Support Orientation Training Program and the System Engineer Specific Orientation ,

Training Program. Thirteen System Engineers have completed System Engineer Position Specific Training Qualification and four System Engineers are expected to complete this program shonly.

l In addition,16 of the System Engineers have completed the new 3 week systems course, developed in February 1996, and the system engineers attended the Operator License Training class presentations during 1996 that pertained to their systems. The fully staffed System Engineering Group currently contains 5 engineers (out of 17 total System Engineers) with current l or previous SRO/STA/STE certification, whereas, immediately following the reorganization, System Engineering had only one STA certification.

System Engineering has made good, steady progress in its capability to identify, rigorously evaluate and effectively resolve day-to-day operational and maintenance issues and problems. In i addition to the examples cited in the SALP Report, two recent examples of the improvement l made in this area are the Cooper-Besemer diesel cylinder liner cracking issue and the Limitorque I motor lead issue. In the case of the diesel cylinder liners, System Engineering noted the cracking concern identified at another utility and took immediate action to investigate the potential for this condition at CNS (including sending the Diesel System Engineer to the other plant to look at tne condition first hand) in order to ensure an adequate evaluation of the condition at CNS. These actions were taken prior to formal notification of the industry. In the case of the Limitorque motor lead issue, proactive action is being taken to make the appropriate modifications to the afTected CNS valves during the March 1997 refueling outage even though an oflicial NRC l position has yet to be documented.

l Attachment I to NLS970054 Page 3 of 6 System Engineering has also made progress in its ability to be forward looking and to resolve issues before they become operations and maintenance issues. Examples of this include the i

Preventative Maintenance Standards that the System Engineers are developing, with Maintenance, and the PM Optimization that is being performed for 13 systems, for implementation immediately i following the March 1997 refueling outage. These efforts will help to ensure that the right preventative maintenance is performed at the right times, to avoid equipment challenges. The l challenge now is to continue to improve in this area and to better balance the proactive and reactive components of the engineering support function.

Management has identified the following actions to continue to improve System Engineering's ability to respond both proactively and reactively to plant needs :

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1) Implement the new monitoring and trending software to make system performance monitoring easier for System Engineers by September 1997.

2) Additional performance indicators that clearly track System Engineering results are under development.

3) System Engineers will be provided enhanced problem solving skills training.

Design Basis and Configuration Control Significant progress has been made in providing a user friendly, documented and retrievable design basis. This is most evident in the completion of the twenty-two safety-related system and eight topical Design Criteria Documents (DCDs), and the on-going mLintenace and improvement of these documents.

A complete re-engineering of the Change Control Processes has resulted in many improvements in l configuration control. Some of these improvements include:

Addition of requirements to complete procedure and drawing updates at the time of Modification Package approval to prevent backlog creation and simplify package closure.

Improved configuration document checklists added to the change process to ensure relevant documents are properly updated.

Supporting improvements in the drawing control process to ensure that Control Room drawings are updated in a more timely manner and to ensure that peiiding drawing changes are accessible and retrievable.

Development and implementation of a process to evaluate and disposition as-found field discrepancies.

Implementation of administrative controls for the use of engineering judgements.

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Attachment I to NLS970054 Page 4 of 6 Separation of modification design development from implementation instruction development.

The process now utilizes modification planners to ensure proper use of resources and expert review ofinstallation instructions by work planners.

Improved controls over plant labeling.

Implemented new guidelines for improved as-building of Control Room drawings before release to Operations following a modification.

e The efrort to develop and submit the Improved Technical Specifications (ITS), which involved significant Engineering evaluation and review, is complete. The instrument setpoint calculations, which provide the analytical limits and setpoint bases for the ITS instrument setpoints, have been upgraded to a state of the art, NRC approved, setpoint methodology. The CNS LOCA Analysis has been revised and submitted for NRC approval. In addition, Engineering has completed the analytical work necessary to rebaseline the 10 CFR 50 Appendix R Fire Protection safe shutdown analysis. These four Engineering intensive efforts have resulted in major improvements in the understanding and documentation of many aspects of the plant design and licensing basis.

Additional improvements being implemented during 1997 to continue to strengthen design basis knowledge and use, and configuration control, include the following:

1) The Engineering backlog identified in July 1996 that was to be assigned to a consultant (approximately 1800 items)is expected to be eliminated by August 1997.

2) The Updated Safety Analysis Report rebaselining effort currently underway will be completed by October 1998.

3) Complete the screening and/or review of historical documenis that may have inadvertently installed a plant configuration change for potential unauthorized modifications by December 1997. At the present time, approximately 150 of the approximately 500 currently identified unauthorized modifications have been resolved and approximately 8800 of the nearly 34,000 historical MWRs, screened as requiring detailed review, have been reviewed for potential unauthorized modifications. Significant changes in the work control processes have previously been made, and site wide awareness has been raised, to provide assurance that new unauthorized modifications are not installed.

Roles. Responsibilities and Expectations Significant management attention has been applied to the establishment of expectations and definition of roles and responsibilities since the February 1996 Engineering Self Assessment.

These efTorts have resulted in clearer focus and improved understanding ofindividual roles and responsibilities. For example, a set of written roles, responsibilities and expectations for the Engineering Division was published and discussed over the course of several months at the group, department and division level.

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Attachment I to NLS970054 Page 5 of 6 Organizational units have taken full ownership of their roles and responsibilities (for example the MOV Group, Reactor Engineering, Civil Design Engineering and the ISI/IST Programs Group). -

As the organization matures and adjusts to continuous improvement, roles and responsibilities will

' continue to be adjusted to fit needs.

As noted in the SALP Repon, Engineering performance in some areas has been inconsistent.

CNS management believes that this inconsistent performance is related to the infrastructure from which Engineering bases its performance. This infrastructure includes both technical and administrative information and processes, training and qualification, and includes management skills, such as setting clear standards for performance and holding individuals accountable for meeting the standards. In the SALP Report, the NRC concludes that our inconsistent performance is a result of CNS being ineffective in conveying clear standards to the Engineering Organization. This conclusion, although partly correct, is not based on a root cause analysis of the situation, and does not address the crux of the problem. CNS engineering management has very concisely and clearly conveyed standards for performance to the Engineering Organization, but has not efTectively enforced these standards through training, coaching, and accountability.

Additionally, the remainder of the CNS staff, and in particular Maintenance and Operations, has not demanded from our Engineering Organization the level of performance necessary to meet our standards. Our future focus, therefore, must be on continued development of the Engineering infrastructure. This includes continued improvement in engineering technical information and processes, as well as improvements in management skills.

Management attention is being focused on communicating performance standards, and not accepting low performance levels. These standards willinclude appropriate emphasis on safety focus, questioning attitude, engineering rigor and procedural compliance in all engineering activities. Special attention will be applied to root cause evaluations, corrective actions and follow-up to ensure effectiveness, and to the thoroughness, technical accuracy and rigor applied to operability assessments and 10 CFR 50.59 safety evaluations. This increased focus will be manifested in the form of continuing training; in the setting of expectations for supervisors and managers with respect to monitoring, coaching and oversight; follow-up to ensure that expectations and performance standards are being met; and the appropriate use of performance indicators.

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. Corrective Actions In order to bring completion to the long standing issues in Engineering, management began last November by focusing improvement plans on the most important activities that need attention.

This resulted in the "Must Do" list that was shared with the NRr tathe December management meeting in Region IV. Engineering has made significant proc n in completing these "Must Do" items. The top item on the list, Engineering Support Personne Training, is complete and the

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Attachment 1 to NLS970054 -

Page 6 of 6 renewal of this training program is scheduled for March 20,1997. Trainmg Program involvement and continuous improvement is fully ingrained in the culture of the Engineering Division and has i been established down to the engineer level as a lasting part of the engineering function. Other  !

"Must Do" items that have been successfully completed or to be completed by April 1996

, , l include the 50.54(f) response, establishment and active participation in the Fix-It-Now (FIN)

Team, and completion of the original scope of outage modification development. Other items on the list of thineen "Must Do's" are progressing on schedule. Engineering will continue to focus on a relatively short list of the most impodant issues, providing focused management attention on complete and final resolution, and adding new issues as old ones are resolved. There were fourteen items on the "Must Do" list in December 1996. Of that total, three have been completed, five are expected to be complete by September 1997, and the remaining five are on schedule for completion by December 1997.

In addition, several additional actions are being considered to further strengthen Engineering's i

ability to identify and implement effective long-lasting corrective actions. These actions will be provided in a follow up letter by mid-April.

The CNS Engineering Division has made considerable progress in the past two years. There have been major improvements in the infrastructure that provides the base for good Engineering performance Engineering is poised to make rapid and demonstrable improvements over the course of the remainder of this year. The Engineering Organization is committed to continuous improvement and continuously higher performance standards that will ensure excellent engineering support at CNS. The progress toward achievement of these goals will be measured, adjustments will be made rapidly when needed, and the StafTwill be regularly updated in a candid and open dialog on Engineering perfonnance.

4 Note that this response is intended to be a brief status only; the actions detailed above are informational in nature and not specific commitments. As such, detailed plans for continued improvement in Engineering at CNS, as well as the measures to be used to gage performance, will be included in a follow-up letter to be submitted by mid-April.

. , l 4 l l ATTACHMENT 3 LIST OF NRC COMMITMENTS l ]

l Corrbspondence No: NLS970054 The following table identifies those actions committed to by the District in this document. Any other actions discussed in the submittal represent intended or l planned actions by the District. They are described to the NRC for the NRC's I information and are not regulatory commitments. Please notify the Licensing Manager  !

at Cooper Nuclear Station of any questions regarding this document or any associated '

regulatory commitments.

COMMITTED DATE COMMITMENT OR OUTAGE Additional details for continued performance improvement Mid-April, 1997 will be provided.

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l PROCEDURE NUMBER 0.42 l REVISION NUMBER 4 l PAGE 8 OF 9 l