ML20198C222
| ML20198C222 | |
| Person / Time | |
|---|---|
| Site: | Cooper  |
| Issue date: | 12/31/1997 |
| From: | Horn J NEBRASKA PUBLIC POWER DISTRICT |
| To: | NRC OFFICE OF ENFORCEMENT (OE) |
| References | |
| 50-298-97-07, 50-298-97-12, 50-298-97-7, NLS970215, NUDOCS 9801070223 | |
| Download: ML20198C222 (18) | |
Text
- - _ - _ _ _ _ _ _ _ _ _ _ - _ _ _ _ _ _
2>2-s m
GENE RAL Of FICE c.m P O DOR on COLUuDus. NEBRA%KA t,8002 069 Nebraska Public Power District
"/n"s@2"
~ evenermemmamacuumwuammmwemwm-mmw-wmmee-weew-mme t
G. Il florn Senior l'ke l' resident vf1:nergr Supply NLS970215 December 31,1997 Director, Office of Enforcement U.S. Nuclear Regulatory Commission Washington, D.C, 20555 0001 Dentlemen:
Subject:
Reply to a Notice of Violation NRC Inspection Report No 50 298/97-07 and 9712 Cocper Nuclear Station, NRC Docket 50 298, DPR-46
Reference:
letter to G. It llorn (NPPD) from E. W. Merschoff(USNRC) dated December 1, 1997," NOTICE OF VIOLATION AND PROPOSED IMPOSITION OF CIVIL PENALTY - $110,000 "
(NRC Inspection Report Nos. 50 298/97-07 and 9712)
Ily letter dated tjecember 1,1997 (Reference 1), the NRC cited Nebraska Public Power District (District) as being in violation of NRC requirements. This letter, including ' ttachment 1, provides the District's admission of and reply to the referenced Notice of Violation in accordance with 10 CPR 2.201. Attachment I details the reasons for the violation and specifies the corrective actions for each of the nine examples in Reference 1. In addition, corrective actions addressing the overall Corrective Action Program ellbetiveness issue are discussed. is a certified check in the amount of $110,000, for payment of the civil peneliy.
The District agrees that implementation of the Cooper Nucicar Station (CNS) Corrective Action M'
N Program (CAP), overall, has been ineffective. A detailed plan was established in 1994 g*
describing the elements which would make CAP cffective implementation began taJ g
preliminary results indicated that progress was being made. Ilowever, the plan did i.mntinue g-to receive the appropriate level of Management attention tmd emphasis, and progress reeched a N'
- plateau. The root cause was a failure by Management, in that it mistook pregren in the CAP for N'
success, and aggressive management involvement and direction was removed too soon. Once emphasis was removed. netions to correct identified weaknesses and change the fundamental h'
behaviors of the statien were never fully realized. As a res. tit, Management did not ensure that the required knowledge and skills to promptly recognize and identify problems, evaluate and understand causes, and take effcetive, long lasting, comprehensive corrective actions, was t
established throughout the organization, jb,///
in tb: late fall of 1996, Management began to recognize that the corrective action program was no longer impmving, and in particular, problem identification was weak in particular areas of the
.,a
+
%MO70223 971231 h
m,&
ItDN
.) [ h k f l l ?.
D
_mm.
m m
=..
m m_
-mmmmmm
~= mm
s N1.S97021$
I)ecember 31,1997 Page 2 of 4 organization. Senior hinnagement began to re emphasize problem identification, and notable improvement was made in lowering the threshold ihr reporting as evidenced by an increased number of Problem identification llepons being initiated.
In early 1997, Senior hianagement also realized that corrective action effectiveness did not meet established standards, and an initiative was begun to align the station organization on improving the effectiveness of the Corrective Action Program. This initiative included emphasis at daily meetings, development of talking papers fbr supervision to use with their stafTs, reinforcement of positive behaviors, and enfbreement of accountability where perfbnnance did not meet expectr.tlons. Senior hinnagement believes that the identification and successful resolution of the Z sump longstanding design flaw, and the Diesel Generator relay testing issue were the direct result of the increased emphasis placed on improving our Corrective Action Program.
Station hinnagement recognizes that an effective Corrective Action Program is a comerstone fbr contimdng safe op" ration of the plant. Clearly, a more aggressive approach is required, and it must be sustained. As such, hianagement has established a Corrective Action Program improvement strategy, and actions that will improve performance. liighlights of the strategy include actions to funher educate the hinnagement Team on its roles and responsibilities in implementing our Conective Action Program, pinpoint measures and behaviors for improved performance, and measurenant of the results. hianagement accountability will play a much more aggressive role than in previous attempts to improve Corrective Action Program perfc mance. Specific changes to the Corrective Action Program implementation include:
assigning the Co:Tective Action Program to the Plant hianager and the station line organization to emphasize line organization ownership; establishment of a Nuclear Safety Assessment Group (NS AG), composed of senior, experienced individuals who will be responsible for assuring proper issue recognition and safety classification, perfonn root cause evaluations, and provide euucational opportunities fbr the ttation staff, and, impmvemcats in the station's trending capability and closcout reviews to add assurance that the actions taken efTectively address and correct the identified issue. The establishment of the NSAG, combined with perfonning back-end reviews by CitG are measures to provide inunediate and efTective improvements, while changes in the organization's standards and behaviors associated with an efTective Corrective Action Program me pursued. These actions will remain in place until sustained improvement is demonstrated.
Senior hianagement recognizes that a technically sound, aggressive engineering program is also a cornerstone for continuing safe operation of the plant. Although not a specific example used in this violation, hianagement recognites that our failure to significantly improve our Engineering Department's effectiveness is a direct reflection on our Corrective Action Program's ineffectiveness. Clearly, Engin:ering hianagement's perfonnance haa not met Senior hianagement's standards, and Senior hianagement takes full responsibility and accountability for not taking efTective conective action to resolve this situation. The root cause for this hianagement failure is similar to the root cause identified above. Feedback indicated that engineering was continuing to improve their perfoimance, and Senior hianagement took this feedback as a signal of success. Emphasis was removed, and attention was distracted.
hianagement, supervisoiy, and leadership skills were not recognized earlier as being deficient in l
l
r d.
NLS')70315 -
l December 31,1997 i
Page 3 of 4 the lingineering hianagement Team, and actions taken to correct these weaknesses were not i
pursued in a timely and aggressive manner.
The Engineering Management Tearn is fonnulating a strategy and corrective actions to i,lgnliicantly imptove their perfonnance. Details of this strategy are still under development, but j
will include: an engineering resource i,tudy, the installation of experienced engineering supervisors and managers to quickly address the behavbrs and standards irsue, the formation of sn Engincedng Assunmce Group to maintain high standards for engineering work products, the institution of an engineering work management system that will allow Engineering hinnagement to effectively allocate resources; and, the develop nent of specific engineering perfonnance j
measures that Senior hianagement will use to monitor and adjust improvement initiatives.
I suggest that the engineering focus meeting that will be scheduled in January 1998, and i
thereafler, be used to address our Corrective Action Program and engineering improvement actiom taken and results r.chieved to date.
Should you have any questions concerning this matter, please contact me.
Sin rely,
.1 om
- Wice President, Energy Supply j
llrd i
Attachments i
i ec: Regional Administrator USNRC - Region IV j
Senior Project hianager
- USNRC NRR Project Directorate IV 1 i
Senior Resident inspector r
USNRC NPG Distribution -
t I
. i
?
t y
ef-w=y--gu,..,
m r,
s
.e
,.y,,
e
-y,. - -
4 w,a_,4.%.,
ro w.
...w w,. - -,..e
+
y y ev e..edr.ws,rwc.,-1._-
n -o.
\\
. 1
'. i NIS970215
' December 31,1997 Page'4 of 4 4
i STATl!OF NEllRA$K A.
)
)
t PIAITE COUNTY
)
P G. R; llom, being first duly swom, deposes and says that he is an authorized representative of l
i the Nebraska Pubile Power District, a public corporation and political subdivision of the State of
- Nebraska; that he is duly authorized to submit this correspondence on behalf of Nebraska Public Power District; and that the statements contained herein are true to the best of his knowledge and
- belief, j
1
~,)Gw G. R. Ilom J
Subcaribed in my presence and worn to before me thisd/ day of
/M>n[(A>l997;
- t t
REW WIWsus W mkeh M
esp yh
/
y NOTARY PUllLIC t
e e
r
?
a I
r
+
.4
~
e
.-,.g..w..
w...
r to N1 S970215 Page 1 of 12 lli!Pl.Y TO Dl!CliMHi!R 1,1997, NOTICI! Ol' VIOLATION COOPFR NUCl.liAlt STATION NRC DOCKl!T NO. 50 298,1.lCENSE DPR-46 During NRC inspection activities conducted from June 29 through August 9,1997, and July 8 through September 5,1997, violations of NRC requirements were identified. The panicular violations and the District's reply are set forth below:
Violation A. 10 CFR Part 50, Anpendix P, Criterion Xi'lrequires that measures shall be established to anure Ihat cond::lons c.dverse to quality, such asfaihtres, malfimctions, deficiencies, deviations, defective material and equipment and nonconformances are promptly identified and corrected in the case of'significant conditions adverse to quality, the measures shall assure that the cause of'the conditions is determined and corrective action taken to preclude repetition. The ident!11 cation of'the condition. and the corrective action taken shall be documented and reported to the appropriate levels of manojement.
1.
Contrary to the above, benveen December i994 andJuly 1997, established measures d;I not ident!17 and correct u ater retention in the o.figas system holdup line, a sign!ficant condition adverse to quality. Tids conditicn could have under certain circumstances, rendered both trains oflht slandby gas treatment systCm inopCrahle. (0101])
Admission or Deniaho Violation The District admits the violation.
Reason for Violatien The failure to identify and correct water retention in the off gas system 48 inch hold up Ime between December 1994 and July 1997 was the result of a failure to perform a thorough evaluation upon discovery of the potential (br the non-essential Z sump pump power supply to impact the operability of the essential 'handby Gas 1 reatment (SGT) system. The 1994 modification addressed the link between Z sump and SGT operability upon loss of olTsite power.
The modification Ibcused on restoring power to the Z sump pumps prior to a time when anticipated condensation draining to the sump would reach a level impacting the SGT system.
inadequate questioning attitude and failure by Management and Engineering to postulate the intrusion of othei sources of water into the Z-sump, led to the ineffective decision to not install permanent " essential" power in 1994, but rather make it available in an appropriate paiod of time.
Cmetive Steos Taken and the Results Achieved Interim coITective actions were taken to modify the system to eliminate the potential for water accumulation in the 48 inch hold up line. Additionally, pressure indication was installed to allow monitoring. Special testing has been perfonned with the "A" train of Augmented off gas
s Attachment i I
to N1.S970215 Page 2 of12 (ADG)in service. !!ngineering has confirmed that the water accumulation in the 48 inch hold up line does not occur with the "A" train of AOG in service.
Dnective Skps 'Ihat WilLDe Taken tojagd Further Violations To avoid further violations, essential power will be supplied to the Z sump pumps.
To address the overall Corrective Action Program ineffectiveness issue, hianagement has initiated action to emphasize and fbcus hianagement's attention on the measures and behaviors of an effective Corrective Action Program. Our response to the ove all Corrective Action Program violation is included later in this attachment. This aspect of our corrective steps that will be taken to avoid further violations is applicable to each example cited in this violation, but will not be included in the specific response to each.
Date When Full Comp.liartce Will lle Achieved The District is currently in comptinnee regarding the identified violation. Completion of our actions to upgrade the power supplied to the su'np pumps to essential power will be completed by hiarch.11.1998.
2.
Contrary to the abm'e, as ofAugust 1997, established measures did not identifi or correct inadequacies in the heat exchanger testing prograin which allowed significant degradation of the "H " Residual Heat Removal System heat exchanger, a significant condition adverse la quality. Additionally, the s ause ofthe significant condition adverse to quality was not identifled and, once identifled to the licensee by the NRC, corrective action to preclude repetition had not bt en identifled or taken. (01023)
Admission or Denial to M9]ntien The District admits the violation.
}kason_ for Violation The failure to appropriately respond to the degraded condition at the time of discovery and during follow up investigations was the result oflow Station hianagement and Engineering hianagement standards for safety conscious decision making, which was manifested in acceptance of the condition as routine and expected. Low management standards for questioning attitude and the pursuit oflong standing issue resolution contributed to this hianagement failure.
In addition, the low standards alTected the performance of the Condition Review Group (CRG) and Station Operating Review Committee (SORC), and prevented these groups from recognizing the seriousness of this conelition.
i l
s Attachment I to NI.S970215 Page 3 of12 (sective Steps Taken and the Itesults Achieved 1.
1111111IX Il was cleaned and retumed to operability in accordance with its design basis.
t 2.
A Significant Condition Adverse to Quality (SCAQ) condition report was initiated and evaluated to detennine the root cause, corrective actions, and actions to prevent recurrence of significant fouling of the heat exchanger.
3.
A review was conducted of past operation, maintenance and testing to determine if either itilll llX-A or D could have been significantly degraded in the past. No similar conditions were found.
4.
hianagement involved in the event was counseled on the importance of professional conduct and perfonnance requirements relating to heat exchanger perfonnance monitoring.
5.
Testing of one 111111 heat exchanger has been added to the Forced Outage Strategy Guldebook and the Plant hianager and Senior Engineering hianager have reintbreed the expectation that this testing shall occur at the frequency specified in the GL 89 13 program.
6.
Procedure 0.5, Pmblem Identification and itesolution, was modified to include the requirement to use a Problem llesolution hiatrix to address Significant Conditions /
Conditions Adverse to Quality requiring a root cause. A key element of change is the requirement to specifically address the safety significance of the condition.
Correctivejitsps Thadhlljkloken to Avoid Further Violations 1.
Rllit lleat Exchanger perfbnnance testing of at least ora heat exchanger will be perfonned during the scheduled mid cycle outage, or befbre, if there is an unscheduled Ibreed outage.
2.
Ile evaluate the Generic 1 etter 8913 maintenance and testing program, related commitments, and prognun implementation.
3.
I evelop a fonnal Genue lxtter 89-13 program document, with defined ownership,
" roles and responsibilities," and program criteri.'.
4.
111111 Ileat lixchanger preventive maintenance (Phi) tasks and procedures will be revised to include references to the appropriate bases (br test and cleaning frequency.
5.
Rllit lleat Exchanger Perfbnnance Evaluation Procedure (Proadure 13.17), which pmvides instructions to personnel to collect data on the heat exchargers for monitoring and trending heat exchanger perfonnance, will be revised to require its perfonnance as specified in the GL 8913 program.
s Attachment I to NLS97021$
Page 4 of f 6.
incorporation oflessons learned into the maintenance procedure for cleaning the 111111 heat exchangers.
7.
Provide additional training on problem recognition and sensitivity to safety significant issues to station management, the CitG, and the SOllC.
8.
lxssons leamed from this issue are being reviewed with lingineering personnel in fourth quarter Engineering Support Personnel (lisp) Training.
DMg_When Full Compliance Will lie Achieved RilR lleat I?xchangers A and 11 are operable and in compliance with design requirements, however the District will not declare full compliance with the identified violation until the GL 89-13 program has been re-evaluated and a fonnal program document developed. This will be completed by January 31,1998.
J.
Contrary to the above,,for thefullmving conditions adverse to quality, each ofu hich constitutes a separate violation, catablished measures did not:
a.
Identify and correct degraded seats offimr torus-to-drywell vacuum breaker valves, which were evident during testing in Afay I997 c.nd required modification ofthe testingprocedure to allow completion. The valve conditions became evident again during testing in July I997, and the licensee corrected the condillon. (01033) zhlnjission or Denial to Vhillint)
The District admits the violation.
nson for Violatian The reason for the violation was a lack of conservative decision making, and a questioning attitude by fingineering and hianagement regarding the condition of valves that had failed to meet established surveillance testing criteria.
Corrective Steps Taken and the Results Acitieved Actions were taken to shut down the plant in accordance with Technical Specifications, and inspect the torus-to-drywell vacuum breaker valves. Inspections revealed valve degradation, however, the conditian of the valves should not have prevented them from performing their safety function. hiaintenance was performed and the valves were satisfactorily tested prior to retuming the plant to operation.
5 to N1.S970215 Page5of12
' Gnhtive Steps That Will lic Ttdiep to Avoid Further Violallens A new method for establishing initial testing parameters will be developed and as found leakage rates will be determined at the end of each operating cycle (at or near shutdown for refueling outages).
An evaluation of the Preventive Maintenance Program is currently being conducted, which will address appropriate management standards for perfonning preventive maintenance.
Date When FulLCempliance Will lie Achieved The District is in full compliance regarding the identified violation.
3.
h.
(Established measures did not] preclude recurrence offailure tofollow Procedure 4,13. " Elevated Release Point and Huilding Radiation Afonitoring Systems, " used to return to service the continuous lodh.e andparticulate sample radiation monitorfor the elevated release pointflowpath. its a residt, on July 14, I997, there was no sampling of the elevated release point dischargeflow during a routine egluent release. (010D)
Admission or Denial to Violation
'the District admits the violation.
Reason for Violation
'lhe reason for this violation is failure of Operations Management to establish high standarda for p"rfbmiance in situations where operators encounter unexpected conditions. llecause the appropriate standards had not been established, the operator made incorrect assumptions, and failed to enlist the help of shin management in detemiining the appropriate course of action.
Compounding the failure in this situation was an ineffective pre-job brief by shift management.
Centslive Steps Taken and the Results Achieved Upon discovery of the error (approximately 16 hours1.851852e-4 days <br />0.00444 hours <br />2.645503e-5 weeks <br />6.088e-6 months <br /> later), the Elevated Release Point (ERP)
Kaman was placed in the proper condition per the applicable procedure. The operator who had made the error was counseled on proceeding when uncertain conditions exist.
The Chemistry / Radiological department has taken ownership for station radiation monitors including the associated procedures.
Attachment I to NLS970215 Pagc 6 cfl2 Cerrcetive SJcps 'Ihat Will lle Taken to Avoid Funber Violah Operations Management will reinforce high standards for aperator perfumance, including procedure use and adherence, encountering unexpected s tuations, and cornmunicatior.s.
Standards for the conduct and adequacy of pre je$ briefs will be re-emphasized.
llate When Full Compliance Willlle Achieved The District is in full compliance regarding the identified violation.
flhtablished measures did not.] as ofAugust 1. I997, Ident# and c, t long-3.
c.
standing, recurring testfailures associated with emergency dieselgeni s
,r breaker testing, a condition adverse to quality, in that the operablHty assessment did not address the possibility that previous surveillance results had been invalid, or the inadequacy oflong standing instructions to technicians to repeat the test until acceptable results were achieved. (01053)
&lmission or Denial to Violation e
'lhe District admits the violation.
Iteason for Viola. lieu The reason for this violation was low Maintenance and Engineering Management standards associated with post modification testing and lack of a questioning attitude. Additionally, failure of the Operability Assessment to appropriately address the validity of previous surveillance testing results is indicative of management standards that did not meet current industry expectations.
~
CatItfilXe Steos Taken and the Itesults Achieved The test methodology was revised to a more reliable method. In addition, management emphasized and is continuing to reinforce that long-standing problems are unacceptable and that CNS will not accept a " test till pass" mentality.
Corrective Steos That Will Be Taken to Avoid Further '. iolations No additienal corrective steps are bemg taken specific to this issue. llowever, the Opciability Assessment program perfomiance standards are being raised to meet industry guidance in a procedure revision expected to be complete by January 31,1998.
Date When Full Con 1pliance Will 11e Achieved The District is in full compliance regarding the identiced violation.
11 I
I 11'II l'I'
Attaclunent I to NLS970215 Page'iof12 9
3.
4 (Estabitshed measures did not] preclude recurrence offallare tofollow procedures, in that corrective actionsJbr the June 19 and 20,1996,Jalhore to use proceduresJhr opening and closing ofthe secondary containtnent hatch did not i
linplement the procedure to secure the hatch. as required. (01063)
AdmissiorwtDenial to Viehtien
'lhe District admits the violation.
Ikahen for ViolgliOB
'lhe reason for the violation was Manag<: ment's failure to adequately communicate the expectations and standards for procedural adherence and conservative de:ision making.
forrective Steps Taken2md the Itesults Achieved
'the reactor building roof hatch was closed per procedure.
Corrective Stens That Will lie Taken to Avoid I urther Violations i
Procedure adherence is being monitored and reinforced at the station to ensure continued improvement in this area.
Date When 1 ull Compliance Will lle Achieved The District is in full compliance regarding the identified violation.
(Established measures did not] correct conditions adverse to quality in that the 3.
c.
corrective actionsfor a May I996 uru.athari:cd modification to the No. 2 Emergency Diesel Generator that installed a J-tube on the Emergency Diesel Generatorfailed to identify untilJuly ) 7, I997, thatfive additional unauthori:ed modifications that had been inAlalled at the same time as the J tube. (01073) dibniniD.ttor Deniallg YJ2 blind The District admits the violation.
Reason for Violation The exclasion of this walkdown of the Cooper Bessemer portion of Design Change (DC) 93 024 was base;d on the assumption the Cooper-Bc>semer components were installed under their (Cooper llessemer's) Appendix 11 program. The unauthorized modification (J tube) was installed by contracted crafl working under the NPPD QA program. The corrective action was
4
\\
to N1.S970215 Page 8 of12 inNective in that it did not adequately bound the as building discrepancies of DC 93-024. This was due to the failure to exercise conservative judgement on determining the extent of the condition.
Conectivelikriluken and the Results Achieved 1.
'lhe remainder of the Cooper llessemer installed components were walked down and "as-built." Drawing Change Notices (DCNs) for identified discrepancies during this walkdown are being processed.
2.
Post modification walk down procedural guidelinc were strengthened.
3.
Training requirements which clearly defined responsibilities and expectations for field engineers when following a modification installation were developed in order to prevent additional unauthori/cd modifications from occurring.
4.
Site awareness regarding unauthorized modifications and need for configuration control has been significantly enhanced.
5.
Outage contractor training has been enhanced.
Centgjive Steps _'Ihat Will lie Taken to Avoid Further Violations Guidance for determining the extent of the condition will be added to the Preblem Identification and Resolution Procedure to assist in evaluating issues of this nature.
Ihit_When Full Con)pliance Will lie Achiesed
'the District is in full compliance regarding the identified violation.
3.
f flhtablished measures dH not] correct wrimg acceptance criteria in Surveillance Procedure 61E602, IdentWed on June $ 1997, with the result that the incorrect criteriafor the specfle gravity of the dieselfire pump batteries, a condition adverse to tjuality, was used again during a surveillance on June i),1997.
(01083)
AdminionPr Denial to Violalien The District admits the violation.
Etunn for ViolatiDD Although a review of battery test equipment calibration methods and procedure acceptance criteria was perfonned, which determined that the procedural acceptance criteria was corTect, no action was taken to preclude use of the suspect procedure, while promptly resolving the identified concern pilor to subsequent performance of the test. The reason for this violation
5 to NLS970215 Page 9 ef l2 was kianagement's acceptance oflow standards of perfonnance in elTectively executing the Corrective Action Program with regards to the need to identify and take inunediate corrective or compensatory actions (e.g., putting the procedure on administrative hold until the problem is resolved).
Qnclin.fikpilkken and the Itesults Achieved The test equipment calibration methods and procedure acceptance criteria were evaluated, which detennined the acceptance criteria was correct.
Q1Kfdig Steps 'lhat Willlie Taken to Avoid Further Vinlations Administrative guidance will be added to require that surveillance test acceptance enteria discrepancies must be resolved prior to the next perfonnance of the procedure.
Menagement standards for promptly correcting or taking appropriate compensatory action will be reinforced.
- 1) ate When Full Compljance Willlie Achieved The 1)istrict is in full compliance regarding the identified violation.
3.
g
[ Established measures did not] correctfailure ofa Service Water Hooster Pump breaker anti-pump mechanism, a condition adverse to quality, identijled on Februmy 28, I997 and documented in Problem Identification Report 2 13047.
(01093)
Adminion or I)enipi to Violation The 1)istrict admits the violation.
Reason fbr Violation the reason for the violation was Management expectations and standards were not adequate to ensure that unexpected results or situations encountered during testing requires stopping the test, preserving evidence, notifying the control room, and evaluating the problem prior to proceeding.
Gactive Skps Taken and the 1(esults Achicled 1,
Maintenance Procedure 7.3.17.1 was revised to provide a caution and a requirement that two iodividuals be present when testing the anti pump relay. This resolves the inadequate testing methodology which allowcd this testing anomaly to occur.
2.
Management has established clear expectations and standards regarding the " test-till-pass" issue. Personnel are expected to stop, preserve evidence, and go 80 the Shift Supervisor or theit supervisor in the event a problem is encountered.
4 Attachment I to NI.S970215 Page 10 er12 3.
Procedure 0.26, Surveillance Program, requires that if any acceptance criteria in a surveillance test is not utisfied, the Shift Supervisor must be notified and if appropriate, perfomiance of the procedure tenninated.
Cmeetive Steps 1 hat Will lie Taken to Avoid Funber Violations No additional corrective steps are being taken specific to this issue.
Date When Fullfompliance Will lie Achieved
'lhe District is in full compliance reganling the identifica iolation.
These violations represent a Severity Level 111 problem. (Supplement 1)
Civil Penalty - $l10,000.
Mmission or Denial to Violatioal The District admits the violations.
Rga$on for ViolDliall
'lhese iaues, as discussed at the October 17,1997, Predecisional Enforcement Conference, are attributed to an ineITective Corrective Action Program, and in particular, poor problem identification, inadequate corrective action, poor hianagement and Engineering decision making, and recognition of safety significance.
'the reason for the violations in the aggregate was failure of Station hianagement to establish and enforce sulliciently high performance standards in the area of conservative, safety conscious decision making, and questioning attitude. Additionally, Station hianagement failed to ensure adequate line management ownership, skill level, and resources for efTectively implementing the Corrective Action Program. 1he lack of high standards prevented the pinpointing of behaviorr and measures necessary for elTective Corrective Action Program execution.
Corrective Steps Taken and the Results Achieved 1.
Problem identification was emphasized at all levels of the organization, and the threshold Ihr problem reporting was lowered. This action resulted in a notable increase in the number of problem identification reports initiated, especially in the hiaintenance Department.
2.
Senior hianagement implemented an initiative to align the organization on improving the effectiveness of the Corrective Action Program. Actions included clearly establishing hianagement's standards and expectations for questioning attitude and conservative, safety conscious decision making, increased communicat. ions of these standards, identification of perfonnance measures, and re aforcing appropriate behaviors. Results c
of these ef%s led to the identification and resolution of the long standing design flaw F
associated with the Z sump, and resolution of the diesel generator relay testing problem.
3.
A strategy has been developed to aggressively intensify efforts to improve Management's i;tandards and behaviors that create an environment for a strong, efTective Corrective Action Program. The strategy contains actions to es.iblish Management's roles and responsibilities, identify high standards for oerfonnance and communicate these to the staff, pinpoint measures for improved perfennance, and meesure the results.
c Concetive Deps Thqt Will lle Taken to Avoid Further Violations Senior Management will implement the individual action plans as outlined in the performance improvement strategy. Some key actions of the plan include:
Establishing line Management's ownership, roles and responsibilities, and high perfonnance standards for Corrective Action Program effectiveness; listablish a Nuclear Safety Assessment Group (NS AG) composed of experienced individuals with standards and behaviors e mensurate with top performing Corrective Act' 'r "rograms. I" 9 establish immediate performance md staff skills weaknesses; improvemen' -
e addressir &
Implement improved trendh we and perfomi bek end reviews of root cause evaluations to ensure tecnnical quality and implemented corrective actions effectively addressed the fundamental causes; Establish an Engineering Assurance Group to review completed engineering work products to high quality and technical standards. Develop a perfonnance measure ta indicate perfonnance and monitor progress in improving the quality and technical capabilitics of the engineering staff; Apply immediate resources to evaluate safety significance, prioritize, and chse backlogged open corrective act ons. Additionally, an engineering resource study i
is being perfonned to identify resource needs to address the curre. ; weaknesses in egineering, and provid; sufficient resources to sustain engineering perfomiance improvement; Pinpoint required behaviors and measures and aggressively communicate them to the staff. - Use individual perfonnance management to monitor performance,' vi appropriately reinforce the required standards of behavior. Adjust the initiatives based on the perfonnance measures; Immediately improve the skills of the Engineering Management Team by installing experienced mar. agers and supervisors with proven experience in developing and executing effective engineering programs identify and recruit experienced sapervisor and manager bench strength.. A.ess existing supervisor w
1
^
.~
to NLS970215 Page 12 of 12 and manager capabilities by utilizing an industry recognized management / leadership assessment tool, and developing personal development plans that reinforce Senior Management's standards and expectations for attaining
" top quartile" performance in the Corrective Action Program and Engineering areas; Develop and u c an effective set of perfomiance measures to monitor Corrective Action Program and Engineering efTectiveness, and adjust improvement initiatives to sustain a positive improvement trend.
1kte When Fuit Compliance Willlle Achieved The District is in compliance with weaknesses identified. Elimination of the weaknesses and full compliance will be achieved by April 30,1998, with sustained positive improvement thereafler,
+
.m
4
- g l
ATTACHMENT 3 LIST OF NRC COMMITMENTS l
8 Correspondence Nos_NLS970215 The following table identifies those actions committed to by the District in this document. Any other actions discussed in the sabmittal represent intended or planned actions ti the District. They are described to the NRC for tne NRC's information and are not regulatory commitments.
Please notify the Licensing Manager at Cooper Nuclear Station of any questions regarding this document 3r any associated regulatory commitments.
COMMITTID DATE COMMITMENT OR OUTAGE 3/31/98 Essential Power will be supplied to the Z-sump pumps.
RHR Heat Exchanger performance testing of at least one 1998 mid-cycle heat exchar ger will be per f ortaed during the scheduled n;tage.
mid-cycle outage, or before, if there is an unscheduled forced outage.
Re-evaluate the Generic Letter 89-13 maintenance and 1/31/98 testing program, related commitment s, and program implemt.antion.
Develop a formal Cencric Letter 89-13 program document, 1/31/98 with defined ownership, " roles and responsibilities," and program crit eria.
RHR Heat Exchanger preventive Maintenance (PM)taskgjpnd procedures will be revised to include references to the appropriate bases for test and cleaning frequency.
RHR Heat Exchanger Performanto Evaluation Procedure (Procedure 13.17), which provides instructions to personnel to collect data on tre heat exchangers fcr N/A monitoring and trending heat exchanger performance, will be revised to require its pertormance as specified in the Gb 89-13 program.
M/A Incorporate lessons learned into the maintenance procedure for c)3 ning the RHR heat exchangers.
Provide additional training on problem resagnition and gjg sensitivity to safety significant issues to station management, the CRG and the SORC.
hessons learned from this saue are being reviewed with gjg Engineering personnel in fourth quarter Engineering Fupport Personnel (ESP' training.
For the torus-to-drywell vacuum breakers, a new method for establishing lnitial testing parameters will be N/A developed ano as-tound leakage rates will be determined at the end of esch operating cycle (at or near shutdown for refueling c" aacs).
An evaluation af the Preventive Maintenance Program is being conducted, which will address appropriate NiA management standards fcr performing preventive maintenance.
Operations Management will reinforce high stcndstda for operator performance, including procedure use and N/A adherence, encountering unexpected situations, and
, communications.
Standardt for the conduct and'ac auacy of pre-job briefs N/A will be re-emphastrod.
}
PROCEDURE NUMBER 0.42 l
REVISION NUMBER 5 l
PAGE 1 OF 2
s l
ATTACHMENT 3 LIST OF NRC COMMITMENTS (CONTINUED) l 8
t The, Operability Assessment prog am pertormance standarCa 1/31/98 i
are being raised to meet industry guidance in a procedure revision.
Additional DCNs for identified discrepancies found during the recent walkdown of DC 93-024 will be processed per N/A existing site procedures.
Guidance for determining the extent of a condition will N/A be added to the Problem Identification and Resolution procedure.
Administrative guidance will be added to require that pfg i
surveillance test acceptance criteria be rasolved prior to the next performance of the procedure.
Managenient standards for promptly correcting or taking gfg appropriate compensatcry action will be reinforced.
Senior Management will imp 1.ement the individual action 4/30/98 N
plans as outlined in the performance improvement strategy (both CAP and Engineering).
L l
PROCEDURE NUMBER 0.42 l
REVISION NUMBER 5 l
PAGE 2 OF 2 I
o nl\\.1