ML20199H926
| ML20199H926 | |
| Person / Time | |
|---|---|
| Site: | Cooper  |
| Issue date: | 01/28/1998 |
| From: | Graham P NEBRASKA PUBLIC POWER DISTRICT |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| 50-298-97-07, 50-298-97-12, 50-298-97-7, NLS980016, NUDOCS 9802050155 | |
| Download: ML20199H926 (5) | |
Text
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Nebraska Public Power District.
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- NLS980016-January 28,1998 -
U.S. Nuclear Regulatory Commission
- Attention: Document Control Desk l;
- Washington, D.C. 20555-0001 Gentlemen:
Subject:
Clarification cf Commitments with Respect to NRC Irispection Report Nos. 97-07 and 9712 Cooper Nuclear Station, NRC Docket 50-298, DPR-46'-
Reference:
. G, R. Horn (NPPD) dated December 31,1997, " Reply to a Notice of 2 Violation--NRC Inspection Report Nos. 50-298/97-07 and 97-12."
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= As discussed in the January 12,1998, telephone conversation between E. E. Collins (USNRC) and L. R. Dewhirst (NPPD), this letter is being issued as a follow-up to Nebraska Public Power L District's (District) Reply to a Notice of Violation (Reference 1) in order to clarify the list of commitments. -In Reference 1, the District described a variety of actions being taken to address improvement of the Corrective Action Program (CAP). These actions were not listed in their entirety in the Attachment to Reference 1, " List of Commitments."
,The List of Commitments is a tool utilized by the District to quickly and conveniently referer ce
- those items that the Distric: intends to implement as regulatory commitments to ensure compliance to regulations, address identified weaknesses, and make improvements. This list is -
- translated to an internal commitment tracking system, and is many times expanded to include the specific tasks required to meet the identified comrainnent.
! Thus, the' actior.s specific to CAP improvement, most notably the key elements documented in
' Reference 1,"were rolled up mto a single commitment: " Senior Management will implement the s
inoividu'al action plans as outlined in the performance improvement strategy (both CAP and Engineering) on the List 'of Commitments accompanying the District's response. The key
- elements to' meet this commitment were then entered into the District's internal commitment -
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. tracking system as tasks required to meet the identified commitment The District believes that to icommit to implementing the " action plans ~as outlined in the performance improvernent strategy
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Lwould, by defmition, require implementation of the key elements as described in Reference 1.-
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NLS980016 I
january *28,19tyg Page 2 of 2 However, to clarify the District's commitments, a revised Ust of Commitments *nay be found in Attachment I to this letter. This list is simply a clarification of the items alreat, discussed in Reference 1.
Should you have any ouestions concerning this matter, please contact me.
Sincerely, PBBL P. D. Graham Vice President of Nuclear Energy
/lrd Attachment cc. Regional Administrator w/ attachment USNRC - Region IV Senior Project Manager w/ attachment USNRC - NRR Project Directorate IV-1 Senior Resident inspector w/ attachment USNRC Director, Ollice of Enforcement w/attcchment U.S. Nuclear Regulatory Commission Washington, D.C. 20555-0001 NPG Distribution w/ attachment 1
l ATTACHMENT 3 LIST OF NRC COMMITKENTS (CONTINUED) l Correspondence No: NLS98001f, The following table identifies those actions committed to by the District in this document.
Any other actions discussed in the submittal represent intended or planned actions by the District.
They are described to the NRC for the NRC's information and are not regulatory ctmmitments.
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 Essential Power will be supplied to the Z-sump pumps.
RHR Heat Exchanger performance testing of at least one 1998 mid-7ycle heat exchanger will be performed during the scheduled
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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 commitments, and pt> gram implementation.
Develop a forrhal Generic Letter 89-13 program document, 1/31/98 with defined ownership, " roles and responsibilities," and program criteria.
RHR Heat Exchanger Preventive Maintenance (PM) tasks and N/A procedures will be revised to include references to the appropriate bases for test and cleaning frequency.
RHR Heat Exchanger Performance Evaluation Procedure (Procedure 13.17), which provides instructions to personnel to collect data on the heat ey hangers for N/A monitoring and trending heat exchanger performance, will be revised to require its performance as specified in the GL 39-13 program.
N/A Incorporate lessons learned into the maintenance procedure for cleaning the RHR heat exchangers.
Provide additional training on problem recognitfon and N/A sensitivity to safety significant issues to station management, the CRG and the SORC.
Lessons learned from this issue are being reviewed with N/A Engineering personnel in fourth quarter Engineering Support Personnel (ESP) training.
For the torus-to-drywell vacuum breakers, a new method for establishing initial testing parameters will be N/A developed and as-found leakage rates will be determined at the end of each operating cycle (at or near shutdowr for refuelina outages).
An evaluation of the Prever
.e Maintenance Program is being conducted, which will address appropriate N/A management standards for performing preventive maintenance.
Operations Management will reinforce high standards for operator performance, includina procedure use and N/A adherence, encountering unexpected situations, and communica tions.
3 Standards for the conduct and adequacy of pre-job briefs N/A will be re-emphasized.
l 1
l PROCEDURE NWBER 0. 42 l
REVISION NUMBER 5 l
PAGE 1 OF 3 l
l
-ATTACHMFNT 3 lib OF N'RC COMMITMENTS l
Correspondence No:NLS980016 The following table identifies those actions committed to by the District in this document.
Any other actions discussed in the submittal repreeent intended or planned actions by the District. They are described to the NRC for the NRC's 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 The Operability Assessment program performance standards 1/31/98 are being raised to meet industry guidance in a procedure revision.
Additional DCNs for identified discrepancies forud during the recent walkdown of DC 93-024 will be proceLsad per N/A existing site procedures.
Guidance for determining 'he extent of a condition will N/A be added to the Problem Identification and Resolution procedure.
Administrative guidance will be added to require that N/A acceptance c1teria be resolved prior surveillance test r
to the next performance of the procedure.
Management standards for promptly correcting or taking N/A appropriate compensatory action will be-reinforced.
Senior Management & 311 implement the individual action 4/30/98 plans as outlined in the performance improvement strategy (both CAP and Engineering).
Pinpoint measures and behaviors for improved performance N/A and aggressively communicate to the staff.
Use individual performance management to monitor performance, and appropriately reinforce the required N/A standards of behavior. Adjust the initiatives based on the performance measures.
Develop and use an effective set of performance measures
(
to monitor CAP and Engineering results and effectiveness, N/A and adjust improvement initiatives to sustain a positive improvement trend.
Establish a Nuclear Safety 3ssment Group composed of senior, experienced incividu.
with standards and behaviors commensurate with top performing CAPS.
Use this group to establish immediate performance improvement while addressing management and staff skills weaknesses; N/A also responsible for assuring proper issue recognition anu safety classification, performing roce cause cvaluations, and providing educational opportunities for the station staff.
Imnlement improve; trending capability (software).
N/A Perform an engin_ering resource study to identify resource needs to address the current weaknesses in "b
engineering, and= provide sufficient resources to sustain engineering performance improvement.
l PROCEDURE NUMBER 0.42 l
REVISION NUMBER $
l PAGE 2 OF 3 l
l ATTACHMENT 3 LIST OF NRC COMMITMENTS l
Correspondence No:_NLS980016 The following table identifies those actions committed to by the District in this document. Any other actions discussed in the submittal represent intended or planned ac' ions by the District. They are described to the NRC for the NRC's information and are not regulatory commitments.
Please notify the Licensing Manager at Cooper Nuclear Station or any questions regarding this document or ar y associated regulatory connitments.
COMMI fTEI) DATE Cok.ITMENT OR OUTAGE Establish an Engineering Assurance Group, to maintain high standards for engineering work products.
This group N/A will review completed er.gineering work products to high quality and technical standards.
Assess existing supervisor and manager capabilities by utilizing an industry recognized management / leadership assessment tool, and developing personal development N/A plans that reinforce Senior Management's standards and expectations for attaining *.op quartile performance in the CAP and Engineering areas.
Develop a performance measure to indicate performance and monitor progress in improving the quality and technical N/A capabilities of the engineering staff.
Apply immediate resources to evaluate safety significance, prioritize, and close backlogged open N/A corrective action items.
Institute an engineering work management system to allow N/A Engineering Management to effectively allocate resources.
Develop specific engineering performance measures that senior Management will use to monitor and adjust N/A improvement initiatives.
Assigt. CAP to the Plant Manager and station line organization to emphasize line organization ownership.
This initiative involves establishing line management COMPLETE ownership, high performance standards for CAP effectiveness, and further educating the management team on their roles and responsibilitica in implemeting CAP.
. Back-end review of root cause evaluations is being IN PROGRESS conducted by the Condition Review Group (CRG).
l PROCEDURE NUMBER 0.42 l
REVISION NUMBER 5 l
PAGE 3 OF 3 l