ML20207A070

Forwards Rev 3 to CNS Strategy for Achieving Engineering Excellence, Which Provides Effective Tool for Overall Engineering Work Mgt.Commitments Made by Util,Encl

ML20207A070
Person / Time
Site:	Cooper
Issue date:	05/19/1999
From:	Swailes J NEBRASKA PUBLIC POWER DISTRICT
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML20207A075	List: ML20207A070 ML20207A076
References
NLS990053, NUDOCS 9905260131
Download: ML20207A070 (7)

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N Nebraska Public Power District  :

NLS990053 NeWdg M i May 19,1999 l i

U.S. Nuclear Regulatory Commission Attention: Document Control Desk Washington, D.C. 20555-0001 Gentlemen:

Subject:

CNS Strategy for Achieving Engineering Excellence, Revision 3

References:

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1) Letter NLS990009 from John H. Swailes (Nebraska Public Power District) to Document  !

Control Desk (U.S. Nuclear Regulatory Commission), dated February 2,1999,

" Extension of Commitment Dates and Anticipated Revision to the CNS Strategy for Achieving Engineering Excellence"

2) Letter NLS990038 from J. H. Swailes (Nebraska Public Power District) to the Document Control Desk (U.S. Nuclear Regulatory Commission) dated April 1,1999, " Extension of  ;

Commitment Date for Revision to the CNS Strategy for Achieving Engmeenng Excellence" .

3) Letter from Thomas P. Gwynn (U.S. Nuclear Regulatory Commission) to G. R. Horn (Nebraska Public Power District), dated October 30,1998," Plans for Monitoring i Progress of the Cooper Nuclear Station Strategy for Achieving Engineering Excellence"

4) Letter NLS980105 from J. H. Swailes (Nebraska Public Power District) to the Document Control Desk (U.S. Nuclear Regulatory Commission), dated July 8,1998, " Strategy for i Achieving Engineering Excellence, Revision 2"

5) Letter NLS980165 from John H. Swailes (Nebraska Public Power District), to Document Control Desk (U.S. Nuclear Regulatory Commission), dated October 7,1998, " Plans for Monitoring Progress of the CNS Strategy for Achieving Engineering Excellence"

6) Letter NLS980094 from John H. Swailes (Nebraska Public Power District) to Document f Control Desk (U.S. Nuclear Regulatory Commission), dated July 23,1998, " Reply to a Notice of Violation, NRC Inspection Report No. 50-298/98-02" On February 2,1999, and April 1,1999, the Nebraska Public Power District (District) submitted to the Nuclear Regulatory Commission (NRC) correspondence summarizing anticipated j revisions to the subject Strategy for Achieving Engineering Excellence (" Strategy")

(References I and 2). Consistent with the NRC request (Reference 3) to be kept informed of gI .

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Cooper Nudear Station f.0 Dn *~ 98/ Brownville. NE 683210098 9905260131 990519 4a2) s25asn / rax:(4a2) s25.s?n http //www nppd com pDR ADOCK 05000298 P PM '

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NLS990053 Page 2 of 3

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significant schedule and/or content changes in the Strategy, the District is transmitting to the NRC Revision 3 of the subject Strategy as Attachment B.

In a meeting held between members of the District and NRC on May 6,1999, the District explained that several factors contributed to the evolution of Revision 3 of the Strategy, including sitewide self assessments, Quality Assurance audits, Focus meetings with the NRC, and Closure Package Revie$vs, to name just a few. The District has employed a more risk informed approach to Strategy activities, ensuring that resources are applied to the most significant activities, thus maximizing the improvement rate. Additional emphasis was placed on producing an all. inclusive plan,in which the Strategy efforts complement each other and other station priorities.

As discussed in our May 6 meeting, Revision 2 (Reference 4) of the Strategy focused primarily on improvement activities while Revision 3 seeks to provide an effective tool for overall engineering work management. Revision 3 integrates the improvement strategies of Revision 2 into the broader, engineering wotk baseload, largely governed by the stations's Business Plan (which was also discussed in our May 6 meeting). This was done to give us confidence that we can continue to address the Strategy's improvement initiatives and also properly manage and complete our baselead ensineering tasks.

The fbrmal commitments from Revision 2 agreed upon between the District and the NRC (Reference 5) continue to be a part of Revision 3 of the Strategy as illustrated in Attachment A of this correspondence. Strategy activities have been man loaded into the Engineering Work Management System which is used to manage the overall Engineering workload, understand the nature of emergent work and improve effectiveness of Engineering resources. Schedule changes resulting from the above activities have been annotated in Attachment A. In some cases the commitment description has been altered for clarity within the Strategy, however the intent of the commitment remains the same and is illustrated in italics.

Should you have any questions concerning this matter, please contact Bruce Rash, Senior Engineering Manager,(402) 825-2943.

Sincerpy, I

John IL Swailes Vice President of Nuclear Energy

/lrd Attachments i

cc: Regional Administrator w/ attachments USNRC - Region IV Senior Project Manager w/ attachments

NLS990053 l Page 3 of 3 l

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Senior Resident Inspector w/ attachments j USNRC 4 NPG Distribution w/ attachments 1

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F NLS990053 l Attachment A l

STRATEGY FOR ENGINEERING EXCELLENCE i

SUMMARY

OF COMMITMENTS l COOPER NUCLEAR STATION NRC DOCKET NO. 50-298, LICENSE DPR-46 The following table outlines the key commitments from the CNS Strategy for Achieving Engineering Excellence. This table contains those activities that the District and the NRC agreed upon as being the key actions within the Strategy that are being treated as formal commitments, as documented in Letter NLS980165 to Document Control Desk (USNRC) from John H. Swailes (NPPD), dated October 7,1998," Plans for Monitoring Progress of the CNS Strategy for Achieving Engineering Excellence"(Reference 5).

The far left column, "Rev. 2 Item," identifies the Revision 2 item number. The second column "Rev. 2/ Updated Est. Comp. Date," indicates the original estimated completion date indicated in the letter referenced above (NLS980165), and updated date, as applicable, as communicated in subsequent correspondence (NLS990009). For commitments that have earlier source documents, the source document is listed at the end of this table under " Additional References." The

" Description" column contains the Revision 2 description of the commitment; the italics in parentheses identify wording changes made in Revision 3. The fourth column, "Rev. 3 item,"

identifies the corresponding identification number in Revision 3 of the strategy. The last column, "Est. Comp. Date," contains the most current estimated completion date as reflected in Revision 3.

REV. 2 REV. 2/ DESCRIPTION RI(V. 3 REV.3 EST.

ITEM UPDATED ITEM COMP.

EST. COMP. DATE DATE _ _ _ _ ___ _ ,_ _ _. _ _.

l.l.g 12/31/2002 Select and enroll Engineering personnel in the plant 2.4.5.1 12/31/2002 certification courses.

(Plant Certification Training) 1.1.o 12/31/1999 Develop a six year system improvement plan for 4.2.1.2 12/31/1999 each system.

(Develop 6 year system improvementplans) 1.4.b 12/30/1999 Implement revised design and licensing basis 2.4.5.2 12/30/1999 (Ref. A) training (based on results of strategy item 1.4.a.

" Conduct a self-assessmen. af the current design basis training and revise the training, if necessary.").

(Upgrade and implement design basis training) 1.4.g 12/31/1999 Develop and Implement 1998-1999 Engineering 2.4.2.1 12/31/1999 Support Personnel (ESP) training and qualification plan.

(Implement i999 ESP training and quahfication plan) 2.3.c 10/31/1998 Complete Phase 1 of backlog reduction project. No Note I r

l NLS990053 .

Attachment A l REV. 2 REV. 2/ DESCRIPTION REV. 3 REV.3 EST.

ITEM UPDATED ITEM COMP.

EST. COMP. DATE DATE 2.3.d 07/01/1999 Complete Phase 2 of backlog reduction project. 3.3.1.5 07/01/1999 (Phase 2 backlog reductionproject) 3.2.b 03/31/2000 Review modifications for installation during RE-18 3.2.2 03/31/2000 and RE-19 using a design review team containing CNS and external expertise.

(Senior Engineering Review Group (SERG) review ofmodifications) 3.2.c Note ! Implement " configuration change" process No Note 1 improvements, Phase I (make processes consistent, enhance Replacement Component Evaluation (RCE) and minor mod processes).

3.2.d 12/31/1998 Implement " configuration change" process 3.1.3 06/30/1999 Updated in improvements, Phase 2, to align to new NLS990009 to Engineering vision.

04/0l/l999 (Configuration change process phase 2) 3.2.c Note 1 Complete the unauthorized rnodification review. No Note 1 (Refs. B and C) 3.2.f 12/31/1998 Verify Maintenance Work Request No Note 1 (MWR)/ configuration change process prevents unauthorized modifications.

3.3.d 12/31/1998 Perform review of selected past modifications. 3.3.1.4 12/31/1999 Updated in (Reviewpast modifications)

NLS990009 to 06/30/1999 3.3.e 04/01/1999 An EOP/ design basis review will be conducted as 3.3.1.2 6/30/1999 per Action 3.3.e of the Strategy.

(Perform an EOP/ Design basis review) 3.3.f 06/01/1999 CNS will conduct an "SSF1-type" review of primary 3.3.1.6 09/30/1999 Updated in and secondary containment, focusing on the current NLS990009 to design basis and specifically on implementation of 09/30/1999 these design bases in previously designed modifications. (Conduct SSFI-Opc inspection).

3.3.g 12/31/2002 Verify that the inputs and assumptions for the 3.1.1 12/31/2002 (Ref. E) station's safety analysis are properly translated into the appropriate policies, procedures and programs.

(Translate safety analysis inputs and assumptions into engineeringprocesses andprograms)

l NLS990053 Attachment A

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REV.2 REV. 2/ DESCRIPTION REV. 3 REV. 3 EST.

ITEM UPDATED ITEM COMP.

EST COMP. DATE DATE 3.3.1 04/01/1999 Form a multi-disciplined team ofinternal 1.1.1.1 12/31/2000 (Ref. A) Updated in employees and outside industry consultants to l NLS990009 to review the adequacy of the specinc and generic 12/31/1999 corrective actions and the degree of their effectiveness for signi6 cant conditions adverse to quality between 1990 and the present.

(Conduct Sigmficant Condition Report (SCR) e efectiveness review (1/90 thru 3/98))

4.3.d 04/01/2000 Conduct outside expert review of all Significant 1.1.1.2 04/01/2000 Conditions Adverse to Quality (SCAQs) issued since 4/1/98.

(Outside expert review ofSCR 's (4/98 thru 12/99))

4.3.e 01/31/1999 Complete a comprehensive self-assessment to No Note 1 (Ref. F) Complete formally evaluate the effectiveness of actions taken Assessment in 1998 with Engineering and its interface with the 03/01/1999 plant being a significant component. A majority of Revise the assessment team will be off-site experts. Based Strategy on the results and what we learn, we will report our progress and revise the strategy.

None Perfonn an Independent Assessment of the CNS 6.2.3 10/31/1999 Strategy for Achieving Engineering Excellence I using a panel of recognized experts in the field of l engineering at nuclear power plants. l (Mid-Cycle Engineering Evaluation)  ;

I Note 1: These Revision 2 activities (no longer described in Revision 3) are complete, have been through independent review, and are in the final review and closeout stages.  ;

ADDITIONAL

REFERENCES:

A. NPPD Letter NLS980103 to Document Control Desk (USNRC) from John H. Swailes (NPPD), dated June 25,1998," Anticipated Revisions to CNS Strategy for Achieving Engineering Excellence" H. NPPD Letter NLS970056 to Document Control Desk (USNRC) from P. D. Graham (NPPD), dated April 17,1998, " Reply to a Notice of Violation, NRC Inspection Report No. 50-298/96-25" C. NPPD Letter NLS980101 to Document Control Desk (USNRC) from J. H. Swailes (NPPD), dated June 18,1998," Change of Commitment" D. NPPD Letter NLS970209 to Document Control Desk (USNRC) from M. F. Peckham (NPPD), dated December 12,1997, " Licensee Event Report No.97-014"

. NLS990053' Attachment A

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NPPD Letter NLS980058 to Document Control Desk (USNRC) from J. H. Swailes j (NPPD), dated April 9,1998," Strategy for Achieving Engineering Excellence, j Revision 1" 4

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