ML20216D883
| ML20216D883 | |
| Person / Time | |
|---|---|
| Site: | Cooper  |
| Issue date: | 04/09/1998 |
| From: | Swailes J NEBRASKA PUBLIC POWER DISTRICT |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| Shared Package | |
| ML20216D888 | List: |
| References | |
| NLS980058, NUDOCS 9804160024 | |
| Download: ML20216D883 (5) | |
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n NLS980058 April 9,1998 U.S. Nuclear Regulatory Commission Attention: Document Control Desk Washington, D.C. 20555-0001 1
Gentlemen:
Subject:
Strategy for Achieving Engineering Excellence, Revision 1 Cooper Nuclear Station, NRC Docket 50-298, DPR-46
References:
- 1. Letter NLS980030 to Document Control Desk (USNRC) from J.11. Swailes (NPPD) dated February 13,1998," Strategy for Achieving Engineering Excellence, Cooper Nuclear Station,'NRC Docket 50-298, DPR-46" j
- 2. Letter to G. R. Ilorn (NPPD) from E. W. Merschoff(USNRC) dated March 12,1998," Cooper Nuclear Station Strategy for Achieving Engineering Excellence" Ily letter dated February 13,1998 (Reference 1), the Nebraska Public Power District (District) provided the NRC a copy of the Strategy for Achieving Engineering Excellence. Following
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initial review, the NRC, by letter dated March 12,1998 (Reference 2), noted that the Strategy j
lacked sufficient information to support a detailed review or a decision of regulatory 4
confinnation. Accordingly, Revision I to the Strategy is being provided as an enclosure to this letter. Whereas this revision was developed, in large part, following additional direction from me and as a result of feedback from a peer review, it is also responsive to the NRC's concerns.
j As previously described in Reference 1, future revisions to the Strategy will be issued as we continue to assess the effectiveness of actions taken and gain new insights from self assessments, benchmarking activities, and external evaluations.
While we are investing significant time and resources to achieve engineering excellence, I wish to stress that there has been no impact on the health and safety of the public as a result of the weaknesses identified and being addressed as part of this Strategy.
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The Strategy has been revised to:
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- 1. Provide additional discussion on the nature of the problems being addressed. Although an assessment of performance deficiencies was used to develop the original Strategy, these details were not included in Revision 0 because the Strategy was viewed primarily as a document for internal use.
9804160024 980409 DR ADOCK 05000298 PDR
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i NLS980058 Page 2
- 2. Provide additional performance measures. The previous revision relied heavily on existing plant performance indicators and h:alth monitors. In retrospect, the District agrees that more focused indicators and performance monitors are necessary in order to assess the effectiveness of each specific action plan.
Although the District has modified Revision 1 of the Strategy to agree with several NRC concerns provided in Reference 2, we are concerned with the NRC's apparent perception that, after three months, CNS has not made improvements in Engineering performance. While the rate of overall achievement may be debatable, measurable progress has been made in the following areas:
I Leadership. Additional Ibcus by the Chief Executive Officer and Senior Vice President of Energy Supply has been evident. Also, the new Vice President of Nuclear Energy is providing new leadership and direction that departs from the previous way of doing business in the Engineering Department. Engineering management has been strengthened by new personnel, repositioning ofexisting leaders, and mentoring of senior engineering managemem.
Staffing. On November 1,1997, the staffing level within the Engineering organization totaled 110 people. As of March,241998, the staffing level reflected a net increase of 21 people. This increase is the result of considerable recruiting efforts. These efforts will j
continue until required staffing levels are achieved.
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Plant IVork Schedule Support. The average number ofitems removed from the plant schedule due to lack of Engineering support has declined substantially. Approximately four items per week were removed prior to November 1997. As of March 1998 the average is approaching one item per week.
Emergent Issue Resolution. Engineering has worked closely with plant staff to improve the management and resolution of emergent issues. Feedback from the Operations and Maintenance Managers indicates that emergent issues are being resolved in a more effective and timely manner.
Engineering IVork Management. An Engineering work management system has been instituted throughout the organization. This system is being used to manage the overall Engineering work load, understand the nature of emergent work, and improve effectiveness l
by changing the way Engineering does business.
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While progress has been made, the District acknowledges that significant challenges remain.
Accordingly, the attached plan provides our vision for the Engineering Division, the strategies we will use to achieve that vision and excellent performance, and top level actions to carry out those strategies. Objectives for the key elements of the plan are summarized below:
We will strengthen the Engineering organization by transferring and recruiting strong engineering talent into the division and by increasing the qualifications of engineers, with particular emphasis on System Engineering.
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NLS980058 j
Page 3 We will manage and prioritize Engineering work more effectively in order to ensure that important technical issues are resolved fully and in a more timely fashion.
We will enhance the quality and accuracy of Engineering products and strengthen control of f
the plant design and configuration in order to ensure conformance with the design basis.
We will manage the division more effectively by increasing involvement and coaching by senior managers, improving our performance management methods, and using various
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additional means to hold the organization and individuals accountable for results.
While we estimate that it will take three or more years to fully attain the high levels of excellence that we want to achieve, we expect to see significant improvement by the end of 1998. To this end, specific year end success measures have been included in the enclosed Strategy. The most significant year end success measures include:
Division staffed to ninety-five percent or greater of the levels established fbr the new organization.
Ten or more additional engineers have obtained plant certifications and returned to Engineering, and a second set of ten or more engineers have begun a similar training course.
Engineering work inventories are trending down.
Ninety percent of the actions associated with the Strategy are complete or on schedule.
l The Severe Accident Management project is completed on schedule without significant problems.
l The improved Technical Specifications project is completed on schedule without significant problems I
l Ninety percent of Engineering personnel receive documented quarterly performance reviews i
with their supervisor.
In January 1999, we will formally evaluate the effectiveness of the actions taken in 1998 through a comprehensive self-assessment. Based on the results and what we learn, we wE report our progress and revise the Strategy.
I In closing, we view Engineering performance as our most significant challenge. We are committed to taking the necessary steps and making the necessary investments to achieve very high levels of excellence. While we expect this may take several years to fully achieve, we expect to make suflicient progress during the remainder of 1998 to demonstrate a definite enhancement and to regain the confidence of all of those concerned with our performance in this area.
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NLS980058 Page 4 We would like to schedule a follow-up focus meeting as soon as possible with the regional management to ensure a uniform understanding of our plans and expectations, and to communicate our level of commitment, To this end, Mr. Brad flouston of our staff has been in contact with Mr. Elmo Collins to make the necessary arrangements.
Sincerely, J n-J. b ai Vi :e Pr sident O ' Nuclet Ene 'gy
/crm Enclosure cc: Regional Administrator USNRC - Region IV Senior Project Manager USNRC - NRR Project Directora e IV-1 Senior Resident Inspector USNRC NPG Distribution l
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l ATTACHMENT 3 LIST OF NRC COMMITMENTS l
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Correspondence No: MIS 980058 The following table identifies those actions committed to by the District in this i
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 commitments, Please notify the Licensing Manager at Cooper Nuclear Station of any questions regarding this document or any associated regulatory commitments, i
COMMITTED DATE COMMITMENT OR OUTAGE A comprehensive self-assessment will be done to formally January 31' 1999 evaluate the effectiveness of the actions taken in,1998.
Based on the self-assessment results and what we learn, March 1, 1999 we will report our progress and revise the Strategy.
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l PROCEDURE NUMBER 0.42 l
REVISION NUMBER S l
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