ML20216E541
| ML20216E541 | |
| Person / Time | |
|---|---|
| Site: | Cooper  |
| Issue date: | 03/12/1998 |
| From: | Merschoff E NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | Horn G NEBRASKA PUBLIC POWER DISTRICT |
| References | |
| NUDOCS 9803180079 | |
| Download: ML20216E541 (6) | |
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NUCLEAR REGULATORY COMMISSION
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ARLINGTON, TEXAS 76011,8064 MAR I 21998 G. R. dorn, Senior Vice President
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of Energy Supply Nebraska Public Power District 141415th Street Columbus, Nebraska 68601
SUBJECT:
COOPER NUCLEAR STATION STRATEGY FOR ACHIEVING ENGINEERING EXCELLENCE
Dear Mr. Horn:
Recently we received cupies of your strategic plan for improving engineering performance at Cooper Nuclear Station (CNS). This plan was discussed at our last two focus meetings on engineering performance. In those meetings we emphasized our belief that this effort was essential to the recovery of the engineering function at the site.
I was pleased to note that your introductory remarks acknowledged the seriousness of the consequences to CNS' long-term viability should you not ba able to improve performance and attain engineering excellence at CNS. We fully agree with that assessment. Your success in developing an effective and comprehensive strategy and implemeriting it is crucial to the long-term safe operation of CNS.
As we discussed during the January 30,1998, focus meeting, the NRC has decided to have members of the Region IV and NRR staffs review your strategy. When the agency is satisfied that you have developed a viable strategy, I intend to formally confirm your commitment to implementing the strategy and attain %g the desired engineering impmvement.
Mindful of that goal, we have reviewed your submittal of February 13,1998; additionally, on March 2, we telephonically discussed the plan with members of your staff. Bac,ed upon our initial review and the supplemental information provided by your staff, y e have concluded that this initial plan does not contain suff&nt information to support our reviewing it in detail or reaching a decision of regulatory confirmation. The below listed points are provided to you as points of consideration for developing what we believe would be even a baseline submittal.
We could not determine that the overall strategy, and the individual areas which you believe are appropriate to be addressed, were develope.d from a systematic analysis of documented engineering performance deficiencies, such as Problem Identification Reports. Tne strategy identifies general areas of performance failure, but we could not determine that you had identified and were, therefore, addressing all underlying causes for those failure modes. Also, we could not dCermine that you had developed j
appropriate tools by which to measure your success or deviation from expected g
performance; consequently, we could not evaluate these measurement tools.
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i Nebraska Public Power District Although the strateg> assigned respons,,bility for implementation actions, we could not determine the basis by which you had assigned that responsibility within your organization. This raises the question of how you can ensure that the actions will be properly integrated. In addition, we could not determine how the strategy clearly and specifically established accountability for implementation issues.
During the March 2 telephone conference, members of your staff stated that you had not yet adequately considered the resources necessary to implement the strategy. As a result, we could not determine the accuracy of the scheduled completion dates. From our understanding, this is an issue which your staff is also reviewing at this time.
Your staff has also told uw that the strategy does not yet address significant observations from independent assessment or from newly arrived senior managers.
In summary, your Strategy for Achieving Engineering Excellence lacks sufficient information to allow the NRC to determine whether you have effectively identified and developed actions to address the causes for your continuing engineering problems. I understand, based on your conference with my staff on March 2,1998, that you intend to revise the plan. The quantity and substance of the changes needed and being considered do not, in our opinion, equate to what one would expect in a "living" document. They appear, instead, to be much more fundamental and reflect a plan which is still in the early developmental phase.
We have determined that the plan, as submitted, is unacceptable; therefore, we will expend no further effort in its review. Additionally, we are concerned that, after three months, CNS has not yet developed an acceptable improvement plan. It is essential that a realistic and comprehensive plan be produced and communicated to us in a timely manner. Mr. Elmo Collins, of my staff, is the point of contact for this information. Please provide him with your revised ;.hedule for submittal no later than March 20,1998.
Sincerely, Ellis W. Mersch Regional Admi strator Docket No.: 50-298 License No.: DPP 46 l
Nebraska Public Power District cc:
William R. Mayben President and CEO Nebraska Public Power District P.O. Box 499 Columbus, NE 68602-0499 John R. McPhail, General Counsel Nebraska Public Power District P.O. Box 499 Columbus, Nebraska 68602-0499 J. H. Swailes, Vice Prr,sident of Nuciqar Energy Nebraska Public Power District P.O. Box 98 Brownville, Nebraska 68321 B. L. Houston, Nuclear Licensing and Safety Manager Nebraska Pub!ic Power District P.O. Box 98 Brownville, Nebraska 68321 Dr. Wdliam D. Leech MidAmerican Energy 907 Walnut Street P.O. Box 657 Des Moines, Iowa 50303-0657 Mr. Ron Stoddard Lincoln Electric System 11th and O Streets i
Lincoln, Nebraska 68508 i
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Randolph Wood, Director Nebraska 17epartment of Environmental Quality P.O. Box 98922 Lincoln, Nebraska 68509-8922 Chairman Nemaha County Board of Commissioners Nemaha County Courthouse 1824 N Street Aubum, Nebraska 68305 i
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Cheryl Rogers, LLRW Program Manager s-Environmental Protection Section Nebraska Department of Health 301 Centennial Mall, South P.O. Box 95007 Lincoln, Nebraska 68509-5007 R. A. Kucera, Department Dire;; tor of Intergovernmentai C0 operation Department of Natural Resources P.O. Box 176 Jefferson City, Missouri 65102 Kansas Radiation Control Program Director l
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Reg cf al Administrator Resident inspector DRP Director DRS.PSB Branch Chief (DRP/C)
MIS System Branch Chief (DRPTTSS)
RIV File Project Engineer (C'.P/C)
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MIS System Branch Chief (DRP/TSS)
RIV File Project Engineer (DRP/C)
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