ML20236U583
| ML20236U583 | |
| Person / Time | |
|---|---|
| Site: | Cooper  |
| Issue date: | 07/24/1998 |
| From: | Gwynn T NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | Horn G NEBRASKA PUBLIC POWER DISTRICT |
| References | |
| NUDOCS 9807300318 | |
| Download: ML20236U583 (7) | |
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[8Gog UN!TED STATES
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R EGICN IV 4
611 RYAN PLAZA DRIVE, SUIT E 400 0
ARLINCTON, TEXAS 760118X>4
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July 24, 1998 l
G. R. Horn, Senior Vice President of Energy Supply Nebraska Public Power P%trict 141415th Street Columbus, Nebraska 68601 I
SUBJECT:
COOPER NUCLEAR STATION STRATEGY FOR ACHIEVING ENGINEERING 1
EXCELLENCE, REVISION 2 I
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Dear Mr. Horn:
1 Approxirnately 3 months ago, the NRC received your initial version of the strategic plan for improving engineering performance at Cooper Nuclear Station (CNS), dated April 9,1998. CNG z
an.d the NRC discussed this plan at a working level meeting in the NRC Region IV offices on May 4,1998, and at a public meeting at the CNS site on May 18,1998. Both meetings were useful in clarifying various aspects of your plan and in communicating our mutual insights concerning the plan's depth and breadth.
During the May 18 mee'ing, we discussed several revisions that CNS intended to make to the plan; subsequently we received your [[letter::05000298/LER-1998-007, :on 980526,missed Surveillance Testing of Main Turbine Stop Valve Closure,Was Discovered.Caused by Failure to Effectively Implement TS Amend.Main Turbine Stop Valve Closure Scram Function Verified Operable|June 25,1998, letter]] specifying these anticiposed changes.
On July 10,1998, we received Revision 2 to the CNS Strategy for Achieving Engineering Excellence. This letter acknowledges the Agency's receipt of Revision 2, and provides our initial review of its contents. Detailed comments will be provided at a later date.
We believe that six points of improvement deserve comment at this time.
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The process by which CNS developed the Engineering Strategy.
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The NRC questioned Cooper's bases for asserting, without a rigorous analysis, that the improvement plan had addressed a performance deficiencies. We note that Revision 2 l
documents CNS' plans to use an iterative approach to engineering improvement. This l
process that will require hands-ori Senior Management oversight, ongoing feedback and continuous corrective actions to ensure that the extent of conditions addressed by the
{9 plan are appropriately broad a'id comprehensive.
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The inclusion of managerial controis and independent reviews of the strategy.
CNS had noted that detailed review by the current management team and independent l
verification of the plan's adequacy was not contained in the development of the initial l
version of the plan. In Rev;sion 2, CNS has included details concerning how the plan wiH I
be managed, including the identification of those measures which will be used to ensure comp'eted actions have achieved the desired results. The management controls include independent verification, and depending on the nature of the action and its desired effect L
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Nebraska Public Power District on engineering performance, may include an effectiveness review. The NRC views the effectiveness of these controls to be key to the success of the plan.
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Changes to CNS engineering staffing levels and additions to the engineering training and qualification process.
CNS had observed that low staffing had contributed to weak engineering performance.
We found that Revision 2 contains comprehensive and definitive actions to increase the j
engineering staff. Equally important to the health of Cooper engineering are the l
qualifications of and training provided to working level engineers. Revision 2 of the plan
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contains measures to assess and revise the training and qualifications of the engineering j
staff, to include training on the current design basis of the facility and integrated plant i
operations training for selected systems engineers. The plan also addresses assessing engineering management and supervisory skills and the development of a program to address identified deficiencies.
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The inclusion of initiatives to verify CNS' design basis information.
CNS has include d several actions, in part, to address concerns about the quality of design basis information. We believe that your review of the extent of condition for previously identified problems, and the reconfirmation that you have corrected those problems in every applicable instance, is essential to achieving lasting improvement in engineering performance.
Actions included in Revision 2 to address the quality of design basis information included performance of "SSFl-type" reviews to confirm that appropriate safety margins exist. In its June 25 letter, CNS noted that SSF1-type reviews of primary and secondary containment are a key aspect of Revision 2. The "SSFI-type" reviews, if effective, can l
provide information about design adequacy for the subject systems, and further insight I
into the effects of past engineering performance on the " health" of these systems.
Revision 2 has added an action to verify that safety ana!ysis inputs and assumptions
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have been effectively translated to processes and pro!p ams, and the plan now
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addresses the ramifications of engineering weaknesses for previously completed j
modifications, by including a review of a selection of previous modifications. The NRC
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considers effective completion of these actions to verify the quality and implementation of the design basis essential to continued safe operation of Cooper.
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Changes to the schedule for implementing various improvement activities.
Another area that was noted as needing improvement was the accuracy and I
reasonableness of the schedules for implementing the actions contained in the initial j
version of the plan. Some of the schedules in the initial version of the plan were not l
appropriately resource-loaded. For example, CNS discussed plans and a schedule to l
perform design basis self-assessments; however, the scope of this process had not yet been determined. in Revision 2, CNS has added emphasis on producing a workable plan. The impacts of other station priorities and the availability of personnel have been
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Nebraska Public Power District factored into the schedules for completing engineering plan actions. This emphasis and refocused priorities resulted in changes to the schedule, including specific schedules for conducting an EOP/ design basis review, and reviewing effectiveness of corrective actions for significant siditions adverse to quality.
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A description of the Performance Indicators to be used to monitor the adequacy of the strategy.
As we discussed during the May 18 meeting, in using an iterative approach, the ultimate success of CNS' improvement plan will require appropriate means for measuring the effectiveness of your actions. Although the initial version of the plan lacked detail, Revision 2 contains specific critical success factors, performance indicators, and milestones intended to measure the effectiveness of your efforts to improve engineering i
effectiveness. We expect that your iterative process will include periodic adjustments to these performance measures.
In summary, Revision 2 of your Strategy for Achieving Engineering Excellence was a significant improvement over the original plan. Based on our preliminary review, this Revision addressed the concerns we discussed in the meeting on May 18. We intend to review the plan in more detail; we will provide you with any additional insights from that review within the next few weeks. In addition, we intend to identify key provisions of the plan that we consider most l
essential to engineering improvement at Cooper Nuclear Station, and to formally confirm your commitment to implementation of those actions.
l if you have any questions on the information provided in this letter, pier.se feel free to contact 1
Charles Marschall of my staff at (817) 860-8185.
l Sincerely,
%f n n
[ Division om P
, Director Reactor Projects Docket No.: 50-298 License No.: DPR-46 l
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John R. McF' hail. General Counsel Nebraska Public Power District P.O. Box 499 Columbus, Nebraska 68602-0499
s, Nebraska Public Power District J. H. Swailes, Vice President of Nuclear Energy Nebraska Public Power District P.O. Box 98 Brownville, Nebraska 68321 B. L. Houston, Nuclear Licensing and Safety Manager Nebraska Public Power District P.O. Box 98 Brownville, Nebraska 68321 Dr. William D. Leech MidAmerican Energy 907 Walnut Street P.O. Box 657 Des Moines, Iowa 50303-0657 Mr. Ron Stoddard Lincoln Electric System 1040 O Street P.O. Box 80869 Lincoln, Nebraska 68501-0869 Randolph Wood, Director Nebraska Department of Environmental l
Quality.
P.O. Box 98922 Lincoln, Nebraska 68509-8922 j,
. Chairman l
Nernaha County Board of Commissioners Nemaha County Courthouse l,
1824 N Street Auta rn, Nebraska 68305 y_
Cheryl Rogers, LLRW Program Manager Environmental Protection Sectico
- Nebraska Department of Health 301 Centennial Mall, South
. P.O. Box 95007
- Lincoln, Nebraska 68509-5007 m.
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Nebraska' Public Power District.
R._ A. Kucera, Department Director of Intergovernmental Cooperation Department of Natural Resources P.O. Box 176 1
' Jefferson City'l Missouri 65102
. Kansas Radiation Control Program Director
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