ML20247G632
| ML20247G632 | |
| Person / Time | |
|---|---|
| Site: | Cooper  |
| Issue date: | 05/14/1998 |
| From: | Swailes J NEBRASKA PUBLIC POWER DISTRICT |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NLS980077, NUDOCS 9805200307 | |
| Download: ML20247G632 (4) | |
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P o. BOX 499. C LU US. NE A3KA 686024499 Nebraska Public Power District
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- NLS980077 May 14,1998 U.S. Nuclear Regulatory Commission i
Attent on: Document Control Desk Washington, D.C. 20555-0001 Gentlemen:
Subject:
Change of Commitment Cooper Nuclear Station, NRC Docket 50-298, DPR-46
Reference:
- 1. NPPD Letter NLS970215 to Director, Oflice of Enforcement (USNRC) from G. R. Horn (NPPD) dated December 31,1997, " Reply to a Notice of Violation--NRC Inspection Report Nos. 50-298/97-07 and 97-12," with clarification provided in NPPD Letter NLS980016 to Document Control Desk (USNRC) from P. D. Graham (NPPD), dated January 28,1998, " Clarification ofCommitments."
Swailes (NPPD), dated April 9,1998," Strategy for Achieving Engineering Excellence, Revision 1."
In the Nebraska Public Power District (District) response to the Notice of Violation in Reference 1, several initiatives were identified to improve the performance of the Corrective Action Program (CAP) and Engineering Department at Cooper Nuclear Station (CNS). Among these were commitments by Senior Management to implement action plans as outlined in the performance
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improvement strategies for CAP and Engineering by April 30,1998.
Since that time, the District submitted the Strategy for Achieving Engineering Excellence (Reference 2). As a result, the following commitments made in Reference l'are being superseded j
by the action items outlined in the Strategy:
Use individual performance management to monitor performance, and appropriately reinforce the required standards of behavior. Adjust the initiatives based on the performance measures.
I Establish an Engineering Assurance Group, to maintain high standards for engmeenng work products. This group will review completed engineering work products to high quality and technical standards.
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NLS980077 Page 2 of 3 '
l Develop a performance measure to indicate performance and monitor progress in improving the quality and technical capabilities of the engineering staff.
Identify and recruit experienced supervisor and manager bench strength.
Immediately improve the skills of the engineering management team by installing experienced managers and supervisors with proven experience in developing and executing effective engineering programs.
Apply immediate resources to evaluate safety signiDeance, prioritize, and close backlogged open corrective actions. A portion of this commitment has been completed in that an engineering committee was convened to review more than 500 condition reports for safety significance and priority in order to identify issues requiring heightened management attention or reallocation of resources.
Additional commitment changes, which are not being superseded by Reference 2, include the implementation of the action plans as outlined in the CAP performance improvement strategy by April 30,1998. The District intends to aggressively implement CAP performance improvement; recognizing this is an iterative process, the improvement plan is a living document and thus a completion date is not appropriate. The plan will continue to be revised as needed to maintain improving perfomiance. A review of the CAP improvement plan will be completed in March 1999, to assess its overall effectiveness. Reference I committed to specific elements of the CAP improvement plan which have been completed, with the exception of the following:
Assess existing supervisor and manager capabilities by utilizing an industry recognized management / leadership assessment tool, and develop personal development plans that reinforce Senior Management's standards and expectations for attaining top quartile performance in the CAP and Engineering areas. The focus for this action is in the Engineering Department. Initial Management Assessment
. Proficiency Profiles have been completed; training plans will be developed with a schedule for training actions by July 31,1998.
Pinpoint measures and behaviors for improved performance and aggressively communicate to the staff. Based on the experience the District has had to date with the CAP improvement plan, the District believes it inappropriate to assign a specific due date for this activity. Rather, it is an element of the continuous review and analysis of the CAP performance improvement plan as stated above.
The remainder of the commitments listed in Reference I have been completed or are in progress according to District work management schedules and prioritization plans.
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NLS980077 i
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Should you have any questions concerning this matter, please contact me.
Sincerely, Jo H.
ail Vicq l'resi f
clear Energy d
I cc: Regional Administrator USNRC - Region IV i
Senior Project Manager USNRC - NRR Project Direct? rate IV-1 Senior Resident Inspector USNRC NPG Distribution 1
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ATTACHMENT 3 LIST OF NRC COMMITMENTS l
Corresponds,nce No:NLS980077
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The following table identifies those actions committed to by the District in this document. Any other actions discussed in the submittal represent intended or l.
planned actions by the District.
They are described to the NRC for the NRC's l
information and are not regulatory commitments.
Please notify the NL&S Manager at I
' Cooper Nuclear Station of any questions regarding this document or any associated
-regulatory commitments.
COMMITTED DATE COMMITMENT OR OUTAGE Management Assessment Proficiency Profiles have been completed; training plans for
- "I 3I'I998 Engineering Management will be developed with a schedule for training actions by Y
July 31.1998.
h The CAP improvement plan will be reviewed in March 1999, to assess its overall I'
effectiveness.
March 31,1999 I
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PROCEDURE NUMBER 0.42 l
REVISION NUMBER 6 l
PAGE 9 OF 13 l
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