ML20249C668
| ML20249C668 | |
| Person / Time | |
|---|---|
| Site: | Cooper  |
| Issue date: | 06/25/1998 |
| From: | Swailes J NEBRASKA PUBLIC POWER DISTRICT |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NLS980103, NUDOCS 9806300572 | |
| Download: ML20249C668 (3) | |
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maos Uf5E M NE am Nebraska Public Power District "ggTr" NLS980103 j
June 25,1998 j
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U.S. Nuclear Regulatory Commission Attention: Document Control Desk Washington, D.C. 20555-0001
Dear Mr. Merschoff:
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Subject:
Anticipated Revisions to CNS Strategy for Achieving Engineering Excellence
Reference:
Letter from J. H. Swailes (Nebraska Public Power District) to the U. S. Nuclear Regulatory Commission dated April 9,1998," Strategy for Achieving Engineering l
Excellence, Revision 1" l
On May 18,1998, the Nebraska Public Power District (NPPD) and the Nuclear Regulatory Commission (NRC) met to discuss Revision 1 of the Cooper Nuclear Station (CNS) Strategy for Achieving Engineering Excellence. As you are aware, this Strategy has been developed and implemented by NPPD to address long-standing Engineering performance issues During the May 18 meeting, we provided to the NRC presentations on several of the key Strategy actions, including our focus on strengthening system engineering capability and continuing to ensure the adequacy of our design basis. In tum, the NRC provided perspectives on development of the Strategy; concerns with CNS Engineering' implementation of the Corrective Action Program; our focus on effectively applying " extent of condition" methodologies on previously identified conditions or problems; and execution of our Engineering Work Management system, among
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other discussions.
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Achieving sustained improvement in CNS Engineering performance will be an iterative process, requiring " hands-on" Senior Management oversight and course correction. On June 19,1998,we discussed with you during a telephone conference call anticipated changes we are making to the Agh_>
Strategy, which we plan on incorporating into a Revision 2. While the Revision 1 Strategy
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remains a comprehensive tool and provides an effective direction for facilitating improvement, our anticipated changes result from additional analysis of previously identified design basis conditions captured in the CNS Corrective Action Program. Revision 2 will also respond to issues raised by the NRC.
9906300572 900625 PDR ADOCK 05000298 P
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'I NLS980103 l
June 25,1998 Page 2
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The key aspects of the forthcoming Revision 2 are as follows:
1 CNS will form a multi-disciplined team ofinternal employees and outside industry l
consultants to review the adequacy of the specific and generic corrective actions, and the degree of thei effectiveness, for significant conditions adverse to quality occurring between 1990 to the present.
. CNS will perform a review of our Emergency Operating Procedures to validate the appropriate use of safety analyw. and design parameter inputs and assumptions.
l CNS will conduct an "SSFI-type" review of Primary and Secondary Contr nment, focusing on the current design basis, and specifically on implementation of these design bases in previously designed modifications.
CNS will conduct a self-assessment of our current design basis training. We will revise the training, if necessary and begin implementation of any revised design basis training no later than March 1999.
To reflect our need to dedicate attention to the successful completion of Refueling Outage 18, for the period of September 1998 to December 1998, new Strategy initiatives will not be implemented. The Revision 2 implementation schedule, to be submitted along with the Strategy document, veill clearly reflect the impact of this planned outage.
We are currently monitorira strategy initiatives through the use of performance indicators. We also continue to use one-on-one discussions, management observations, and self-assessments to ensure that strategy initiatives are being understood by the workforce and are being implemented
. as expected. Our goal continues to be to develop engineering excellence to the point that significant problems are prevented, and when they occur, resolutions are developed which clearly and convincingly correct the problem and minimice the likelihood of recurrence.
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i, NLS980103 June 25,1998 Page 3 We 160k for\\vard to your continued monitoring and interaction regarding our Engineering Strategy. Please contact Paul Caudill at 402-825-5052 ifyou have any questions.
Sincerely, 1
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.mW es Vihe Presi 'nt of clear Energy
/jrp cc:
Regional Administrator USNRC - Region IV Senior Project Manager USNRC - NRR Project Directorate IV-i Senior Resident Inspector USNRC NPG Distribution 1
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ATTACHMENT 3 LIST OF NRC COMMITMENTS l
Correspondence No: NLS980103 l
The 'following table identifies those actions committed to by the District in this 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 l information and are not regulatory commitments.
Please notify the NL&S Manager at i
l Cooper Nuclear Station of any questions regarding this document or any associated
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l COMMITTED DATE l
COMMITMENT OR OUTAGE l
CNS will form a multi-disciplined team of internal i
employees and outside industry consultants to review the adequacy of the specific and generic corrective actions, l
and the degree of their effectiveness, for significant N/A conditions adverse to quality occurring between 1990 to the present.
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CNS will perform a review of our Emergency Operating N/A Procedures to validate the appropriate use of safety analysis and design parameter inputs and assumptions.
I CNS w.11 conduct an "SSFI-type" review of Primary and l
Secondary Containment, focusing on the current design N/A l
basis, and specifically on implementation of these design bases in previously designed modifications.
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CNS will conduct a self-*Ssessment of our current design j
basis training. We will revise the training, if March 1999 l
l necessary and begin implementation of any revised design basis training no later than March 1999.
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l PROCEDURE NUMBER 0.42 l
REVISION NUMBER 6 l
PAGE 9 OF 13 l
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