NLS2012130, Problem Identification and Resolution P. 1(c) Substantive Cross-Cutting Issue
| ML12354A056 | |
| Person / Time | |
|---|---|
| Site: | Cooper  |
| Issue date: | 12/13/2012 |
| From: | O'Grady B Nebraska Public Power District (NPPD) |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| NLS2012130 | |
| Download: ML12354A056 (12) | |
Text
Nebraska Public Power District Always there when you need us NLS2012130 December 13, 2012 U.S. Nuclear Regulatory Commission Attention: Document Control Desk Washington, D.C. 20555-001
Subject:
Problem Identification and Resolution P. 1 (c) Substantive Cross-Cutting Issue Cooper Nuclear Station, Docket No. 50-298, DPR-46
Reference:
Letter from the U.S. Nuclear Regulatory Commission to Brian J. O'Grady, Nebraska Public Power District, dated September 4, 2012, "Mid-cycle Assessment Letter for Cooper Nuclear Station"
Dear Sir or Madam:
The purpose of this letter is for Nebraska Public Power District (NPPD) to provide the Nuclear Regulatory Commission (NRC) with NPPD's written response as requested in the reference letter. Additionally, this letter serves as notification to the NRC that NPPD is ready for inspection in the Problem Identification and Resolution [P. 1 (c)] area.
In the reference letter, the NRC determined that the performance of Cooper Nuclear Station in the most recent assessment period was in the Licensee Response Column of the NRC's Reactor Oversight Process Action Matrix. However, a Substantive Cross-Cutting Issue (SCCI) was identified in the P.1 (c) area associated with the corrective action component related to the thoroughness of problem evaluations such that resolutions address causes and extent of condition.
As such, the NRC requested a written response detailing corrective actions to address this cross-cutting theme including schedule, milestone, and performance monitoring metrics.
As a result of the evaluation performed to address the SCCI identified in the Problem Identification and Resolution [P.1 (c)] area, three causes were identified. The primary cause identified was management expectation errors due to inadequate or inconsistent standards. Two secondary causes identified were inadequate management oversight and follow-up of issues, as well as inadequate organization to organization performance resulting in organizational interface breakdowns.
COOPER NUCLEAR STATION P.C. Box 98 / Brownville, NE 68321-0098 Telephone: (402) 825-3811 / Fax: (402) 825-5211 www nppd com
NLS2012130 Page 2 of 4 In conjunction with the three causes mentioned above, communication, prioritization, empowerment and teaming were identified as organizational factors.
A need to focus change management on the right issues that impact station performance is attributed to the communication factor. To address this, a standing order requiring the use of a Technical Pre-Job Brief for any operability evaluation assignment was issued. This was to ensure clear task definition was identified for required engineering support. In addition, a change management panel was established and convened to review corrective action plans for root cause and selected apparent cause evaluations.
The prioritization factor identified the need to fix the condition right and understand time restraints to support true corrective action success. As such, a risk tool to aid the Operations Station Technical Engineers in determining if the Condition Report (CR) directly questions site design basis to assess risk impact for appropriate resource support was developed.
The teaming factor identified that the Condition Review Group (CRG) needs to reflect true department ownership to fix multi-discipline issues and site management need to provide the appropriate check and adjust validation, thus ensuring key Corrective Action Program (CAP) issues are truly resolved for the long term. As such, specific resources, with a minimum of six personnel, were established in Engineering to perform Operability Evaluations (OE), including specific additional resources to support OE development and reviews. Selected individuals will be qualified to perform OE tasks. In addition, a brief was completed with CRG members to assign action directly to all impacted departments to develop action plans when a multi-discipline issue is identified (e.g., SCCI or site-wide impact issues). All CR closeout reviews for root cause evaluations and selected apparent cause evaluations are being reviewed by an independent manager.
The empowerment factor (along with aspects of prioritization, teaming, and/or communication) identified the need to fix the condition right and understand time restraints to support true corrective action success and when a key site standard changes, all site departments support the change. Therefore, a requirement was established that requires a review by the site change management panel for any corrective action derived from a root cause that impacts a site level process performance or changed how design configuration is supported by site processes. Also, a schedule to review CRs greater than six months has been established and implemented. This review will be performed once per month to identify challenges and actions needed to fix the significant conditions in a timely manner, including site support needed.
Status updates of these actions will be provided to the Corrective Action Review Board (CARB) until the end of 2012.
Furthermore, the Operability Determination process was revised to drive more consistent investigation and documentation of the results of operability reviews, specifically assumptions, use of references and sources, any differences from Updated Safety Analysis Report methods, use of calculations, and interface guidelines with support staff, was completed.
NLS2012130 Page 3 of 4 CRG members and line management have been briefed on the importance of recognizing aspects of cross-cutting areas and relationships to performance deficiencies to strengthen oversight of problem identification and evaluation based on correct problem statements.
The attachment to this letter provides Performance Indicators (PIs) that will demonstrate sustained improvement. These PIs are described below.
- CAT A Quality - measures the overall quality of the Category A Root Causes based upon scores provided by CARB. The past twelve month rolling average is used for this measure.
- CAT B Quality (Site) - measures the overall quality of the Category B Apparent Causes as evaluated by CARB.
" CAP Actions Average Age - average age in days of CAP action items. The sum of the ages of open CAP actions divided by the total open CAP actions.
" CR (Cat A&B) Evaluation Performance - average evaluation time for CRs during the month (measured in days). Does not include CRs that do not require an evaluation (e.g., CRs that get closed to work orders, trending, etc.). The age of the more significant Category A and Category B evaluations is being tracked due to their importance and complexity.
" CR Average Age - average age in days of CRs that were open at any point during the reporting period, not including CRs restrained by Refueling Outages/Forced Outages, Modification/Design Change, NRC response required and Multi-Cycle training required.
- Operability Assessment - summation of the assessed health of the program for the process elements found in the CNS procedure.
Improvement in the area of P. 1 (c) has been shown in the last half of the assessment period. As such, NPPD considers this substantive cross-cutting issue in P. 1 (c) ready for inspection.
This letter does not contain regulatory commitments.
Should you have any questions or require additional information, please contact David Van Der Kamp at (402) 825-2904.
NLS2012130 Page 4 of 4 Sincerely, Brian J. 0'Gr Vice President - Nuclear and Chief Nuclear Officer
/jo
Attachment:
Performance Indicators cc:
Regional Administrator w/attachment USNRC Region IV Cooper Project Manager w/attachment USNRC NRR Project Directorate IV-1 Senior Resident Inspector w/attachment USNRC - CNS NPG Distribution w/attachment CNS Records w/attachment
NLS2012130 Attachment Page 1 of 8 Performance Indicators
Reporting Authority IPl Titde
,Month/Year Istatus CAP Site CAT A Quality Nov-12 l
CAT A Quality 25 20 15 10 5
0 Jan-12 Feb-12 Mar-12 Apr-12 May-12 Jun-12 Jul-12 Aug-12 Sep-12 Oct-12 Nov-12 Dec-12 CAT A Quality Score (12 Monh Avg) 1-Goal Report Date 12A1 02012 2449:10 PM Descripiol Jan-12 Feb-12 Mar-12 I 2
Mav-12 Jun-12 Ju1-12 Aug-12 S
Oct-12 Dec-12 CAT A Quality Score (12 18.82 18.96 19.22 19.36 19.65 19.96 19.80 19.80 19.76 Month Avg)
CAT A Quality Score (3 20.81 19.70 1635 19.17 19.81 19.81 19.19 19.45 1945 19.44 20.75 Month Avg)
CAT A Quality Score 16.75 20.38 18.67 19.45 19.44 22.05 (Month)
Goal Definidon Measure the overall quality of the CAT A's based upon scores provided by the Corrective Action Review Board (CARB). The past 12 month rolling average is used for this measure.
Goals Green >=20, White >=10, Red <10 Analyss and Actions Slight increase in 12-month rolling average is a sign that the low scores from 2011 are starting to roll off while the higher scores from alignment with Entergy is helping.
Actions: CAA will continue to collect scores from CARB members during CARB meetings and look for any trends in low scoring sections of the evaluations.
Two Cat A Evaluations scored by CARB in November.
CR 2012-07174, Loss of Safety Function in the RHR System; owned by Licensing scored 22.1 CR 2012-07365. Leak on SWBP-D; owned by Engineering Support scored 22.0 DanSoual Lowner La Manual Input ILinda Dewhirst Lisa Mitchell
ReportingAuthority P1 Title Month/Year 1Status CAP Site CAT B Quality (Site)
Nov-12 White CAT B Quality (Site) 25 20 15 10 5
0 Jan-12 Feb-12 Mar-12 Apr-12 May-12 Jun-12 Jul-12 Aug-12 Sep-12 Oct-12 Nov-12 Dec-12 CAT B lQuality Score (12 Month Avg) Goal Report Date 12/10U2012 4:54:47 PM Description
-Jn-12 Feb-12 Mar-12 Ap-
-12 Jun-12 l-12 Nov-12 Dec-12 CAT B Quality Score (12 18.69 18.72 18.57 18.71 18.88 19.27 19.83 19.76 19.74 19.85 19.87 Month Avg)
CAT B Quality Score (3 18.91 18.93 19.25 20.00 19.39 19.40 19.23 19.59 20.03 20.15 20.19 Month Avg)
CAT B Quality Score 19.33 19 0
20.33 18,45 19.42 19.82 19.5 20.12 20.33 0
(Month)
Goal II
- IIII -
I Definiton To measure the overall quality of CAT B Apparent Causes as evaluated by the CAP Staff.
Goals Green >=20, White >=10, Red <10 AnalWs and Actions Problem: Twelve-month rolling average score for Cat B evaluations scored by CARB is not more than 20.
Cause: Lack of management focus on the Entergy procedural requirements has contributed to Cat B Quality scores not being consistently above 20.
Actions: CAA will continue to collect scores from CARB members during evaluation reviews at CARB and look for any trends in low scoring sections of the evaluations. In January 2012, CAA began conducting Apparent Cause Evaluation Training for the site per CR-CNS-2011-04686 CA-05; over 100 employees have attended this training.
Zero Cat B evaluations scored by CARB in November.
Data Source owner Ana er Manual Input Linda Dewhirst Lisa Mitchell
i A
PI -Tie IMonh/year IStatus CAP Site CAP Actions Average Age Nov-12 CAP Actions Average Age 120 100 80 60 40 20 0-Jan-12 Feb-12 Mar-12 Apr-12 May-12 Jun-12 Jul-12 Aug-12 Sep-12 Oct-12 Nov-12 Dec-12 iAg Age CAP Open Aons (Days) --
Goal Report Date 12A10/2012 5:00:30 PM De cipin a -12 Fe -2 M r-12 Jn-2 ul Augnt2...... t-1 NO,1 K -12...
Avg Age CAP Open 102.3 10.2103110.
Goali Average age in days of CAP action items. The sum of the ages of open CAP actions divided by the total open CAP actions.
Green <=100, White <=300, Red >300 Analwi and Actions Slight increase in average age is expected due to the number of open CA's that have not been closed out due to RE27. CAA will continue to monitor and provide CAP Look Ahead reports to the site management team in an effort to keep departments looking forward and addressing CAP items in a timely manner.
I Sou Owner A
r Manual Input I Linda Dewhirst Lisa Mitchell
UnP Perian IlontYear Av AgeI a ys Cooper CR (Cat A&B) Evaluation Performance Nov-12
]StaLtu Status Status IF CR (Cat A&B) Evaluation Performance 35-3 30-J.
J4
- 1.
4
- 1.
4 J.
- 4.
4
.4 30-
-Id l
6 1
25-
-2
&o 20-Nov-t1 Dec-t1 Jan-12 Feb-12 Miar12 Afar-12 May-12 Jun-12 Jul-12 Aug-12 Sep-12 Oct-12 Nov-12 Number of CR Eval's los, d-Mot Evaluaton Age Goal
=
A S">
3Dd M
wg Age of Close Evar's (days)
Dsrlo N Ifov, l e-1 Jan-121 reb-12 Ma,-12 IAm-12 May1 Jun,2 Ju.*12 Aug-12 Sp1 c-2NV1 Number of CR Eval's 14 18 11 4
4 13 17 15 13 18 15 10 18 Closed - Month Evaluation Age Goal 130 30 30 30 1
30 30 30 30 30 30 30 30 30 EOY Estimate11 111111 EOY Goal 30 30 30 0
30 30 30 30 30 30 30 30 30 The average evaluation time for Condition Reports (CR) during the month (measured in days). Does not include Cl~s that do not require an evaluation (e.g. Cl~s that get closed to work orders, trending, etc.). The age of the more significant CAT A and CAT B evaluations is being tracked due to their importance and complexity.
Starting with June 2010 data. PI has changed to red / green status onyy. Green goal changed from 25 to 30.
Monthly average age of evaluations Green: <= 30 days, Red: > 30 days Number CR Evaluations (A&B) >30 days Green: = 0, Red: > 0 Def* san
- tons.
Current performance is Green and the end of the year projection is Green.
Eighteen evaluations were comoleted in Novembrrers trendinghet The comoleted in less than 25 davs.
Data Source
,owner
,Aalyzer
- CAP Index (automated)
Linda Dewhirst Lisa Mitchell
"nl+
101 Titla IUon*hJV.&ikr Ct2tiic I FnV
- runt, Ic C o p
I
- C A v e ra g e t.e I S vW i,
Cooper CR AverageA Ae Nov-12 K
-z=
CR Average Age 200-150-100 50-0 Nov-11 Dec-11 Jlu-12 Feb-12 Mar-12 AM-12 May-12 Jur-12 Jul-12 Aug-12 Sep-12 Oct-12 Nov-12 M CR Average Age CR Average Age Goal Description JNov-11 Dec-11 JaIn4Z2 Fe~b-12 Mar4Z Av4-2 jMsv4Z I Jun-12 Jul-12 Auz-12 Sep412 ~Oct12. Nov412 CR Average Age CR Average Age Goal 160 160 160 1
160 160 160 1
160 160 11 1 6
0 1 160 1
160 EOY Estimate EOY Goal 160 1160 60 1160 60 160 160 160 160 160 160 160 160 Definituon Average Age in days of Condition Reports that were open at any point during the reporting period, not including Condition Reports restrained by RFO/FO, Mod/Design change, NRC Response Req and Multi-cycle training required.
Goals
<161 Green; 161-170 White; 171-180 Yellow: >180 Red Analyss anid Actions.
Condition Report average age is within the green band. Data for November shows average age is lower than almost all of the other months in the nast vear which is due to the increase in new CR's eenerated durine RE27.
Data our.e Ara.
- CAP Index (automated)
I Linda Dewhirst Lisa Mitchell
R r
Auth PTitde Mo earS Operations Operability Assessment Nov-12 Operability Assessment 100 80 60 40 20 0
Jan-12 Feb-12 Mar-12 Apr-12 May-12 Jun-12 Jul-12 Aug-12 Sep-12 Oct-12 Nov-12 Dec-12 Program Heal Scare Goal Report Date 12A12/2012 7:56:37 AM Dmitin IJan-12 Fl-2 Ma-2 Ar1 May-1 Jun212 u-2IAg1 e-2 Ot1 O-2 Dc1 Program Health Score 85 85; 82R 82
=87 I-aA 1
This Performance Indicator is a summation of the assessed health of the program for the process elements found in CNS Procedure 0-CNS-12A, Attachment 2.
Green >=90, White >=75, Red <75 Note -Threshold was revised under 0-CNS-12A, Revision 9.
Analysis and Actions Comments Data Source Owner naye Scorecard Rod Penfield ISteve Wheeler Question Points Earned Points Possible Program compliance as assessed by NRC 4
8 inspections QA/independent assessments show program 8
8 in compliance/outstanding AFIs INPO assessment 4
7 Self assessment conducted within the 3 years 4
4 Clear program scope and direct procedures 10 10 Assigned Program Owner 8
8 Program trends performance 10 10 Program related performance indicators 10 10 Attendance at program specific workshop 5
5 within 18 months Participation as a peer on assessment or audit 5
5 at another station in past 18 months in program area Benchmarking completed within last 18 10 10 months At least ONE Risk Significant related activity 5
5 within last 30 days (as defined in Step 6.3.1 and Procedure 0 CNS-06) with the program as contributing to Apparent/Root Cause
Question Points Earned Points Possibe Risk Significant Activities caused a PCR/IDOCS 5
5 in the past 30 days to a program procedure A program related Risk Significant Activity 5
5 resulted in a Condition Report being generated