ML042950032

Letter to B. Mallett from Nebraska Public Power District Cooper Nuclear Station Readiness for Lifting Confirmatory Action Letter

ML042950032
Person / Time
Site:	Cooper
Issue date:	09/02/2004
From:	Edington R Nebraska Public Power District (NPPD)
To:	Mallett B Division of Nuclear Materials Safety IV
References
CAL-04-03-001 NLS2004093
Download: ML042950032 (13)

Text

Nebraska Public Power District A I W I Lthere I ~ ~tolwn Y O U need tc~

NLS2004093 September 2,2004 Dr. Bruce S. Mallett Regional Administrator U. S. Nuclear Regulatory Commission Region IV 61 1 Ryan Plaza Drive, Suite 400 Arlington, TX 7601 1

Subject:

Readiness for Lifting the Confirmatory Action Letter Cooper Nuclear Station, Docket 50-298, DPR-46

Reference:

1. Nuclear Regulatory Commission letter CAL 4-03-001 to Clay C. Warren (Nebraska Public Power District) dated January 30, 2003, "Confirmatory Action Letter")

The purpose of this letter is for the Nebraska Public Power District (NPPD) to communicate to the Nuclear Regulatory Commission (NRC) Cooper Nuclear Station's (CNS) satisfactory completion of actions in the Confirmatory Action Letter (CAL) and readiness for the CAL to be lifted.

NPPD entered the MultipleIRepetitive Degraded Cornerstone column of the NRC Action Matrix (NRC Inspection Manual Chapter 0305) on April 1,2002. NPPD developed a plan to improve performance at CNS and submitted Revision 1 of The Strategic Improvement Plan (TIP) on June 10, 2002. On August 22,2002, the NRC completed a supplemental inspection of TIP using Inspection Procedure 95003. Following completion of that inspection, NPPD revised the improvement plan and submitted Revision 2 to the NRC on November 25,2002. On January 30,2003, the NRC issued a CAL to NPPD (Reference 1). The purpose of the CAL was to confirnl the commitments made by NPPD regarding those actions in the improvement plan developed to address regulatory performance issues. CNS actions confirmed in the CAL addressed long-standing performance issues in the six areas of emergency preparedness, human performance, material condition and equipment reliability, plant modifications and configuration control, the Corrective Action Program (CAP) and engineering programs. The NRC has performed quarterly inspections to verify completion and effectiveness of actions in CAL-related areas of the TIP.

NPPD conducted an independent assessment from May 17-28,2004 to determine whether CNS was ready for release from the CAL. Readiness was determined by evaluating the extent to COOPER NUCLEAR STATION P 0 Box 98 / arownwlle, NE 68321-0098 Telephone: (402) 825-2811/ F3x: (402) 825-5211 www nppd corn

NLS2004093 Page 2 of 3 which sustainable performance improvement through TIP implementation had occurred in each of the six major CAL areas as well as the extent to which CNS completed the CAL-related actions committed to in the TIP. The NRC observed the Assessment and also conducted independent inspection activities. The results were discussed at a public meeting at Region IV on August 18,2004.

The Assessment Team concluded that performance had improved in all six CAL areas. They also concluded that CAL-related actions in the improvement plan were completed. The Team also found that CNS used feedback from events that occurred during the tenure of the TIP to modify planned and implemented actions to facilitate performance improvement. The Team noted that CNS took actions above and beyond those committed to in the CAL that were effective in facilitating performance improvement in the CAL areas. The CAL-related actions scheduled to start prior to March 3 1,2004 and be completed after that date were confirmed to have started on schedule, had made sufficient progress to date and are scheduled for completion.

The results of the Assessment were that five of the six CAL areas were determined to be ready for release from the CAL. The five areas are emergency preparedness, human performance, plant modifications and configuration control, CAP and engineering programs. These five areas were found to have improved in performance and to have a sufficient infrastructure established with monitoring and management oversight in place to sustain current performance and performance trends and facilitate further improvement toward excellence. The CAL area of material condition and equipment reliability, although improved, required that additional actions identified in four Areas For Improvement (AFI) be satisfactorily addressed before this area would be ready for release from the CAL. These M I ' S would accelerate improvement and strengthen sustainability in this area. The AFI's were entered into the CNS corrective action program and all but one action has been completed. The remaining action involves initiating maintenance activities for critical component f~inctionallocations with near term risk. This action is scheduled to be completed by September 10, 2004.

The Assessment also provided CNS additional insights to take the station to excellence in the form of Observations. Although not discussed in this letter, each Observation has been entered into CAP.

In conclusion, NPPD believes that actions in the CAL have been completed and that these actions have been effective in addressing long-standing performance issues and sustainability.

NPPD recommends that the NRC lift the CAL and believes that CNS no longer requires the additional NRC oversight of the MultipleIRepetitive Degraded Cornerstone column of the NXC Action Matrix to ensure regulatory performance and plant reliability.

A detailed discussion of CNS's readiness is in Attachments 1 and 2 including a summary of the CAL Assessment. That document is available for NRC review.

NLS2004093 Page 3 of 3 Should you have any questions or require additional information, please contact Paul Fleming, Licensing Manager at 402-825-2774.

~ i n d a lK.

l Edington Vice President-Nuclear and Chief Nuclear Officer Cooper Nuclear Station Attachments U.S. Nuclear Regulatory Commission wlattachment Attn: Document Control Desk Washington, D.C. 20555-0001 Senior Project Manager wlattachments USNRC - NRR Project Directorate IV-1 Kriss Kennedy wlattachments Chief, Branch C U S . Nuclear Regulatory Commission Region IV Senior Resident Inspector wlattachments USNRC NPG Distribution wlattachments Records wtattachments

NLS2004093 Page 1 of 8 ATTACHMENT I CAL CLOSURE CAL ASSESSMENT Objectives Confinn that CNS has coinpletcd the CAL-rclated actions committed to in the TIP.

Detennine the extent to which CNS addressed CAL-related problem statements, and whether performance has improved in the six CAL focus areas.

Detennine whether significant challengeslevents that occurred in the recent past should have been prevented by actions taken through TIP, and if so, why they were not. Detennine whether comprehensive prcventivelcorrective actions were developed and implemented, and the extent to which these have been effcctive.

Consider actions that CNS took above and beyond those required by the CAL., and the extent to which these have bcen effective in improving perfonnance.

Detennine CNS' ability to sustain impro\~cdperfonnance andlor positive perfonnance trends in each of'the 6 CAL focus areas.

Assessment Team With the exception of the Assistant Team Leader and the -'Host Peer," the Team was composed of persons independent of CNS line responsibility primarily fiom Entergy to ensure objectivitylindcpendence. Each team incmber was assigned primary responsibility for one of the six CAL areas. Team members possessed extensive knowlectge and experience in their assigned areas. The Team Leader was a director-level ~ndividual,and a majority of the team members were at the manager or supervisor level. Additional oversight and review were provided by two vice-presidents from Entergy and a Director. A CNS Safety Review and Audit Board member was assigned as Team sponsor to provide advice and oversight during all phases of the assessment. A "Host Peer" (a CNS professional) was assigned to provide logistical support to the Team. Although Team members had primary responsibility for their assigned areas, overlap of assessment activities was performed, particularly in the C'AL areas of larger scope (e.g.,

Corrective Action Progain, Human Performance, and Material Condition and Equipment Reliability).

Approach Assess each CAL area inctcpcndently - fbcus on whether sustainable improved perfonnance exists in the six major areas of the CAL.

Establish "measures of effectiveness" against which to judge performance. These measures have been devcloped fi-om Objectivcs (considering Action Plan Causal Factors) from CAL-related TIP Action Plans. Perfonnance that meets the "measures

NLS2004093 Page 2 of 8 of effectiveness" will mean that the CAL-related Action Plan Problem Statements have been effectively addressed.

Through independent assessment, develop a view of current pcrfonnance and compare to "ineasures of'effectiveness."

t Determine the extent to which management is aware of current performance, and Performance Indicators are aligned with performance.

Rate performance in each CAL area using a 4-tiered rating system - "Fully Effective," "Largely Effective, "Marginally Effective,. and "Ineffective."

Draw a conclusion about sustainability.

Recommend actions for CAL focus areas rated other than .'Fully Effective" or "Largely Effective.'.

Consider whether CAL closure is appropriate, given the need for any additional actions.

Draw overall conclusion on readiness for release from the CAL.

In addition, Strengths, Areas for Improvement, Observations and Recommendations were noted in the Assessment for each CAL area, as appropriate. Thc results of the Assessment are summarized in the table in Attachment 2.

In the discussion of the Assessment results that follows, thc TIP applicable Action Plan I'roblein Statement is provided and then the Assessment findings are presented based on the measure of effectiveness ratings. There were no CAL areas or measures of efiectiveness rated as "not effective."

Assessment Results Emergency Preparedness (EP)

TIP Action Plan Problem Statement - The CNS EP program exhibited declining performance over an extended period of time. CNS management failed to take effective corrective action to arrest the declining perfomlance before events caused CNS to enter the degraded area of the NRC Reactor Oversight Program Action Matrix.

Emergency Preparedness was rated as Fully Effective with no Marginally Effective measures of effectiveness. The current DrillIExercise Performance NRC Performance Indicator is above the industry average (CNS - 96.3% verses an industry average of 95.7% for 2Q04 data).

Perfonnance in all three NRC Perfonnance Indicators demonstrates improved and sustained performance. EP use of CAP is effcctive and the latest trend reports do not indicate any degrading or adverse trends associated with EP CAP items. Sustainability is evidenced by the equipment, process, procedural and program improvements that have been made. Departmental performance indicators have been established to provide early indications of performance changes. Management support, involvement and commitment to the Emergency Preparedness program have improved. Several program Strengths were noted including the electronic

NLS2004093 Page 3 of 8 notification process, the weekly Ernergcncy Rcsponse Organization (ERO) team turnover meeting, the EP staff use of computer software to improve ERO perfonnance and the separate simulator computer for training.

En pineering Programs TIP Action Plan Problem Statement - The performance ot'CNS Engineering Progams has historically lacked sustained effectiveness.

Engineering Programs was rated as Largely Effective with no Marginally Effective measures of effectiveness. All related performance indicators were Green or White and show an improving trend. Sustainability is evidenced by process and procedure improvements, management support, involvement and commitment to the Engineering Programs and the oversight controls that are in place. Engineering Program health is rcported and assessed monthly. Future strategies and needs ofthe program are identified so that the programs continue on a path of pcrfonnance improvement.

Plant Modifications and Configuration Control TIP Problem Statement - there are four TIP Action Plans that address this CAL area. The problem statement for each is:

b Resolution of degraded and non-conforming conditions requires improvement in the areas of recognition of degaded and nonconfonning systems, structures and components, completeness of the evaluation of the technical bases for impact on operability and timely completion of corrective actions.

b CNS has produced lower quality documents such as operability determinations and configuration changes when these documents have had a higher reliance on locating and understanding the assumptions used in the CNS safety analysis or required translation of these assumptions into operating procedures.

b Implementation of the Unauthorized Modifications Follow-up Project Plan is not complete.

b In several cases, design modifications have not bccn delivered and installed in a timely manner to support the operational needs of the station. Additional cases have been cited with long-standing problems with the qualityladequacy of modification packages, problems with inadequate rigorlquality of calculations and analyses and problems with addressing component obsolescence issues in a timely manner.

Plant Modifications and Configuration Control was rated Largely Effective with one measurc of effectiveness, "modification, packages, calculations and analyses are rigorous and of high

NLS2004093 Attachment I Page 4 of 8 quality," rated Marginally Effective. The issue that caused the measure to bc rated as such concerned the quality of engineering products relative to administrative detail. Corrective actions included addressing the issue in All Hands Meetings and continuing training focusing on attention to detail. The actions were completed in June 2004. The Unauthorized Modifications Project is complete and the Project Closeout Report concluded that the quality and completeness of the project were effective. Enginecring's activities are integrated with those of other line organizations through the new work management process resulting in work on the correct priorities to support the operational needs of the station. Sustainability is evidenced by procedures controlling configuration change and the station's engineering tools for maintaining, retrieving and improving documents for detailed design and licensing bases. Corrective actions to address errors related to understanding bases that affected operability determinations were effective.

Two Strengths were noted in this CAL focus area, one concerning the h c t that there is a single procedure for all plant processes that can change bases and configuration and the other concerning the ATLAS database that is used to direct users to the appropriate documents for detailed design and licensing bases associated with the safety analyses.

Corrective Action Program (CAP)

TIP Action Plan Problem Statements - There are three TIP Action Plans that address this CAL area. The problem statement for each is:

As an organization, CNS is not using the CAP effectively to understand problems and change behaviors for continuous improvement.

t CNS has had a history of recurring problems that have not been eliminated or prevented by the root cause investigations and subsequent corrective actions.

Long-standing problems exist with applying Operating Experience, such as reporting events to the industry and using operating experience in daily activities.

Additionally, Significant Operating Experience Report recommendations are not implemented and tracked consistently.

There were seven measures of effectiveness in the CAP area. Three measures of effectiveness were rated as Marginally Effective, three were rated as Largely Effective and one was rated as Fully Effective.

CAP (including utilization of industry operating experience and self-assessments) was rated Largely Effective. There was one CAL-related AFI which stated, '-The current level of rigor and methodology applied to apparent causes for critical component failures have not consistently resulted in determining and correcting cause or implementing actions that address extent of

NLS2004093 Page 5 of 8 condition." This AFI is more related to the CAL area of Equipment Reliability and will be addressed in that portion of this Attachment.

The first measure of effectiveness rated Marginally Effective was, "quality and timeliness of evaluations meet established standards and expectations." This rating is based 011 one aspect of apparent cause analysis, the critical component failure apparent cause evaluation issue discussed in the AFI. As stated previously, this AFI will be addressed in the Equipment Reliability area.

The second measure rated Marginally Effective was, "timeliness and effectiveness of corrective actions meet established standards and expectations; repeat events are minimized due to effective problem solving, accurate root cause evaluations and sustainable actions." The 100% back-end reviews indicate CAP corrective action closure quality is improving. Backlog and On-Time Completion Performance Indicators are significantly improved and in the Green or White band.

There has been a handful of recurring significant conditions and a lack of run time on current initiatives which is thc basis for this rating. Equipment Reliability, as addressed in that CAL area, will require several cycles to attain desired levels of performance but the infrastructure to manage and prioritize in support of safe operation is in place.

Because of the recurrent issues, the station's Corrective Action Review Board reviewed 200312004 root cause evaluations to assess the adequacy of interim corrective actions and the timeliness of preventive actions. Some insights from this review regarding recurrence were that:

Long-tenn preventive actions were generally solid.

Interim actions were sometimes insufficient or were untimely.

There are some weaknesses in the station's decision-making process that allowed interim corrective actions not to be implementcd in a timely manner.

Corrective actions incIuded reconfiguring the daily Condition Review Group meeting to review interim actions and developing a guideline for evaluating the risk of interim actions for significant conditions.

The third Marginally Effective rating was, "data/infonnation is reviewed for trends, trends are entered into CAP and actions to address them are effective." The Assessment indicated trending is being performed using multiple data streams and that equipment trending is effectively identifying high failure components, entering them into CAP and taking action to address the issue. The MarginalIy Effective rating is based on problems colnmunicating trend issues and the failure to use trend reports to full advantage, resulting in missed opportunities for more timely actions to address identified emerging trends. The issue was one that concerned the degree of effectiveness of trending through more effective communication of data. Actions have been taken to improve timeliness of communication and follow-up of tl-end infonnation. These include the production of monthly trend reports and discussion and follow-up of trends at daily management meetings.

NLS2004093 Page 6 of 8 There are several reasons for rating the CAP area as Largely Effective. The first Marginally Effective area (and the related AFI) and the second Marginally Effective area are more related to the Equipment Reliability area. The third Marginally Effective area is based on a very specific trending issue related to the more effective communication of data. This issue is only a part of the overall area being evaluated. Finally, the latter two Marginally Effective areas had no AFI-level issues.

Sustainability in the CAP area is evidenced by significant perfonnance improvement and the equipment, process, procedural, program managerial support and oversight changes that have occurred. Most importantly is a change in the station's alignment on the importance of CAP and the belief that CAP is the station tool to resolve problems and improve perfonnance. At CNS, CAP is core business. Applicable operating experience is being effectively used at the station to minimize the potential for occurrence andlor impact.

The Corrective Action Program and processes are sound containing all of the elements necessary for identification, prioritization, evaluation, corrective action and trending. Line management has taken ownership of CAP. Infrastructure, monitoring, oversight and responsiveness are sufficient to sustain performance improvement.

One Strength was identified. The use of operating experience by all levels ofthe organization is fostered by information tailored to the users.

Human Performance Tip Action Plan Problem Statements - There are two TIP Action Plans that address this CAL area. The problem statement for each is:

The station has failed to recognize declining human performance and take effective corrective action.

CNS leadership has cstablished a tolerance for operational challenges as indicated by the number of unacceptable levels of deficient conditions (maintenance backlog, long-term clearance order and caution tags, operator workarounds, excessive numbers of temporary modifications and control room deficiencies, etc.) and has not demonstrated high standards in conduct of operations.

Human Perfonnance was rated Largely Effective with one measure of effectiveness rated as Marginally Effective, "human performance principles and expected behaviors are engrained in station culture." The Assessment indicated that the station has made significant improvements in understanding and recognizing human perfonnance error prevention principles and expected bchaviors. With continued reinforcement and practice, the station is on track to fully meet this Marginally Effective measure of effectiveness. Continued human performance training along

NLS2004093 Page 7 of 8 with continued reinforcement and leadership modeling provides the basis for improvement and the means to achieve full effectiveness in this measure of effectiveness area.

Lower error rates and a reduced significant event rate provide evidence of the improvements.

Thc work force better understands and uses error prevention tools/techniques but continued improvement is needed to reach site-desired levels of perfonnance. Human perfonnance has a program owner, strong senior management support, standards and lines of accountability clearly established, and improved monitoring and measurement. The latter includes quarterly department ongoing self-assessments and other assessments, the management observation program, the daily management review meeting, the increased use of common cause evaluations and comparison to Entergy fleet performance. Recent external reviews have identified Strengths in the implementation of human performance initiatives and in the use of the Engineering Human Performance Trainer.

Sustainability is evidenced by the level of enthusiasm, energy and commitment by station personnel to improving human performance. Performance Indicators provide visibility and focus on human perfonnance. CNS has established a human performance infi-astructure that will insure that improvements will be sustained and future initiatives will be championed.

Equipment Reliability Tip Action Plan Problem Statement - There is one primary TIP Action Plan that addresses this CAL area. The remaining Equipment Reliability action plans are concerned with specific equipment issues. Actions for the specific equipment are on schedule and for some, the schedule has been accelerated (feedwater check valves and air systems). The problem statement from the primary TIP Action Plan is:

Lack of proactive processes to resolve equipment performance problems have resulted in an inability to consistently achieve long-term reliable system and equipment operation.

Equipment Reliability was rated as Marginally Effective. There were three AFl's (accelerated review of the critical component list, review of the critical component list against current monitoring plans, and review of the critical component list to determine what predictive maintenance is required). There was also the AFI that was identified in the CAP area.

Corrective actions for the first three AFI's involved accelerated review of the critical component list relative to scheduling preventive maintenance, appropriate monitoring and predictive maintenance. These actions are complete except for one concenling initiating maintenance activities for critical component functional locations with near term risk which is scheduled to be completed by September 10, 2004. For the AFI identified in the CAP area related to Equipment Reliability, implementation of a template for improved apparent cause analysis has been completed.

NLS2004093 Page 8 of 8 There were two measures of effectiveness that were rated Marginally Effective, "establishment of an integrated equipment reliability process modeled after the INPO AP-913 process established and functioning in a proactive manner to anticipate and prevent system and equipment problems and "reliable equipment operation evidenced by plant operation that meets equipment goals." These two measurcs resulted in the overall rating for this CAL area.

The first Marginally Effective area is related to the three AFI's concerning accelerated review of the critical component list. The second Marginally Effective area was rated as such in that equipment plans are scheduled over an appropriate, but extensive time period and actions completed to date have had a minimal impact on improving overall equipment reliability.

Equipment Reliability as addressed in the CAL would require several cycles to attain desired performance levels but the infrastructure to managelprioritize activities in support of safe operation is in place.

Sustainability is evidenced in that a plan exists to establish the equipment reliability infrastructure, actions that are on schedule per the plan with some program elements already in place, and rigorous management oversight and monitoring of plan implementation. In addition, the Equipment Reliability group provides a dedicated focus on equipment reliability and drives many of the improvement actions underway. Finally, inclusion of high priority projects designed to improve equipment reliability on the Top Ten Technical lssues List assures management focus and funding of these activities.

New tools to assist in the identification of' degraded equipment should result in improvement. It was considered that when monitoring plans are updated and system monitoring improvements effectively utilized, equipment reliability could improve at an accelerated rate. There are several perfonnancc indicators used to monitor Equipment Reliability. Actions are in place to produce substantial progress for systems that are currently Red or Yellow. Shortly after RE22, 7 of 9 will become White or better. Other related Performance Indicators, such as Unplanned Scrams, Unplanned Power Changes and Forced Loss Rate have improved with significant improvement projected by the end of the year.

Two Strengths were recognized. One is the Plant Health Committee which is an effective venue for periodic monitoring of system health to facilitate improved equipment reliability. The second concerns classifying components for preventive maintenance optimization by functional equipment groups. This will result in more efficient utilization of plant resources and fewer tagouts to support maintenance activities.

N LS2004093 Attachmcnt 2 Page 1 of I ATTACHMENT 2 CAL Assessment Summar! Matrix d CAL Focus Areas Corrective 1iuma11 E q ~ ~ i p m te n Engineering Design Mods l Emergency Action Performance Reliability Progranls Configuration Preparedness Managemen t 6 Merr.ccrim Area Effectiveness Largely Largely Marginally Largely Largely Fr~llyEffective Effective ESSective Effective Effective Effective Fully Effective Measures Lmgely Effective Measures Marginally Effective Measures Areas for Improvement Observations

ATTACHMENT 3 LIST O F REGULATORY COMMITMENTSO I Coiwspondence Number: NLS200-1093 The following table identifies those actions committed to hy Nebraska Public Power District (NPPD) in this document. Any other actions discussed in the submittal represent intended or planned actions by NPPD.

They a r e described fbr information only and a r e not regulatory commitments. Please notify t h e Licensing &

Regulatory Affairs Manager a t Cooper Nuclear Station of any questions regarding this document or any associated regu1atoi.y commitments.

COMMITTED DATE COMMITMENT OR 0 UTAGE None PROCEDURE 0.42 REVISION 15 I PAGE 18 O F 2 4 1