ML20202H672

Informs of Changes in Schedule Affecting Four Commitments in ,By Greater than One Month & Notifies of Plans to Issue Rev 3 to Strategy for Achieving Engineering Excellence

ML20202H672
Person / Time
Site:	Cooper
Issue date:	02/02/1999
From:	Swailes J NEBRASKA PUBLIC POWER DISTRICT
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
NLS990009, NUDOCS 9902080176
Download: ML20202H672 (4)

Text

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N Nebraska Public Power Districi Nebraska's Energy Leader NLS990009 February 2,1999 U.S. Nuclear Regulatory Commission Attention: Document Control Desk Washington, D.C. 20555-0001 Gentlemen:

Subject:

Extension of Commitment Dates and Anticipated Revision to the CNS Strategy for Achieving Engineering Excellence Cooper Nuclear Station, NRC Docket No. 50-298, DPR-46

Reference:

1. Letter to Document Control Desk (USNRC) from John II. Swailes (NPPD),

dated October 7,1998," Plans for Monitoring Progress of the CNS Strategy for Achieving Engineering Excellence"

2. Letter to G. R. Horn (NPPD) from Thomas P. Gwynn (USNRC), dated October 30,1998," Plans for Monitoring Progress of the Cooper Nuclear Station Strategy for Achieving Engineering Excellence"

3. Letter to Document Control Desk (USNRC) from John H. Swailes (NPPD),

dated July 8.1998,"CNS Strategy for Achieving Engineering Excellence, Revision 2" Gentlemen:

By letter dated October 7,1998 (Reference 1), the Nebraska Public Power District (District) confirmed understandings reached between the Nuclear Regulatory Commission (NRC) and the District regarding the District's commitment to achieve sustained improvement in Engineering performance at Cooper Nuclear Station (CNS) and the NRC's plans to monitor specific actions. d The NRC requested by letter dated October 30,1998 (Reference 2) that the District inform the NRC, in writing, of significant changes to the CNS Strategy for Achieving Engineering Excellence (Strategy). The purpose of this letter is twofold:

1) To inform the NRC of changes in schedule affecting four commitments in Reference i by greater than a month; 9902080176 990202 F?

PDR ADOCK 050002981 P PDRO >oper Nudear Station UOUUJU~ Po Box 98/ Brownvdle. NE 6832143098 Telephone: (402) 825-3811/ Fax: (402) 825-S211 http //www nppi com

F NLS990009 Page 2 of 3

2) To notify the NRC of the District's plans to issue Revision 3 to the Strategy.

Listed below are the schedule changes affecting four commitments. The first two changes are due to an error made in Reference 1, which incorrectly transcribed the estimated completion date from Revision 2 of the Strategy (Reference 3);

a) Conduct "SSFI-type" reviews of primary and secondary containment, focusing on the current design basis and specifically on implementation of these design bases in previously designed modifications (Strategy item 3.3.f). The estimated completion date of 6/1/99 is being changed to 9/30/99.

b) Form a multi-disciplined team ofinternal employees and outside industry consultants to review the adequacy of the specific and generic corrective actions and the degree of their effectiveness for significant conditions adverse to quality between 1990 and the present (Strategy Item 3.3.i). This activity is scheduled to start 4/1/99, not be completed by 4/1/99. Therefore the District is extending this commitment to 12/31/99, as per Revision 2 of the Strategy.

The next two commitments were originally due 12/31/98 c) Implement configuration change process improvements, Phase 2, to align to the new engineering vision (Strategy Item 3.2.d). A portion of this task is dependent upon a review of experience during CNS Refueling Outage 18, which was extended beyond the original projected schedule. As such, additional time is required to conduct an effective review. The District estimates completion by 4/1/99.

d) Perform a review of selected past modifications (Strategy Item 3.3.d) will be completed by 6/30/99. This extension is also due in part to the extended refueling outage. To date, lessons learned for improving the review process have been identified, such as periodic quality assessments, better documentation of review conclusions, and more defined closure criteria. Additional time is required to incorporate these lessons for the remainder of the modification review.

The above schedule changes will be reflected in the forthcoming Revision 3 of the Strategy. This revision will 1) update the Strategy based on performance to date (action item completion and ,

effectiveness review feedback),2) address additional issues and insights gathered during 1998 assessments, evaluations, and inspections, and 3) improve the efficiency and effectiveness of Strategy implementation by better integration of resource needs and priorities. A separate correspondence will be submitted detailing additional major changes by March 31,1999.

NLS990009 I

Page 3 of 3 Should you have any questions concerning this matter, please contact Bruce Rash Senior Engine: ring Manager,(402) 825-2943.

Sincerely,

\. [

' . 2'rV /r~-

, _f John II. ailes k Vice Presi ent o'f N cle Energy j

/lrd Attachment cc: Regional Administrator USNRC - Region IV Senior Project Manager USNRC - NRR Project Directorate IV-1 Senior Resident inspector USNRC NPG Distribution

s .

l ATTACHMENT 3 LIST OF NRC COMMITMENTS l Correspondence No:NLS990004 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 information and are not regulatory commitments. Please notify the NL&S Manager at Cooper Nuclear Station of any questions regarding this document or any associated iegulatory commitments.

COMMITTED DATE COMMITMENT OR OUTAGE Conduct "SSFI-type" reviews of primary and secondary containment, focusing on the current design basis and specifically on implementation of these design bases in September 30, 1999 previously desioned modifications (Strategy Item 3. 3. f) .

Form a multi-disciplined team of internal employees and outside industry consultants to review the adequacy of the specific and generic corrective actions and the December 31, 1999 degree of their effectiveness for significant conditions adverse to quality between 1990 and the present (Strategy Item 3.3.1).

Implement Configuration change process improvements, Phase 2, to align to the new engineering vision (Strategy Item J,.2.d), April 1, 1999 Perform a review of selected past modifications (Strategy June 30, 1999 Item 3.3.d).

Revision 3 of the CNS Strategy for Achieving Engineering Excellence will be submitted in a separate correspondence detailing additional major changes by March 31, 1999.

This revision will 1) update the Strategy based on performance to date (action item completion and effectiveness review feedback), 2) address additional March 31, 1999 issues and insights gathered during 1998 assessments, evaluations, and inspections, and 3) improve the efficiency and effectiveness of Strategy implementation by better intearation of resource needs and priorities.

l PROCEDURE NUMBER 0.42 l REVISION NUMBER 6 l PAGE 9 OF 13 l

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