ML20098A992
| ML20098A992 | |
| Person / Time | |
|---|---|
| Site: | Cooper  |
| Issue date: | 05/20/1994 |
| From: | NEBRASKA PUBLIC POWER DISTRICT |
| To: | |
| Shared Package | |
| ML20094C015 | List: |
| References | |
| FOIA-95-262 PROC-940520, NUDOCS 9510020020 | |
| Download: ML20098A992 (100) | |
Text
_
i t
COOPER NUCLEAR STATION 3
1 i
NEAR TERM i
j INTEGRATED ENHANCEMENT i
PROGRAM i
i o
4 i'
1 MAY 20,1994 b
l 9510020020 950905 j
EXECUTIVE
SUMMARY
The purpose of.this Integrated Enhancement Program is to provide j
Senior Management focus on the issues that are important to improving the overall performance of the' Nuclear Power Group (NPG) in the near term.
For the long term,' elements of this program, together with other management improvement initiatives, are being incorporated into the NPG Business Plan.
1 Embodied within this Program are several inputs from sources such as the Strategic Plan'for Performance Improvement, Senior Management identified items, the FPI Common Cause Analysis and the NRC Operational Safety Team Inspection.
Individually taken, the items may not indicate a programmatic or organizational weakness; but as a whole there are strong indications that Senior Management has not been effective in directing the operations of Cooper Nuclear Station.
Accordingly, through the successful and timely completion of the
- program enhancements described within this manual, a marked improvement in the safe operation of Cooper Nuclear Station will be realized.
J i
TABLE OF CONTENTS INTRODUCTION PAGE A.
Background
1 B.
Management Changes 1
C.
Deficiencies 2
D.
CNS Integrated Enhancement Program 4
E.
Index of Program Enhancements 8
Section I.
NUCLEAR POWER GROUP Section II.
MANAGEMENT Section III.
OPERATIONS Section IV.
SAFETY ASSESSMENT Section V.
SITE SUPPORT l
I Section VI.
NUCLEAR SUPPORT t
Section VII.
CORPORATE ENGINEERING i
Section VIII.
QUALITY ASSURANCE l
11
INTRODUCTION
'I l
A.
BACKGROUND Cooper Nuclear Station.(CNS) has traditionally been
'l recognized as a good performer within.the Nuclear Power Industry.
However, recent events at CNS indicate a declining trend in performance.
Even though a solid and.
safe operating record has been maintained, the Nuclear Power Group (NPG) Management, based on a number of recent indicators, recognizes that the performance of the entire organization is in question.
Unfortunately, management was remiss in not recognizing earlier the disproportionate number of negative indicators that have been received over the past eighteen months.
NPG Management is keenly aware that major, expeditious changes in how we conduct business must occur if CNS is to remain' economically viable while meeting internal and regulatory expectations.
This Integrated Enhancement Program will provide management and staff with the short term vehicle to ensure that these changes occur in a timely and consistent manner, and that these changes will result in a strong, safety conscious, competitive nuclear
. organization.
Also under development, in a parallel path, is the NPG Business Plan which will contain the elements necessary to ensure long term performance continues to improve in all areas important to safe operation.
4 B..
MANAGEMENT CHANGES Recognizing that the overall performance of CNS was declining, the Vice President - Nuclear made a significant
- management realignment to provide a strong on-site Senior Management team to' focus on the critical issues facing the Nuclear Power Group.
These management changes also 1
L included, but_are not limited to, relocating the Vice
{
President:
Nuclear and the: Division Manager of Quality Assurance and his staff to CNS from the corporate office.
Additional; changes to the NPG organization will also be made where required to further enhance performance.
The new Senior Management team's initial focus is to address significant,. recurring issues'that have contributed to the-declining performance of' Cooper Nuclear Station.
One of the key issues that will be resolved is the failure to provide
[
prompt and positive' resolution to identified problems; and then implementing the appropriate corrective action to p-prevent recurrence in an aggressive manner.
-C.
DEFICIENCIES Various NRC inspections,.NPG self assessments, and broad
[
consultant reviews'have identified concerns with the management and operation of CNS.
Although the focus of I
these inspections and assessments was different, the L
conclusions reached and recommendations made were generally r.
consistent.
There are six areas where the majority of t
concerns fall.
Consequently, the CNS Integrated Enhancement Program has been developed to address these six areas and
(
has been divided into major categories or sections with assigned Senior Managers.
The areas in which concerns have I
been identified include:
e Management i
(=
[
A common finding was that the overall management of the CNS organization was not effective.
Contributing factors include poor communications, an inadequate l
accountability program, the need for improved management training, undefined or poorly communicated h
management expectations, and an inadequate
-prioritization system.
It was also identified that the
(-
Nuclear Power Group did not have a long term business x
2 a
p plan which defines Management's expectations through
{
vision, mission, and goals and-objectives for the entire ~ organization.
e Training The adequacy of training, as.well as the administrative discipline (certification'and compliance) within h
specific areas of the CNS Training Program are deficient.
This is evident due to the lack of certain
{
training programs and the fact that some individuals have continued to perform their assigned tasks even though they were no longer " certified / qualified".
e Problem Identification and Resolution y
{
The NPG has not consistently demonstrated the ability to identify, aggressively pursue, and permanently resolve their own problems.
And when problems were
(
. identified by CNS, the implemented corrective action did not consistently prevent reoccurrence.
The 7
inability to resolve reoccurring problems has been attributed to a failure to conduct thorough root cause investigations or implementing the necessary, enduring
~.
I.
corrective actions.
This has resulted in an overall ineffective Corrective Action Program.
e Engineering Modification and Configuration Control Outside reviews have indicated the need to improve control over plant configuration and the Design Change process.
One clear example of this deficiency is the fact that the Maintenance Work Requests, in some L-instances, have been used in the place of a Design Change.
l b-3 e
[
e Operations Findings'and recommendations noted a general lack of a questioning attitude, fonnality, and ownership.
There is also a lack of standardization in terms of shift turn-over, crew briefings and how operators communicated in the control room.
Procedural Adequacy and Adherence The reviews and audits identified a concern that the necessary balance between reliance upon the " skill of the craft" and the need for procedural detail is not well defined.
Another important finding is that CNS employees do not consistently demonstrate a questioning y_
L attitude when confronted with a procedure which is not clear and workable.
IL D.
CNS INTEGRATED ENHANCEMENT PROGRAM e
l" The CNS Integrated Enhancement Program is a collection of p
short-term prioritized corrective actions and performance improvements.
To develop this program each issue identified in prior audits, assessments or reviews was evaluated.
The y
L issues were then prioritized to ensure the critical issues
.j f
receive the necessary resources and management attention to
[
ensure prompt resolution.
It is these critical (Priority
" RED") issues that make up the Integrated Enhancement F
Program.
L F'
n 4
1.
Proaram Manaaement As previously discussed, the critical issues were then divided into specific groups and assigned.to a Senior Manager for resolution.
The Senior Manager has assigned the specific issue to a Task Manager to develop.an action plan for completing the specific
- Program Enhancement that will resolve the critical ~
- issue,
)
-The enclosed Program Enhancement Task Sheets contain the essential information used'for developing a course of action and provide the means to track the status of each task to completion.
The task sheets that follow i
indicate the title of the task, a task description, the source documents, the program manager (Senior Manager),
the task manager, the planned start date, the planned 1
completion date, references as to where the task i
coriginated from (i.e. OSTI, SPPI), and the major milestones for completing the task.
It should be noted
.that the planned completion dates and milestone dates 1
are based on the best information available and that
)
conditions or scope may change resulting in improvements or delays to the schedule.
Any changes to the schedule must be adequately justified in writing, to the Vice President - Nuclear and this documentation I
included in the Integrated Enhancement Program document.
Every two weeks the Task Manager will communicate to 4
their respective Senior Manager the progress to date.
I The Senior Manager will.then formally provide the status update to the Vice President - Nuclear.
Monthly management reports will be generated reflecting the overall Integrated Enhancement Program status as well as the status of the individual tasks.
r 5
2.
Procram Layout The Integrated Enhancement Program has been divided into several sections which reflect-the functional areas of.the NPG management.
The issues are then assigned to the appropriate Senior Manager.
Section I, Nuclear Power Group, discusses the issues that require specific Vice President - Nuclear attention.
Section II, Management, discusses the management concerns and the specific Integrated Enhancement tasks for resolving the management issues.
It should be noted that management related activities will be pursued in each of the following sections as well asSection II.
Section III, Operations, provides a discussion regarding the operations, maintenance and site engineering concerns that must be addressed.
The tasks developed for resolving the operational aspects are I
included as part of Section III.
Section IV, Safety Assessment, addresses the concern with CNS's ability to identify and resolve problems.
The Integrated Enhancement tasks for improving the Corrective Action process and conducting independent reviews are included in this section.
Section V, Site Support, primarily focuses on the training issues and providing support resources to the Senior Management team such as the NPG Management Development Program.
4 6
Section VI, Nuclear Support, includes communication
{'
issues and how to improve the regulatory interface.
The tasks for dealing with these issues are included within this section.
Section VII, Corporate Engineering, provides the direction for ensuring the concerns with engineering modification and configuration control are resolved.
(
Consequently the tasks for this effort are included as part of this section.
It should be noted, site related
{
engineering is part of the Operations Department, therefore Section III will have certain engineering related tasks.
Section VIII, Quality Assurance, addresses the concerns F-L with procedural adeqascy and adherence as well as the inability to conduct proper problem identification and
[
resolution.
r r
L, b
r L
Ie F
L F-L
/
7 l
E------
E.
E..
'INDEX'OF PROGRAM ENHANCEMENTS.
r
.SECTION I - NUCLEAR POWER GROUP
{
.'It;fm NumbgI '
Descriotion GRH-94-01 Establish' Periodic Communications Meetings GRH-94-02 "One Over One" h
GRH-94-03 Supervisor Meeting with Subordinates GRH-94-04 Management Mentors in Key Areas GRH-94-05 Conduct Study for Appropriate Staffing at CNS L
GRH-94_06 Additional Personnel to Meet the Needs of the NPG Organization
{
GRH-94-07 VP Meetings on Reorganization SECTION II - MANAGEMENT Item Number Descriotion MGMT-94-01 Strengthen the CNS Safety Culture
- MGMT-94-02 Develop an NPG Business Plan l
L MGMT-94 Prioritize Outstanding Work r
u-SECTION III -' OPERATIONS Item Number Description RLG-94-01 Develop Program to Review Maintenance Procedures / Activities RLG-94-02 Review Preventative Maintenance Task Assignments for Adequate Instructions RLG-94-03 Upgrade the System Engineer Program u-RLG-94-04
. Complete the Maintenance Department P
Reorganization u-RLG-94-05 Evaluate PIV, ISI, IST and LLRT Programs L:
8-1 l
u
SECTION III - OPERATIONS (Continued)
[
Item Number Descriotion
{
RLG-94-06 Engineering Backlog RLG-94-07 Maintenance Backlog RLG-94-08 Review the Qualifications and Training of Current CNS System Engineers to Determine Training
(
Required RLG-94-09 Improve Operations Communications
[-
SECTION IV - SAPETY ASSESSMENT
[
Item Number Descriotion JMM-94-01 Upgrade the Corrective Action Program g
L JMM-94-02 Improve Operating Experience Review Program JMM-94-03 Enhance the Human Performance Evaluation Program
(
JMM-94-04 Review / Revise Operability Determination Process
{
JMM-94-05 Develop the Independent Review Group JMM-94-06 Develop an NPG-Wide Priority System r
L JMM-94-07 Implement the Industry Advisory Group
(
SECTION V - SITE SUPPORT
' Item Number Descriotion j
EMM-94-01 NPG Manager and Supervisor Management Skills Training
(
EMM-94-02 Develop User-Friendly Tracking System for Training and Certification I
EMM-94-03 Develop a Comprehensive System Engineering Training Program for CNS System Engineers r
L EMM-94-04 Root Cause Training 9
r t
SECTION V - SITE SUPPORT (Continued)
Item Number Descriotion EMM-94-05 CAP Training EMM-94-06 Implement Recommendation of Fire Protection Assessment EMM-94-07 Conduct a Compliance Review of CNS Training Programs SECTION VI - NUCLEAR SUPPORT Item Number Descriotion DAW-94-01 Evaluate Licensing Department Organization DAW-94-02 Issue NPG Directives in Support of the Strategic Plan for Performance Improvement I
SECTION VII CORPORATE ENGINEERING Item Number Description REW-94-01 Engineering Program Responsibility Assignment
(
REW-94-02 Nuclear Engineering and Construction Division Self-Assessment REW-94-03 Evaluate the Configuration Control and Design Change Process within the NPG SECTION VIII - QUALITY ASSURANCE Item Number Description VLW-94-01 Revise the Self-Assessment Program VLW-94-02 Enhance CAP Audits /QA Trend Report VLW-94-03 Establishment of QA Assessment \\ Evaluation Program VLW-94-04 Upgrade the Internal Audit and l
Surveillance Program (Frequency and Scope) l 1
10 l
s J
1 1
l t
7 I
SECTION I 4
J NUCLEAR POWER GROUP 1
4 i
i i
i I
i i
a 3
l 1
a 6
[
SECTION I
[
NUCLEAR POWER GROUP
[
The Nuclear Power Group (NPG) has recognized as a result of Self
{
Assessments, performance overview, and NRC and INPO feedback that improvements in management oversight, communication, resources, culture, accountability, and identified programs and procedures are required.
This near term plan is the methodology to focus NPG organization attention and resources on those issues requiring immediate attention.
The NPG Business Plan will communicate management expectations and the
{
long term guidance for improving NPG performance and providing a means to constantly monitor this performance in order to ensure Senior Management expectations continue to be maintained.
The status of program enhancement milestones and schedule achievements L
will be reviewed with the NPG Senior Managers on a two week frequency and the plan updated monthly to ensure the expected focus and r
accomplishments are being maintained.
The effectiveness of the program L.
enhancements will also be monitored and revisions made to the near term
{
Integrated Enhancement Program as deemed necessary.
r L
Ea ru l
I l
L i
l E
l 1 -
J
L Program Enhancement Priority:
RED Item No:
GRH-94-01 Title /
Description:
Establish Periodic Communications Date Updated: 5/20/94 Meetings
[
External Funding Requirements: None Internal Resource Requirements: 30 hrs, quarter - Vice President - Nuclear
[
Program Manager: Guy Horn Planned Start Date: 1/24/94 Planned Completion Date: 7/94
[
References (NRC/INPO/NUMARC/NAIT Etc.): CCA
==
Description:==
The purpose of the periodic communication meetings is to communicate L
management expectations to NPG employees.
Objective:
Performance levels within the NPG do not currently meet the high standards i
expected by Senior Management. Establish the desired level of quality in the performance of tasks.
L Major Milestones:
Accomplishment Plan Date Actual Date r
l 1.
Vice President meetings. (GRH-94-01.1) 10/93 10/1/93 2.
Manager meetings with supervision.
3/94 3/31/94 (GRH-94-01.2) 3.
Supervisory meetings with subordinates.
3/94 3/31/94 (GRH-94-01.3) e
[
4.
Perform an effectiveness review.
7/94 L
(GRH-94-01.4) r Update Status:
Vice President, Nuclear-Routine meetings with NPG organizations L
continue to be held, (see attached listing) and am providing valuable input into the NPG health. Manager and Supervisory meetings and
[
supervisory meetings with subordinates have begun in all amas. The CNS Senior Managers have developed a listing of priority issues ie; top ten list, that support the NTIEP as a means of focusing CNS activities
[
in their respective area of responsibility..
r GRH-94-01 1
i l
L____________________________.
L Program Enhancement
{
GRH-94-01 (Continued)
Update Status:
Monthly effectiveness reviews of the CNS culture are being conducted by Quality Assurance and the results documented.
MEETINGS WITH DEPARTMENTAL PERSONNEL To Discuss the Organization
[
August 24,1993 - Maintenance August 26,1993 - Engineering / Technical Staff
[
September 2,1993 - Operations /I&C/ Operations Support September 7,1993 - Security / Training September 8,1993 - Radiological
[
September 16,1993 - NED/QA/ Nuclear Support September 23,1993 - QA/Constmetion Management I
To Discuss Management Exnectations and Solicit Feedback:
October 7 and 11,1993 - CNS (specific) Employee Committee Meetings L
October 14,1993 - Electric Shop October 18,1993 - Maintenance October 19,1993 - Engineering r
L October 29,1993 - Mechanical Maintenance December 10,1993 - Electric Shop 7
January 11,1994 - I&C and Operations January 13,1994 - Engineering January 17,1994 - CNS (specific) Employee Committee Meeting January 29,1994 - License Dinner i
L Febmary 17,1994 - Shift Supervisor Breakfast February 17,1994 - Electric Shop p
February 22,1994 - Mechanical Maintenance Febmary 25,1994 - Radiological / Outage & Modifications L
Febmary 28,1994 - Site Support / NOD Managers and Supervisors
{
March 1,1994 - Training / Site Services /QA/Constmetion Management March 16,1994 - Discussion with Management Development Course Attendees March 28,1994 - NPG GO Personnel F
April 5,1994 - CNS/GO Employee Committee Meeting April 6,1994 - Discunion with Management Development Course Attendees April 11,1994 - CNS (site-specific) Employee Committee Meeting April 15,1994 - Discussion with Management Development Course Attendees i"
April 20,1994 - Discussion with Management Development Curse Attendees April 25,1994 - Department Meeting with CNS Engineering l
L GRH-94-01 (Cont.)
L Program Enhancement p
Priority:
RED L
Item No:
GRH-94-02
{
Title /
Description:
"One Over One" Date Updated: 5/20/94 External Funding Requirements: None
{
Internal Resource Requirements: 200 hrs quarter - NPG Managers / Supervisors Program Manager: Guy Horn
{
Planned Start Date: 1/24/94 Planned Completion Date: 7/94 References (NRC/INPO/NUMARC/NAIT Etc.): OSTI E
==
Description:==
"One over one" meetings will be established on a quarterly basis. A "One over one" meeting involves a manager meeting with his supervisors to discuss issues.
Objective:
To communicate management expectations to supervision, enhance
[
communication between workers and management, improve tearnwork and morale, and improve quality of worker performance.
[
MWor Milestones:
Accomplishment Plan Date Actual Date L
1.
Establish guidelines and implement 3/94 3/31/94 manager meetings with supervision 7
to discuss ongoing issues, enhancements, progress, management expectations and to receive employee feedback.
(GRH-94-02.1)
~
2.
Improved communication and supervisory 7/94 feedback, increased overview of worker L
performance and improved quality of worker performance. (GRH-94-02.2)
E 3.
Perform an effectiveness review.
7/94 (GRH-94-01.3)
I l
GRH-94-02 i
A
Program Enhancement GRH-94-02 (Continued)
Update Status:
Vice President, Nuclear-Routine meetings with NPG organizations continue to be held (see GRH-94-01), and are providing valuable input into the NPG health. Manager and Supervisory meetings and supervisory meetings with subordinates have begun in all areas. The CNS Senior Managers have developed a listing of priority issues ie; top ten list, in each major area that support the NTIEP as a means of focusing CNS activities.
Guidelines for the managers meeting with supervisors and for the supervisory meetings with staff have been provided to the Senior Managers and includes expectations for effectiveness overview.
5/10/94 Senior Managers have begun routine meetings vith their subordinates communicating these expectations. In addition, a dimetive has been issued to Senior Management mquiring weekly walkabouts. The purpose of these walkabouts is to overview CNS field activities, pmvide management expectations, receive feedback, and to maintain first hand knowledge of the NPG culture.
Monthly effectiveness reviews of the CNS culture are being conducted by Quality Assurance and the results documented.
(
l I
i GRH-94-02 (Cont.)
L
Program Enhancement l
Priority:
RED Item No:
GRH-94-03 Title /
Description:
Supervisor Meeting with Subordinates Date Updated: 5/20/94 External Funding Requirements: None Internal Resource Requirements: 100 hrs month by NPG Supervisors /1200 hrs. yr.
Program Manager: Guy Horn Planned Start Date: 1/24/94 Planned Completion Date: 7/94 i
l References (NRC/INPO/NUMARC/NAIT Etc.): OSTI l
==
Description:==
Supervisor meetings with their subordinates will be established on a monthly l-basis.
l Objective:
To establish the desired levels of quality in worker performance, enhance l
communication between management and workers, enhance employee feedback on issues and improve teamwork and morale throughout the NPG, and eliminate barriers to communication.
Major Milestones:
l Accomplishment Plan Date Actual Date 1
1.
Establish quidelines and implement 3/94 3/31/94 monthly meetings with subordinates to discuss ongoing issues, enhancements, pmgress, communicate management i
expectations and receive employee feedback.
(GRH-94-03.1) 2.
Impmve communication and worker feedback, 7/94 improve quality of worker performance.
(GRH-94-03.2) 3.
Perform an effectiveness review.
7/94 (GRH-94-03.3) i GRH-94-03
Program Enhancement GRH-94-03 (Continued)
Update Status:
Vice President, Nuclear-Routine meetings with NPG organizations continue to be held (see GRH-94-01), and are providing valuable input into the NPG health. Manager and Supervisory meetings and supervisory meetings with subordinates have begun in all areas. The CNS Senior Managers have developed a listing of priority issues ie; top ten list, area that support the NTIEP as a means of focusing CNS activities in their respective areas of responsibility.
Guidelines for the managers meeting with supervisors and for the supervisory meetings with staff have been provided to the Senior l
Managers and includes expectations for effectiveness overview.
5/10/94 Senior Managers have begun routine meetings with their subordinates communicating these expectations. In addition, a directive has been issued to Senior Management requiring weekly walkabouts. The purpose of these walkabouts is to overview CNS field activities, provide management expectations, receive feedback, and to maintain first hand knowledge of the NPG culture.
Monthly effectiveness reviews of the CNS culture are being conducted by Quality Assurance and the results documented.
I L
(
(
l l
[
GRH-94-03 (Cont.)
l
J
l L
Program Enhancement
(
Priority:
RED L
Item No:
GRH-94-04
{
Title /
Description:
Management Mentors in Key Amas Date Updated: 5/20/94
(
External Funding Requirements: $500,000 Internal Resource Requirements: Vice President - Nuclear / Senior Managers - 50 hrs.
r L
Program Manager: Guy Horn Planned Start Date: 1/24/94 Planned Completion Date: 4/94 g
L References (NRC/INPO/NUMARC/NAIT Etc.): CCA r
L r
Evaluate the benefit of using management mentors in specific areas within the L
==
Description:==
NPG to expedite the upgrade of management skills to the desimd levels and to e
support programmatic and culture changes within the organization.
L Objective:
To expedite the desired levels of performance impmvement within the NPG in order to achieve internal and regulatory expectations as rapidly as possible.
Major Milestones:
Accomplishment Plan Date Actual Date 1.
Evaluations completed and task 4/94 4/30/94 L
agreements submitted for Board approval. (GRH-94-04.1)
F r
e GRH-94-04 o
A
Program Enhancement GRH-94-04 (Continued)
Update Status:
The assessment of the need for management mentors within the NPG organization continues. A Senior hianagement consultant has been obtained to aid in the overall assessment of the effectiveness of the NTEIP and to provide overview and guidance to the CNS Senior hianagers. This consultant began onsite work March 14,1994. The following is a listing of the mentors currently supporting the CNS organization.
e Safety Assessment - three consultants J. Partlow E. Erickson Failure Preventation, Inc e
Senior Managers - one consultant D. Beckman e
Maintenance - one consultant B. York e
Quality Assurance - one consultant R. Bass The Maintenance mentor has been tasked with performing a overall evaluation of the Maintenance Department effectiveness and to provide recommendations to Management / Supervision to correct identified weaknesses. Past performance history will be used in this evaluation.
The Safety and Assessment mentors are currently supporting the Senior Manager in the establishment of procedures, guidelines and charters to ensure effective oversight of Nuclear Power Group activities. They are also supporting implementation and overview of the enhanced Corrective Action Program.
The Quality Assurance (QA) mentor is providing overall assessment of QA activities including, but not limited to, policy documents, procedures, audit and surveillance programs and organization adequacy and providing enhancement recommendations to the Division Manager of Quality Assurance. This enhancement item is completed.
GRH-94-04 (Continued)
.. ~.
eo A
I L
Program Enhancement p
Priority:
RED L
Item No:
GRH-94-05
{
Title /
Description:
Conduct Study for Appropriate Staffing Date Updated: 5/20/94 at CNS E
External Funding Requirements: $50,000 (for study)
Internal Resource Requirements: Vice President - Nuclear - 30 hrs.
~
Program Manager: Guy Horn Planned Start Date: 1/24/94 Planned Completion Date: 2/94 References (NRC/INPO/NUMARC/NAIT Etc.): OSTI E
==
Description:==
Conduct a study as to what would be the appropriate staffing level for CNS.
This study should consider current staffing compared to industry leaders for a similar unit.
1" Objective:
To determine if current staffing levels are sufficient to achieve and maintain current industry standards and continuing normal workload within the NPG.
y L
Major Milestones:
Accomplishment Plan Date Actual Date y
u 1.
Complete staffing study. (GRH-94-05.1) 1/94 1/94 r
u 2.
Develop a staffing upgrade plan for 2/94 2/94 Senior NPPD Management review and approval. (GRH-94-05.2) 3.
Receive NPPD Board of Directors approval 2/94 2/94 of the staffing upgrade plan. (GRH-94-05.3)
Update Status:
A staffing study by T. Martin and Associates has been completed. The i-~
interim staffing plan has also been developed and submitted to Senior L
NPPD Management. The NPPD Board of Dimctors pmvided their full support of the interim staffing plan at the Febmary Board Meeting.
F-This enhancement item is completed.
F L
GRH-94-05 l
U
r l
Program Enhancement Priority:
RED Item No:
GRH-94-06
(
Title /
Description:
Additional Personnel to Meet the Needs Date Updated: 5/20/94 L
of the NPG Organization
{
External Funding Requirements: $2,000,000 (estimated)
Internal Resource Requirements: Vice President - Nuclear - 30 hrs.
(
Program Manager: Guy Horn Planned Start Date: 1/24/94 Planned Completion Date: 2/94
[
References (NRC/INPO/NUMARC/NAIT Etc.): OSTI f
==
Description:==
Based on the results of the staffing study, develop a plan of action to L
redistribute or hire additional personnel to meet the needs of the NPG organization.
I' Objective:
To achieve and maintain Nuclear industry standards and improve INPO/NRC rating of NPG activities.
Major Milestones:
Accomplishment Plan Date Actual Date L
1.
Develop an interim staffing upgrade 2/94 2/94 plan for Senior Management review and approval. (GRH-94-06.1) 2.
Receive NPPD Board of Director 2/94 2/94 r
L approval of the interim staffing upgrade plan. (GRH-94-06.2) h Update Status:
Interim permanent staffing plans have been developed and approved by r
NPPD Senior Management. This plan was submitted to the NPPD L
Board of Directors at the Febmary Board Meeting and received their full support.
i L
5/10/94:
In addition, approval was received from the NPPD Boatti of Directors to hire 20 consultants,15 in engineering and five in maintenance, to
[
provide immediate support to these areas. These personnel are on-sita.
i and working in support of program enhancements / upgrades and routine l
station activities. This enhancement item is completed.
l' GRH-94-%
l L
a
Program Enhancement Priority:
RED Item No:
GRH-94-07 r
Title /
Description:
VP Meetings on Staffing Study Date Updated: 5/20/94 L
{
External Funding Requirements: None Internal Resource Requirements: Vice President - Nuclear / Senior Management - 20 hrs.
[
Program Manager: Guy Hom Planned Start Date: 1/24/94 Planned Completion Date: 6/94 r
L References (NRC/INPO/NUMARC/NAIT Etc.): 070 SPPI L
[
==
Description:==
Communicate results of staffing study to NPG employees and plan of action to redistribute or hire additional personnel.
L Objective:
To make CNS employees aware of planned staffm' g upgrades for long term r
L planning and budgeting purposes and to acquire staff suppon and ownership of the staffing study.
6 Major Milestones:
r Accomplishment Plan Date Actual Date L
1.
NPG staff aware of organizational 4/94 4/30/94
[
upgrades and assign appropriate NPG depanments action to complete L
any necessary redistribution studies.
r (GRH-94-07.1) 4 I
r a
I L
I GRH-94-07 I
[
l L
Program Enhancement GRH-94-07 (Continued)
{
Update Status:
A stafDng study by T. Martin and Associates has been completed. The
{
interim stafGng plan has also been developed and approved by to Senior NPPD Management. This plan was submitted to the NPPD Board of Directors at the February meeting and it received their full support.
[
The results of the staffing study is being discussed at the frequent Communication Meetings by the Vice President - Nuclear. Assignment of action to perform a redistribution study in the areas of security and
[
training has been made to the Senior Management of Site Support and contains a completions date of 6/1/94.
+
L EL L
E c
m FL u
m u
{
GRH-94-07 (Cont.)
y l
I I
~
I I
I I
I SECTION II I
MANAGEMENT I
.I I
- I I
SECTION II MANAGEMENT These management issues are an indication of the present Nuclear Power Group culture.
The lack of a questioning attitude, accountability and ownership; poor communication, inappropriate delegation; and poorly communicated management expectations are examples of the type of management concerns identified. In order for management to become more effective in instilling the improved culture throughout the NPG, a long term business plan that includes the organization's visions, goals and objectives is being developed.
Previously, many of the plans and programs that had been established focused on the short term corrective actions without considering the long term impact.
The CNS Integrated Enhancement Program tasks, as part of the Management section, will address many of these cultural issues, l
as well as bring about other improvements within the NPG.
For the long term, the NPG Business Plan will be used to maintain the I
expected improvements.
To address these issues, the following Integrated Enhancement Program tasks have been developed and are being implemented.
The tasks included in this section are Program Enhancements which provide a description of the task, the responsible manager, and the expected completion date.
l l
I 1
{
l
Program Enhancement Priority:
RED Item No:
MGMT-94-01 Title /
Description:
Strengthen the CNS Safety Culture Date Updated: 5/20/94
{
External Funding Requirements: NONE Internal Resource Requirements: 100 Hours / Senior Manager; 600 Hours Total L
Program Manager: All Pl:nned Start Date: 1/24/94 Planned Completion Date: 10/94 f
L R:ferences (NRC/INPO/NUMARC/NAIT Etc.): CCA, OSTI L
[
Description:
The purpose of this enhancement is to instill in management / supervision and the workforce the culture and values to make the changes necessary to become a more healthy organization; ever improving the quality of the work we do.
7 L
Objective:
To improve the management effectiveness of the NPG organization, continue to provide safe and reliable power, to maintain a cost competitive operation, and to meet or exceed industry standards in all aspects of our operation.
L M40r Milestones:
E Accomplishment Plan Date Actual Date L
1.
Convey to employees their right 6/94 r
as well as their responsibility L
to have a questioning attitude.
(MGMT-94-01.1) -
E 2.
Create an atmosphem where employees 6/94 feel comfortable having a questioning
[
attitude. (MGMT-94-01.2) 4 1
r L
MGMT-94-01 l
l l
Program Enhancement I
Major Milestones: (MGMT-94-01 Continued)
Accomplishment Plan Date Actual Date I
3.
Emphasize the importance of and 6/94 encoumge employees to use the l
corrective action program.
(MGMT-94-01.3) 4.
Encourage employee feedback to 6/94 management on emerging issues, concerns and suggested corrective I
actions. (MGMT-94-01.4) 5.
Conduct an effectiveness review 10/94 I
of the Corrective Action Program.
(MGMT-94-01.5)
Update Status:
A number of specific actions am underway, including divisional and depanmental meetings, specific newsletter articles and management walkarounds.
A Level I CAP Trairing course has also been developed and delivered to the majority of the NPG. This levelI course provides employees with an understanding of the CAP. This training will encourage the use of the CAP
[
and also stress its imponance and effectiveness.
7 To provide additional feedback to Senior Management (beyond meetings and l
walkarounds) the QA Assessment Depanment has developed and implemented a monthly employee, one on one, interview questionnaire. The results will be used to measure success and failure at the departmental level and adjust L
accordingly, The new Corrective Action Program has been implemented and contains the r
attributes of successful programs at other leading nuclear facilities. This program allows for autonomy in generating condition reports to ensure total employee independence for expressing concerns.
L l
One very important aspect of this specific enhancement item is leadership by
{
example. To ensure management / supervision and the workforce fully understand Senior Managements support of a constantly improving safety culture continued reinforcement is being provided by the Condition Report E
Overview Group, Nuclear Overview Publications, management meetings, L
management walkabouts and memorandums. In addition the Business Plan, Vision, Mission and Values have been finalized and sent to all NPG
[
employees.
MGMT-94-01 (Cont.)
L Progra:n Enhancement F.
Priority:
RED L
Item No:
MGMT-94-02
{
Title /
Description:
Develop an NPG Business Plan Date Updated: 5/20/94
{
External Funding Requirements: $100,000 Internal Resource Requirements: 80 Hours / Senior Manager; 480 Hours Total' Program Manager: All (M. Sparr)
~
Planned Start Date: 1/24/94 Planned Completion Date: 7/94 References (NRC/INPO/NUMARC/NAIT Etc.): OSTI, CCA e
L I
==
Description:==
Develop an NPG Business Plan that establishes the goals and objectives to be attained over the next four years. Provide a means for issuing a monthly performance monitoring report which provides status and prognss on business plan goals, L
objectives, and performance indicators. Develop Branch Business Plans for each NPG Senior Manager / Division.
Objective:
The Business Plan will improve overall performance by providing the NPG with a master management plan.
L Major Milestones:
Accomplishment Plan Date Actual Date u
1.
Contact Senior Management level personnel 1/94 1/94 7
at the best performing plant and discuss i
their development and use of a Business Plan.
(MGMT-94-02.1) m 2.
Conduct workshops, etc., to develop 1/94 1/94 vision, mission and value statements
{
of the Business Plan. (MGMT-94-02.2)
~
I~
MGMT-94-02
~
l l
L Program Enhancement Major Milestones: (MGMT-94-02 Continued)
Accomplishment Plan Date Actual Date L
3.
Conduct workshops' to develop 3/94 3/31/94 suppostive missions, goals, objectives,
{
and performance indicators. (MGMT-94-02.3)
~
Hold departmental meetings to communicate 5/94 4.
the visicn, mission and value statements of the Business Plan. (MGMT-94-02.4)
{
5.
Develop targets for performance indicators, 5/94 5/19/94 actions plan summaries for objectives, and performance measures. (MGMT-94-02.5) l" 6.
Complete the 1994 - 1997 Business Plan.
5/94 (MGMT-94-02.6)
. 7.
Develop transition plan for IEP to 6/94 Business Plan and revise NPG Directive 1.3.
L (MGMT-94-02.7) 8.
Develop 1994 - 1997 Branch Business Plan 7/94 L
for each NPG Senior Manager / Division.
(MGMT-94-02.8) r 9.
Issue l'irst monthly performance monitoring 7/94 report. (MGMT-94-02.9) i Update Status:
r-L 5/20/94:
Milestones number 1 thmugh 5 are completed. Milestones number 6 and 7 are in progress. Preliminary work has begun for Milestones 8 and 9.
L
?~
l E
h.
4.
MGMT-94-02 (Cont.)
i A
[
L Program Enhancement r
Priodty:
RED L
Item No:
MGMT-94-03
{
Title /
Description:
' Prioritize Outstanding Work Date Updated: 5/20/94
[
External Funding Requirements: $10,000 Internal Resource Requirements: 5 Department Personnel for 2 Months; Total 1200 Hours
{
(Engineering, Maintenance, Tech. Staff)
Program Manager: All
[
Planned Start Date: 1/24/94 Pianned Completion Date: 4/94
[
References (NRC/INPO/NUMARC/NAIT Etc.): OSTI n
==
Description:==
Develop a priority system to prioritize outstanding work to ensure the critical items are being worked first.
y
't
[
Objective:
To focus management and personnel resources in the most effective means possible.
e i
M4or Milestones:
Accomplishment Plan Date Actual Date r
L 1.
Develop an interim prioritization 4/94 4/30/94 scheme in noted areas. (MGMT-94-03.1) r L
2.
Assemble items to be prioritized.
3/94 3/7/94 (MGMT-94-03.2)
I L
E I
u 1
F u
IE MGMT-94-03
)
?
l p
l l
'u j
Program Enhancement s
[
Major Milestones: (MGMT-94-03 Continued)
Accomplishment Plan Date Actual Date 3.
Establish departmental team to 3/94 3/7/94 conduct the initial prioritization.
f (MGMT-94-03.3) l.
4.
Complete the prioritization of 4/94-4/30/94
{
existing items. (MGMT-94-03.4)
(
l Update Status:
Within the Engineering organization the significant work items which include NCRs, DRs, as well as external commitments, are being prioritized via the interim Prioritization Program. The prioritization of the MWRs, TWRs, and r
[
PCNs is being validated / established. (See Action Item JMM-94-06)
Our existing priority schemes (for EWR, MWR, TWR, and PCN) are being r
[
revalidated to ensure their adequacy and correctness of application.
r Items #2 and #3 were completed for the Engineering Department on 2/9/94; L
The prioritization of outstanding engineering work (Item #4) was completed on 3/10/94. Items #2 and #3 were completed for the Maintenance Department the week of 3/7/94; The prioritization of outstanding maintenance work (Item #4) is in progn:ss with an expected completion of 4/30/94. (Forced shutdown maintenance activities in the month of March precluded completion of this activity on schedule.)
This item is completed; the specific, outstanding work items are being tracked by RLG-94-06 and RLG-94-07.
f L
I L
r I
\\
MGMT-94-03 (Cont.)
r
_a
l
(
l
(
SECTION III L
OPERATIONS L
[
b
(
r l
i L
r L
r L
[
c 1
r L--___---__---__------_-___
f L
SECTION III
{
OPERATIONS
(
l The issues covered in this section focus on operations, procedural adequacy and adherence, engineering program adequacy, and certain management issues.
The concerns regarding operations include the communication of management expectations and the lack i
of standardization with how operating shifts communicate.
There f
l is also a lack of a questioning attitude, accountability and a lack of ownership within the operations organization, r
l The procedural adequacy and adherence concern included three
(
issues.
The first issue is that the work force ja changing and, therefore, the content of the procedures have co be revised.
The second issue involves the proper balance between the " Skill of the Craft" and the necessary amount of detail in each procedure.
Finally, the employees who use the procedures do not display a
[
questioning attitude when confronted with a situation that does not appear to be correct.
To address these issues, the following Integrated Enhancement Program tasks have been developed and are being implemented.
The tasks included in this section are Program Enhancements which provide a description of the task, the responsible manager, and the expected completion date.
I L
Program Enhancement Priority: RED
[
Item No: RLG-94-01 Title'
Description:
Develop Program to Review Maintenance Date Updated: 5/20/94
[
Procedures
{
External Funding Requirements: $275,000 Internal Resource Requirements: Support to research, revise and develop Maintenance Procedures during the course of 1994.
b Program Manager: Rick Gardner (Mike Unruh)
Planned Start Date: 1/24/94 Planned Completion Date: 12/94 r'
References (NRC/INPO/NUMARC/NAIT Etc.): SPPI 340, OSTI, SMM E'
==
Description:==
The actions that will be addressed under this action include the following:
[
e Review selected Maintenance Procedures to verify the incorporation of accurate and sufficient information (including vendor information).
[
e Determine that sufficient technical detail is incorporated into Maintenance Procedures to allow the Craft to perform the activity.
[
e Establish and communicate a definition of " Skill of the Craft".
Determine that adequate training is provided to support the performance e
g L
of the Maintenance Pmcedures, as written.
I L
Objective:
To provide the appropriate level of detail for the craftsmen and to address performance deficiencies.
c 1
L M40r Milestones:
Accomplishment Plan Date Actual Date r
L-1.
Determine manpower requirements, pmpam and 2/94 2/94 approve position authorizations, conduct p
- interviews and him temporary employees.
(RLG-94-01.1) r L
I i
l RLG-94-01 l
+
.e Program Enhancement Major Milestones: (RLG-94-01 Continued)
Accomplishment Plan Date Actual Date 2.
Provide facilities, equipment and supplies to 2/94 2/28/94 procedure upgrade team. (RLG-94-01.2) 3.
Conduct scope meeting, outline goals, 2/94 2/28/94 expectations, and schedule. (RLG-94-01.3) 4.
Define " Skill of the Craft". (RLG-94-01.4) 4/94 4/29/94 5.
Vendor Manual Validation 6/94 and Verification (V&V) complete.
(RLG-94-01.5) 6.
Revise current, safety related and important to 12/94 safety maintenance procedures as necessary to ensure skill of the cmft is addressed and the necessary technical details are provided.
(RLG-94-01.6) 7.
Interface with the Training Department to 12/94 ensum the incorporation of maintenance procedure changes into trammg.
(RLG-94-01.7)
Update Status:
1)
Temporary employees have been hired, completed training and these employees have been incorporated into the workforce.
2)
Facilities and equipment have been identified. Currently sufficient facilities and equipment have been provided to support the procedures upgrade effort.
3)
Initial " Scope Meeting" was conducted on 2/28/94. Additional meetings will be conducted on a bi-weekly basis as necessary to support this project. This meeting was not held as scheduled due to the plant scram on March 2,1994, the shutdown for RHR-27A, and work on the HPCI stop valve. Next meeting to be held April 29,1994.
4)
Defining " Skill of the Craft" effort is complete. Definition is included in procedure 7.0.4.
RLG-94-01 (Cont.)
l i
L Program Enhancement
{
RLG-94-01 (Continued)
Update Status:
5)
The Validation and Verification of Vendor Manuals is presently
{
performed in accordance with our response to GL 90-03, see CNSS907416 dated September 17,1990.
[
The intent of item #6 in this Enhancement was to review a selected number of vendor manuals to verify that the manual and the applicable procedure were in agreement. Further actions
[
will be contingent upon outcome of this item.
6)
A scoping and assessment methodology is being established to
[
address improvement of maintenance procedures. Six;;dsft personnel'has.been brought.out';6f.the_Electricalind Mechahical Maintenance.Shogss;. And haVe bsenTrevieping[s@
[
revising. Maintenance Procedures as of MayJD994 r
L r
L r
L r
L Iu r
L r
L
[
L RLG-94-01 (Cont.)
u
l Program Enhancement Priority:- RED l
Item No: RLG-94-02 Title /
Description:
Review Preventive Maintenance Date Updated: 5/20/94 Task Assignments for Adequate Instructions External Funding Requirements: $150,000 (Estimated)
Internal Resource Requirements: 350 hours0.00405 days <br />0.0972 hours <br />5.787037e-4 weeks <br />1.33175e-4 months <br /> Program Manager: Rick Gardner (Mike Unmh)
Planned Start Date: 1/24/94 Planned Completion Date: 12/94 l
References (NRC/INPO/ETC.): OSTI
==
Description:==
Review Preventive Maintenance (PM) tasks under the responsibility of the Maintenance Department to systemically document the adequacy of the work instmetion, and revise those PMs that do not contain adequate work instmetions.
Objective:
To provide the appropriate level of detail for the craftsmen and to address performance deficiencies.
i Major Milestones:
Accomplishment Plan Date Actual Date 1.
Establish a Task Group to establish / develop 2/94 2/28/94 criteria (i.e. checklist) for documents which set forth acceptable practices and/or i
provide information mgarding activities that are considered within the Skill of the Craft (Maintenance Work Practices)
(RLG-94-02.1) 2.
Collect requimments that define what 2/94 2/28/94 constitutes SORC procedures.
(RLG-94-02.2) 3.
Based on items 1 and 2, establish / develop 3/94 3/31/94 criteria to identify the level of detail required for work instruction documents.
(RLG-94-02.3)
RLG-94-02 1
J
L Program Enhancement
{
_ Major Milestones: (RLG-94-02 Continued)
Accomplishment Plan Date Actual Date
{
4.
Submit criteria to the appropriate 3/94 3/31/94 organizations for review and acceptance.
{
(RLG-94-02.4) 5.
Procure services as necessary to review the 3/94 3/7/94
[
existing PMs using the criteria established in items 3 and 4. (RLG-94-02.5)
(
6.
Perform the review of approximately 12/94 5540 PMs (Planning - 1500, I-Shop - 2270, E-Shop - 900, M-Shop - 800, UT-Shop - 55, g
L and W-Shop - 15), and revise PMs, maintenance procedures and Maintenance Work Practices to insure adequate work instmetions exist.
y l
(RLG-94-02.6)
Update Status:
A chairman has been named for the Task Group to establish / develop a 7
criterial document. Four additional Maintenance Depanment L
individuals have been identified to serve in the Task Group. One additional task force member will be added, r-L The February Board meeting should appmve Tasks with various companies to obtain the manpower to perform the PM review.
L Maior Milestone 1
[-
Establish a Task Group to establish / develop criteria (i.e. checklist) for documents which set fonh acceptable practices and/or provide information regarding activities that are considered within the " Skill of the Craft".
r.
1"
- Status 3/7/94
[
A Task Group has been formed and met to discuss the objective of milestone 3. Reference 1 provides more details regarding the Task Group, and it identifies the personnel in the Task Group. The Task L
Group has developed a draft definition for " Skill of the Craft".
1 r-L-
RLG-94-02 (Cont.)
l
[
-- A
Program Enhancement Update Status: (RLG-94-02 Continued) 1 Major Milestone 2 Collect requirements that define what constitutes SORC procedures.
Status 3/7/94 This milestone is completed. Reference 3 provides the discussion of what constitutes SORC procedures.
Maior Milestone 3 Based on items 1 and 2, establish / develop criteria to identify the level of detail required for work instmetion documents.
Status 3/7/94
(
The Task Group identified in milestone I has met to discuss the objective of the milestone.
(
Status 3/24/94 A document that provides guidance on procedural detail is currently r
[
being written. The initial draft may be ready for myiew by the first of April.
L Status 3/31/94 r
The initial draft has been developed and issued for comments. This milestone is completed.
r Status 5/10/94 l
Guidance documents have been developed to establish required content
(
and level of detail of procedums and instmetions.
L Major Milestone 4 I
l Submit criteria to the appropriate organizations for review and acceptance.
4
(
Status 3/7/94 No Action f
i RLG-94-02 (Cont.)
Program Enhancement Update Status: (RLG-94-02 Continued)
Status 3/31/94 A draft document that provides guidance on procedural detail has been i
l submitted for review and acceptance, this milestone is completed.
Maior Milestone 5 Procure services as necessary to review the existing PMs using the criteria j
established in items 3 and 4.
1 Status 3/7/94 l
l Three people from General Physics Corporation has been procured under General Services Agreeraent No. 86A-C1, Task 42, to perform the review. This milestone is completed.
Maior Milestone 6 Perform the PM review, and revise PMs, procedures and MWPs to insum adequate work instmetions exist.
Status 3/7/94 Refemnce 2 discusses and includes a checklist for the items being addressed in the PM review. The checklist has been mvised to review the "P" Shop PMs that were originally excluded from the PM myiew.
A copy of the revised checklist is attached. The three people from General Physics will be starting the PM review this week.
Status 3/24/94 An initial review of all PMs should be completed before the first of April. This review will identify the PMs that need revision and which PMs that are currently adequate based on the review criteria.
Status 5/10/94 l
Review of all PMs is 57% complete. This review is identifying PMs I
that require revision to meet curent expectations.
l RLG-94-02 (Cont.)
Program Enhancement Update Status: (RLG-94-02 Continued)
Status 5/20/94 Approximately'63% (3800) of the PMs;haVe been reviewbd and~found acceptable'and/or PM chsnges submitteda About 21 %l.(1780) of the
~
remaining PMs will. require minor changes l and aboutl16%i(970 PMs)
{
of thefremaising!PMs':will;mqsire~ procedures /instmetionslto,be developed.
i l
l I
i i
i i
4 1
l V
i I
i RLG-94-02 (Cont.)
i 1
Program Enhancement Priority:
RED Item No:
RLG-94-03 Title /
Description:
Upgrade the System Engineer Program Date Updated: 5/20/94 External Funding Requirements: $25,000
~ Internal Resource Requirements: The entire Engineering Depanment will be involved over an appmximate two-year period.
I i
- Program Manager: Rick Gardner (Jim Lynch)
Planned Start Date: 10/18/93 Planned Completion Date: 12/94 References (NRC/INPO/NUMARC/NAIT Etc.): SMM
==
Description:==
Upgrade of the System Engineer Program consists of the following activities:
A.
Implementation of the Engineering Plan for performance improvement, the elements of which are described below under major milestones.
B.
Improvements to System Engineer training, described in Program Enhancement Item RLG-94-08.
C.
Engineering backlog mduction, described in Program Enhancement Item RLG-94-06.
[
Objective:
Improve the effectiveness of the Engineering Depanment. Improvements will focus on work management system and program reponing, and definition of roles in the Engineering Depanment.
I M4or Milestones:
(
Accomplishment Plan Date Actual Date 1.
Perform assessment of Engineering Depanment 1/94 1/22/94
(
effectiveness and organization.
(RLG-94-03.1)
(
2.
Develop an integrated plan to address various 1/94 1/21/94 assessments of engineering at CNS.
Submit to Region IV. (RLG-94-03.2) l RLG-94-03 f
l' t
Pregram Enhancement Major Milestones: (RLG-94-03 Continued)
Accomplishment Plan Date Actual Date 3.
Work management improvements:
Develop criteria for prioritization 1/94 2/9/94
. 'of engineering NAIT and ACT items.
(RLG-94-03.3)
Prioritize and schedule NAIT and 2/94 3/10/94 ACT items.
(RLG-94-03.4)
Develop a set of engineering depanment 2/94 3/15/94 performance indicators. Produce appropriate charts and graphs for depanment and senior management review. (RLG-94-03.5)
Produce final set of department performance 4/94 5/20/94 indicators, publish monthly. Determine performance goals and incentives for achieving goals. (RLG-94-03,6) 4.
Establish system and program report cards:
i l
Pruduce first draft system report card 2/94 3/4/94 I
for one system. (RLG-94-03.7)
L Produce final system report card.
2/94 4/15/94 (RLG-94-03.8)
Produce first draft program report 2/94 3/4/94 card for one program. (RLG-94-03.9)
Produce final program report card.
6/94 (RLG-94-03.10)
I Produce report cards for all 6/94 assigned systems monthly. (RLG-94-03.11)
I Issue approved EDIs for both report cards.
7/94 (RLG-94-03.12)
(
Produce program report card for all 7/94 assigned programs monthly. (RLG-94-03.13)
RLG-94-03 (Cont.)
Program Enhancement I
Major Milestones: (RLG-94-03 Continued) l Accomplishment Plan Date Actual Date 5.
Evaluate Engineering Department functions for 6/94 l
ef0ciency improvements. Examples include the way NPRDS reports are prepared and procurement activities. Complete evaluation and plan for I
implementation. (RLG-94-03.14) 6.
Define roles, management expectations, 6/94 1
functions, and accountability for system and program engineers, lead engineers, senior engineers, supervisors, and managers.
I (RLG-94-03.15) 7.
Develop succession plan for manager, 6/94 I
assistant manager, supervisor and lead positions.
Succession plan will include appropriate developmental assignments and training.
(RLG-94-03.16) 8.
Perform an assessment and develop a plan to 8/94 identify candidate processes for re-engineering.
The plan should identify and prioritize candidate processes and develop a schedule for completion of the re-engineering analyses. Candidate processes include procuremect and engineering work request.
u (RLG-94-03.17) 9.
Self assess the CNS Engineering Depaitment 12/94 upgrades for effectiveness. (RLG-94-03.18)
F Update Status:
2/10/94 Item #1 is complete. Item #2 is complete and was transmitted to Region IV on 1/21/94 (CNSS941043).
Item #3 a memo (CNSS943517) was issued on 2/8/94 to engineering supervisors to describe the process and criteria to be used to prioritize the workload.
{
Prioritization is expected to be complete by 2/18/94. A set of 10 draft engineering performance indicators has been completed. Draft indicators are currently under
[
review. Item #4 system report cards used at SONGS, Crystal River 3, and Fermi have been gathered as examples.
RLG-94-03 (Cont.)
l U
_ --- A
Program Enhancement Update Status: (RLG-94-03 Continued) 3/10/94 Item #5, a draft set has been produced and is being reviewed by management. Item #8 will be completed during 3/94. Item #14, procurement, change process, design and NPRDS reporting are currently being evaluated. No results to report to date.
3/31/94 Item #5, Draft performance indicators have been produced 3/10/94. On schedule for final set by 4/94.
Items #8 and #10 has been completed. Item #11, System Report Cards will be produced in April. Item #i4, changes are currently being made to the way purchase requisitions and NPRDS reports are handled within Engineering. Comprehensive evaluation will be performed in April.
l
)
5/10/94 Ite m #1 Complete Item #2 Complete Item #3 Draft performance indicators are being routed for management review and comment. Anticipate final set of
(
indicators developed by 5/15/94.
Item #4 Draft program and system report cards are
(
complete and being distributed for comment. Report cards for all programs and systems anticipated to be finalized by e
(
7/31/94.
Item #5 Program is being made at present time.
NPRDS and purchase requisitions efficiency are being addressed, r
l RLG-94-03 (Cont.)
l Program Enhancement
{
Update Status: (RLG-94-03 Continued) 5/20/941 i;Itsm'#3l
) The final seiof Engincaring Department performance liidicators were issusdlori 5/20/94J% full. set of psrformance indicat65 will beiissued to selected CNS Managers add theLEngineering Dpment monthly 5This. completes Item f3l Itsm '#41 (Draft Sistsm ReporiCards. wereleissued to;. solicit; additional'SystersMiM?-:
feedbackMThe feedbacli(was"requsksd.bj 5/18/940;1he final Report; Cards;(shou.ld be in place byLJune 3,il994.8 System Report Castis1should bs produced bs June 24;1994l1 Program Repott C.ards
~ hould be produced tj LJuly;1994k Repoli s
y l
Card EDI's1should be1 completed b' July y
1994'also]
l l
l RLG-94-03 (Cont.)
I
Program Enhancement Priority:
RED Item No:
RLG-94-04 Title /
Description:
Complete the Maintenance Department Date Updated: 5/20/94 Reorganization External Funding Requirements: $50,000 Consultant to identify structure and positions.
Internal Resource Requirements: 100 hours0.00116 days <br />0.0278 hours <br />1.653439e-4 weeks <br />3.805e-5 months <br /> Prograin Manager: Rick Gardner (Mike Unruh)
Pinnned Start Date: 1/24/94 Planned Completion Date: 9/94 References (NRC/INPO/NUMARC/NAIT Etc.): SMM
==
Description:==
Develop and implement a reorganization of the Maintenance Department.
Objective:
To reduce the number of reporting layers in order to improve communications within the department and to create a Maintenance Support group.
Major Milestones:
Accomplishment Plan Date Actual Date 1.
Develop organization structure. (RLG-94-04.1) 1/94 1/94 2.
Obtain approval of structure and manpower 2/94 2/94 increases. (RLG-94-04.2) 3.
Acquire approval to combine lead Person 2/94 2/15/94 and Crew Leaderjobs. (RLG-94-04.3) 4.
Determine space requirements and provide 4/94 4/29/94 same. (RLG-94-04.4) 5.
Re-assign personnel to positions as necessary, 6/94 and finalize the new position descriptions and postings. (RLG-94-04.5) 6.
Self assess the reorganized department for 9/94 effectiveness. (RLG-94-04.6)
RLG-94-04
Program Enhancement Update Status: (RLG-94-04 Continued) 1)
Organization structure development complet.e.
i 2)
Organization stmeture approved and manpower.:ncreases for initial stages of restructure approved.
3)
Reclassification of Lead Person positions to Crew leader is complete.
Reclassifications took affect 3/1/94.
I 4)
Space requirements for initial stages of restmeture have been
{
determined and a Purchase Requisition for same has been submitted.
Received approval of PR for trailer on 3/12/94 P.O. 379174 issued for trailer on 3/23/94.
5/10/94 Item #1 Complete Item #2 Complete Item #3 Complete Item #4 Space requirement for initial stages of restmeture have l
been determined. Trailer is scheduled to arrive end of I
May.
Item #5 Met with Human Resources personnel on 3/7 and 3/8 to begin development of new position descriptions to support reorganization. One position description remains to be developed.
5/20/94?
lItsnf#43 Trailer far Ma%RpSupport gr60p shbsid beFict;sp
^
~
and ;icady; fotoccupying by June 20/1994l Item';#5}
l Request f6rl Position Auth6rizatisni(for^neppositi6si T
wem approved by. G.R{ Horn on MayJ17[1994j 1
l l
l l
l I
l RLG-94-04 (Cont.)
I
(
Program Enhancement Priority:
RED Item No:
RLG-94-05 Title /
Description:
Evaluate PIV, ISI, IST and LLRT Programs Date Updated: 5/20/94 f
External Funding Requirements: 5800,000 (Estimate)
Internal Resource Requirements:
(
l Licensing Manager / Supervisor - 40 hours4.62963e-4 days <br />0.0111 hours <br />6.613757e-5 weeks <br />1.522e-5 months <br /> / year, Configuration Management Manager / Supervisor - 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br /> / year, CNS Engineers - 240 hours0.00278 days <br />0.0667 hours <br />3.968254e-4 weeks <br />9.132e-5 months <br /> / cycle, NED Engineer - 1040 hours0.012 days <br />0.289 hours <br />0.00172 weeks <br />3.9572e-4 months <br /> / year, Operations / Maintenance support - 640 hours0.00741 days <br />0.178 hours <br />0.00106 weeks <br />2.4352e-4 months <br /> / cycle l
Program Manager:
Rick Gardner (Jim Lynch) i Planned Start Date: 9/1/93 Planned Completion Date: 4/95 References (NRC/INPO/NUMARC/NAIT Etc.): SPPI 350 l
==
Description:==
Develop and implement programs and program changes to resolve SALP MS-1 concerns for Pmssure Isolation Valve testing, I.ocal Leak Rate Testing, and r
[
Inservice Inspection / Testing including:
e Develop and implement a Pressure Isolation Valve test program.
e Identify safety related manual valves required to be operated in emergency conditions and implement PM requirements.
r Identify and implement ISI requimments for safety related non-code e
[
class 1,2,or 3 systems containing piping, pressure vessels, pumps, or i
valves.
[
e Implement modification, testing, and program development to resolve SALP MS-1 LLRT concerns.
f l
Objective:
Evaluate and improve PIV, ISI, IST and LLRT progmms to ensure regulatory l
compliance and sound program bases.
I L
i RLG-94-05
. _D
L Program Enhancement I
Major Milestones: (RLG-94-05 Continued) r L
Accomplishment Plan Date Actual Date f
1.
Initiate / approve PMs for manual valves 12/93 11/17/93 used in EOPs. (RLG-94-05.1) 2.
Develop an Engineering Department Instruction 4/94 4/29/94 which provides guidance for action to be
[
taken when components are place on increased test frequency. (RLG-94-05.2) i 3.
Evaluate safety related non-code class 1, 6/94 2, and 3 systems for ISI program inclusion.
(RLG-94-05.3) 4.
Determine ISI boundaries and inspection 7/94 scope for SW and REC systems. (RLG-94-05.4) 5.
Determine ISI boundaries and inspection 7/94 scope for safety related non-code class 1,2, and 3 systems. (RLG-94-05.5) 6.
Complete design basis reconstitution for 6/94 primary containment (Cost not included in funding itquirements). (RLG-94-05.6) 7.
Submit relief requests for SW and REC 8/94 i
inspection program addenda. (RLG-94-05.7) 8.
Submit 10CFR50.55a exemption requests for 8/94 safety related non-code class 1,2, and 3 l
systems not to be added to ISI program.
l (RLG-94-05.8) l 9.
Submit relief requests for safety related 8/94 non-code class 1,2, and 3 systems l
inspection program addenda. (RLG-94-05.9) 10.
Develop procedures for PIV testing.
8/94 (RLG-94-05.10) 11.
Review safety related manual valves for 8/94 inclusion in IST or augmented testing programs. (RLG-94-05.11)
RLG-94-05 (Cont.)
Program Enhancement Major Milestones: (RLG-94-05 Continued)
Accomplishment Plan Date -
Actual Date 12.
Initiate / approve PMs for stroking 10/94 identified manual valves. (RLG-94-05.12) 13.
Complete design basis reconstitution 11/94 walkdown (cost not included in funding requirements). (RLG-94-05.13) l l
14.
Submit ISI program addenda for SW and 12/94 REC systems. (RLG-94-05.14) 15.
Submit ISI program addenda for safety 12/94 related non-code class 1,2, and 3 systems. (RLG-94-05.15) 16.
Approve procedures for PIV testing.
12/94 (RLG-94-05.16) 17.
Conduct a third party review ofIST 12/94 program manual valves. (RLG-94-05.17) 18.
Develop an Appendix J program document.
12/94 (RLG-94-05.18) 19.
Complete installation of test connections 4/95 and isolation valves for LLRT accident direction testing (cost not included in funding requirements). (RLG-94-05.19) 20.
Perform LLRT accident direction testing 4/95 l
for modified penetrations. (RLG-94-05.20) l 1
RLG-94-05 (Cont.)
i ex a mm um a ed
Program Enhancement RLG-94-05 (Continued)
Update Status:
Contractor selected for staff augmentation to complete Item # 4.
Funding expenditure request to go to the Febmary Board of Directors for approval.
PIV testing methods selected and verified to be effective during 1993 i
outage.
5/10/94 Item #1 Complete Item #2 Instructions are contained in Engineering Procedure 3.9.
The need for additional instmetions is being evaluated by the IST Engineer and is on schedule.
5/20/94j iApproximitely 55% of thelsafetyfielated.~manualystvesNvs beeni
~
initially; reviewed;;.;The effort is approximately)35% complete overall.
A* project"plari has been'dsseloped whichiill_complsie"ithmsl'#37#4;
- 5, #7, #8,;#9, #14, #15, and #16J A contracior;(VECTRA) is on' sits; and ' project workLis proceeding onl schedule);
Recent changes to' Procedure 3.9 appear to pr6 vide l, adequate guidancs
~
for action' to.be.taken' wben~ components'are placed on'incicased, test frequency (item #2)S The need for an _ Engineering Deparui.d Instruction is currently;bsing evaluated. {All' action is anticipated it6;be completed by 6/94l RLG-94-05 (Cont.)
I
Program Enhancement Pri:rity: RED Item No:
RLG-94-06 Title /
Description:
Engineering Backlog Date Updated: 5/20/94 External Funding Requirements: $1,200,000 (estimate). Estimate is based on 15 contractors for six to nine months to help reduce engineering backlog and to upgrade programs.
Internal Resource Requirements: Estimate 25% paid overtime per engineer for the next six to nine months.
Program Manager: Rick Gardner (Jim Lynch)
PI:nned Start Date: 1/10/94 Planned Completion Date: 4/94 References (NRC/INPO/NUMARC/NAIT Etc.): OSTI, INP0
==
Description:==
Reduction of the Engineering Department backlog will result in an Engineering Department workload that is prioritized, manageable in size, delivers pmducts on time, and has measurable results and goals and allow CNS engineering time to establish a enhanced system engineer program and establish healthy reports of assigned systems.
Objective:
Reduce engineering backlog and improve the effectiveness of managing the workload.
This will allow System and Program Engineers to more effectively manage their systems and programs.
Major Milestones:
Accomplishment Plan Date Actual Date 1.
Develop criteria for prioritization 1/94 2/8/94 of engineering NAIT and ACT items.
(RLG-94-06.1) 2.
Frioritize and schedule NAIT and 2/94 2/28/94 ACT items. (RLG-94-06.2) 3.
Prepare point papers for contractor 1/94 1/94 assistance. (RLG-94-06.3)
RLG-94-06
7 Program Enhancement Maj:r Milest:nes: (RLG-94-06 Centinued) i Accomplishment Plan Date Actual Date 4.
Plan for contractor site arrival 2/94 2/28/94 training, badging, office space.
(RLG-94-06.4) 5.
Identify specific work packages for 2/94 2/28/94 contractorr.. Assign contractors for specific engineers. (RLG-94-06.5) 6.
Develop a set of Engineering Depanment 2/94 3/10/94 perfonnance indicators. Produce appropriate charts and graphs for depanment and senior management review. (RLG-94-06.6) 7.
Produce final set of department performance 4/94 5/20/94 indicators, publish monthly. Determine goals and incentives for achieving goals. (RLG-94-06.7) l Update Status:
2/10/94 Item #1 is complete, memo (CNSS943517) was issued on 2/8/94. Item #2 is in progress with completion expected by 2/18/94. Item #3, Point Papers have been prepared and i
discussed with the ERC. Board Of Directors discussion planned for 2/11/94. Item 4, tmiler space identified, PO for computer i
purchase written, Computer Applications setting up a computer i
trunk line to the trailer. Item #6, draft indicators have been l
produced.
3/10/94 Item #2 and #4 are complete. Item #5, contractors began arriving on 2/14. All contractors are on-site and have been assigned to specific supervisors. Item #6, a draft set has been produced and are being reviewed by management.
5/10/94 Item #7 Engineering department performance indicators are expected to be completed by 5/15/94.
5/20/941 (The final set of Enginsering'Departinent' psrformaiiceFindicst6rs wsre issued on 5/20/94iThe full set of performance indicators will.be issued t6 selected CNS. Managers land the Engineering Department monthly _ meeting! ?RLG-94:06 isl considered to;be completei RLG-94-06 (Cont.)
L Program Enhancement r
Priority: -
RED L
Item No:
RLG-94-07
{
Title /
Description:
Maintenance Bacidog Date Updated: 5/20/94 External Funding Requirements: $200,000 Internal Resource Requirements: 6,000 hours0 days <br />0 hours <br />0 weeks <br />0 months <br /> Program Manager: Rick Gardner (Mike Unruh) t Planned Start Date: 1/24/94 Planned Completion Date: 9/94 References (NRC/INPO/NUMARC/NAIT Etc.): OSTI L
==
Description:==
Provide Maintenance Department review of all commitments (MWRs/NCRs/DRs) in I
order to ensure control of same. Additionally, provide interim resources to address incoming items until the maintenance support group is functional.
Objective:
Reduce maintenance backlog and improve the effective management of the workload.
L Major Milestone:
Accomplishment Plan Date Actual Date u
1.
Def* e Backlog. (RLG-94-07.1) 2/94 2/23/94 m
m 2.
Determine additional resource requirements 2/94 2/28/94 and obtain. (RLG-94-07.2)
L 3.
Review all commitments to determine depth 4/94 4/28/94 of problem (this will be a group review).
(RLG-94-07.3) r L
4.
Set Priorities fmm review. (RLG-94-07.4) 4/94 4/28/94 r
f 5.
Identify and plan for resolution of the 6/94 problem areas. The major points are spam
[
parts, resources and enhanced scheduling.
(RLG-94-07.5) r L
RLG-94-07
l Program Enhancement Major Milestones: (RLG-94-07 Continued)
Accomplishment Plan Date Actual Date
(
6.
Provide permanent resources to maintain a 6/94 periodic review of all open items.
(RLG-94-07.6) 7.
Provide a means for continuous monitoring 9/94
(
of Maintenance Group / Shop Backlog.
(RLG-94-07.7)
(
Update Status:
2/10/94 Item #1, define backlog, is in progress. Item #2, additional resource requirements have been identified and the resources
(
should be approved at the February board meeting, t
3/10/94 Item #1, definition for backlog has been established and is being
(
included in M.P. 7.0.4 Conduct of Maintenance. Additionally a
~
method for prioritizing backlog items has been established.
Procedure revision is ready to be submitted for SORC routing.
Item #6, resources to maintain periodic review of all open items has been provided on a temporary basis through use of a consultant engineer.
3/31/94 The prioritization of outstanding maintenance work is in progress with an expected completion of 4/30/94. (Forced shutdown maintenance activities in the month of March precluded completion of this activity on schedule.)
5/20/947 ihem #3J' '
Mcontradot,with{maintensnbe management tiackground
' reviewed the non cfaft' Maintenance Department backlogLt6 i
determine thidepth of theiroblesdA[meetinglwas_ held l66 4/28/94Lwhich discussd the findings of;te contactor;with l
Maintenance Departmeni managesent '% letteryasLissued'6n 4/28/94lwhich summhrizediheitend tisodiduringiths meeting]
(
l ItemL#41 ~ iTifeine(CorreciiWAstiba Programfthatiiiisn[ini6?effebt ths
~
fintL6f April lhsr@et[ priorities of alllnesliisues. PlantM L
i policiechhave;bseiset[td pribrities? pre existing"issuesd'Ihi priorities"of tb CorrectivdAstion backloglissues huyelbssi l
establishedMIhisTmilestone is completedj l
l RLG-94-07 (Cont.)
1 1
L Program Enhancement Priority:
RED Item No:
RLG-94-08 Title /
Description:
Review the Qualifications Date Updated: 5/20/94 and Training of Current CNS System Engineers to Detennine
{
Training Required External Funding Requirements: None
[
Internal Resource Requirements: Approximately 20 system engineers each attending two newly revised system training courses per year; 30 system engineers attending courses required by revised Training Program
[
Descriptions (TPDs) for one year (qualification to revised TPDs must be completed within one year) training resources to develop and deliver the newly revised system training courses.
Program Manager: Rick Gardner (Jim Lynch)
Planned Start Date: 11/3/93 Planned Completion Date: 7/94 l'
References (NRC/INPO/NUMARC/NAIT Etc.): OSTI, SPPI
[
==
Description:==
Upgrade the training provided to system engineers to include system task oriented objectives. Provide appropriate system training for all engineers assigned systems.
Objective:
Organize, enhance, and communicate improvements in engineering training. This includes enhanced systems training and improvements to positional requirements for engineers.
r Major Milestones:
7 Accomplishment Plan Date Actual Date L
1.
Review and revise TPD 502 - Technical Staff, 12/93 12/30/93 r
TPD 509 - Station Engineer, L
TPD 526 - Station Nuclear Engineer, TPD 527 - ISI Engineer (RLG-94-08.1) e L
2.
Identify system engineers assigned 1/94 1/24/94 systems who have not completed
[
system training. (RLG-94-08.2) 3.
System engineers complete system 2/94 2/28/94 training as identified in Item 2 (above).
(RLG-94-08.3)
F RLG-94-08
Program Enhancement Major Milestones: (RLG-94-08 Continued)
Accomplishment Plan Date Actual Date 4.
Develop a plan and schedule for system 2/94 3/3/94 lesson plans to be upgraded for system engineers j
(i.e., begin with SRO level training lesson plans and revise objectives as appropriate for system engineer). (RLG-94-08.4) f 5.
Complete revision to system engineer 7/94 lesson plans and begin delivering
(
new system training lessons.
(RLG-94-08.5)
[
6.
Develop individualized training plans 7/94 appropriate for Engineering Department personnel. (RLG-94-08.6) i' 7.
System Engineer Certification 7/94 (RLG-94-08.7) r t
Update Status:
2/10/94 Item #1 is complete. TPDs have been reviewed and changes L
were made regarding position and task required lessons, and optional lessons. Item #2 is complete. Engineers assigned r
systems who have not completed training on their assigned L
systems have been identified. Item #3 is in progress.
r 3/10/94 Item #3, all System Engineers have completed the appropriate systems training. Item #4, discussions with training have begun and three meeting have been held. Schedules have not been
[
produced but are scheduled to be completed during 3/94.
t 3/31/94 Item #4, lesson objectives for System Engineer Training have
[
been completed 3/9/94. Schedule for lesson plan upgrades to be L
developed in April.
[
5/10/94 Training records are being reviewed and serve as documentation utilized in items #1, #2, and #3.
[
Item #4 Lesson Plan upgrades are continuing.
5/2.0/94j ' ; Item #43 ~
Lesson [ Planlupgrades#Ere"onjioliig[and]Willlts
[
ccmpleted to aspport Jul[tfainingl RLG-94-08 (Cont.)
r 1
Program Enhancement Priority:
RED Item No:
RLG-94-09 Title /
Description:
Improve Operations Communications Date Updated: 5/20/94 External Funding Requirements: None Internal Resource Requirements: 60 hours6.944444e-4 days <br />0.0167 hours <br />9.920635e-5 weeks <br />2.283e-5 months <br /> per year Program Manager: Rick Gardner (Bob Bmngardt)
Planned Start Date: 12/1/93 Planned Completion Date: 6/94 R:ferences (NRC/INPO/NUMARC/NAIT Etc.): OSTI
==
Description:==
The actions that will be addressed under this action include the following:
)
e Evaluate the conduct of crew briefings including frequency and adequacy of information exchange.
Standardize the shift turnover process such that operational information/ plant e
station information is communicated between shifts in a consistent manner.
Establish a mechanism to ensure long term issues / problems are communicated to all shifts.
e Evaluate operator verbal communications against the CNS Directive on communications.
Objective:
Ensure complete, accumte and consistent transfer of information through improved operator communications.
Major Milestones:
Accomplishment Plan Date Actual Date 1.
Implement a Control Room Operator Turnover 3/94 3/10/94 Checklist to support consistent turnovers.
(RLG-94-09.1) 2.
Obtain approval of Procedure 2.0.2 4/94 3/30/94 which incorporates Long Term Concems into the Shift Supervisor's turnover.
(RLG-94-09.2) 3.
Observe shift crews and document 6/94 communications effectiveness.
(RLG-94-09.3)
RLG-94-09
Program Enhancement RLG-94-09 (Continued)
{
Update Status:
2/10/94 Shift crews were previously observed in September - October
[
1993, and communications observations documented. Milestone
- 3 will measure the effectiveness of communication improvements previously implemented.
Procedure 2.0.2 has been revised and a draft of the Ieng Term Concerns is already in use.
3/10/94 (RLG-94-09.1)
[
A Control Room Operator Turnover Checksheet is in use by the CRS, RO, and BOP.
[
(RLG-94-09.2)
Procedure 2.0.2 is in technical review routing.
I t
5/10/94 Item #1 Complete
[
Item #2 Procedure 2.0.2 incorporated revision to turnover requirements. This revision was approved r
3/30/94. This completes this item.
L Item #3 Observation of turnover and communication p
effectiveness is scheduled to begin third week of May.
5/20/94.L 1.. Item.'#. 3. ?. =FATC6atrol Room". Observation ChecklistL has been.
I-r L
4 c
L I
f L
RLG-94-09 (Cont.)
l
{
{
l I
(
l SECTION IV L
SAFETY ASSESSMENT L
[
[
[
I l
[
(
(
[
[
SECTION IV
[
SAFETY ASSESSMENT
[
{
Within this section the issues regarding problem identification, corrective action, procedural adequacy and adherence will be addressed.
The procedural adequacy and adherence concern focused on whether the procedures, as they are currently written, provide the necessary guidance and detail.
Part of the oversight
(
function at CNS is to determine if appropriate solutions to existing problems is being provided.
A new Correccive Action
[
Program is being developed to accomplish this.
Part of the culture change that must happen before CNS can significantly improve performance is that the employees need to develop a more questioning attitude.
To support this change in L
attitude a mechanism to solicit and implement employee concerns will be developed as a task within this section.
F L
To address these issues, the following Integrated Enhancement
[
Program tasks have been developed and are being implemented.
The tasks included in this section are Program Enhancements which 7
provide a description of the task, the responsible manager, and L
the expected completion date, r
L f
[-
L Program Enhancement Priority:
RED L-Item No:
JMM-94-01 Title /
Description:
Upgrade the Corrective Action Program Date Updated: 5/20/94 External Funding Requirements: $400,000 Internal Resource Requirements: 2500 hours0.0289 days <br />0.694 hours <br />0.00413 weeks <br />9.5125e-4 months <br /> Program Manager: John Meacham (Chris Moeller)
{
Planned Start Date: 9/17/93 Planned Completion Date: 10/94 References (NRC/INPO/NUMARC/NAIT Etc.): CCA, SPPI, SMM, OSTI
==
Description:==
Various internal and regulatory assessments of the existing Corrective Action
[
Program have identified several weaknesses. These weaknesses are being resolved through this action item.
I" Objective:
In support of the culture change to a more questioning attitude, provide a completely new Corrective Action Program, which facilitates:
1.
Easy problem identification.
2.
Def' ed problem ownership and accountability.
m g
L 3.
More in-depth root cause analysis.
4.
Improved human performance evaluation.
5.
Enhanced trending capability.
Major Milestones:
7 Accomplishment Plan Date Actual Date L
1.
Establish Steering Committee.
9/93 9/24/93 r
(JMM-94-01.1)
L 2.
Develop project goals.
10/93 9/30/93 (JMM-94-01.2) 3.
Approve conceptual design.
10/93 10/11/93 p
(JMM-94-01.3) 4.
Conduct plant visits.
10/93 10/29/93 (JMM-94-01.4) 5.
Conduct manager / supervisor workshops.
12/93 12/1/93
{
(JMM-94-01.5)
JMM-94-01 l
l L
Program Enhancement Major Milestones: (JMM-94-01 Continued)
Accomplishment Plan Date Actual Date 6.
SORC review of draft procedures. (JMM-94-01.6) 12/93 12/23/93 6a.
Implementation of interim changes. (JMM-94-01.6a) 1/94 1/27/94
{
7.
Preliminan approval of CAP implementation 2/94 2/28/94
{
procedures. (JMM. 24-01.7) 8.
Provide CAP training. (JMM-94-01.8) 3/94 3/31/94 b
9.
Preliminan approval of Root Cause Guideline.
3/94 3/31/94 (JMM-94-01.9) l 10.
Provide root cause training. (JMM-94-01.10) 3/94 3/31/94 l
11.
Implement program and supporting procedure 3/94 3/31/94 changes. (JMM-94-01.11) 12.
Convert existing trending records to new 6/94 database. (JMM-94-01.12) i 13.
Assess program effectiveness. (JMM-94-01.13) 10/94 l
Update Status:
All CAP procedures have been completed and SORC approval received. The Root Cause Guideline has been completed, reviewed and i
epproved for general use. Root Cause Training began on March 28, 1994 for the first group of tminees. Durin(April hiki Mip(Root Cause 7
Traising continifid.?AdvancodiR66i Cause; Training?is nopbeing providedltojselected individuals and.;manrgeriOPPIMMare"sii site;*and p'roviding mentoring;in rcotcause evaluationsOhel trending l
database is ubder dvshe ;andlpiesently[onTschshda. Program implementation has been affected and full implementation achieved.
I i
u rL JMM-94-01 (Cont.)
l l
l l
Program Enhancement JMM-94-02 (Continued)
Status Update:
Assessment of the existing CNS OER program has been completed.
The review of past OER dispositions, as well as the evaluation by an independent consultant has shown a need to revise the current program.
Efforts have begun to revise the program procedures in areas where weakness has been identified. The previous plan date for B31-94-02.4 of 3/31/94 was in error. It was always anticipated that the OER Program would be reviewed after the assessments were complete.
5/10/94:
A revision to CNS Procedure 0.10.1, Operating Experience Review, has been submitted. This revision accommodates the assessments which were previously performed. Additionally, the need to assess the improvement efforts after six months was recognized.
5/20/94:
No~ Change in statusi l
l BIM-94-02 (Cont.)
Program Enhancement Priority: RED Item No: JMM-94-03 Title /
Description:
Enhance the Human Performance Evaluation Date Updated: 5/20/94 Program External Funding Requirements: $50,000 Internal Resource Requirements: 4500 hours0.0521 days <br />1.25 hours <br />0.00744 weeks <br />0.00171 months <br /> Program Manager: John Meacham (IRG Manager)
Planned Start Date: 1/24/94 Planned Completion Date: 3/94 References (NRC/INPO/NUMARC/NAIT Etc.): CCA, SMM
==
Description:==
The existing Human Performance Evaluation Program is somewhat rudimentary and is used within the existing Corrective Action Program only when consequential human errors arise. Enhancements to this program, embodied in the aforementioned elements of this action item, will be described in a Nuclear Power Group Directive and will be applicable to all personnel in the NPG The thresholds for human error and the actions necessary to co: rect their causes will be decided and implemented at the departmental leve.l. The new Corrective Action Program will serve as the vehicle to implement this program. An Independent Review Group (IRG) will be formed to assess human performance through investigate assessments by Senior Management.
The development activities associated with this program will be performed as item No. JMM-94-05. Develop the Independent Review Group.
Objective:
Reduce human errors through a programmatic approach to human performance evaluation.
Major Milestones:
Accomplishment Plan Date Actual Date 1.
Establish the IRG Manager as the 2/94 2/24/94 Program Manager. (331-94-03.1) 2.
Perform assessment of recent human errors 2/94 3/18/94 by outside experts. (331-94-03.2) 3.
Provide input to CAP final procedun:s.
3/94 3/18/94 (3 31-94-03.3)
JMM-94-03
Program Enhancement JMM-94-03 (Continued)
Update Status:
The INPO assessment report on human performance problems was received during the first week in March. Recommendations from this report were reviewed. CAP pmcedures were reviewed to insure that the issues identified by INPO has been addressed by the CAP program.
The evaluation determined that the new CAP program encompassed the INPO concern. This completes the activities associated with this l
program.
l l
l L
l JMM-94-03 (Cont.)
Program Enhancement Priority:
RED Item No:
JMM-94-02 Title /
Description:
Improve Operating Experience Review Date Updated: 5/20/94 Program External Fimding Requirements: $35,000 Internal Resource Requirements: 700 hours0.0081 days <br />0.194 hours <br />0.00116 weeks <br />2.6635e-4 months <br /> Program Manager: John Meacham (C.R. Moeller)
Planned Start Date: 1/24/94 Planned Completion Date: 12/94 References (NRC/INPO/NUMARC/NAIT Etc.): CCA
==
Description:==
The NPPD CNS OER Program has come under scmtiny by CNS Senior Management and the NRC because of several recent incidents. Consequently, an effort is undenvay to improve the effectiveness of the program.
Objective:
Improve the CNS OER Pmgram through:
1.
Iessons learned from a critical review of past document dispositions.
2.
Assessing the current program and correcting weaknesses.
3.
Enhanced training of involved personnel.
[
Mador Milestones:
Accomplishment Plan Date Actual Date c
L 1.
Assess cunent OER pmgram. (JMM-94-02.1) 2/94 2/25/94 r
2.
Assess 20% of OER dispositioned in the 3/94 3/31/94 L
last two years. (BiM-94-02.2) 3.
Assess certain OER dispositioned within the 3/94 3/31/94 last ten years. (JMM-94-02.3) 4.
Based on the results of assessments, revise the 4/94 4/29/94 CNS OER Program. (BIM-94-02.4) i l
5.
Develop training module and train personnel on 6/94 revised program. (BfM-94-02.5) 6.
Assess program effectiveness. (JMM-94-02.6) 12/94 BBi-94-02 o
c Program Enhancement
(
Priority:
RED L
Item No:
JMM 94-04 Title /
Description:
Review / Revise Operability Determination Date Updated: 5/20/94 Process External Funding Requirements: $30,000 Internal Resource Requirements: 1000 hours0.0116 days <br />0.278 hours <br />0.00165 weeks <br />3.805e-4 months <br /> f
L Program Manager: John Meacham/(R.L. Sanchez/E.A. Erickson)
[
Planned Start Date: 1/24/94 Planned Completion Date: 12/94 References (NRC/INPO/NUMARC/NAIT Etc.): SPPI i
==
Description:==
Over the past two years, several lessons have been learned regarding the use of the operability determination / operability evaluation process. In view of the changes being made to the Corrective Action Program, management has L
determined that it would be timely to also enhance this pmcess.
Objective:
Revise the OD/OE procedures to allow for termination when no longer
[.
applicable, to assure inputs are pmperly reviewed and prepared in accordance with other CNS Procedums, to describe needed thmshold, and to allow r
searching on past OEs/ODs. In addition, provide training to involved L
personnel.
M4or Milestones:
Accomplishment Plan Date Actual Date r
L 1.
Assess existing proceduml weakness.
3/94 3/31/94 (JMM-94-04.1)
L 2.
Based on assessment, revise procedure.
5/94 (JMM-94-04.2) l l
3.
Establish process " owners" for OD and 5/94 OE process. (JMM-94-04.3)
JMM-94-04 i
_. ]
I L
' Program Enhancement Major Milestones: JMM-94-04 (Continued)
(
Accomplishment Plan Date Actual Date 4
Develop training module and train 6/94
[
appmpriate personnel on revised procedure. (JMM-94-04.4) 5.
Evaluate effectiveness of new process.
12/94 (JMM-94-04.5) f Update Status:
. The assessment of existing OD/OE procedures is completed and the procedure is currently undergoing revision. Due to the extensive nature of the changes involved (a fonnat similar to the new Corrective Action Progam is being put into place), approximately a one month delay has.
[
been experienced. The'OD/OEyrocedarti;';ssisionsWcurrentlyysisj
- 9ieped? Process' ownenhip]s being evaluatedj l
L L
L l
r u
l l
r e
]
I JMM-94-04 (Cont.)
Program Enhancement Priority:
RED Item No:
JMM-94-05 Title /
Description:
Develop the Independent Review Group Date Updated: 5/20/94 External Funding Requirements: $30,000 Internal Resource Requirements: 200 hours0.00231 days <br />0.0556 hours <br />3.306878e-4 weeks <br />7.61e-5 months <br /> Program Manager: John Meacham Planned Start Date: 1/24/94 Planned Completion Date: 12/94 References (NRC/INPO/NUMARC/NAIT Etc.): N/A
==
Description:==
The Independent Review Group (IRG) will perform selected reviews of NPG activities, without constraints or limitations of any kind and has unlimited access to existing trending information and other peninent data. The outcome of these reviews will be reported to Senior NPG Management and will identify the cause, or causes, which keep the desired results from being obtained.
Areas with severe shortcomings will undergo increased overview by the IRG until a positive trend is achieved.
Objective; To ensure that the Nuclear Power Group is achieving results which meet management expectations and, if not, to provide feedback to NPG Senior Management.
M4or Milestones:
Accomplishment Plan Date Actual Date L
1.
Internal review of related programs.
2/94 2/10/94 e
(JMM-94-05.1)
L 2.
Evaluate how other utilities perform 2/94 2/24/94 IRG functions. (JMM-94-05.2) e L
3.
Develop IRG Chaner. (JMM-94-05.3) 2/94 2/28/94 4.
Develop IRG staffing plan and job 3/94 3/31/94 descriptions. (JMM-94-05.4) 5.
Develop IRG procedures and guidance 6/94 documents. (JMM-94-05.5)
L L
l JMM-94-05 l
I L
Program Enhancement l
M40r Milestones: (JMM-94-05 Continued)
Accomplishment Plan Date Actual Date
}
Develop assessment schedule for IRG.
6/94 6.
l (JMM-94-05.6) 7.
Provide overview report on IRG 7/94 implementation. (JMM-94-05.7) l 8.
Assess program effectiveness. (JMM-94-05.8) 12/94 i
Update Status:
The IRG Charter has been developed in the form of an NPG Directive which is now undergoing review. Job Descriptions have been defined, the jobs posted, and staffing for the group is underway.
5/10/94:
The developmental activities for the IRG have been delayed for l
approximately one month. Recent efforts have been directed towards l
filling the IRG Manager position. Additionally, the need was recognized to assess the effectiveness six months after program l
implementation.
5/20/94i An'additi6nalfoseirs6 nth ~; delay:is beisiincuned.^):Thifl lido 6Vthi Pmeess pf identigingjgialified candidat4pfgjhe;IRG Manager l
P9.sition) l l
l JMM-94-05 (Cont.)
Program Enhancement Priority:
RED Item No:
IMM-94-06 Title /
Description:
Develop an NPG-Wide Priority System Date Update: 5/20/94 External Funding Requirements: $15,000 Internal Resource Requirements: 1600 hours0.0185 days <br />0.444 hours <br />0.00265 weeks <br />6.088e-4 months <br /> Program Manager: John Meacham (E. Erickson)
Planned Start Date: 1/24/94 Planned Completion Date: 11/94 References (NRC/INPO/NUMARC/NAIT Etc.): CCA, OSTI (Observation 93-202-05)
==
Description:==
At the present time, the various organizational entities in the Nuclear Power Group are using different methods to prioritize their work. Simple priority schemes are needed to ensure that everyone understands what the highest priority work is.
Objective:
1.
To ensure critical work is completed first.
2.
To ensure backlog work is being processed in an efficient manner.
(
Major Milestones:
Accomplishment Plan Date Actual Date
[
1.
Conduct survey to c'etennine how other 2/94 2/24/94 plants prioritize work. (JMM-94-06.1) 2.
Evaluate work areas needing prioritization.
2/94 2/24/94 (JMM-94-06.2) r L
3.
Develop formal conceptual description for 2/94 2/24/94 priority program. (3B1-94-06.3) f L
4.
Revalidate existing priority schedules for 4/94 4/29/94 EWR, MWR, TWR, PCN. (31M-94-06.4) 5.
Implement any upgrades stemming from 5/94 revalidation effort. (JMM-94-06.5) l L
6.
Assess program effectiveness. (nni-94-06.6) 11/94 B BI-94-06 l
Program Enhancement JMM-94-06 (Continued)
Update Status:
The industry survey of other utility prioritization programs has been completed. Work areas at CNS which require prioritization are being evaluated.
5/10/94:
Review of existing priority schemes (for EWR, MWR, TWR, and PCN) has been conducted to ensure their adequacy and correctness of application. It was found that while the existing prioritization schemes are valid, they are not consistent, program-to-program. Therefore, the remaining action is to develop a generalized set of priority criteria which accommodates the existing ones. This effort will be completed in May, as scheduled. The need to assess the effectiveness of this process after six months was also recognized.
5/20/94i A generalized set of priority criteria are under developmentChese will be set forth in a policy'. directive and implemented thmugh procedure revision to existing priority schemes; JMM-94-06 (Cont.)
Program Enhancement Priority:
RED Item No:
JMM-94-07 Title /
Description:
Implement the Industry Advisory Group Date Updated: 5/20/94 External Funding Requirements: $50,000 Internal Resource Requirements: 150 hours0.00174 days <br />0.0417 hours <br />2.480159e-4 weeks <br />5.7075e-5 months <br /> Program Manager: John Meacham Planned Start Date: 1/24/94 Planned Completion Date: 11/94 References (NRC/INPO/NUMARC/NAIT ETC.): N/A
==
Description:==
One of the causes of the recent declining performance of the Nuclear Power
(
Group has been a failure to keep abreast of emerging issues and take action accordingly. An Industry Advisory Group (IAG) will be comprised of several nuclear industry executive level personnel and be chaired by the Senior
(
Nuclear Division Manager of Safety Assessment. The Group will met periodically to discuss emerging issues, compam CNS performance to industry standards, and provide acdback to Senior Management.
Objective:
Ensure that the Nuclear Power Group remains abreast of emerging industry r
L issues and proactively responds to those affecting Cooper Nuclear Station.
f Major Milestones:
Accomplishment Plan Date Actual Date l.
Develop IAG Charter. (JMM-94-07.1) 2/94 2/28/94 r
2.
Develop " Rules of Practice". (BiM-94-07.2) 3/94 3/31/94 L
3.
Obtain industry experts for IAG.
4/94 5/6/94 (BIM-94-07.3) 4.
Develop meeting schedule and hold 5/94
[
first meeting. (BBi-94-07.4)
I 5.
Assess IAG effectiveness. (JMM-94-07.5) 11/94 B Bi-94-07 l
I
I Program Enhancement JNB1-94-07 (Continued)
Update Status:
The IAG " Rules of Practice" have been developed and are undergoing review. Resume's have been obtained for potential candidates to serve on the IAG. Activity remains on schedule.
5/10/94:
The industry experts for the IAG have been obtained. The first meeting of the IAG has been tentatively scheduled for the week of May I
30,1994. Additionally, the need to assess the effectiveness of the IAG after six months was recognized.
5/20/94:
No other changes, I
i i
l l
!I il l
l l
JMM-94-07 (Cont.)
l l
4 I
i 4
4 1
i 1
1 SECTION V
- i
- t SITE SUPPORT 1
ii 1
e d
i 4
l 1
a J
l.
1 l
SECTION V SITE SUPPORT The primary purpose of the Site Support Division enhancements is to resolve the training issues identified by previous audits and assessments and to support the training requirements of several other Program Enhancements.
The training deficiencies were centered around the certification process, the adequacy of training, and the apparent inability to maintain the training compliance and qualification requirements for NPG employees.
The Site Support enhancement items address seven areas for improvement.
These areas were developed as a result of several inputs and are scheduled and prioritized to provide the required management and staff focus to ensure reasonable and timely progress is achieved and the end product fully addresses the issue.
It is recognized that to improve station performance, increased management attention is needed to increase emphasis on leadership, teamwork, communications and accountability among management, supervision and the workforce.
This portion of the Integrated Enhancement Program will support the actions required for these needed improvements.
To address these issues, the following Integrated Enhancement Program tasks have been developed and are being implemented.
The tasks included in this section are Program Enhancements which provide a description of the task, the responsible manager, and the expected completion date.
Program Enhancement Priority:
RED
)
Item No:
EMM-94-01 Title /
Description:
NPG Manager and Supervisor Management Date Updated: 5/20/94 i
Skills Training External Funding Requirements: $225,000/YR (Estimate)
Internal Resource Requirements: Approximately 75 people,4 24-hour workshops / year, 2-3 years. Senior management participation. Nuclear Training Manager - 200 i
hours / year, Corporate Training Manager / Supervisor - 50
]
hours / year.
l Program Manager: E.M. Mace (J.W. Dutton)
Planned Start Date: 11/22/93 Planned Completion Date: 2/95 i
5 References (NRC/INPO/NUMARC/NAIT Etc.): OSTI, SPPI 270 (Enercon Report), SMM, CCA
==
Description:==
Develop long term Management Training Program for NPG Supervisors and j
Managers including:
e Assess each NPG Supervisor and Manager to determine what level of l
training or suppott they may requim o
Develop Training schedule for NPG Supervisors and Managers e
Develop Management / Supervisor Training Program Train Management / Supervision in Basic Management Skills e
4 Establish Positive Feedback and Improvement areas to Managers and e
Supervisors Objective:
To provide a strong, focused management development within the NPG.
M4or Milestones:
l Accomplishment Plan Date Actual Date 1.
Establish overview, basic approach and treatment.
11/93 11/22/93 (EMM-94-01.1) 2.
Establish Advisory Committee, 12/93 12/22/93 (EMM-94-01.2)
EMM-94-01
Program Enhancement r
Major Milestones: (EMM-94-01 Continued)
Accomplishment Plan Date Actual Date 3.
Initial design of Workshop #1 (WI).
12/93 12/22/93
(
(EMM-94-01.3) 4.
Administer Diagnostic Instmments.
2/94 2/4/94 (EMM-94-01.4) 5.
Finalize design of Wl, Initial design of W2.
2/94 02/12/94
(
(EMM-94-01.5) 6.
Finalize design of W2, Initial design of W3.
4/94 4/29/94 l
(EMM-94-01.6) 7.
Delivery of W1 completed to all Management teams.
5/94 5/13/94 l
(EMM-94-01.7) 8.
Finalize design of W3, Initial design of W4.
5/94 (EMM-94-01.8) 9.
Delivery of W2 completed to all Management teams.
6/94 (EMM-94-01.9) 10.
Survey to determine effectiveness of W1.
7/94 l
(EMM-94-01.10) 11.
Finalize design of W4, Initial design of W5.
7/94 (EMM-94-01.11) j 12.
Survey to determine effectiveness of W2.
8/94 I
(EMM-94-01.12) 13.
Delivery of W3 completed to all Management teams.
9/94 (EMM-94-01.13) 14.
Finalize design of W5, Initial design of W6.
10/94 (EMM-94-01.14) 15.
Survey to determine effectiveness of W3.
11/94 (EMM-94-01.15) 16.
Delivery of W4 completed to all Management teams.
12/94 (EMM-94-01.16) 17.
Survey of CNS to determine effectiveness of W4.
2/95 (EMM-94-01.17)
EMM-94-01 (Cont.)
l l
Program Enhancement l
Update Status: (EMM-94-01 Continued)
On schedule Plan is established for one year of a 2-3 year program. Plan will be updated for second year in the third quaner.
Diagnostic instruments delivered, and evaluation in-progress. Final design of Workshop #1 will be set on Saturday, February 12,1994 and schedule for Workshops 1-4 will be determined.
Workshop #1 is scheduled, design finalized and in development.
Agreement with Lied Conference in progress. GSA with BCAL and JP & Associates completed. Teams identified.
Team #1 has completed workshop #1, with good acceptance. Delivery of workshop #1 to teams 2-6 is in-progress.
5/10/94 Teams #1-5 have completed Workshop #1. The " Dialogue" Technique is being used in the plant, with good success. Workshop #2 has been designed.
5/20/94 Workshop one has been completed for all tedniiffW6rksh5y6
' tarted 5/18/94; s
l EMM-94-01 (Cont.)
J'..'..
~
J.
. ~. '.'
^
lL Program Enhancement E
Priority:
RED
. Item No:
EMM-94-02 Title /
Description:
Develop User-Friendly Tracking Date Updated: 5/20/94 System for Training and Cedification External Funding Requirements: $350,000 (Estimate)
Internal Resource Requirements: Information Systems assistance, clerical support for m
L testing, Management / Supervision time for design Program Manager: E. M. Mace (J. W. Dutton)
L Planned Start Date: 1/24/94 Planned Completion Date: 1/95 r
References (NRC/INPOINUMARC/NAIT Etc.): OSTI L
==
Description:==
Develop user-friendly computerized database for tracking when various F
certifications or requalifications are mquired and who the affected personnel are. Ensure NPG managers / supervisors are involved in the development of
{
this program - OSTI.
E Objective:
To develop a user-friendly system to identify certification status of employees prior to work assignment.
~
M40r Milestones:
Accomplishment Plan Date Actual Date 1.
Establish interim Progmm to ensum maintenance of 1/94 1/94 certification. (EMM-94-02.1) 2.
Scoping session with ISD, Training, Steve Woerth, 1/94 1/11/94 and CS. (EMM-94-02.2)
Conduct Business Area Analysis at CNS and GO.
2/94 2/9/94 3.
(EMM-94-02.3)
Define and ref' e requimments. (EMM-94-02.4) 3/94 3/9/94 4.
m 5.
Determine alternatives, select best approach, develop 3/94 3/15/94 1
Functional Specification. (EMM-94-02.5)
EMM-94-02
l Program Enhancement l
Major Milestones: (EMM-94-02 Continued)
Accomplishment Plan Date Actual Date 6.
Request for Bids. (EMM-94-02.6) 4/94 4/18/94 7.
Award contract. (EMM-94-02.7) 6/94 4/18/94 8.
Install / Test system. (EMM-94-02.8) 9/94 l
9.
Acceptance Testing Complete. (EMM-94-02.9) 10/94 i
10.
The tangible deliverable will be the final 1/95 testing of the new 'ITS software and hardware platform. Thme months following final testing an effectiveness myiew will be conducted consisting of a questionnaim completed by a random sample of users; followed by targeted interviews and appropriate software changes. (EMM-94-02.10)
Update Status:
1/11/94 Meeting was held at CNS with Information System and Training Department to develop scope of project.
2/8 & 9/94 Meetings were held at CNS with Information Systems to identify the problems with the current TTS system and gain input for the new system requirements.
2/8/94 Nuclear Network is being used to explore what other plants are using for software.
3/3/94 Meeting scheduled for 3/9/94 at the G.O. with Information Systems to define and mfine requirements.
3/9/94 Meeting was held on 3/9/94 with IS to define and refine requirements.
3/28/94 ISSC (NPPD VP committee) approved expenditure for upgrade
($350,000 Work Order). Will be submitted for Board approval 4/7/94.
5/10/94 Task Authorization No. 94A-MS29 with Mincom USA, Inc. was issued April 18,1994. This authorization diacts Mincom to provide NPPD with a functional design of the new CTS system. In accordance with said authorization, Mincom was on-site the week of 4/18/94.
EMM-94-02 (Cont.)
l Program Enhancement Priority:
RED
' Item No:
EMM-94-03 Title /
Description:
Develop a Comprehensive System Date Updated: 5/20/94 Engineering Training Program for CNS System Engineers External Funding Requirements:
1 Internal Resource Requirements: 860 hours0.00995 days <br />0.239 hours <br />0.00142 weeks <br />3.2723e-4 months <br /> l
l Program Manager: E. M. Mace (J. W. Dutton)
Planned Start Date: 1/24/94 Planned Completion Date: 2/95 References (NRC/INPO/NUMARC/NAIT Etc.): OSTI
==
Description:==
Develop a comprehensive System Engineering Training Program for CNS System Engineers - OSTI.
Objective:
To provide well qualified system engineers to support safe station operation.
Major Milestones:
Accomplishment Plan Date Actual Date 1.
Establish Task Group. (EMM-94-03.1) 1/94 1/7/94 2.
Establish Objectives. (EMM-94-03.2) 5/94 3.
Develop Training Material. (EMM-94-03.3) 6/94 4.
Develop Evaluation Method. (EMM-94-03.4) 7/94 5.
Conduct Training - (EMM-94-03.5) 8/94 1
6.
Conduct effectiveness review. (EMM-94-03.6) 2/95 l
I i
EMM-94-03
l l
Program Enhancement EMM-94-03 (Continued)
Update Status:
(1)
Upgrade Meeting held January 27,1994 S. Winn to provide first cut on " Systems" objectives to R.
Sanchez and T. Black, this includes oi>jectives from " Tech Spec" material.
B. Toline to provide updated Engineering Task List.
M. Bohling to provide overview of current TPDs.
j M. Bohling gave trip repon of Monticello Trip.
(2)
February 3,1994 EMR met with Sanchez and Black to review effons on making
" Qual Card" for engineering. They will provide feedback at February 17,1994, Task Group meeting from Engineering Supervisors.
(3)
March 3,1994 Meeting:
A)
S. Winn has completed review of all COR002 Systems objectives. Fonvard to Sanchez and Black.
B)
R. Sanchez presented a cross matrix of integrated systems for engineers. Will select five systems for review and " buy in" by engineer supervision.
C)
M. Bohling developed a flow chan of current TPDs.
This should aid in an overall understanding of the training program.
D)
"Expen Level" Qual Card developed by B. Toline.
Presently under review for comments by T.B., R.S.,
J.B., W.M.
E)
Review of the "under development" Manager / Supervisor Systems training course may be suited for 2 week course by new engineers.
F)
Next task group meeting March 17, 1994.
EMM-94-03 (Cont.)
a
Program Enhancement EMM-94-03 (Continued)
Update Status:
3/31/93 1)
Due to unplasmed outage, task group meetings scheduled for 3-17 and 3-23 were cancelled at Engineering's request.
2)
A TWR was written by EMR for Program Development to pinduce a Task to Training matrix. This will justify the current approved Engineering Task list and identify areas needing training development.
3)
B. Toline will produce a " Generic" workbook for Engineering review; to be included with " System Specific" qual cards.
4)
Task group meeting for 4-7-94 will pick up where 3-17-94 agenda left off. This resulted in a one month schedule slippage, i
l 5/10/94 1)
Terminal objectives have been written.
2)
Enabling objectives have been selected.
l I
3)
Task to Training Matrix has been produced.
Items not identified to be completed by May 13.
l 4)
An effectiveness review will be scheduled and conducted by CNS Engineering with training support as required.
i i
i i
l EMM-94-03 (Cont.)
l Program Enhancement Priority:
RED Item No:
EMM-94-04 Title /
Description:
Root Cause Training Date Updated: 5/20/94 External Funding Requirements: $19,250 Internal Resource Requirements: 255 hours0.00295 days <br />0.0708 hours <br />4.21627e-4 weeks <br />9.70275e-5 months <br /> Program Manager: E. M. Mace (J. W. Dutton)
Planned Start Date: 1/24/94 Planned Completion Date: 12/94 References (NRC/INPO/NUMARC/NAIT Etc.): 190 SPPI,200 SPPI
==
Description:==
Provide Root Cause Training for the NPG. Root Cause evaluation training needs to be made a part of Engineering and Tech Staff training, and reinforced i
by continuing training.
Objective:
To develop an engineering staff that is well qualified in Root Cause Analysis.
Major Milestones:
Accomplishment Plan Date Actual Date 1.
Revise GOT Training. (EMM-94-04.1) 3/94 3/31/94 2.
Develop K-T ATS Tmining Schedule.
3/94 3/29/94 (EMM-94-04.2) 3.
Final Root Cause'- 101 approach.
56/94
~
(EMM-94-04.3) 4.
Complete classes. (EMM-94-04.4) 11/94 5.
Revise TPDs 0509 - Station Engineer, 12/94 0526 - Station Nuclear Engineer, 0527 - ISI Engineer, and 0516 - Design Engineer to include K-T (ATS) Root Cause as Position Required. (EMM-94-04.5)
EMM-94-04
l
[
Program Enhancement FAIM-94-04 (Continued)
Update Status:
Discussion with Engineering Manager on 2/8/94 indicates that the r
KePner Tregoe (ATS) Root Cause classes should be placed as Position L
specific on Engineering TPDs versus TPD 0502, Tech Staff. This would focus the sessions more towards personnel who perform Root r
Cause Analysis.
L The K-T classes will be offered five (5) times over the next year to
[
accommodate personnel. Once the classes are completed, the TPDs L
will be revised to mfiect the requirement. Providing the classes, then adding the lesson to the TPD as per NTP: 02, Training Program Descriptions.
{
The three ATS Instmetors completed upgrade by Kepner Tregoe on
[
March 23 and 24,1994. The first three ATS classes have been scheduled for April 11,12,13, May 17,18,19, and June 27,28,29, 1994.
I The CAP material has been developed as a " Stand Alone" lesson in GOT. All personnel who have completed the " Level One" CAP l
training will be " Alternately Completed" to the GOT lesson. The
" Stand Alone" lesson has been incorporated on a TPD.
L 5/10/94 A meeting was held to discuss providing K-T to station personnel. A second meeting was completed the week of 5/2/94.
[
5/20/94 Ruot Cause 10_1 class is being' presented tolststisii personnel 5/18&l9/940 Bissd on fesdback furtheFRdCsuss Tfaisingjillibs determlM m
l c
l E
I m
F f~
L EMM-94-04 I~
I l
Program Enhancement Priority:
RED
[
Item No:
EMM-94 05 Title /
Description:
CAP Training Date Updated: 5/20/94 External Funding Requirements: $0
[
Internal Resource Requirements: 100 Professional hours, 20 Clerical hours Program Manager: E. M. Mace (J. W. Dutton)
Planned Start Date: 1/24/94 Planned Completion Dae: 4/94 References (NRC/INPO/NUMARC/NAIT Etc.): 180 SPPI
[~
==
Description:==
Develop and present training on the new CAP, upon finalization of CAP procedures.
I" Objective:
To provide training to plant personnel on the new CAP progmm.
Major Milestones:
Accomplishment Plan Date Actual Date L
1.
Develop lesson on CAP. (EMM-94-05.1) 3/94 3/23/94 2.
Present Lesson on CAP. (EMM-94-05.2) 3/94 3/31/94 3.
Generate report to Training Manager 4/94 5/2/94 L
outlining the results of the initial training. (EMM-94-05.3)
I Update Status:
Ixvel I training has been developed and submitted to C. Moeller for review / approval. Awaiting information on objectives from C. Moeller to begin development of LevelII training.
r a
Received objectives for level II Training. Development of Level II
[
lesson in progress, completion is dependent upon approval of Corrective Action Program.
Eu EMM-94-05 I
1
Program Enhancement F3fM-94-05 (Continued) l Update Status:
Lesson Plans for Level I and II submitted for review /appmval. During the week of 3/28/94,20 classes for Level I and 10 for Ixvel II training have been scheduled on site. In addition, seven classes for Level I and Level II have been scheduled in Columbus. It is the intent to train majority of NPG personnel by 3/31/94.
5/10/94 Conducted numerous sessions of CAP Level I and II on-site and at the General Office, 637 individuals completed Level I Training, and the total completing Level II was 335. Initial implementation is considered to be complete and CAP Training has been turned over to the Technical Training Group. A report of these results has been submitted to the Nuclear Training Manager. An effectiveness r; view will be scheduled and conducted by the Safety Assessment divi.on 'vith training support
[
as required. This item is complete.
[
[
F L
I L
r L
I L
E L
EMM-94-05 (Cont.)
l J
I L
Program Enhancement Priority:
RED
[
Item No:
EMM-94-%
[
Title /
Description:
Implement Recommendations of Date Updated: 5/20/94 L
Fire Protection Assessment
[
External Funding Requirements: $500,000 Internal Resource Requirements: 600 hours0.00694 days <br />0.167 hours <br />9.920635e-4 weeks <br />2.283e-4 months <br />
{
Program Manager: E. M. Mace (H. T. Hitch)
Planned Start Date: 1/24/94 Planned Completion Date: 12/94
{
References (NRC/INPO/ETC.): CCA, OSTI
==
Description:==
The Purpose of the F/P Assessment is to determine the overall adequacy of the
[
NPG Fim Protection Program.
Objective:
To evaluate the adequacy of the existing F/P Program and make the necessary L
enhancements to improve the overall Fire Protection Program.
Mador Milestones:
~
L Accomplishment Plan Date Actual Date b
1.
Complete the F/P Assessment.
2/94 2/10/94 (EMM-94-06.1) e L
2.
Deliver the results of the 2/94 3/2/94 F/P Assessment to NRC Region IV.
r (EMM-94-06.2) 3.
Complete the implementation of the 12/94 appropriate recommendations of the F/P Assessment. (EMM-94-06.3)
Update Status:
The Fire Protection Assessment inspection was completed on January L
14,1994. As of February 8,1994, the second draft of the report comments are being incorporated. Within the next 2 weeks the fm' al l
[
Fire Assessment report will be issued, with an advanced copy being l
sent to the Senior Resident Inspector. A drop in visit of to Region IV is planned during February to present the Fire Assessment report to the
{
NRC.
Item #2 NRC rescheduled meeting from February 28,1994 to March 2,
[
1994.
EMM-94-M i
Program Enhancement EMM-94-06 (Continued)
Update Status:
The Fire Protection Assessment results have been entered into Action
[
Tracking with Senior Management responsibility assigned. The contract project engineer assigned to the Senior Manager Site Support was badgV. the week of 3/21/94. E :pect to have a dmft responsibility
[
matrix rao :roject schedule by 3/31/94. Meeting scheduled with responsitic ite managers the week of 4/4/94.
5/10/94.
With the exception of the one item, all priority items are being
[
addressed and are progressing. The development of the DCD has been slow due to the workload of NED personnel restricting initial data
{
collection activities. However, actions are being taken to supply the contractor with the required information to start the DCD development and this item should be back on track shortly.
r L
This item will not have an effectiveness review, as this item is an effectiveness review in and of itself. Additionally, techniques that will
[
identify an adverse trend regarding ineffective implementation of this IEP item.
m I
L E
L L
?
l l
L F
L Eu r
L EMM-94-06 (Cont.)
1 l
J
f L
Program Enhancement
[
Priority:
RED l
Item No:
EMM-94-07
[
Title /
Description:
Conduct a Compliance Review of Date Updated: 5/20/94 L
CNS Training Program External Funding Requirements: $100,000 Internal Resource Requirements: 1000 hours0.0116 days <br />0.278 hours <br />0.00165 weeks <br />3.805e-4 months <br /> of project management and analysis Program Manager: E. M. Mace (Dutton)
. Planned Start Date: 1/24/94 Planned Completion Date: 2/95
[
References (NRC/INPO/NUMARC/NAIT Etc.): OSTI
==
Description:==
This plan serves as the basis for implementation of a conewted self-inspection
(
program which will precisely focus upon all of the regulatocy nrpirements which impact training. This self-inspection will identify all internal and external training requirements and insure that they are being uet, thus taking a
[
strong proactive approach toward ensuring that key training pmgrams are in full compliance. Any identified deficiencies will be factored into training and there will be assurance that the training is meeting / exceeding requirements in a L
cost-effective manner.
This Pmgram Plan is intended to cover / describe the planning and resources c
L required to: obtain and research documentation, develop requisite checklists, and determine how the requirements are being satisfied. It also covers the 7
development of action plans to correct any deficiencies.
u Objective:
To ensure that all internal and external training requirements are being met.
7 This will assist in assuring the training programs truly support the safe and efficient operation of the plant. It will minimize regulatory agency f~mdings and resultant corrective actions. Finally, it will pmvide a mechanism for determining commitments / requirements to ensure they are not erroneously L
deleted or changed by later revisions to tmining.
p M4or Milestones:
I L
Accomplishment Plan Date Actual Date j
[
1.
Submit requests for quotations for man-power.
1/94 1/27/94 (EMM-94-07.1)
[
2.
Select vendor and let contract for man-power.
3/94 3/3/94 (EMM-94-07.2) r L
EMM-94-07 t
I
Program Enhancement Major Milestones: (EMM-94-07 Continued)
Accomplishment Plan Date Actual Date 3.-
Gather references for checklist construction for NRC 3/94 3/30/94 requirements and licensing commitments. (EMM-94-07.3) 4.
Research references, validate commitments and 4/94 4/29/94 build checklists for NRC requirements and licensing commitments.-(EMM-94-07.4) l t
5.
Inspect training programs to determine how/if 6/94 commitments and requirements are being met.
(
(EMM-94-07.5) 6.
Resolve discrepancies with management, develop actions 6/94
[
necessary for resolution, submit f' mal product.
(EMM-94-07.6) 7.
Gather references for checklist constmetion for INPO 7/94 requirements. (EMM-94-07.7)
(
8.
Build checklists for INPO requirements and past three 8/84 years operating experience commitments. (EMM-94-07.8)
(
9.
Inspect training programs to determine how/if 10/94 requirements are being met. (EMM-94-07.9) 10.
Resolve discrepancies with management, develop actions 10/94 necessary for resolution, submit final product.
r (EMM-94-07.10) 11.
Complete modification of programs and lessons as 12/94 r
identified in action plan. (EMM-94-07.11)
L 12.
This IEP will not have an effectiveness review as 2/95 such, since the end product is a design basis document for the Training Program. However,3 months L
following completion, a random spot check of the
[
finished product will be conducted to ensure requirements were captured. (EMM-94-07.12) l.
I L
EMM-94-07 (Cont.)
l 1
Program Enhancement Update Status: (EMM-94-07 Continued) 2/2/94 -
Request for quotations sent to prospective vendors with replies requested by 2/7/94. Point paper will need to be completed immediately to allow review by the various boards / committees prior to Board of Directors meeting on 3/4/94.
2/8/94 -
Quotations have been received from approximately 8 vendors. Currently developing a spreadsheet to compare costs and qualifications. A point paper should be developed and forwarded for review by the various committees and boards so it can be ready for the next (March) Board of Directors meeting.
3/3/94 -
A point paper was developed and has gone through both the ERB and ERC. It was to be presented to the Board today or tomorrow. (3/3 or 3/4) 3/23/94 -
Board approval was obtained on 3/3/94. Both contractors are on-site and have completed required training. The gathering of references and checklist constmetion has been completed. A trail run of requirements for 10CFR20 will be made to ensure that the process developed for this review is satisfactory. This is being done to ensure the process is satisfactory before proceeding too far into the project.
5/10/94 The project schedule with the process of compiling requirements is essentially complete. The next phase of the process, the inspection of training programs to ensure requirements are being met, is beginning. During the phase of the project just completed, over 36 regulatory documents, 20 years of correspondence, LER's, and inspection reports were reviewed to identify the nearly 2000 training requirements located to date. As the project continues, it is expected that a few additional requirements will be identified.
}
)
EMM-94-07 (Cont.)
sp SECTION VI NUCLEAR SUPPORT r
t I
L L
f
[
[
[
SECTION VI NUCLEAR SUPPORT Nuclear Support is conducting an ev?luation of the Licensing Department to improve the Regulatory Support for CNS.
Nuclear Support will also develop directives which will provide policy guidance and management expectations to the organization.
It is expected that enhanced organization communications, more effective management oversight, and improved performance will result.
To address these issues, the following Integrated Enhancement Program tasks have been developed and are being implemented.
The tasks included in this section are Program Enhancements which provide a description of the task, the responsible manager, and the expected completion date.
Program Enhancement t
Priority:
RED
{
Item No:
DAW-944)1
[
Title /
Description:
Evaluate Licensing Department Date Updated: 5/20/94 Organization
{
External Funding Requirements: O&M Budget Internal Resource Requirements: 1 Licensing Manager 40 hours4.62963e-4 days <br />0.0111 hours <br />6.613757e-5 weeks <br />1.522e-5 months <br />; Division Manager of Nuclear Suppon 20 hours2.314815e-4 days <br />0.00556 hours <br />3.306878e-5 weeks <br />7.61e-6 months <br /> b
Program Manager: G. R. Smith Planned Start Date: 12/2/94 Planned Completion Date: 1/95
[
References (NRC/INPO/NUMARC/NAIT Etc.): SMM
[
==
Description:==
This effon involves a study to compare the NPG Licensing function with the Licensing functions of several other utilities operating single unit nuclear plants. The staffing, functions performed, work location, personnel L
qualifications, and other factors will be compared. This study is intended to suppon management decision-making relative to the Licensing Depanment.
[
Objective:
This effort is being undenaken in order to provide information to suppon decisions regarding the Licensing Department in order to impmve the Licensing suppon for CNS.
7 L
Major Milestones:
Accomplishment Plan Date Actual Date r
u 1.
Interview OPPD (DAW-94-01.1) 12/93 12/10/93 2.
Interview Wolf Creek (DAW-94-01.2) 1/94 1/6/94 s
r 3.
Interview Crystal River (DAW-94-01.3) 1/94 1/7/94 L
4.
Interview Nonhern States (DAW-94-01.4) 1/94 2/4/94 E
L 5.
Interview Duane Arnold (DAW-94-01.5) 1/94 2/4/94
[
6.
Issue repon containing findings to 2/94 2/9/94 Vice President - Nuclear. (DAW-94-01.6)
[
7.
Prepare Licensing Department Reorganization 3/94 3/4/94 Plan for Vice President - Nuclear approval.
(DAW-94-01.7)
DAW-94-01 l
l Program Enhancement Major Milestones: DAW-94-01 (Continued)
Accomplishment Plan Date Actual Date
[
_8.
Implement Licensing Depanment 6/94 Reorganization Plan. (DAW-94-01.8) 9.
Assess Reorganization Effectiveness.
1/95 (DAW-94-01.9) f L'
r Update Status:
All interviews were completed on 2/4/94. A repon containing the L
msults has been completed and provided to the Vice President -
Nuclear. Milestone DAW-94-01.7 has been added to this item to
[
develop a plan for reorganizing Licensing. The Licensing Department Reorganization Plan was completed and submitted to the Vice President
- Nuclear on 3/4/94. The contents of the plan have been approved by
[
the Vice President - Nuclear and am being implemented. Major milestones DAW-94-01.8 and DAW-94-01.9 have been added to reflect the implementation of the reorganization plan and to assess the L
effectiveness of the reorganization after six months.
r i
4 r
a r
L F
L i
l 7.
s DAW-94-01 (Cont.)
1
l L
Program Enhancement Priority:
RED
[
Item No:
DAW-94-02 r
Title /
Description:
Issue NPG Dimetives in Support Date Updated: 5/20/94 L
of the Strategic Plan for Performance Improvement r
L External Funding Requirements: O&M Budget
[
Internal Resource Requirements: 96 hours0.00111 days <br />0.0267 hours <br />1.587302e-4 weeks <br />3.6528e-5 months <br /> (exclusive of management review and appmval time)
I Program Manager: A. L. Dostal Planned Start Date: 10/22/93 Planned Completion Date: 5/94 r
l" References (NRC/INPO/NUMARC/NAIT Etc.): SPPI Activity 030,40,220
==
Description:==
Issue NPG Directive on Teamwork / Communications Issue NPG Directive on Management /StaffInterface r
L Issue NPG Directive on Business Plan Preparation Objective:
The development and issuance of these directives are specified as actions
).
contained in the SPPI. The intent of these documents is to provide policy J
guidance and management expectations to the organization. It is expected that enhanced organizational communications, more effective management u
oversight, and improved performance will result.
M40r Milestones:
E Accomplishment Plan Date Actual Date 1.
Issue NPG Directive on Teamwork / Communications 12/93 12/23/93 for comment. (DAW-94-02.1) 2.
Issue NPG Directive on Management /StaffInterface 1/94 1/28/94 P
for comment. (DAW-94-02.2) l
]
3.
Develop NPG Directive on Business Plan Preparation 5/94 with assistance from Senior Management consultant.
(DAW-94-02.3) e DAW-94-02
Program Enhancement Major Milestones: (DAW-94-02 Continued)
Accomplishment Plan Date Actual Date 4.
Approve NPG Directive on Teamwork / Communications.
2/94 1/24/94 (DAW-94-02.4) 5.
Approve NPG Directive on Management /StaffInterface.
3/94 4/12/94 (DAW-94-02.5) 6.
Approve NPG Directive on Business Plan Preparation.
6/94 (DAW-94-02.6)
Update Status:
The NPG Directive on Teamwork / Communications was approved on 1/24/94. The directive on management / staff interface was approved on April 12,1994. The title of the NPG Directive on Goals and Objectives has been changed to " Business Plan Pmparation" to reflect the planning process being pursued. A draft directive on NPG Business Plan Preparations.ha(been developed with the assistance of a senior management consultant. Approval of;tlie dinxtiVe'isleW~idJniis]
DAW-94-02 (Cont.)
.-m.-
m
i 4
i i
i i
a SECTION VII 1
CORPORATE ENGINEERING
~
1 I
i l
4 I.
i 4
4 i
)
I I
SECTION VII
[
CORPORATE ENGINEERING
[
The primary focus of the Corporate Engineering effort is on the concern regarding engineering programs assigned to the corporate engineering staff.
In addition, assessments rill be made of the engineering modification and configuration control process.
The tasks developed for this section will better define the plant change process and upgrade the Configuration Management Program at CNS.
[
To address these issues, the following Integrated Enhancement Program tasks have been developed and are being implemented.
The tasks included in this section are Program Enhancements which provide a description of the task, the responsible manager, and the expected completion date.
L I
i k
f t
I L
F t
I L
i
_i
[,
a l
Prograrn Enhancement l
Priority:
RED Item No:
REW-94-01 Title /
Description:
Engineering Program Date Updated: 5/20/94 Responsibility Assignment External Funding Requirements: Engineering Program Review - NED O&M Budget
$2,500 Design Criteria Document - W.O. 24700 $375,000 Internal Resource Requirements: Design Basis Project - 10,000 man-hours NED - 100 hours0.00116 days <br />0.0278 hours <br />1.653439e-4 weeks <br />3.805e-5 months <br /> Program Manager: Robert Wilbur (Steve McClure, Kim Walden)
Planned Start Date: 1/24/94 Planned Completion Date: 11/94 References (NRC/INPO/NUMARC/NAIT Etc.): Self-Identified 1)
Letter CNSS937311 R. L. Gardner to R. E. Wilbur dated 11/2/93: Program Turnover 2)
INPO assist visit December 6-10,1993.
3)
Letter CNSS940106 G. R. Hom to NPG Senior Managers dated 1/5/94: INPO Assist Visit - CNS Engineering 4)
Letter R. E. Wilbur to G. R. Horn dated 1/18/94: INPO Assist Visit - CNS Engineering 5)
Letter G. R. Horn to J. E. Gagliardo dated 1/21/94: Cooper Nuclear Station (CNS)
Engineering Plan for Performance Improvement 6)
Letter CNSS941089 G. R. Horn to R. E. Wilbur dated 3/1/94: Engineering Programs 7)
Letter A. G. Boesch to G. S. McClure dated 4/7/94: Meter Banding Procedure Review 8)
Letter M. J. Siedlik to R. E. Wilbur dated 4/25/94: CNS Procedure 3.6.4 - Core Drill Procedure 9):: Estter K7C1Walden to Those Listed l dated 5/16/94f PrimarflContaihment](PC)
~
System Design Criteria; Document;.(DCDf)
REW-94-01
.xg Program Enhancement (REW-94-01 Continued)
==
Description:==
In order to provide more time for the System Engineer to address specific issues related to his assigned plant systems, a review of work assignments and a reassignment of engineering work was required. A portion of the engineering programs were to be transferred to the Corporate Engineering Group. The transferred procedures / programs will be reviewed and upgraded as appropriate to meet industry standards. The Design Basis Project will produce the Primary Containment Design Criteria Document to support the program review and upgrade of the Appendix J Program.
Objective:
To shift some of the assigned program engineer workload to allow the system engineers to focus on their plant system responsibilities.
Major Milestones:
Accomplishment Plan Date Actual Date 1.
Review of site engineering functions.
5/94 1/18/94 (REW-94-01.1) 2.
Reassignment of specific work functions 5/94 1/18/94 to other groups. (REW-94-01.2) (S. McClure) 3.
Review and upgrade the five programs tmnsferred from CNS to NED.
a.
Core Drill Procedure 5/94 4/25/94 b.
Meter Green Band Procedure 5/94 4/7/94 c.
Temporary Shielding Procedure 9/94 d.
Freeze Seal Procedure 11/94 e.
Relief Valve Setpoint Program 6/94 4.
Generate the Design Specification Document 6/94 for Primary Containment to support the Appendix J Program. (REW-94-01.3) (K. Walden)
Update Status:
1.
The site engineering function has been reviewed and resulted in the generation of the Cooper Nuclear Station (CNS) Engineering Plan for Performance Improvement.
Performance Indicator: None required.
REW-94-01 (Cont.)
m.-- - --
l L
Program Enhancement (REW-94-01 Continued)
Update Status (Cont.):
[
2.
A preliminary plan to address 15 engineering programs at CNS was generated. It was agreed that Temporary Shielding, Core Drill, Meter Banding, Freeze Seals and Relief Valve Setpoint
[
programs would transfer to NED. NED has accepted responsibility for these programs.
Discussions related to the Check Valve Program, Inservice Testing Program, Repairs and Replacement Program, Appendix J Program and the Inservice Inspection Program were waiting for J. Lynch to finalize his plans as to how the site proposes to handle these programs. Discussions with J. Lynch on 1/17/94 indicated that the five engineering programs in questions would stay at the site.
Performance Indicator: None required.
l 3.
NED will review and upgrade, as appropriate, the pmgramiasd procedums controlling the five programs turned over to NED by the dates indicated.
I a)
Freeze Seal Procedure (M. Siedlik) - 5 % Complete b)
Com Drill Procedure (M. Siedlik) - Completed 4/25/94 c)
Temporary Shielding Procedure (M. Siedlik) -
L 40% Complete d)
Meter Banding Procedure (A. Boesch) -
r Completed 4/7/94 L
e)
Relief Valve Setpoint Program (M. Hillstrom) -
p0% Complete I
The Meter Banding Procedure review and upgrade was completed April 7,1994 (see Reference 7).
\\
The Core Drill Procedure review was completed on April 25, l
1994 (see Refemnce 8).
[
Tius Relief Vals Setpoint Pr6iiriiuid?hidhlW'alippedlhiid L
by June 15(willlstill support the)need toLbe readysfor the B&TS Inspection'in JunenThis will include programsland procedures]
r Data bases for essential'rslieffal L
essentialidata basessill follow; pes; win,be completed.M~~
r-L Performance Indicator: The Relief Valve Setpoint Program will be inspected by the NRC as part of the Engineering & Technical Support Inspection in June 1994. Due to the very limited use of
~
L.
the other four procedums except during an outage, these will be evaluated following the 1995 outage.
[-
REW-94-01 (Cont.)
l
l L
Program Enhancement (REW-94-01 Continued)
Update Status (Cont.):
b 4.
The Design Basis Group has scheduled the development of the Primary Containment Design Criteria Document to commence in
{
January 1994. A consultant has been identified and is available on an as-needed basis. In addition, the consultant the site used to generate the original Appendix J Program has been made
{
available for support of this work.
Ths"draftIPhimary Containment Dssign Cristial[Docubisitjas E
bompletedLon schedule 1on Msy)15th?iTheffinal DCD;;is ssheduled toKappmvedLbyJsne?30thKAMof[ tin" penetrations.thatlaie accessible %:alljPrimarffantaM validation pacess,1&aikdown of nW6usside wasLplannedh L
begini the' week of May]l6thMSpecial ProcedureL94-202j
" Primary;iConuinment Walkdow4" jai' approved lonlMay[lh L
1994yThe;Prhnary Containmant walkdown started lonLMay 18th!!A'walkdown ofinside!6f the:Prhnary I'antainmaat asi those inaccessible ~ exterior penetrations lllsTpienent$ mehaadar!
L for the' fall. maintenance outaieh.Upon completipbfltle exterioEwalkdownfachaadad for Junejothfsndjppross1Wths PC.DCD,7 scheduled foiIsas.l30tiffa'completeyslidatine[6f dis L
Primary [C6ntainment[Sysies%s-built 3veCir.Qbf sashp inslude an evaluation of ths a 7
penetratios"against;ttWdesiin,; testing, functionalfandfoperational minimnents snd commitmentsjThisfactivityNplannedMb complete by, November 30th?tbLinchsie thslsesultslbflths r
walkdowniof tine 7msidisf'bontainmes@Anjldiscrepanilsiiyill L
be entered intoLthe1 Corrective 1Astion Prograniissd sessived accordindyyne tsojsek]oss;6fjiss wasidugextensive E
activities ~at the,~ site!
Performance Indicator: The Primary Containment Design E
Criteria Document will be reviewed and upgraded annually in accordance with the Design Basis Project Procedure NECDP-03,
" Design Criteria Document Production."
r L
i l
i
~
1 L.
Iu i
REW-94-01 (Cont.)
y
Program Enhancement Priority:
RED Item No:
REW-94-02 Title /
Description:
Nuclear Engineering and Constmetion Date Updated: 5/20/94 Division Self-Assessment External Funding Requirements: NED O&M Budget, Configuration Management O&M Budget $100,000 Internal Resource Requirements: OSC Self-Assessment - 500 hours0.00579 days <br />0.139 hours <br />8.267196e-4 weeks <br />1.9025e-4 months <br /> MOV Self-Assessment - 1000 man-hours Design Change Closeout Self-Assessment - 1000 hours0.0116 days <br />0.278 hours <br />0.00165 weeks <br />3.805e-4 months <br /> NED Self-Assessment - 1000Llhiiii Program Manager: Robert Wilbur (Steve McClure, Ken Almquist) t Planned Start Date: 1/24/94 Planned Completion Date: 12/94 References (NRC/INPO/NUMARC/NAIT Etc.):
i i
NRC Inspection Report 93-01, Inspection of Engineering & Technical Support, Page 19.
G. Horn from V. Wolstenholm memo dated April 26,1994: Design Change Closeout l-Process, Evaluation QE9418.
==
Description:==
The Licensee was encouraged by the NRC to consider conducting a self-i assessment of design engineering.
Objective:
For the Nuclear Engineering and Construction Division to self-assess its activities and assure that the functions of NED are adequate, appropriate, and consistent with industry standards.
Major Milestones:
Accomplishment Plan Date Actual Date l.
OSC Self-Assessment (REW-94-02.1) 1/94 1/27/94 i
2.
NED Self-Assessment Activities (REW-94-02.2) j (S. McClure)
{
a)
MOV Program Project 4/94 4/6/94 b)
Design Change Closeout Process 4/94 4/26/94 c)
NED Self-Assessment 12/94 REW-94-02
)
Program Enhancement (REW-94-02 Continued)
Update Status:
1.
The OSC Self-Assessment team has been established. A contractor to lead the self-assessment and provide technical training and guidance to the team arrived on site January 17, 1994. The assessment was conducted the week of January 17 &
24, 1994. The draft repon was received the week of January 31 and was reviewed by the assessment team. Comments were incorporated and the report issued by Febmary 11,1994. There were no safety issues identified and a list of improvements was generated. NED has generated an action plan to address the findings. Action assignments were made on March 22,1994.
Performance Indicator: An evaluation of the use of OSCs will be conducted following the 1995 outage since the major ponion of OSCs are generated during and following an outage.
i 2.
a)
The MOV Program Pmject conducted a self-assessment of the project. The assessment staned on March 10 and was complete on March 18. A draft report was issued for review April 1. The final report was distributed on April 6,1994. (K. Almquist)
Performance Indicator: The major portion of the assessment items resulted in specific actions which were logged into the Project action item data base. The monitoring of the data base in addition to the CNS QA audit function and the planned NRC MOV Project inspections will assure progress is made/ monitored.
b)
NED organized a self-assessment of the design change closeout process. A team was organized to collect required information. It was then decided to have QA use this task as their first assignment for their new Assessment Group. The NED data was turned over to j
QA which started the evaluation on March 22. The evaluation is now complete, and a report was transmitted to NED on April 26,1994. (S. McClure)
Performance Indicator: DealkChange"eldiesu[ status is I
tracked safmonthlpLbasisi c)
A complete self-assessment of NED has been scheduled i
for the fourth quaner of 1994. (S. McClure)
Performance Indicator: To be determined.
REW-94-02 (Cont.)
Program Enhancement Priority:
RED Item No:
REW-94-03 Title /
Description:
Evaluate the Configuration Date Updated: 5/20/94 Control and Design Change Process within the NPG External INnding Requirements: $250;000 Internal Resource Requirements: 1100 hours0.0127 days <br />0.306 hours <br />0.00182 weeks <br />4.1855e-4 months <br /> Program Manager: Robert Wilbur (Kim Walden, Steve McClure)
Planned Start Date: 1/24/94 Planned Completion Date: 9/94 References (NRC/INPO/NUMARC/NAIT Etc.): OSTI Letter R. E. Wilbur to Senior Managers dated February 3,1994: Engineering Assessment G. Horn from V. Wolstenholm memo dated April 26,1994: Design Change Closeout Process, Evaluation QE9418.
==
Description:==
Conduct a reengineering study of the configuration control and design change process within the NPG. This will include, the design change process, as well as the technical issues / programs associated with the Design Change Pmcedure l
and the Maintenance Work Request Procedure. Also evaluate the design i
change closeout process for timeliness of the processes.
Objective:
To enhance the configuration control process and the design change methodology. The present system is not logically consistent and not all modifications are handled the same. NPG resources are not optimizea during the design change generation and review proceses. In addition, the DC close out process is not timely. Insulation materials configuration management l
needs to be upgraded.
Major Milestones:
Accomplishment Plan Date Actual Date 1.
Conduct an assessment of the 4/94 2/25/94 modification contml process related to the methods used to make changes to CNS.
l (REW-94-03.1) (K. Walden) 1
- 24. ]Bvaluate"th6Le#c6tiv~h
" ^ " ' "} ~ $
of ths configuration management contmll (REW-94-03.2) l REW-94-03
Program Enhancement-
' (REW-94-03 Continued)
Major Milestones (Cont.):
Accomplishment Plan Date Actual Date 2.
Conduct an evaluation of the 4/94 4/26/94 design change closure process.
j (REW-94-03.2) (S. McClure)
I 3.
Generate system insulation 5/94 l
cross-reference document.
l 4.
Based on the results of item 1 6/94 l
above, develop the necessary I
improvement program to generate the enhancements to ensure plant configuration is protected and the design change process is optimized.
(REW-94-03.3) (K. Walden) 5.
Based on the results of item 2 6/94 above, develop the necessary impmvement program to ensure a more responsive design change l
closure process. (REW-94-03.4)
(S. McClure) l 6.
Communicate procedumi and 9/94 management expectations to NPG personnel. (REW-94-03.5)
Updated Status:
1.
The reengineering process for the CNS configuration control of the design has progn:ssed thru the preliminary study stage. Industry input has also been obtained from the following utility programs, a)
Florida Power & Light d)
Toledo Edison b)
Baltimore Gas & Electric e)
Iowa Electric c)
Kansas Gas & Electric f)] jFiiluMPrsVintionIn6}
REW-94-03 (Cont.)
l
__A
Program Enhancement (REW-94-03 Continued)
Update Status (Cont.):
- 1. (Cont.)
In addition, the EPRI Engineering Change Optimization Study has been reviewed and the industry workshop was attended. This input is being combined with the information produced by the General Physics' study "Reengineering Assessment of the Cooper Nuclear Station Modification Control Program.
~ Discussions with utilities have indicated to us that additional time needs to be spent in the area of "is-mapping" and "should mapping" to further optimize resource utilization as previously recommended by our consultant. This needs to be done by District personnel with consultants as facilitators. However, success is highly dependent upon the quality and dedication of District resources.
2.
On January 31,1994, S. McClure was directed to generate a plan to evaluate the closure process for the Design Change Procedure by February 18, 1994.
j NED organized a self-assessment of the design change closcout process. A team was organized to collect required information. It was then decided to have QA use this task as their first assignment for their new Assessment Group. The NED data was turned over to QA which started the evaluation on March 22. The evaluation is now complete, and a report was transmitted to NED on April 26,1994.
Performance Indicator: The action plan generated in Milestone 5 will address this requirement.
3.
Although not a direct result of the study ofItem 1 above, work was directed to start on the generation of a reference document for insulation. The Configuration Management Department has generated a draft document that will provide a ready cross-reference of the system insulation requirements at CNS as well as reference any walkdown data that will be generated. This document will be referenced in the appropriate Design Change and maintenance procedures to provide craft and engineers a ready reference to insulation requirements. A completion date of Mapl 30,1994, has been set for the document.
Performance Indicator: This document will be reviewed and upgraded as necessary in accordance with the Design Basis Project Procedure NECDP-03, " Design Criteria Document Production."
REW-94-03 (Cont.)
[.,
I
~
Program Enhancement (REW-94-03 Continued)
Update Status (Cont.):
4.
Presently, a Modification Control Program Engineering Project Plan is being developed. The following preliminary project schedule has been developed.
Slatt Complete 1);
TObjectives/ Team Assignmentsi
~
15/23/94 2h
-:."Is": Mapping l q7/15/94 3)'
- Develop Concept Map 2 9/2/94 4)?
- Concept Map;Approvalj 49/16/94 5)!
?"Should" Mapping';
110/14/94 6).;[
TProgram Descripti6n Appsdalj (10/28/94, 7))
. Procedure l'ApprovalF
!!/6/95
- 8) '.
' Complete Training J
[l/20/95 9){
1: Implement New Process
[1/20/95 y
i This~scheduls will bi:ni6dified bised~sp65~theriessifsT6f the ConfiguratiotfLManagement Contml Studylin progress perl1s) atsps and thelavailability)f ths; critical Districtiegi6nn61lyeqUirsd. I6l-cany out.this; program?
- 5. ~ iTha evalsition of the' Design Change Clossost Process hsi bess;^E6inpletsd?'NED h6 received the report from QA and is developing anl action l piss to address [th6ll issues
~
identified.'
i i
i i
d l
l l
REW-94-03 (Cont.)
l 1
m i
k I
i i
1 i
- 1 SECTION VIII 4
l QUALITY ASSURANCE 3
i 4
1 i
i l
l l
f SECTION VIII QUALITY ASSURANCE I
Realizing CNS has not consistently identified or resolved recurring problems, the Quality Assurance Department (QA) is revising their self-assessment and auditing programs.
QA is also enhancing the trending program to more effectively support their assessment activities and keep NPG management aware of possible negative trends.
To address these issues, the following Integrated Enhancement Program tasks have been developed and are being implemented.
The tasks included in this section are Program Enhancements which provide a description of the task, the responsible manager, and the expected completion date.
r l
(
t L
I
)
I'
l Program Enhancement Priority:
RED Item No:
VLW-94-01 Title /
Description:
Revise the Self-Assessment Program Date Updated: 5/20/94 External Funding Requirements: Account #948-2007 $2400.00 (FPI Consultant)
Internal Resource Requirements: 3 weeks Program Manager: Verne Wolstenhol'm (D. R. Robinson)
Planned Start Date: 1/24/94 Planned Completion Date: 6/94 References (NRC/INPO/NUMARC/NAIT Etc.): SMM Inter-District Memo (CNSS931273), G. R. Horn to V. L. Wolstenholm
==
Description:==
SRAB recommended that the NPG Self-Assessment Program be converted to an NPG Directive.
The Vice-President, Nuclear requested that the Self-Assessment Program also address NRC Administrative Letter 94-03 " Announcing an NRC Inspection Procedum on Licensee Self-Assessment Programs l
for NRC Area-of-Emphasis Inspections."
Objective:
This task wr s established by the Vice President - Nuclear to address the l
concern that "self assessment activities were not always acceptable and will require additional management attention to assure that these activities provide management insight into the performance of the plant and the operating staff."
Major Milestones:
1.
Survey recognized industry leaders for informational input to the revised program.
2.
Obtain the services of a consultant to provide review, evaluation, and
~
recommendations for the program revision.
l 1
3.
Provide the draft revision of the program to NPG Senior Management for review and comment.
4.
Approval of the revised program.
5.
Convert the NPG Self-Assessment Program to an NPG Directive.
6.
Address NRC Administrative Letter 94-03 within the new NPG Directive.
VLW-94-01 l
)
1 C
J
Program Enhancement Major Milestones (VLW-94-01 Continued) 7.
Submit the new NPG Directive to the Program Control Department for approval and issuance.
8.
New NPG Directive approved and issued.
Accomplishment Plan Date Actual Date 1
1.
Complete industry survey (VLW-94-01.1) 1/94 1/21/94 2.
Consultant services (VLW-94-01.2) 2/94 2/17/94 3.
Issue draft revision (VLW-94-01.3) 2/94 1/31/94 4.
Program approval (VLW-94-01.4) 3/94 2/26/94 5.
Completed conversion of the Self-Assessment 4/94 4/30/94 Program to an NPG Directive and address NRC AL 94-03. (VLW-94-01.5) 6.
Submit the NPG Directive to the Program 4/94 4/30/94 Control Department. (VLW-94-01.6) 7.
NPG Directive approval and issuance.
6/94
(
(VLW-94-01.7)
Update Status:
Item 1):
completed plant visits to Waterford (1/20-21/94) and Clinton (1/18-19/94). Also obtained information fmm Yankee Atomic.
l Item 2):
Consultant services to review and comment on the revised Self Assessment Program has been acquired. Consultant review completed l
2/17/94, comments were reviewed with consultant and applicable comments were incorpomted.
I l
Item 3):
A DRAFT revision of the Self Assessment Program was issued to the Vice President - Nuclear, NPG Senior Management, and the Consultant for review and comment.
l l
Item 4):
Comments from Senior Management were reviewed, discussed, and
[
incorporated where appropriate. Revision 2 of the NPG Self-l Assessment Program was approved by the Vice-President - Nuclear on 2/26/94.
1 VLW-94-01 (Cont.)
)
Program Enhancement Update Status: VLW-94-01 (Continued) 5/10/94 NOTE:
1.
This item includes the OSTI item which stated self-assessments, root cause analysis etc. should be properly documented.
l i
t i'
t L
I L
f l
VLW-94-01 (Cont.)
l l
l Program Enhancement
(
Priority:
RED L
Item No:
VLW-94-02 Title /
Description:
Enhance the CAP Audits /QA Trend Report Date Updated: 5/20/94 External Funding Requirements: N/A
{
Internal Resource Requirements: 2 years for development Program Manager: Verne Wolstenholm/S. L. Bray (CAP)/P. K. Adelung (Trend) f L
Planned Start Date: 1/24/94 Planned Completion Date: 8/94
[
References (NRC/INPO/NUMARC/NAIT Etc.): 210 SPPI
==
Description:==
Revise the semi-annual audit of the Corrective Action Program to ensure that
(
it provides management with a clear insight as to the effectiveness of the Pmgnm.
I Upgrade the QA Trend Repon program to provide a simplified format which provides a thorough analysis of trend information.
(
Objective:
This task was established to address concerns raised in various internal and external evaluation and inspection reports regarding the effectiveness of the r
Corrective Action Effectiveness Audit and the effectiveness of the analysis L
provided by the Quarterly Trend Report, e
MMor Milestones:
L 1.
Provide additional information and parameters needed to support the Trend Program p
for inclusion in the new CAP.
L 2.
Survey / visit recognized industry leaders for input to the revised CAP Audit and obtain associated CAP Audits from those utilities.
3.
Establish a " Functional / Program Area" and " System" Performance Panel display format within the Trend Report.
L 4.
Develop and revise associated NQPs, QAIs, and QA Guidelines for the Trend Report after implementation of the new CAP.
5.
Provide the DRAFT revision of the CAP Audit Plan and checklist to QA management
[
for review.
6.
Approve the revised CAP Audit Plan and checklist.
l VLW-94-02 l
l lw
.a
Program Enhancement Major Milestones: (VLW-94-02 Continued) 7.
Modify the QA Trend Report format by Issuance of the Second Quaner 1994 QA Trend.
(.
Accomplishment Plan Date Actual Date 1.
Provide additional information and 2/94 11/93 parameters for new CAP. (Trend report)
(VLW-94-02.1) 2.
Survey / visit other utilities CAP audits.
3/94 3/31/94 (VLW-94-02.2) 3.
Establish panei display for Trend Repon.
4/94 4/30/94 (VLW-94-02.3) 4.
Develop / revise NQPs, QAIs & QA Guidelines 6/94 l
for trend reponing with new CAP.
(VLW-94-02.4) 5.
Draft CAP QA Audit Plan and checklist.
5/94 4/30/94 (VLW-94-02.5)
(
6.
Approve CAP QA Audit Plan and checklist.
5/94 (VLW-94-02.6)
[
7.
Incorporate format modifications in 2nd 8/94 Quaner 1994 Trend Repon. (VLW-94-02.7)
F Update Status:
Item #1:
Proposed trend parameters and data base for the new CAP was submitted to the Technical Staff Manager on 11/03/93.
L Item #2:
Selected and scheduled visits to three 3 utilities, e
Comanche Peak, Fon Calhoun, and Calloway in March,1994. Completed 3/18/94.
5/10/94 Item #3:
Identified in NQP 2.4 Item #4:
NQP 2.4 approved - QA Guideline 1.1 revision will be completed 6/94.
VLW-94-02 (Cont.)
1
Program Enhancement Priority:
RED Item No:
VLW-94-03 Title /
Description:
Establishment of QA Assessment / Evaluation Date Updated: 5/20/94 Program External Funding Requirements: N/A Internal Resource Requirements: 1 year for development Program Manager: Verne Wolstenholm (D. R. Robinson)
Planned Stad Date: 1/24/94 Planned Completion Date: 1/95 References (NRC/INPO/NUMARC/NAIT Etc.): SelfImposed -
==
Description:==
Establish a Quality Assessment Group which will enhance the Division's ability to provide effective proactive oversight of Nuclear Power Group activities and provide timely and effective feedback to senior NPG management on applicability of emerging industry issues and regulatory concerns, in addition to feedback on NPG activities.
Objective:
This Task was established as a result of concerns raised in several NRC inspection reports issued in 1993 as well as the QA Division's recognition that
(
some of the Division's resources were not being utilized effectively.
Major Milestones:
1.
Reorganize the Quality Assurance Division to provide the resources necessary to establish the assessment group.
2.'
Relocate personnel assigned to the assessment group to CNS.
3.
Develop a Nuclear Quality Procedure which defines the Assessment Group's functions and responsibilities.
4.
Identify training needs for the Assessment Group and submit training work request.
5.
Complete training for all members of the Assessment Group.
6.
Identify and develop supporting instmetions/ guidelines needed to support the activities of the Assessment Group.
7.
Arrange for an independent assessment of the Assessment Ginup's effectiveness.
VLW-93-03
[
l
Program Enhancement (VLW-94-03 Continued)
Accomplishment Plan Date Actual Date 1.
Reorganize QA Division. (VLW-94-03.1) 10/93 10/16/93 2.
Relocate QA Assessment Group to CNS.
2/94 12/31/93 (VLW-94-03.2) 3.
Develop Nuclear Quality Procedure.
2/94 11/30/93 (VLW-94-03.3) 4.
Identify training needs & submit TWRs.
2/94 10/93 (VLW-94-03.4) 5.
Complete Assessment Group training.
9/94 (VLW-94-03.5) 6.
Identify & develop instmetions/ guidelines.
6/94 (30/94 (VLW-94-03.6) 7.
Arrange for independent assessment.
1/95 (VLW-94-03.7)
Update Status:
Item 1):
A proposed QA Division reorganization plan was submitted to the Vice Pmsident - Nuclear and approved.
Item 2):
The Quality Assurance Assessment Group completed relocation from the G.O. to CNS.
Item 3):
Nuclear Quality Procedure 2.3, " Quality Assessments / Evaluations", has been approved and issued.
Item 4):
Training Work Requests have been initiated for the following training: Technical Staff; Root Cause Analysis (from INPO); Human Performance Evaluation (from INPO); and Problem Solving and Decision Making (TWRs 93-1000,93-1001, and 93-1002).
Item 5):
The Assessment Group training is not complete, however they have sufficient training to be functional. Root Cause Analysis Training completed 4/94. KT Training scheduled for 6/94. Adsnced %sditTschnligssTjilping is sshedsled foiJsne%2A1924i VLW-94-03 (Cont.)
Program Enhancement VLW-94-03 (Continued)
Item 6):
One guideline is currently under development to describe generally how assessments and evaluations are to be conducted (Completed 2/94). Another is being initiateu to describe how externally generated documents will be screened for their applicability to Assessment Group activitim. Additional reviews are being conducted to determine if other guidelines an: needed. Guidelines completed 4/94.
[
[
f L
[
[
[
[
f 1
t VLW-94-03 (Cont.)
r l
l N_____________-_____-_______________________
Program Enhancement Priority: -
RED-Item No:
VLW-94-04 Title /
Description:
Upgrade the Intemal Audit and Date Updated: 5/20/94 Surveillance Program (Frequency & Scope)
External Funding Requirements: _N/A Internal Resource Requirements: 2 years for development Program Manager: Verne Wolstenholm (G. E. Smith)
Planned Start Date: 1/24/94 Planned Completion Date: 12/95 References (NRC/INPO/NUMARC/NAIT Etc.): SelfImposed
==
Description:==
The existing internal audit program requires restmeturing in light of QA's recent clarification of QA Program Audit Fmquency Requirements as described in the CNS QA Program for Operation Policy Document and CNS Technical Specifications. (Reference G. E. Smith to SRAB Chairman memo
. and attached 10CFR50.59 Reportability Review, dated September 8,1993.)
Revision of the QA surveillance Program to coincide with the objectives of the audit program.
Objective:
The purpose of this project is to upgrade the QA audit and surveillance programs to provide scoping of audits and surveillance which focus on specific
(
technical programs or activities of concern / declining performance.
Major Milestones:
1.
Identify activities that are to be subject to QA audit / surveillance.
2.
Generate a Position Paper which describes the District's position on conducting internal audits.
3.
Revise QAI-5 to mflect the new audit process.
4.
Generate a grouping of activities for audit scoping.
5.
Revise QAI-4 to reflect the new surveillance progam.
)
F NOTE: QAI-4 is being converted to NQP.
L 6.
Revise the QA Guidelines to describe the new approach to conducting audits.
)
VLW-94-04 t
i L
Program Enhancement M40r Milestones: (VLW-94-04 Continued).
7.
Develop new QA Audit Plans.
8.
Train auditors on the new approach to auditing.
9.
Train auditors on the objectives and performance expectations of the new surveillance program.
10.
Complete revision / development of surveillance checklist.
I1.
Complete development of Audit Scoping Plans.
Accomplishment Plan Date Actual Date 1.
Activities subject to QA audits / surveillance.
11/93 11/23/93 (VLW-94-04.1) 2.
Generate intemal audit Position Paper.
12/93 12/22/93 (VLW-94-04.2)
. 3.
Revise QAI to reflect the new audit process.
1/94 1/14/94 (VLW-94-04.3) 4.
Grouping of activities. (VLW-94-04.4) 11/93 11/23/93 h
5.
Revise QAI to reflect the surveillance process.
5/94 5/19/ 8 (VLW-94-04.5)
NOTE: This QAI is being converted to NQP.
~ 6.
Revise the QA Guidelines for auditing.
5/94 5.~/19/_94
-7.
Develop new QAPs. (VLW-94-04.7) 5/94 5[19/$
8.
Train Auditors (audits). (VLW-94-04.8) 6/94 9.
[
Train Auditors (surveillance). (VLW-94-04.9) 6/94 10.
Complete surveillance checklist. (VLW-94-04.10) 12/95 11.
Complete audit scoping plans. (VLW-94-04.11) 12/95 I
l 1
VLW-94-04 (Cont.)
Program Enhancement VLW-94-04 (Continued)
Update Status:
Item 1):
Activities subject to QA audits / surveillance have been identified and the 1994 audit schedule has been issued.
Item 2):
Audit Requirements / Frequencies position paper has been developed and distributed.
Item 3):
QAI-5 has been revised to mflect the new audit process.
QAI-5 being converted to NQP 2.0 which is out for revision. Complsied 5/94j Item 4):
Activities have been grouped for audit scoping.
Item 5):
QAI-4 is being converted to NQP. Change to 5/94 completion NQP 2.6 out for comment. Coinpleted;5/94)
(
Item 6):
Audit guidelines drafted and out of review.
Completed 5/94;
(
Item 7):
A total of five QAPs are being developed. As of 2/8/94 two of the QAPs have been completed and approved. A thirti is ready for review, one is in writing and the fifth
[
one has not been initiated. 4/94 four QAP's approved and the fifth one is in review.
(
Item 8 & 9): Scheduling training for.iune;;1-2E1994l I
(
(
I f
f L
VLW-94-04 (Cont.)
l-
[
- P "!O UNITED STATES
/
- g NUCLEAR REGULATORY COMMISSION
{
REGION IV k,
611 RYAN PLAZA DRIVE, SUITE 400 n
ARLINGTON, TEXAS 76011-8064 ATTACHMENT A REGION IV INSPECTION SCHEDULE FACILITY:
CNS REPORT NUMBER:
94-14 START DATE:
6/13/94 LEAD INSPECTOR:
Chuck Paulk ORG CODE:
4610 ACCOMPANYING INSPECTORS:
P. Goldberg, W. McNeill, George Cha (Consultant)
MODULES TO BE PERFORMED 37550 MODULE IPE CODE CURRENT APPROVED PLANNED ESTIMATED (00/RI/RR STATUS IN HOURS HOURS AF/0A/RT (N/M/P MIP ON TO ST/HT/SI)
R/C)
(Y/N)
MIP COMPLETE 37550 RR N
N 0
35 37550 C0 N
Y 180 180 OPEN ITEMS TO BE REVIEWED:
RESIDENT INSPECTOR NOTIFIED:
Y X N
LEAD INSPECTOR:
Chuck Paulk DATE:
6/10/94 INSPECTOR'S BRANCH CHIEF:
T.F. Westerman DATE:
6/09/94 DRP BRANCH CHIEF:
Phil Harrell DATE:
INSPECTION ANN 0UNCED:
YX N
WHEN6/9/94 BY WHOM T. Westerman A 7
s.
y-INSPECTION PLAN INSPECTION PROCEDURE 37550 CNS ENGINEERING Using the guidance provided in IP 37550, select the following:
FIVE SIGNIFICANT SAFETY-RELATED DESIGN CHANGES / MODIFICATIONS DURING LAST RF0 OR NEXT RF0 FIVE SAFETY-SIGNIFICANT TEMPORARY MODIFICATIONS NONCONFORMANCES OR DEFICIENCIES (E.G. CRs, DRs, MATERIAL NCRs) DURING PAST YEAR AUDITS AND SELF-ASSESSMENTS PERFORMED ON THE EDG SYSTEM Evaluate the effectiveness of the licensee's engineering staff to support plant operations based on the above items.
Perform a sampling of the following to evaluate the licensee's engineering capabilities:
CRs WRITTEN AGAINST DESIGN / SYSTEM ENGINEERING PRODUCTS FOR LAST 2 YRS o
DOCUMENTS THAT HAVE HAD DESIGN / SYSTEM ENGINEERING INPUTS (I.E. CRs, DRs, NCRs, WRs) FOR LAST 2 YRS DATA ASSOCIATED W/ PRIMARY SRVs, MSSRVs PROCEDURES FOR TESTING SAFETY / RELIEF VLVS SYSTEM REPORT CARDS Inspector Assignments:
Paula Goldberg:
Select one safety-related design change / plant modification.
Evaluate in accordance with Section 03.01a. through o.
Select one safety-related temporary modification.
Evaluate in accordance with Section 03.02a. through j.
Evaluate the SRVs and MSSVs using Section 03.04a. through c.
as guidance.
Evaluate containment penetration designs and testing, old designs, etc.
Review licensee actions related to penetration issues.
\\
Bill McNeill:
Select one. safety-related design change / plant modification.
Evaluate in accordance with Section 03.01a. through o.
Select one safety-related temporary modification.
Evaluate in accordance with Section 03.02a. through j.
Evaluate audits / assessments of EDG system.
Evaluate system engineering.
Chuck Paulk:
Select one safety-related design change / plant modification.
Evaluate in accordance with Section 03.01a. through o.
Select one safety-related temporary modification.
Evaluate in accordance with Section 03.02a. through j.
Evaluate the electrical and I&C portion of the EDG DBD.
Verify design basis requirements have been adequately translated into procedures.
)
George Cha:
Review design basis documents.
Review containment penetration design and testing, review old modifications.
All:
Review selected corrective action documents for engineering capabilities.
! 1.
@vnh O,,y
/
NEBRASKA Pusuc POWER DISTRICT AQD940ll7 Dati June 24.1994 To V. L Wolsti lolm FOR INTER-DISTRICT BUSINESS ONLY From D. R. Robinson /S. L Brav i
subject Culture Index Evaluation As part of-the Corrective Action Program Audit, the' Quality Assessment Department conducted a survey of a limited sample of Nuclear Power Group (NPG) personnel utilizing the Culture Index concept developed by Failure Prevention, Inc (FPI). The purpose of this survey was to determine how the Nuclear Power Group performance culture compares to the industry and to utilize the information gained as an indicator of improving or declining performance.
Based on the results of this activity, it appears that the Nuclear Power Group culture is relatively healthy. This conclusion is based on a comparison of data obtained in our survey, which established the Nuclear Power Group average Culture Indicator (CI) at 10.4 to data compiled by FPI which established the average CI for United States Nuclear Power Plants at i
9.5 (1991 data). As a point of reference, the 1991 CI for top performers was 14-16, while the CI for problem plants was 6.7.
It must be recognized that the NPPD data must be qualified by two factors. First, the sample size for this survey was forty-five individuals selected from six departments in the Nuclear Power Group. Secondly, this is only the second data point obtained utilizing this survey tool.
The results do compare favorably with results obtained by FPI personnel during a Root Cause Training class conducted in March of this year. That group, composed of approximately thirty individuals from all areas of the Nuclear Power Group, established an average indicator of 11.3. It should also be noted that the accuracy of these average indicators is assumed to be 1.0.
In analyzing the responses received from this survey two areas appear to be of concern to NPG personnel.
The overall averages show that Work Process and Self Improvement activities fell below the 2.0 rating, which has been selected as the indicator point for areas that may need attention.
The scope of this survey was limited to the collection and analysis of data. Future surveys will involve follow-up interviews that will attempt to develop additional information regarding specific concerns of the personnel responding to the survey. This will be accomplished by combining the use of the CI Worksheet with the culture interviews we have been conducting.
Please note that we feel that the effectiveness of these tools could be diluted if performed too frequently. It is our opinion that the schedule for these activities be established at once per quarter.
A,>b
[h m g & 4 w w~,
x m.
2 he Gb ;Powejful! Pride intNebisski m:
g
u i
4 C.
V. L. Wolstentiolm June 24,1994 Page 2 of 2
~
- Should you have any questions or comments regarding this matter, please advise us.
u D. R. Robinson S. L. Bray 7
Quality Assessment Manager Quality Assessment Supervisor
- Cooper Nuclear Station Cooper Nuclear Station -
DRR:SLB:mrc Attachments l
> vgsr
> ce y;,
<s 3 o g,g, g g,,,- D ;; A A ' ; W M A t h e li n <
' ' ~
- -, ' ~
y or m g,:
gg;p
-:r-r_
f _,.:
.:. gen
<f
e o
Page 1 of 2 CULTURE INDEX WORKSIIEET 1
INSTRUCTION 1
Please rate each of the following areas by circling the number beside the description which you feel best describes the Nuclear Power Group.
l' YOUR DEPARTMENT AREA RATING KN k dDOB AkD SKILL 5 M N[fbhNhhfkkik h $[hfb A *$Idhk[Ekh bd-k[h All personnel involved know the work process, have the 4
skills to perform the work, and are experienced in the assigned work.
All personnel involved have the skills to perform the work 3
and are experienced in the assigned work.
All personnel involved have the skills to perform the work.
2 Some of the involved personnel have the skills to perform 1
the work.
None of the people involved have the skills to perform the 0
work.
(NORK PROCESSES)
\\
^
S M
The work processes are streamlined with strong 4
interorganizational interfaces. The resources are more than enough to support the work processes.
The work processes contain many unnecessary steps and 3
reviews.
The number of organizational interfaces is low.
The level of complexity matches the existing resources.
The work processes are complex. The level of complexity 2
matches the existing resources.
The level of complexity of all major work processes exceeds 1
what can be supported by the existing resources.
The complexity of the processes makes them unworkable.
O
~
^
MISSION AND"OOALSh s
Mission statements are used to prioritize work and goals are 4
set to achieve incremental improvements at all levels of management.
-Short term goals are used for all groups. Mission 3
statements are used to prioritize work for some groups.
Short term goals are specified for some groups.
No mission 2
statements are used to prioritize the work.
No corporate, plant, division, or department Mission and 1
Goals exist.
Page 2 of 2
^
[LhTERAL INTEGRATION-Permanent work processes and program managers are assigned.
4 Task forces and team coordinators are routinely used to deal with multi-department special issues and tasks.
Permanent program managers are assigned. Task forces and 3
team coordinators are used for special issues.
Some program managers are assigned. Some task forces and 2
team coordinators are used for special programs and tasks.
Few work. process and program mangers are assigned.
Few task 1
forces and team coordinators are used.
No work process and program mangers are assigned. No task O
forces and team coordinators are used. *.
en y;; myp
. aw x>'
., uppgmg;9p" -
p>
rr gg SELF.. T MPROVEMENT ',.., :#3 >
% dC 3 ei
g
- J 4; strong equipment, human error, and 4
Organizational / Programmatic root cause programs exist which are supported with adequate resources and training.
Strong equipment and human error root cause programs exist 3
which are supported with adequate resources and training.
An equipment root cause program exists without adequate 2
resources. An adequate human performance root cause program exists.
No equipment root cause program exists.
The human 1
performance root cause program is sketchy.
No human performance root cause program exists.
O i
l 1
i l
i I
4
,....... -.. ~. ~. -.
l l
Plant Engineering Department 1
2 3
4 5
6 7
8 9
10 11 Ave.
Total
=::=":,"'
i
- i if l
"!:"""e A
age 2.
2.
1.
2.
1.
O.
2.
1.
1.
1.
2.
20 i
l E Knowledge and Suls Plant Engineering Department 4.
O Lateralintegracion E senkreovement 3.5 --
E Average j
j
Training Knowledge and Skills 3
1 3
2 3
3 3
2.6 0
d lS 2
2 PJ0'"l"!"
'i ll C':"'
'd d 's A A 'd d
, l "A
i E Knowledge and skus I
E Vork Processes E Mssion andGoals 4 __
O Latefalintegration 3.5 E Average
,s
Maintenance 1
2 3
4 5
6 7
8 9
10 11 12 13 Ave.
Total l
Knowledge and Skills 1
2 2
3 3
3 3
2 2
3 2
2 3
2.4 31 s on a d als 2
3 3
2 2
2 3
re I"
^:"T"
'd 4 'd 4 *d 'l '11 *d '1 'd "i "'s i
l E-.
l 1.
E seuimptovement 3 5 --
5 Average
I i
l i-i i,
4 Utility Department 1
2 3
4 Ave.
Total l
Knowledge and Skills 3
3 1
3 2.5 10 l
Work Processes 2
3 2
3 2.5 10 Mission and Goals 3
3 3
3 3.0 12 l
Lateralintegration 3
4 2
3 3.0 12 i
Selfimprovement 3
3 3
3 3.0 12 l
' Average.
2.8 3.2 2.2 3.0 2.8 11.2 j
Total 14 16 11 15 14.0 56 i
l
(
E Knowledge and Skies Utility Department i
E Msskm and Goals i
4..
O Lated wegrmke l
E ser herovement 3.5 - -
E Average 1
3--
i g
=-
[
h -i dj 7Qi k-]
1 I-2.5 -
4 p! f... ;,;
.9; :. 0 m
1
- n pp s
.8 2-L i
1.5 -
q 1-0.5 -
~~
-~
i O'
{
~
~-
1 3
4
- Ave, i
i l
i
f l
I&C 4
1 2
3 4
5 6
7 Ave.
Total
. Knowledge and Skills 2
1 1
2 1
1 2
1A 10 Work Processes 2
0 0
1 0
2 3
1.1 8
Mission and Goals 2
2 2
2 2
2 3
2.1 15 Lateralintegration 2
1 1
1 1
2 2
1A 10 i
Selfimprovement 2
2 2
2 2
2-3 2.1 15 l
Average 2.0 1.2 1.2 1.6 1.2 1.8 2.6 1.7 11.6 j
Total 10 6
6 8
6 9
13 8.3 58 1
l E - - -..
E VorkProcesses gg l
E Mission and Goals -
4 __
O Lueralintegration 5 salmprovernent 3.5 --
E Average 3--
l 2.5 --
1 i
j i
1-2 3
4 5
6 7'
Ave.
I
l' i
Quality Assurance l
1 2
3 Ave.
Total Knowledge and Skills 3
1 2
1.5 6
Work Processes 3
1 2
1.5 6
l Mission and Goals 2
2 3
1.8 7
l Laterallntegration 2
2 3
1.8 7
i SelfImprovement 2
1 2
1.3 5
Average 2.4 1.4 2.4 1.6 6.2 l
Total '
12 7 12' 7.8 31 i
I~
l E Knowledge and Skms E V rk Processes u mlity Assurance E MssionandGoals j
4 O Leeratintegreion E Sdirrprovement 3.5 -..
E Average 1
3 25 --
E 1
2--
1 1.5 -
1-t i
j 0.5 '--
l 0-t i
1 1
2 3
Ave.
)
i l
i a
l Overall Averages
)
i j
Plant Engineering 9.4 Maintenance 11.1 Utility Department 14.0
!&C 8.3 -
Training '
11.7 j
OualityAssurance 7.8 j
Average 10.4 i
Total 62.3 j
1 1
I Overall Averages 4
14.0 --
l 12.0 --
- N 10 0 -
80 -
~
~
60 -
(
4.0 -
2.0 --
0.0 l
1 1
I I
I i
l r
8 i
s e
s a
a e
- =
s e
=
c v
g
- 5 O.
A e
i a-I c
l 0
5 6
---e
Overall Average By Categmy Knowledge and Skills 2.1 Work Processes
- 1.7 Mission and Goals 2.6 Laterallntegration 2.2 SelfImprovement 1.9 i
Overall Average By Category t
4.0 -
3.5 --
f 30 --
2.5 t
_e
.5 -
0.0 l
i I
i
--- i l
l Knowledge Work Mission and Lateral Self i
and Skills Processes Goals integration improvement l
L i
?
.]
Plant Engineering Department Total Average Knowledge and Skills 2
3 1
4 1
1 4
1 1
1 4
23 2.1 Work Processes 1
1 1
0 1
1 3
0 1
1 1
11 1.0 Mission and Goals 3
3 3
3 3
1 3
2 2
3 3
29 2.6 Lateral Intergration 2
2 3
4 2
1 2
2 2
2 3
25 2.3 Self improvement 2
2 1
2 1
0 1
1 2
1 2
15 1.4 Total 10 11 9
13 8
4 13 6
8 8
13 103 9.4 Average 2
2.2 1.8 2.6 1.6 0.8 2.6 1.2 1.6 1.6 2.6 20.6 1.9 Maintenance Total Average Knowledge and Skills 1
2 2
3 3
3 3
2 2
3 2
2 3
31 2.4 Work Processes 2
3 1
1 3
3 3
3 0
1 2
3 3
28 2.2 Mission and Goals 2
3 3
2 2
4 2
3 3
3 4
1 3
35 2.7 Lateral Intergration 1
2 2
2 2
1 3
2 2
2 3
1 3
26 2.0 Self improvement 3
1 1
3 3
1 2
2 2
2 3
0 1
24 1.8 Total 9
11 9
11 13 12 13 12 9
11 14 7
13 144 11.1 Average 1.8 2.2 1.8 2.2 2.6 2.4 2.6 2.4 1.8 2.2 2.8 1.4 2.6 28.8 2.6 Utility Department Total Average Knowledge and Skills 3
3 1
3 10 2.5 Work Processes 2
3 2
3 10 2.5 Mission and Goals 3
3 3
3 12 3
Lateral Intergration 3
4 2
3 12 3
Selfimprovement 3
3 3
3 12 3
Tot;l 14 16 11 15 56 14 Average 2.8 3.2 2.2 3
11.2 2.8 l
i Page 1
.y.
~
i h
b IGC b
Total Average Knowledge and Skills.
2 1
1 2
1 1
2 10 1.4 Work Processes 2
0 0
1 0
2 3
8 1.1 Mission and Goals 2
2 2
2 2
2 3
15 2.1 Lateral Intergration 2
1 1
1 1
2 2
10 1.4 Self Improvement 2
2-2 2
2 2
3 13 1.9
- Total -
10 6
6 8
6 9
13 58 Average 2
1.2 1.2 1.6 1.2 1.8 2.6 11.6 1.7 Training Total Average Knowledge and Skills 3
1 3
2 3
3 3
18 2.6 Work Processes 1
2 2
2 2
3 1
13 1.9 Mission and Goals 4
3 4
3 2
3 2
21 3.0 Lateral Integration 3
2 3
2 3
2 3
18 2.6 Self improvement 2
2 3
2 2
0 1
12 1.7 Total 13 10 15 11 12 11 10 82 Average 2.6 2
3 2.2 2.4 2.2 2 16.4 2.3 Qurlity Assurance Total Average Knowledge and Skills 3
1 2
6 2.0 Work Processes 3
1 2
6
, 2.0 Mission and Goals 2
2 3
7 2.3 Lateral Integration 2
2 3
7 2.3 Self Improvement 2
1 2
5 1.7 Tot:_I 12 7
12 31 Average 2.4 1.4 2.4 6.2 2.1 i
Page 2
7 s?j?a 34 13:43
'3402 $25 5640 f.00PER N13. STATN
@ 001 Oc N:
\\
[1 l
H Nebraska Public Power District cocewuca4a su P.O. 00X sa. 8MoWNVE15. PEWASKA
- Y==W,""
NL8940001 Post-lt' brand fax transmmal memo 7671
- sia9" '
Jdy2a p', }4 4
j 'ff la llt yg
}
UlI x.ik
.y o
. IL llf -
,; pmma lp si II
{
'., li '
1, TT.~l.' i t llf f"h p,
. ' h' j h '
g, G[!
h, i h.
f
h '
b.
f
(
j Suite 400 l
Arlington, Texas 76011 s
1 1 - --.i s j e d : -
Respan.le to *Confirmatcry Action Letter Cooper Nuclear Staticn i
NRC Docket No. 50-238 l
l l
References:
(1)
Confirmatory Action Letter (Revision 0) Dated May 27, 1994, to j
Guy R. Horn - Nebraska Public Power District (CAL 4-94-06).
(2)
Confirmatory Action Letter (Revision 1) Cated June 16, 1994, I
to Guy R.
Horn Nebraska Public Power District
( CAL 4 06 A) l (3)
Confirmatory Action Letter (Revision 2) Dated July 1, 1994, to Guy R. Horn - Nebraska Public Power District (CAL 4-94-06B)
{
Dear Mr. Callan:
l l
References (1l, (2), and
(*)
- cnfirmed Nebraska Pu.bl;. c Power District's tthe i
District's) ccmmitment te addrees four items prior to restart of the Cooper f
Nuclear Station (CNS)
Several technical meetings already have been held which j
addressed NRC concerns described ir tne Confirmatory Action Letter ICAL) Items 1,
2, 3, and 4.
'"hese items involved: 1) as-f ound testing of 4160- and 400-volt j
undervoltage devices: 2) the design basis for surveillance acceptance criteria j
for the Control Room and Turbine Building Ventilat1Cn Systems; 3) primary j
containment penetration diocrepancies;
- and, 4) electrical distribution j
surveillance testing and inservice inspection of penetration welds.
An i
additional meeting will be held in NRO Headquarters office to review
- 1) the
{
conclusions discussed during the f our technical meetinge noted above 2) actions
]
taken to resolve the noted issues; and, 3) the basis for District management's i
conclusion that CNS is ready for restart.
That meeting has been scheduled for July 29, 1994, at 9:00 a.m.
j CAL Item 5 required the District, prior to plant restart, to provide the NRC.
mession IV office with a letter discussing eight areas of NRC interest.
The
}
attached discussion responds to *his NRC request.
However, limiting this 8
response to just answering NRC questions would not fully capture the extensive j
ef forts that the District has expended to addreS3 not Cnly NRC issues, but also 1
issues that CNS management has determined must be resolved prior to plant i
startup.
During this shutdown, CIS has assessed several areas of Technical j
~
specification interpretation, system design basis requirements, maintenance 1
b d
h[
~
Roweriui Pride i.;.*e'2Draska l
1 NL8940001 July 28, 1994 c
Page 2 practices, and management oversight, Additionally, several CNS ef forts resulted in eastension of the shutdown period because District management took a careful and conservative approach to resolving these emerging issues.
Region IV management has been kept apprised of the District's actions.
The Dis trict.'s
- findings, while having a negative connotation regarding i
camellance, also have a positive side.
Recent findings are in great part a l
result of management ef forts to improve the questioning attitude of personnel and
- afement's commitment to resolving emerging issues.
CNS culture improvement initiatives to identify and fix problems correctly the first time are working.
New management has brought to CNS fresh ideas and higher standards for problem identification and resolution.
Issues are being raised and resolved which, in past years, may have been placed at a lower priority. District management firmly believes that these initiatives will result in suetained improvement for the long
_ _ _ _ _ _. M*'m,,,23A J11sprigLWJ.J.. continpe to monitor the effectiveness of performance._
inyrovement of forta to ensure that desired results are being achieved. The NRC will be kept informed of the progress of performance improvement efforts.
If there are any questions about the information presented in the attachment, or
'on other matters, please call, si rely h
G
. Horn Vi resident, Nuclear
/nr Attachment cc:
U.S. Nuclear Regulatory Commission Attenticn:
Document Control Oesk NRC Residant Inspector Office Cooper Nuclear Station NPG Distribution
g
-A-.
Msa940001 July 28, 1994 At' h nt f ne enAir t ion CAA, 4-94-06B, :' tam 5, required that prior to restart, the District provide Region IV with a letter that discusses the following:
(a) the root cause(s) for defeating the undervoltage trip function in the Motor Control Center N supply breaker; (b) the actions taken to confirm the design basis for the Control Room and Turbine Building Ventilation Systems (c) the results of air testing that was performed for the issues discussed in Items 1, 2,
and 3 of the CAL;
'e!
--'r-,
ri f "derr--of.41L4cff-normal cr discrepan.cnnai tions.,in ~ -..
Items 1,
2, 3,
and 4 of the CAL; (e) the corrective actions that will be taken to prevent recurrence of the installation of devicea (i.e.,
cable ties, jumpers, blocks, etc.) that will prevent the actuation of safety system functions and to ensure that the design basis surveillance testing criteria are established and maintained for the facility; (f) the lessons learned by CNS staf f in response to the incident involving the undervoltage trip function in the motor control center supply breakers, including the lack of prompt recogniticn of the potential safety significance; (g) the basis for the District's determinatier that the testing programs for Electrical Distributton System surveillance testing and inservice inspection of penetration welds are technically adequate and complete; 4
- and, (h) the basis for the District's acaurance that the testing programs for other licensed activities are adequately implemented.
Bach of these CAL issueo are addressed in this attachment.
Where appropriate, tbs utstrict also has addressed previously engoing activities that are responsive to umC concerns and additional issues that have emergod as a result of initial problem investigations.
Page 1 of 19
3 MLSS40001 July 28, 1994 Attachment CAA,4-94-06b I--
5 (a)
"Diacuss the root cause(s) for defeating the undervoltage trip function in the Motor Control Center N supply breaker. "
M Eggmamae On May 16, 1994, a cable tie was found installed on the undervoltage trip device for the 400-volt !aeder breaker to MCC-N.
Its installation defeated this undervoltage trip device which was installed to isolate (shed) its load in the event of Loss of off site Power.
The root cause of the event is the failure of management to ensure that -^
- Me configuration. control wara_not adequately._. imp.lementad..
t into the maintenance procedure.
Maintenance procedures must have appropriate configuration control elements.
Management's expectations must be clearly communicated and ef fected through the procedurw review and approval process. While procedure content guidance existed regarding this issue, it was not well expressed.
Strong, clear management expectations regarding its inclusion in maintenance procedures was not provided.
The immediate cause of the loss of configuration control was found to be an inadequate maintenance procedure.
The procedure allowed installation of a cable tie, but did not provide specific guidance to remove, or verify removal, of the cable tie.
While not the root cause, post-maintenance testing and surveillance tests both failed to identify that the cable tie was still installed and that the breaker could not perform its intended safety function.
Human error also was involved.
However, it wao only a symptom and not the root cause.
CAL 4-74-06b T'-
5 (b) r
- Discuss the actions taken to confirm the deargn basis for the Control Room and Turbine Building Ventilation Systems."
WWW 4eamense The District has reviewed several hundred documents to verify the design basis for the Control Room and Turbine Building Ventilation Systems.
These documents span nearly 30 years, beginning with pre-construction in the mid 196 0 's, through the present.
The documents reviewed included General Electric plant design criteria; Burns and Roe calculations, system descriptions and correspondence; pre-operaticnal test procedures and test results; the FSAR and related amendments, questions and answers; the SER; the USAR; correspondence with the NRC; internal NPPD correspondence; test procedures, design changes and supporting calculations.
The results of our review are as follows:
Page 2 of 19
Ed M0001 July 28i 1994 ALta m nt Q ggrol' Room Ventilation System Desion Saa_1.1 The Control. Room Ventilation System design basis ist a)
Provide temperature and humidity control and air movement for personnel comfort and optimum equipment performance.
b)
Provide sufficient filtered fresh air supply for personnel, c)
Minimize the possibil;;y of exhaust air recirculation into the air
- intake, d)
Provide for operator protection in the event of a Design Basis Accident by providing filtered air and maintaining the Control Room
-- ---' ^^- *.A.. pons.tive. pressure, wis,h respect to _adja_copt., areas....
This function is performed by the Control Room Emergency Filter Dose calculatiens assume a positive pressure in the Control System.
Room Envelope; however, no specific value of pressure is assumed for use in the calculations,
Dose calculations assume 10 CFM of unfiltered inleakage in accordance with guidance furnished by Murphy and Campe in a paper titled, " Nuclear Power Plant Control Room Ventilation system Design for Meeting General Criterien 19."
The Control Room Ver.tilation System is not designed to automatically respond to toxic gas events; rather, operatore don self Contained Breathing Apparatus (SCBA) and manually secure the outside air supply to the Control Room.
The administrative, operability, and surveillance requirements for the i
Control Room Emergency Filter System were discussed during a meeting
{
between NPPD and NRC cn July 7, 1994, and c0nfirmed in a letter to the Imc i
from G.
R.
Horn, dated July 20, 1994.
Turbine Buildine Ventilation Avstem Desien Basis The Turbine Building Ventilation System derign basis is a)
Provide temperature centrol and air movement for personnel comfort and optimum equipment performance.
j b)
Provide sufficient filtared fresh air supply for personnel.
c)
Provide for air movement from lesser to progressively greater areas of radioactive centamination potencial prior to final exhaust.
di Minimize the possibility of exhaust air recirculation into the air
- intake, e)~
Accommodate effluent monitoring capability.
)
Page 3 of 19
MAD 4000$
j July 20, 1994 Attactement CM, 4 94 - 0 8b P-5 (c)1
" Discuss che resulcs of all cescing thac was performed for the issue discussed in Item 1 of che CM,:
4160-volt undervolcage relay logic and 480-volc undervolcage devices i
(as-found)."
E,. M e 4160-Volt Tes tinct l
As-found testing
- f the 4160-volt undervoltage devices for electrical
- y..f som~ the-two.. amargency bus ses.1F..and. 1G. was.-
"~+1 1-
- - ru;;1ird performed.
Two discrepancies were identified.
The discrepancies consisted of one relay that exceeded the allowable time delay setting and one relay contact that had marginally high resistance. Retests following resetting of the relay timing and cleaning of the contacts were satiefactory.
4AO-Volt Te stinct 1
Out of a total of 12 breakers that were as-found tested, two breakers failed to trip and two breakers failed to trip within the time delay acceptance criteria.
Subsequent testing of the undervoltage trip assemblies (UvTAs) identified a fif th breaker which previously passed its acceptance testing but failed due to slow actuation timing.
The unreliable and inconsistent performance of these UVTAs was either caused by mechanical binding in the latching mechanism or a. defect in the time delay attachment.
As a result, the UVTAs for these twelve breakers were repliced with a shunt Ortp device that is activated by the loss of voltage logs.c for the 4160-volt breakers.
Successful testing of this shunt trip network for the 480-volt bus loads was completed on July 4, 1994.
Cab 4-94-06b i
I* - 5 (c)2:
" Discuss che results of all ceecing that was performed for the issue discussed in ZCem 2 of the CAL:
Control Room and Turbine Building Ventilacton Systems. "
m Reasonan Control Room Envelore On April 11, 1994 the Control Room Emergency Bypase Filter System failed post-maintenance testing which was being performed following maintenance i
on a door that formed part of the control Room pressurization boundary.
(See LER 94-006, dated May 11, 1994)
Several leak pathways were sealed 1
and the Control Room Envelope was successfully tested on April 28, 1994.
l Page 4 of 19
7---
3E4940001 July 28, 1994 Attachstant on June 24, 1994 another test of the Control Room Envelope was conducted to verify that the new administrative limit (a
+0.04" wg) could be satisfied.
The test failed.
Another search for new or degrading lealc paths was conducted.
Several small leaks were identified and sealed.
Recent testing confirms that the Control Room Emergency Bypus Filter System can satisfy its design basis of providing a positive pressure to the Control Room envelcpe.
The administrative limit of p. +0.04" wg has been consistently achieved during numerous tests of Control Room Envelope integrity conducted since July 9,
1994, with the exception of a test conducted on July 22,
- 1994, which failed due to a flow balancing deficiency.
The balancing deficiency has been corrected and appropriate Control Room Envelope testing was eatisf actorily performed on July 27, 1994.
..~ -.-. -
The effects of wind speed have also been considered during recent testing and will be considered during future testing.
Investigation into system design improvements to increase system performance margins is continuing.
These improvements will be implemented prior to startup from the spring 1995 refueling outage.
Turbine Building Actions taken recently to correct operational deficiencies in the Turbine Building Ventilation System discovered following the unsatisfactory control Room Emergency Dypass Filter System test conducted on April 11, 1994, include the following:
a)
Repaired exhaust fan vortex and outlet dampers and controls.
b)
Cleaned and lubricated the vortex dampere for the exhaust fan.
c)
Repaired damaged ductwork.
j d) verified sensing line integrity.
e)
Cleaned and balanced the system to obtain -0.25" wg in the Steam Jet Air E]ector ($JAE) Room at design flow.
i f)
Updated the system operating procedure to require operation at 4
-0.2E" wg with respect to the environment in the SJAE Room.
This l
parameter is also rcutinely logged in the Control Room Data log in the control Room.
As a result of the above actions, eatisf actor / system operation at the
-0.25" wg differential pressure margin in the SJAE Room has been demonstrated. Preventive measures will be implemented through the ongoing Preventive Maintenance Program to ensure that performance of the Turbine Building ventilation system will remain satisfactory.
i Fage 5 of 19
.. se n s..
a v. -
u... ~......
.au NLS9*,0001 July 28, 1994 1
-Attaciument i
Oma. 4 94 06b I'-
3 (e)3:
- Discuss the results of all tes ting that vaa per!crmed !ct che issue discussed in Ztem 3 of the CAL:
Primary Containment Penetrations."
M W8 j
Walkdowns of primary containment penetrations for Design Basis Reconstitution purposes were performed from May 18 through June 5, 1994.
As a result of identified discrepancies, eleven design changes were developed and implemented.
These actions included the addition of test
. _ n n... n - M;;4en-ee.we4 ded-cape epa re penetreeioner-cemplebe--- - -. --
redesign of several containment isolation barriers, and installation of cape on vents, drain lines and test conneccions.
As-found testing was performed for penetrations which had not previously been Type A, B, or C tested and for which as.found testing was determined to be practicable.
The total as-found leak rate due to these additional tests was approximately 26 SCFH, not including drywell pneumatic supply check valve IA-CV-65CV.
Leak rate testing for this check valve revealed j
that it could not be pressurized.
The safety significance of this leak rate is discussed in the response to Issue 5 (d) 3.
Following modifications and repairs, the total Primary Containment as-left leak rate, including IA-CV-65CV, was less than the 0.6 La (189 SCMI) limit specified in CNS Technical Specifications.
Penetrations classified as IIIN, IVP, or indeterminate, were identified for which appropriate NDE records cculd not be found to ensure that the piping welds were of egaivalent quality level to the centainment.
A design change was completed on forty-seven penetrations dur:ng this outage to upgrade the design and installation of this piping to a T.tality that is equivalent to the primary containment.
The District will update the CNS ASME Section XI Inservice Inspection Program prior to the 1995 outage to include these piping segments.
This aetton will ensure that the quality level of these piping segments will be maintained in the future.
Thirty-five related butt welds were radiographed.
Of that total, five rejectable indications were fcund.
Two of the five rejected welds were removed by shortening a piping run and the remaining three welds were repaired.
In addition, a total of 262 aoeket welds were subjected to liquid penetrant examination.
There were no rejectable indications.
Based on the as-left leak rate, the repair of re]ectable NOE indications on butt welds, and no reJectacle indications for socket welds, the District concludes that containment integrity satisfies regulatory requirements.
This issue was discussed with the NRC on June 27, 1994.
Page 6 of 19
NLSD40002.
July 29, 1994 Attachment (25. 4-94 06b
& --- 1 (d31 ;
" Discuss che satecy significance at all off-normal or discrepant conditions found in Item 1 of the Ch*.,:
.n 4260-volt undervolcage relay logic and 490-volt undervaltage devices (as J.
found).
p i.:
m Bamansase b
Also-volt Undervoltace Relav Logic The safety significance of the 4160-volt undervoltage relay discrepancies M__ _-___f trirg p rfc. u_mi@emal Procedure-e4-.3Ohis-as-to4,lowse-- - -
a)
EE-REL-27X3/1G timed out at 14.63 seconds, which is 3.63 seconds longer than allowed by acceptance criteria (10 seconds 10%).
This relay provides a close interlock in the DG breaker EG2 close circuit to prevent breaker closure until the 4eo-volt switchgear breakers feeding non-essential loads have adequate time to trip. The design basis for the DGs specify that the output breaker of the DGs must be closed within sixteen seconds from the time of DG actuation to meet the 10CFR, Part 50, Appendix K Analysis. The 14. 63 second timing of EE-REL-27X3/1G would not have prevented DG2 from meeting this requirement.
Concurrent with relay timing, DG2 would start, reach required speed, and bus load shedding would occur. Since DG2 would have started within the sixteen second limit and relay EE-REL-f 27X2/1G would have closed within the sixteen second limit, Eus 1G also would have been. powered within the required sixteen seconde and the intended safety function would have been satisfied.
b)
The resistance of contacts 11-12 of EE-REL-27X/1GB was found to be higher than the acceptance criteria limits. These contacts provide a trip signal to breaker 1GB during a loss of voltage. The trip of breaker 1GB separates Bus 1G from the off-site power supply and allows transfer to the Emergency Transformer, if available.
The acceptance criteria is <1 chm and the resistance of these contacts was measured at 3.1 chms. The 1 chm acceptance criteria was chosen as a acreening point for contacts requiring further evaluation.
Subsequent review determined that this contact would have been able to perform as designed under all design basis conditions. Based on the above, the as-found contact resistance had minimal safety significance, c)
On June 16, during performance of testing associated with Special Procedure (SP)94-208, a malfunction associated with the 52/IN contact, the breaker position switch, for breaker 1GS occurred af ter the breaker had been racked to the test positton to support testing and then racked in.
The breaker malfunction was due to mis-ad3ustment of ite guide wheels which resulted in it becoming misaligned as it was racked into its cubicle. The misalignment led to an over-travel in the position switch as the breaker was electrically cycled, which resulted in the breaker malfunction.
Page 7 of 19
~
~~
u-
IGA M0001 July 23, 1994 Attachament thcroughly understood the cause of failure, a To ensure that we vender representative was utilized to assist in evaluating the condition and correcting it.
All other safety related breakers of this type have been inspected and no similar conditions were fcund.
The inoperable status of the breaker did not have an adverse impact on plant safety during the special procedure.
Bus 1G had already was in Cold shutdown.
The been declared inoperable and the plant redundant division was available during performance of the special procedure and during repair of the breaker.
During normal operatiens, breaker 1GS is normally open, and would automatically close upon loss of power from the Normal and Startup Transformers, powering the 10 bus, providing that power is available
'.c-th; cm:poy4penefemer-.- Mad thie malfunction. --vad whi b -
the effect would have been that the breaker would not have at power, tripped upon loss of power from the Emergency Transfortner.
To assess the operabilit'/ of the breaker during the past operating cycle, a review of the operating history cf the breaker was performed.
It was determned that in each case where the breaker was racked in and cycled once successfully, the breaker would then operate properly in each subecquant demand.
All failures of the breaker to operate properly have occurred on the first cycle of the breaker after it has been racked in, on July 18, 1993, the 1GS breaker was racked in and was successfully cycled during the transfer to the emergency transformer and back to the startup transformer.
No indication of a breaker problem was indicated between the July 18 cycling and the performance of STP 94-208.
In the misaligned condition, the ability of the breaker to perform its function during a seismic event is being evaluated.
In the event that the seismic qualification was not affected by the misalignment, this condition would have had no safety significance.
Should the breaker not be found seismically qualified, the safety significance would have been minimal based upon the following discussion.
The sequence of events that would have resulted in an accident scenario of concern is as follows:
as loss of a portion of the transmission system and normal off-site pcwer temergency transformer power source remains available);
b) closure of the 1GS breaker, transferring the Divtsion II emergency bus to the emergency tranoformer; loss of the iGS breaker trip function due to the effects of a ci seismic event; Page 8 of 19
u.u MAS 40001 Jialy 28, 1994 At.tachment d) loss of the emergency transformer, de-energizing both 4160-volt busses; and, e) failure of Diesel Generator 1.
Given this sequence, HPCI and RCIC would have been operated in accordance with plant procedures to stabilize the plant.
Operator action would be necessary to locally trip the 1GS breaker, permitting breaker EG2 to close, allowing the DG to assume the necessary loads.
3 i.
eso-volt Undervoltaere Devices Due to test failures and demcnstrated unreliability of the 480-volt L ~1u.g; n 1. f; icc HUYTAHdiectiseed 4n-Item sdoM-above,.. Nuclear- ---...
7 magineering Design Calculations (NEDC)94-110, " Operability of DG1 With Additional Loads," and NEDO 94-114, " Steady State Operability of DG and ET With Additional Loads," were prepared to assess whether the EDG units would satisfy their intended safety function, even if the INTAs did no't function as intended.
As a result of these calculations, the District concluded that: 1) the EDGs would not have stalled; 2.) EDG capacity would not have been exceeded to the degree that performance would have been adversely impacted; 2) EDG tie breakers would not have tripped; 4) the fuel supply would have been adequate; and, 5) all electric motors supplied by the EDGs would have successfully accelerated to operating speed.
In summary, the EDG units would have been able to perform their intended safety function, even if all twelve of the UVTAs failed.
M 4 0 6b r-5 (d) 2 :
" Discuss the safecy significance of all aff-normal or discrepant cond1tions found in Iccm 2 of the CW Surveillance cescing accepcance cricaria !ct the con:rol room and turbine building vencilacion systems."
M.Egamonse As previously discussed, the design basis Centrol Room operator dose calculation assumes :.0 CFM of unfiltered inleakage based on positive pressure in the Control Room envelope. Therefore, the safety significance of the f ailure to achieve a positive pressure was evaluated by calculating the dose consequences of up to 2000 CFM of unfiltered inleakage.
The basis for this assumption and the detailed results of the calculation has been provided to the NRC by separate letter from G.
R.
Horn, dated July 20, 1994.
In summary, the resulting dose would be within GDC 19 and Standard Review Plan (SRP), Section 6.4 1;mits.
Based on the results of the calculations eunmarized in the referenced correspondence, the District concludes that the as-cound condition of the Control Room envelope had minimal safety significance.
Page 9 of 19
.c,.
IEA M0001 July 28, 1994 At.techument tans, 4 M -05b I -- 9 (d)3r
- Discuss che safety s1gn1ficance of all of f-nomal cr discrepant condicians found in reem 3 of the CAL:
Containment penetracions."
m naspoenna
'Mie majority of the centainment penetrations that did not comply with design requirements had been successfully tested at design pressure during the primary containment ILRT last perfomed in 1991. As-found testing was performed for penetrations which had not previously been sub]ected to ILRT
- - ' P
%.and for whl.ch as.-f ound testing.was dete4 ned.tp he...
rr n,-
practicable.
Testing demonstrated that the leak rates were within Technical Specification limits with the exception of the Drywell Pneumatic Supply Check Valve, IA-CV-65CV, in penetration X-22.
Type C LLRT testing revealed this penetration could not be pressurized.
Potential off-site and en-site radiological dose consequences due to leakage from penetration X-22 during the 30 days following the accident were evaluated per calculation NEDC 94-154, "Off-site and On-Site Dose Consequences For LLRT Failure of IA-CV-65CV."
The results of this calculation are summarized in the following chart.
scenarlo:
whole Body Dose Thyroid Dose Whole Body cosa Thyroid Cose Lim:.ts (Rem) 1ittit s (Rem)
- Rem (
(Rem)
- 1) currant off-site LO:A
~1.4 x 10" 9.0 x 10" 25 300 Done ( USAR Xf'/* 6. 31
- 3) Off-site LOCA Dese 4.2 x 1[
5.2 x 10" With Additiona'.
Leakage from m tration X-22
- 3) current unsign Basis 1.74 11.39 5
30 control Room oCA Bose el control Room Design 4.42 58.51 Basis Loch Dose With Additional :.eakage froe penetration x-22 s1 control Room LOCA cose 4.42 10.85 wLth Addittor.al f.ea4sge from Par.etration X-22 and and no SGTs Actuation Delay Page 10 of 19
a.
15d940001 July 28, 1994 Aatacament off-site doses, considering the additional leakage in Scenario 2, are far below the 10CFR100 limits cf 25 Rem whole body and 300 Rem thyroid.
For scenario 4 the Control Room doses exceed the SRP 6.4 limit of 30 Rem thyroid, but are below 10CFR Part 100 limits.
However, thie scenario reflects conservatiams which go beyond those required by the relevant guidance documents for dose calculations of this type.
The more accurate anal.ysis is discussed below.
' 2 i,
, d.
a e,
r '... ~
p.
,f a
eo 2
- 5, which ' addresses additional leakage with no S
- ardby Gas i o imWdoks noe consider 90 seconds of unfilten.M.d'i l !:,l, j]
is more accurate in depicting Lbejd
@#%iM,e%@$) delay, tes e udi 1 y;.N F
P from secondary containment prior to SGTS actuation, which is assessed in design basis calculations based upon worst case secondary containment valve closure time.
The basis for removing this assumption comes from
, ar,.maecm r..awrn...Texa.Lan.. Light " ~r w ~r. Power.
Plants," which indicates that it would take over one hour for fission product radionuclides to begin to exit containment.
Therefore, it is a more realistic case to assume that all flow from secondary containment containing fission products would be filtered through the Standby Gas Treatmant System within this time.
Since Control Room dose for the more realistic Scenario, No.
5, is within GDC 19 and SRP 6.4 limits and the off-site dose would be within 10 CPR Part 100 limits. the safety significance of the inoperable X-22 penetration is minimal.
Additionally, barriers that should realistically mitigate the effects of the assigned leak rate include two other valves outboard of IA-CV-65CV and the Instrument Air and Nitregen Systems.
However, since these barriers are non-safety related, they were not taken credit for in the analysis I
described above.
The design pressure / temperature for the associated piping is 125 psi /200*F and the piping system operating pressure for both systems is above 100 psi, well in excess of containment design pressure.
These conservatisms provide further assurance that the Control Room operator thyroid dose would be within regulatory limits.
l l
Creatien of the postulated release pathway from primary containment 4
requires a failure in the instrument air system piping, both inside and j
outside containment, concurrent with a DBA LOCA.
A Probabilistic Safety
)
Analysis (PSA) was used to estimate the frequency. It was postulated that under accident conditions (large break LCCA resulting in core damage, probability of occurrence 5. 5 4 E- 0 0 /yr. ), the line could become a pathway j
for radienuclides to reach the environment.
The probability of a line
]
break outside of containment was assumed to be bounded by the probability of a loss of the Instrument Air System. This probability, including pipe breaks, is conservatively assumed to be 2.58E-04.
Therefore, the frequency cf occurrence of this scenario resulting in a release of radionuclides outside of containment through this penetration to the environment is 1.43E-11/yr.
This value is well below the regulatory concern value cf 1.0E-07/yr used in Probabilistic Safety f
Assessments for centainment bypass events.
Based on the above
]
considerations, containment penetration loak pathways had minimal safety l
significance.
)
I 1
{
Page 11 of 19
~
ei/ae. w, iv Qu" wev.
a.,
vv.v'
~
- c,w i.a..c m ' $ ' '
- se66 MLS M 0001 July 28, 1994 Atta h nt (3S. 4 - H - 04b 1^ - 1 fale.a:
siTnificance of all off-normal or discrepant
- Discuss the safety S
)
conditions found in Icem 4 of the CAbi Electrical distribution syscen surveillance."
m amammase i
A review of the Electrical Distribution System was conducted to verify testing was performed as specified in the Technical Specifications, USAR, l
and Design Basis. This review identified two discrepancies with potential safety concerns which are discussed below:
..4..............
a)
Relays 27/1F-1 and 27/1G-1 were not being tested properly per the definition of the instrument functional test.
The monthly functional test visually verified contact closure; however, the Technical Specification definition required the associated auxiliary relay to be energized. The past method of functionally testing the relay was not a safety eencern because:
1)
Relays 27/1F-1 and 27/1G-1 are calibration tested once per cycle and functionally tested once per cycle by surveillance procedure 6.3.4.3.
2)
The subject relays are protective relays which have contact mechanisms in which the relay contact position is visible in the both the open and close conditions. In the test mode, the relay contact will not be in the intermediate position.
3)
The monthly functional check did prove the induction disk rotated when the input voltage was removed. indicating a loss of voltage had been detected by the relay mechanism.
The monthly surveillance procodure has since been revised to correct this discrepancy and the relays have been satisfactorily tested.
b)
Two installed Diesel Generator Starting Air pressure indicators for which qualification was in question were discovered. An engineering evaluation was performed which verified that the instruments were qua11fiable and capable of performing their safety function.
Documentation of their qualification has now been developed.
Therefore, the safety significance cf this discrepancy was minimal.
Page 12 of 19
e,
,o
.m.
-o_.
Esp 40001 July 28, 1994 Attachement (mL 4 06b r-5 (A14.b:
" Discuss che safecy significance of all off-normal or discrepant condictons found in Icem 4 of :te CAL:
Zasezvice inspection of penetrac1on welds. "
M.M 9 Twelve Class 2 welds were found to have been excluded from the ISI However, ~even with the addition cf the twelve welds to the total Program.
Clasa 2 weld population, the required weld examination percentages are still satisfied. For the current ten year interval, one outage remains to
- _ '--- 4 apt 4 =.i.ncecyalMuunInstion requirementis J gis.Jg cangdent that the welds are mechanically sound based on NDE verification at original :: ens t ruction.
As such. the District has concluded that the safety significance of excluding the 12 class 2 welds from the ISI Program is minimal.
Further information related to this issue is provided in the response to CAL Item 5 (g).
(BL 4-94-06b T' - 5 (Al4e:
i
'" Discuss the safecy significance of all oif-normal or discrepant condicions found in Icem 4 of the CAL:
Tescing programs i.m.plemented in ocher areas of licensed accivities. "
M Bemanstaa The safety significance associated with ongoing testing programs implemented in other areas of licensed activities ;s addressed in the response to Item 5 (h)
SL 4 06b 1r - - 1 (alls
" Discuss che correccive acticos chac will be caken to:
Prevent recurrence of the installac1on af devices (i. e., cie wraps, jumpers, blocks, ecc.) that will prevenc che actuacion of safecy-system fuoccions."
W S Beamonse The follcwing corrective actions have been or will be taken:
a)
A walkdown was conducted to vert!y that no similar cable tie installations were in place.
None were found.
I b)
A review was performed of station mechanical and electrical maintenanca procedures surveillance procedures in the chemistry, operatione, and instrument and control areas, as well as the Page 13 of 19
- ..,, ~.,,,,
~
- i
.~4 W.
t MEJ900001 July 20, 1994 Attachment 14.x series instrument and control procedures, to identify similar procedural deficiencies.
Three mechanical procedures were identified as deficient.
Changes have been initiated to correct them.
Fifteen electrical procedural deficiencies were identified.
Changes have been initiated to correct them.
Three minor discrepancies were identified and corrected in the operations and
{.
instrument and control procedures.
The noted procedure discrepancies will be corrected and approved prior to next use. No i
discrepaneses were identified in the chemistry precedures.
Field perf ormed f or similar deficiencies that could have
[
walkdowns were been created during past use of the deficient procedures.
No equipment contiguration discrepancies were found.
c)
A revision has been made to Maintenance Work Practice (MWP) 5. 0. 4 to 7 4 a. _,..,_g.. %
m.
w h t. g..s e m..changea,..or _....
22 blocking devices installed during performance of maintenance have been removed prior to completion of the procedure.
d)
In response to management deficiencies, maintenance supervision has held meetings with their personnel to emphasize the need for procedure compliance and immediate correction of problems and Considerable incomplete understanding of procedure requirements.
effort is also being expended by Maintenance Management to ensure that expectations are clear regarding procedure compliance, procedure adequacy, and control of maintenance activities.
mb 4-94-06b T^-
5 fa)2:
" Discuss the corrective actict.s that will be caken to ensure chac che des 1gn basis surveillance resting criteria are established and maintained for che faciliry."
WWW..Renanaam The testing requirements specified in Technical Specifications and the USAR for the ma3cr components of six critical systems have been reviewed against existing surveillance procedures. The systems reviewed included:
High Pressure Coolant In]ection Reactor Core Isolation Cooling Residual Heat Removal (Low Pressure Coolant Inj ection mode)
Core Spray Automatic Depressurization Emergency Diesel Generators The review was performed as folicws.
a)
An existing cross ref erence between Technical Specificaticus and surveillance precedures, which is maintained by the Surveillance Coordinator, was independently reviewed for correctness.
Page 14 of 19
vE a s.n
.*L.
J 4.s a.'
cvAs Of de 00 Ad.v.
w ev.
J.o ousv t
IELA 940001 July 28, 1394 Attachment b)
The Technical Specif;;ation surveillance requirements were reviewed against the respective surveillance procedures to determine if the requirements were being met.
c)
USAR sections describing the six systems were reviewed to determine if the USAR requirements were being met by the surveillance.
'LL;
'the results of this review are summarized in the response to Item 5 (h).
W 4 40ss, the District will verify that operating and surve'illance test N E.. ':
'iprotsledure content and surveillance test acceptance criteria are consistent with the design basis.
'/erification of surveillance testing program adequacy will be accomplished for future system-related Design Criteria Documents (DCDs) as part of the Design Basis Reconstitution Proj ect.
^
. r. ; ; c : ; _. _, _;. g = nt mHP-seleeeed-shese -.syeme~c hag----- - -
--y~..
will be completed on an expeditious basis.
An in-depth systematic review of the surveillance test program was initiated on July, 11 1994.
Thie review addresses testing requirements specified in the Technical Specifications, the USAR, and those completed DCDs to ensure that the surveillance test procedures, including those specifically developed for ASME IST purposes, adequately incorporate pertinent requirements. This review is scheduled to be completed by March are those for 1995.
The systems included in the scope of this review which Technical Specification testing requirements are specified.
Organizational and programmatic changes will be made to enhance configuration control consistency between design input and design output documents to ensure that :
- 1) procedure m3difications are reviewed for Impact on design input documents: 2) design output documents are revised when affected by changes to calculattens;
- and, 3) changes to CNS engineering program documents te.g.,
LLRT) are reviewed for impact on design input documents. Additionally, the District will perform a review to identify additional design input and output documents that require enhanced configuration maintenance provisions.
C&B 4-94-06b 5 (f)
" Discuss the lessons learned by the Cccper nuclear Station statf in response to the incident nvolving the undervolcage trip funct.Lon in the motor control concer supply breaker, inclu d.tng the lack of prompt recognirion of the potential safety significance of. ome issues. "
hutense An assesement was perfer,ed of CNS performance related to the noted incident.
The District found that the initial response was narrow, compliance-based, and poorly directed by management. Management and staf f exhibited narrow-focused and Ocmpliance-based values.
Although the District has been striving to prcvide the te01s and management oversight to overcome those behaviors, it is clear that afforts have not yet been succesoful.
Page 15 of 19
IE.5940001 Aly 2 5, 1994 Attachment Management performance issues are being addressed in great part by changes in management staff, communicating management expectations, and requiring an increased level of accountability. The District's immediate goal is to acquire new talent with higher performance standards, to deepen management resources, and to allow reassignment of some incumbent managers to other arena of need, while bringing fresh industry perspective to Cooper Nuclear m.'.
n's central management structure. A new Site Manager and Iddusfrigl
- frcat. %1 ants which recently improved their % rMheried/l' L
M ItM)) dW! July 11.
The Maintenance ManageM M IbNti i
dNN ! $' p
%@&shN} I UA%ewseniormanager,withmanyyeard(dh M
i Ph ed hired. A new Corrective Action Progr5tav%dtagerl' 4
i-I has been assigned, Condition Resolution Team mentor support has been provided, and five full-time, rotational condition Resolution Team Leader positions are being established.
Additional planning is underway for or reassimaga_t.o.f 3hA ptbeL py seniorlqd middle manager _,.,__
k mnw=* e t
positions, as appropriate.
Weakneeses in Quality Assurance staf f performance during recent events are being addressed by: 1) the establishment of stronger guidance for dealing with emerging issues and interaction with the line organization 2) increased oversight and supervision of QA field activ:. ties by QA Division and Department Managers,
- 3) training to improve safety and assessment skills (underway and to be completed by August 1994) ; and, 4) publication of senior management expectations for quality assessment activities.
Management oversight of Condit1cn Feview Group (CRG) activities has been j
a senior manager oversee the CRG's evaluation and increased by having decision making activities in the role of a protagonist to ensure adequate rigor and urgency.
Condition Reports are being more thoroughly screened for significance by the Technical Staff prior to submittal to the CRG.
To improve saf ety attitudes and perf ormance, training in saf ety principles and performance-based evaluation techniques will be provided to appropriate segments of the NPG staff start;.ng an September 1994.
Advanced root cause analysis and inve s t:. gat ion training will also be provided.
Other programs were found to be ineffective dur:.ng recent events.
For example, the Operating Deperience Review (GER) program should have addressed the inadequate diesel load shed t! sting and logic system functional testing problems.
To ensure that this deficiency is not pervasive, a ccmprehensive review of past operating experience documents has begun.
The absence of design basis inf ormation adversely af f ected the District's efficiency in responding to potential safety issues.
As a result, the reconstitution schedule has been accelerated.
Efforts to review and upgrade the CNS surveillance and other testing programs are discussed elsewhere in this letter.
In summary, the District has taken, and will continue to take actions responsive to technical, programmatic, and managerial problems as they are identified.
Page 16 cf 19
)
- ~ _
ESM0001 July 28, 1994 A46 =d===n t i
tag. 4 0 6b I' - - 5 fa)
- Discuss che basis for your deceminacion chat the testing programs for electrical distribucion system surveillance cesting and inservice inspection of penecrac1on welds are technically adequate and complace. "
m amanoasse ut=ntrical Distribution The District is confident that the surveillance testing of the Electrical Distribution System (EDS) for Cooper Nuclear Station is adequate.
This confidance is based on the number and scope of actions that have been
-'7.
% _rn11 u,w __m - 4.a= m m_o Ltha. m re a42n4H ennt nctly M.c h _
and improvements that have been made during the current outage.
a) compared the General Electric ECCS input assumptions against the Emergency Diesel Generator (EDG) load calculation; b) upgraded the 480-volt undervoltage design; c) reviewed the 4160-volt first and second level undervoltage logic and conducted additional testing via special procedures, temporary procedure changes, or new surveillance procedures; d) revised the EDG sequential loading test procedure and performed the revised test on both divisions to ensure appropriata load shedciing; e) reviewed maintenance practices regarding installation and removal of devices such as cable ties, jumpers and contact boots and initiated procedure changes where necessary; f) reviewed operating procedures for proper operation of the Electrical Distribution Systemt g) reviewed the battery load study and compared it with battery load testing procedures; b) reviewed Design Criteria Documents (DCDs) for AC, DC, and EDGs at the component level, including support systems (e.g.,
Fuel Oil Transfer, HVAC, etc.,
that support the EDGs) to ensure proper testing /functionalita/ could be demonstrated; and, i) reviewed the above DCD listings for Licensing commitments and open items identify items of potential safety significance.
Future actions planned by the District are addressed in response to Items 5 (e)1 and 5 (e) 2.
With regard to precenditioning, CNS will neither test nor repair components, systems, or structures for the purpose of satisfying as-found acceptance criteria in surveillance tests.
As-found testing will be performed prior to maintenance requiring adjustment of setpoints or Tage 17 of 19
e l
ES900001 July 20, 1994 Attachement re-calibration per the surveillance program.
For example, prior to performance of Technical Specification instrument surveillance calibrations and setpoint adjustments as-found data will.be recorded.
similarly, prior to performance of maintenance en essential electrical breakers, as-found data will be recorded.
J l
T-vice Insoection of Penetration Welds _
1
,j As discussed during the July 9, 1994, meeting with the NRC, examples of incorrect classification of primary containment penetration piping welds n
8 were identified.
As a result, a commitment was made to assess the ISI Program, to submit an addendum to add the excluded welds, component supports, and pressure test boundaries to the ISI Program, and to submit relief requests if required prior to the 1995 refueling outage to ensure rama r-n ggy,g jggegggj,,Jpog,gggqq,tolgese
- 6 H nn rr activities, the District will consider the ISI Program to be technically adequate and complete.
cas, 4 o sb
& _5 (h)
" Discuss the basis for your assurance chat che testing programs for other licensed accivities are adequacely implemenced. "
m ammonae As discussed in Item 5(el, the surveillance testing for the major components of six critical plant systems has been reviewed to ensure coenfortnance to the USAR and Technical Specification testing requirements.
These reviews were performed on systems with substantial safety significance:
High Pressure Coolant Injection, Reactor Core Isolation Cooling, Residual Heat Removal Low Pressure Coolant Injection Mode, Core Spray, Automatic Depressurizatien, and Emergency Diesel Generator Systems.
The review found several discrepancies between CNS tests and the USAR. The discrepancies were corrected by USAR revisions or were incorporated into surveillance test procedures.
As a result of the investigation of the undervoltage trip assembly problems, the District also reviewed its program for logic system functional testing (LSFr).
This review included the following systema.
High Pressure Coolant Injectica Standby Gas Treatment Reactor Core Isolation Cooling Reactor Building HVAC Reactor Protection Diesel Generator HVAC Control Room HVAC Reactor Equipment Cooling Residual Heat Removal Core Spray Alternate Rod Insertion Fire Protection Service Water Low-Low Set Automatic Depressurization Diesel Generator Lube Oil J
Standby Liquid Control Diesel Generator Auto Start Diesel Generator Fuel Oil Primary Containment Isolation (Gr 1-7)
Diesel Generator Starting Air Anticipated Transient w/o Scram Page 18 of 19 J
e MA D40001 July 20, 1994 Attachneent Bach contact in the above listed systems was evaluated to determine if it performed an essential safety function and to determine whether a procedure existed which confirmed each contact's operability.
Where testing was not being performed, either appropriate procedures were revised or special test procedures were issued to perform the testing.
Completion of this testing has confirmed the design and functionality of g +..
Char logic systems.
From all of the testing performed,, pun. t%r@r I
c fety significant discrepancy associated with relay timinef h ' not%d.!-
l d k';
nh-k i)y. relay REC-REL-1FR was found outside of its allowable!r j
u
- j,
g SiMa.N),,,butC$t procedural limits (15 to 60 secondy. ' gtiplj
% l ;
E dlulay waai'33.27 seconds. The relay was calibrated and r et;d.gted
' i
,l i
satisfactorily.
Furthermore, the District has implemented several programs and activities
=
a H,,- s 3 u.mi m.
..a w rru. cux: ng rm s em. Am pa rt-e m. c,. mg,. r a series of self-evaluations of key programs continues to range programs, be perf ortned, including those involving licensed testing activities.
Examples include: fire protection, MOV program, Appendix J, ISI, IST, and instrument setpoint.
" Health Reports" are also being generated for each program.
These reports consider a number of program performance factors including currency of the program with industry practice, currency with regulatory issues and commitments, and establishment of adequate program controls.
The health reports for activities involving testing programs include the surveillance testing program, the calibration program, inservice testing program, containment leak rate testing program, relief valve setpoints, instrument setpoints, relay setpoints, and the Mov program.
While no significant deficiencies were identified, a health report for the Protective Relay Setpoint Program identified concerns related to overall program management. Previously, control of the setpointe included in this program was considered one of many elements of the electrical maintenance program, not a unique setpoint program. Currently, program responsibility has been assigned to the design engineering group.
In addition, inservice testing and inspection, contcinment leak rate testing (program upgrades in progress), and the Check Valve and Vendor Manual Programs were all found to have health ratings that require further in-depth assessment and program improvements.
The most significant concerns have been related to program ownership and support (i.e.,
tsanagement), not technical concerns. No technical deficiencies that would inapact safe plant operation have been identified.
Management concerns previously noted will be addressed.
Any safety significant technical deficiencies discovered during in-depth program reviews will be evaluated for impact on safe plant operation and aggressively resolved.
While some activities remain to be completed, the District has concluded that testing programs for other licensed activities are adequately implemented.
Page 19 of 19
e COOPER NUCLEAR ST ATION P.O. BOX 98. BROWNVILLE. NEBRASKA 68321
~
Nebraska Public Power District "iW e #'
NLS9400026 August 8,
1994 Mr.
L.
J.
Callan Regional Administrator j
NRC Region IV j
611 Ryan Plaza Drive Suite 400 Arlington, Texas 76011 i
Subject:
Response to Request for Additional Information Cooper Nuclear Station Docket No. 50-298, DPR-46
References:
1.
Confirmatory Action Letter (Revision 2) dated July 1, 1994 to Guy R.
Horn - Nebraska Public Power District (CAL 4-94-06B),
2.
Letter from G.
R. Horn (NPPD) to L.
J. Callan (NRC) dated' July 29, 1994, " Response to Confirmatory Action Letter."
- 3. Meeting Between Nebraska Public Power District and the Nuclear Regulatory Commission on July 29, 1994, concerning restart readiness.
4.
Confirmatory Action Letter Dated August 2, 1994, to Guy R.
Horn
- Nebraska Public Power District (CAL 4-94-08).
Dear Mr. Callan:
On July 1, 1994, Confirmatory Action Letter 4-94-06B was issued which verified, among other things, that Nebraska Public Power District (the District) would provide the Nuclear Regulatory Commission (NRC) RegiorfIV office with a letter that discussed eight areas of interest.
On July 29, 1994, the District provided the letter to the NRC and participated in a meeting with the NRC to discuss plant restart. With these two activities completed, all items in CAL 4-94-06B that were agreed upon as a precursor to plant restart were satisfied.
However, at this meeting, the NRC requested additional, more detailed information regarding the District's component and system preconditioning policy, and its relationship to the implementation of testing programs. The NRC also requested, prior to restart, that the District document some of the detailed discussions held during the meeting and, in some cases, provide more detailed information on how reviews addressed in the July 29, 1994, letter were conducted. Attachment 1 to this letter provides the detailed information.
On August 2, 1994, the NRC issued CAL 4-94-08, which requested that (as a supplement to the CAL 4-94-06B response) the District describe its basis for concluding that an adequate review of Cooper Station operational experience, A*
44fn5%p-9
---==.amfammmmunemmiomnmaamnummmmmmmmmmmmesw
..__..m._,
~*
x=
NLS940026 August l8,.1994' Page 2 industry' experience, and NRC information has been conducted to support. plant restart. The NRC requested that the District's discussion also address two
[
recent cases where previous District reviews apparently did not' address certain precursor information. to this. letter provides this information..The NRC requested that all of the above information be provided before plant restart and that the information be discussed at a public meeting, currently scheduled for August 12, 1994,.at the Cooper Station.
'All of the District's activities, collectively considered, represent an extensive amount of work aimed at confirming that there are no significant.
issues at the Cooper Station which would warrant continued plant shutdown.
'The District has been very responsive to NRC concerns and often has conducted investigations that typically would not be considered a condition for plant' restart. The District acknowledges that some of its reviews (e.g.,
Operating Experience Reviews) may not have identified all issues.
Although some investigations are ongoing, the District does not anticipate that its continuing efforts will uncover deficiencies that have a significant impact on public health and safety.
If any safety significant findings. occur, the District'will take appropriate actions up to and including plant shutdown, if
.necessary.
Of course, further evaluations will be conducted as soon as possible, consistent with schedules discussed with the NRC.
If there are.any questions.regarding information presented.in the attachments, or on other matters, please call.
Sine rely V ce resident, Nuclear RCG/nr Attachments cc:
U.S. Nuclear Regulatory Commission w/ attachments Attention:
Document Control Desk NRC Resident Inspector Office w/ attachments Cooper Nuclear Station NPG Distribution w/ attachments
.w t
j
. NLS 9 4 0 02 6._
August 8l.1994 LTTACHMENT 1 j
l i
A.
- DETAILED DISCUSSION OF' INITIATIVES I
'Recent events at Cooper Nuclear Station'(CNS) promp'ted several District initiatives to determine the scope of the equipment and process deficiencies
- that exist at the Cooper Station. Many of the actions taken to correct.
immediate deficiencies have been detailed in meetings and/or other correspondence ~with the NRC.
While'there'may be several ways to perform
)
reviews of issues, the District-is confident that its approach is satisfa'ctory i
.for determining. restart readiness.
The following section details 1 actions
.taken by the' District.
1.
GONFIGURATION CONTROL - CABLE TIE..
LThe District concludes that the following actions represent a comprehensive finvestigation of the cable tie issue and should prevent recurrence of similar
-deficiencies.
The District took the following. actions to, determine the scope of the problem and to correct any actual or incipient configuration control deficiencies.
First, a walkdown was conducted to verify that no similar cable tie installations were in place..None were found. The next step was to review
' station mechanical and elec'trical maintenance procedures; surveillance i
procedures in the chemistry, operations, and instrument and control areas; and
.the 14.x series instrument and control procedures,' to ensure that configuration control had been maintained.
Three mechanical procedures and fifteen electrical procedures required revision, along with three minor discrepancies in the operations and instrument and control procedures.
No
. discrepancies were identified in the chemistry procedures. The above listed items will be corrected prior.to next use of the procedure and do not adversely impact restart of the plant.
Concurrent with these activities, field walkdowns were performed to look for deficiencies that could have been created as a result of using the deficient procedures. No equipment configuration discrepancies were found.
Based on these activities it was reasonably concluded that the cable tie condition was limited to the example identified.
To ensure that configuration control continues to be procedurally maintained, a' revision has been made to Maintenance Work Practice (MWP) 5.0.4 to add guidance to further ensure that any impairments, changes, or blocking devices
~
' installed during performance of maintenance are removed prior to completion of the procedure.
Also, management has held meetings with maintenance personnel
- to emphasize expectations with regard to configuration control, procedure compliance, and immediate correction of ambiguous or incomplete procedures.
Additional meetings will be held to ensure that sensitivity to this issue
-continues.
Page 1 of 9
~.
m i
7 7
.NLS940026-.
s August 8,t1994:
kTTACHMENT'1 s
2.~
' LOGIC SYSTEN' FUNCTIONAL TESTING
'The activities-summarized below provide adequate assurance that logic system functional testing at Cooper Station is adequate. This concern evolved as a J
result of the discovery of the RHR Service Water Booster pump contacts that
'l l
hadenot been tested. 'The process utilized for this issue is described below:
-When th'e District discovered that. contacts had not been tested as required, a
~
review of the following systems was begun:
f'
-High Pressure Coolant Injection
' Standby' Gas Treatment Reactor Core Isolation Cooling
' Reactor Building HVAC 1
LReactor protection Diesel Generator HVAC
[
Control Room HVAC Reactor Equipment Cooling Residual Heat Removal Core Spray
{
Alternate Rod Insertion Fire Protection Service Water Low-Low Set i
Automatic Depressurization Diesel Generator Lube Oil l
Standby Liquid Control Diesel Generator Auto Start Diesel Generator Fuel Oil Primary Containment Isolation (Gr_1-7)
~
i Diesel Generator Starting Air Anticipated Transient w/o Scram a
The elementary logic diagrams for each system were reviewed, contact by contact, and correlated against the existing surveillances. The screening methodology was as follows:
3 a,
Does an existing surveillance actually verify the operation of the contact directly? If yes, then no further action is necessary. If no, then proceed to b.
1
~
b.
Does the contact perform an automatic essential function as determined by an engineering review of the Technical Specifications
- i and the USAR?
If yes, then test prior to startup.
If no, test after startup.
1 This review was completed on June 5, 1994, and testing commenced.
In mid-July, due to a question concerning the LOCA signal auto close contacts for the Core Spray full flow test valves (which had been scheduled for post startup testing),
a re-review of the post startup population of contacts was directed by senior management using.this additional criterien:
1{
Is the contact operationally significant (i.e., interlock that. prevents an operator error) and not verified by existing testing?
If_yes, then test 1
before startup.
If no, then test after startup.
5 i
The second screen was completed on July 18, 1994.
All contacts have been satisfactorily tested. A plan will be generated to address contacts requiring
~
testing after startup.
j j
e d
i Page 2 of.9
i MLS940026 August'8, 1994
&TTACHMENT 1 3.
SURVEILLANCE REVIEW j
The District concludes that the following activities adequately determined the j
extent of the surveillance deficiency revealed by the undervoltage and load shed testing inadequacies. A team of experienced Senior Licensed Operators reviewed the CNS Technical Specificat, ions, USAR, and surveillance programs to identify any weaknesses or discrepancies. The major components (i.e.,
pumps and valves) of the following systems were reviewed: High Pressure Coolant Injection, Reactor Core Isolation Cooling, Residual Heat Removal (Low Pressure Coolant Injection
]
mode), Core Spray, Automatic Depressurization, and Emergency Diesel Generators, j
The review was performed as follows:
An existing cross reference between Technical Specifications and surveillance procedures, which is maintained by the Surveillance Coordinator, was independently reviewed for correctness.
The Technical Specification surveillance requirements were reviewed e
against the respective surveillance procedures to determine if the requirements were being met.
USAR sections describing the six systems were reviewed to determine if the USAR requirements were being met by the surveillance.
The above reviews represent a significant undertaking by District personnel in a short period of time (July 2 to July 5, 1994).
Reviewers developed a list of questions / discrepancies which was assigned to the appropriate departments (engineering, maintenance, etc.) for resolution.
The discrepancies have been evaluated and incorporated into surveillance procedures, or corrected by USAR revisions.
Additionally, the Design Basis Reconstitution Project will be accelerated and will include a review of surveillance testing adequacy for all systems in the project.
Based on the above reviews, the District has reasonable assurance that surveillance procedures adequately implement regulatory requirements.
4.
DESIGN BASJS REVIEW OF THE ELECTRICAL DISTRIBUTION SYSTEM While the reviews of various specific items were addressing individual concerns, the District determined that a comprehensive evaluation of the entire system should be performed to ensure that the problems were not endemic. As a secondary matter, this review also would address the adequacy of implementation of the t
Operating Experience Review (OER) program. This ef fort has received additional i
scrutiny because of its failure to adequately address the Westinghouse DB 50 breaker issue.
The Electrical Distribution System (EDS) (AC Distribution, DC Distribution, and the Emerge
' Diesel Generators) was chosen because many of the recent problems appeared t' ect electrical components and testing, and because of this system's criti.
Ature.
The investigation concluded that EDS components would have pert
..ad their intended safety function.
Page 3 of 9
a 9
NLS940026 August 8, 1994 ATTACHMENT 1 Starting on July 19, 1994, a multi-discipline integrated review of the EDS was performed. The team consisted of personnel from the Engineering Department and
- Senior Reactor Operators. This review utilized design criteria documents (DCD) and evaluated the actual requirements at not only the systems level, but also at the component level. Included in these system level and component level reviews were support systems such as DG fuel oil, HVAC, DG lube oil, etc.
Each of the commitments affecting testing or plant safety was reviewed to determine if they were adequately met.
The initial review of the DCDs resulted in 49 questions requiring further evaluation and were investigated by Design Engineering, System Engineering, Operations Engineering, Configuration Management, or Operations Support Group. All of these items have been addressed. The review was completed on July 28, 1994.
B.
ADDITIONAL DISTRICT REVIEWS While the actions taken as a result of the technical issues that arose during the current shutdown provide some assurance that systems and components required for plant operation will function as required, the District concluded that additional reviews were warranted before startup.
Therefore, the following actions have been taken:
1.
OPERATING EXPERIENCE REVIEW In 1993, the District recognized that its Operating Experience Review (OER) j Program must be improved. This effort began in September 1993. The 1993 program began with a review by the Corrective Action Program Overview Group (CAPOG) of twenty percent of approximately two years of operating experience documents. On December 1,
- 1993, due to approximately a ten percent rejection of OER assessments, the sample size was expanded by another twenty percent.
As discussed further in Attachment 3,
the SBM switch and REC corrosion-related correspondence were not in the CAPOG sample population. Again, CAPOG re-reviews were a sampling effort that was not intended to assess all OER closecut documentation.
Therefore, the fact that these issues were not satisf"actorily closed was not fostered by 1993 OER oversight efforts.
However, due to the failure of the 480 VAC undervoltage trip devices, the District has commenced an additional pre-startup review of closed OER information.
The scope of this review covers all closed OER responses for the years 1992, 1993, and 1994, all closed pre-1987, and 25% of 1987-1991 responses.
The 1992-1994 period was chosen to validate the adequacy of the current program and represents approximately 25% of the entire historical database.
A 100%
review of the pre-1987 period was chosen because there was an apparent lack of f ormality in the program at that time. A 25% sample of the 1987-1991 population was chosen to provide assurance of program adequacy after it was formalized in 1987. This recent limited review provides a reasonable basis for the District's Page 4 of 9 j
I 1
NLS940026 August 8, 1994 ATTACRMENT 1 conclusion that the OER program has not overlooked issues that have a significant impact on plant safety. The screening criteria used during this review are as follows:
The item could adversely affect nuclear safety.
The item is needed to comply with the CNS Technical Specifications.
The consequences of not completing the OER action could affect the ability of a safety system to satisfy its design function.
The consequences of not completing the OER action could result in reduced safety system availability.
The closure documentation for items meeting the screening criteria are then reviewed f or adequacy. If the basis for closure does not appear fully adequate, the item will be re-reviewed by NPPD engineering. CNS management will cetermine if pre-startup actions are required for any inadequate responses as determined by engineering.
If an item does not satisfy the above criteria, it is assumed that the previous review, if inadequate, would not have a significant safety impact.
Approximately 14% of the pre-1987 items, approximately 6% of the 1987 - 1991 items, and approximately 0.4% of the post 1991 items (2 out of 552) have been returned for review of response adequacy.
A full review of the OER database responses for adequacy will be performed with an estimated completion time of 2 years.
The LER database also is being screened to identify recurring issues. Recurrence of the same or similar issues is indicative of a potentially inadequate corrective action. Those items found by the screening will be evaluated against the criteria defined above to determine if corrective action review is required prior to startup and CNS management will determine if any followup corrective actions will be required prior to startup. The remaining items will be reviewed after startup and the need for further action determined.
2.
ASSESSMENT OF COMMUNICATION EFFECTIVENESS Recent events at CNS have shown that additional efforts are necessary to ensure that everyone understands management expectations, especially for those issues that have been named as causes of recently discovered deficiencies, e.g.,
procedure use, preconditioning, and importance of problem identification. Since the maintenance organization also has been involved in several recent findings, additional management meetings have been held with the maintenance staff to 1
discuss issues and to communicate expectations, i
To reenforce the expectations expressed in the management meetings, the Site j
Manager issued a memorandum to the site dated July 29, 1994.
This memorandum l
specifically addressed preconditioning of components for the purpose of passing l
Page 5 of 9 I
^
NLS940026-
~*
.l August 8,-1994 ATTACHMENT l'
- surveillanceftests, maintaining a questioning attitude, and the importance'of clear and precise communication.
Independent of the~above, from July 30,'1994,' to August 1, 1994.,.the QA Division conducted.a, series of interviews with maintenance, operations, instrumentation and. control, and-chemistry to assess the state of understanding and acceptance of management's expectations. A specific list of questions covering procedural adherence, preconditioning, and identification and reporting of deficiencies was used.
The.following discussion provides a summary of the QA effort.
Preconditioninct The interviews had mixed results.
For example, within the areas explored, management has been effective in communicating its expectations to NPG personnel with one notable exception. While over 93% (222 of 238) of personnel interviewed
-.had an acceptable understanding of what constitutes preconditioning, 45% (107 of c238) did not clearly understand the importance of not preconditioning.
The majority of these personnel discussed the effects on as-found readings, the ability to accurately identify problems or the inability to trend problems.
While these are also important factors, the key issue of functionality does not appear to have been adequately communicated and/or absorbed.
It appears that this lack of full' understanding is the result of inadequate training on the subject.
CNS management is currently evaluating appropriate ways to expand preconditioning training to' ensure complete understanding of the policy by all personnel.
Procedure Adherence Interview results indicate that there is a very good understanding of management's expectations throughout the Nuclear Power Group. Virtually every individual interviewed clearly understood both the need for procedural use and corapliance, as well as the need to question the adequacy of the procedures and 7
-instructions they use as part of their daily routine.
Fifteen percent of interviewees, however, expressed that they did not fully understand management's expectations, many because the expectations were changing so rapidly, it was difficult to definitively state that they were understood.
This is an understandable reaction to the many recent culture improvement initiatives.
Through continued management reenforcement of expectations, this concern will dissipate.
Problem Identification The interview results indicate that management has been very effective in communicating expectations in this area.
Virtually all of those interviewed expressed a clear understanding of their responsibility to identify and document problems and concerns to ensure that they are corrected. However, management is concerned that interviews also indicated that several individuals are reluctant
-and/or uncomfortable with escalating problems that they did not feel had been resolved to their satisfaction. In this regard, reluctance by one individual is too many. Therefore,. management will be increasing its focus on this aspect of problem identification.
Page 6 of 9
.n...,,....
- . 1
.'.NLS940026 August 8,~1994'
' ATTACHMENT 1
.a~.
3.-
~ STARTUP AND~ POWER' ASCENSION MANAGEMENT PLAN Cooper Nuclear Station has ' developed a Startup.and Power Ascension Management l
Plan to' ensure that plant equipment, personnel performance,.and organizational responsiveness are ready to support a safe and reliable plant ' startup. and
' ascension < to full power operation.
A copy of this plan ' is provided ' (for information) ' as 1 Attachment 3.
The District does not anticipate forwarding 4
l
- subsequent revisions.to the NRC. The Plan's purpose will be accomplished through j
the following objectives:
Y e
Assign temporary positions and responsibilities to provide accountability and clear lines of responsibility during the startup and power ascension
- process, y
i
'e Establish communication paths to ensure accurate and timely transfer of information-to support startup and power ascension.
y:
Describe outage activities to ensure completion of work supports a safe i
l startup.
1 e
Resolve emergent issues in a timely manner so safe startup and power ascension are'not impeded.
e Conduct startup and surveillance testing in a safe and efficient manner to l
ensure that system and component operability. support startup and power j
ascension Two aspects of the plan are of special interest.
First, each system engineer will review open items for his or-her system to ensure there are no unresolved 4
- items which may impact that system. Open items for review include (among others) operating experience reviews, maintenance work requests, and temporary conditions.
The completion of this review will be certified by the ' system engineer and reviewed by management, second, the manager of each station department will review open action items, condition reports, training, etc., to ensure that.his department is ready to support startup and plant operation. As with the system engineer, the completion 1
of the review will be certified by the department' manager and reviewed by senior management.
i Any item that meets one or more of the following criteria must be addressed prior j
-to startup:
e
.-The item could affect nuclear safety.
4 i
e.
The ' item is necessary for a safety system to satisfy its design function.
l
'e
The item'is needed to comply with the CNS Technical Specifications.
)
j e
.The item - may' result in reduced safety system availability, increased forced. outage rate, or reduced capacity factor in the time before.it is
~
geompleted or resolved.
j
.Page 7 of 9
.j 1
m
-4
ih.. '
LyLS940036..
August 8, 1994 s
ATTACHMENT'1<
4.
FIELD COACHING TEAM Obtaining prompt and. precise feedback on performance in the field has been a
[
problem at Cooper Station.
This has occurred in great part because effective communication methods to ensure that this information exchange occurred did not exist in all areas.
To remedy this deficiency. for.. the short term, CNS has established a multi-dinciplined team of CNS personnel headed by an independent manager charged with monitoring operations, maintenance, and surveillance testing
.in the field to ensure management requirements for proper testing and maintenance are understood and executed.
i Charter A charter has been written for this Field Coaching Team (FCT) which establishes specific criteria f or observation and evaluation of field activities.
At a
' minimum, the FCT team will observe adherence to procedures, identification and resolution of procedural inadequacies, awareness of any potential-for a process.
or activity to contribute to preconditioning, demonstration of effective communication, and the performance of work in a safe and quality manner.
4 Scone l'
This process will focus at a minimum on:
J-
'e-Adherence to procedures / instructions.
e Identification and resolution of procedure / instruction problems and inadequacies.
Identification and resolution of any potential preconditioning problem.
e Identification and resolution of ineffective communication.
o-Ensuring ef fective utilization of resources to accomplish tasks safely and with quality results, e
Insuring any perceived schedule pressure is corrected.
Insuring identification of problems and generation of CRs when appropriate.
Application and consistent use of self-checking.
A j
e Supervisory involvement in field activities, Process FCT personnel will be provided with orientation training by the Site Manager to ensure _that-they fully understand management expectations.
Once trained, team members will disperse into the field, making their presence and function known to.. all personnel engaged in an observed activity.
At no time will the team Page 8 of 9
ali
.+.
,. + -
..W45 A
, a42 a
.e&
,.4e A a J 4+4_.Ar#,
sah.g a
c..
NLS940026 August-8, 1994 ATTAC}DfENT 1 s
subvert the role of line management -- in fact, they will serve as augmentation to line management's ability to observe and correct inappropriate practices.
Specific. techniques.for assessment will be as dictated by:the activity.being observed, with appropriate consideration to the level of intrusiveness necessary
- to fulfill the objective and purpose of the FCT process. The District currently i~
- anticipates that the FCT team will observe pre-startup testing, and startup and power ascension testing, once the startup and power ascension is complete, the c
[
team will remain in place to observe field activities until its purpose has been fulfilled, f
i 4
3 a
i.
?
1 A
d e.
1
.i 1
l l
l 4
1 Page-9 of 9
a NLS940026 August 8, 1994
&TTACHMENT 2 i
ABM Switches and Reector Eauipment Coolina Pioina As noted in Attachment 1, the 1993 CER review effort established a screening criteria for determining which findings required additional focus. This effort utilized a sampling approach to determine with reasonable assurance that previous OER efforts were satisfactory.
Results of an assessment of the 1993 reviews could fall in one of three primary categories: (1) the components were not part of the sample group and therefore, the District's re-review did not directly miss potential safety issues, (2) the components were reviewed by the District as part of its sampling effort and it was reasonably concluded that the issues had been adequately addressed, or (3) the components were reviewed by the District as part of its sampling effort and it was erroneously concluded that the issues had been adequately addressed.
A review was performed to determine whether the SBM switches and REC issues had been specifically assessed by the OER review. Neither the SBM switches nor the
- REC issues were included in the sampling review. Therefore, it is reasonable to conclude, based on current findings, that these previous reviews were adequate.
This conclusion, however, should not be considered an excuse for not identifying the SBM switch and REC issues. Proper questioning attitudes should have led to further discussion and satisfactory resolution of these issues. Notwithstanding these conclusions, the District assessed the potential safety significance of SBM switch failures and the REC System.
A brief summary of safety significance conclusions is provided below.
SBM Switches 4
A review of SBM switch operating history at CNS illustrates that since GE SIL 155, "Possible Failures of Type SBM Control Switches," recommended inspection and refurbishment of the switches in 1980, there have been two switch failures (February 1989 and July 1994) due to the phenomenon described in the SIL.
Seven additional switches with broken cam followers have been observed. However, this condition did not result in switch failure and none of the failures or cracks have occurred in switches refurbished in 1980.
During recent inspections a majority of switches not refurbished in 1980, had one or more cam followers categorized as " Category B" per GE SIL 155.
However, this status is not considered a failure.
GE does not recommend these switches be replaced and has conducted testing that shows approximately 45,000 successful switch cycles can be expected before switch failure. Therefore, the Category B switches are expected to perform upon demand.
However, the District will establish a replacement protocol for the pre-1976 switches.
With approximately 140 installed essential switches and 14 years of operating experience since switch refurbishment, two switch failures equals a failure rate of 0.001 f ailures per year or approximately one switch failure every eight years.
Additionally, industry experience (as evidenced by industry data base searches) indicates an extremely reliable switch operating history.
The District evaluated whether any safety functions would have been defeated had the switch failures occurred during a design basis accident.
In summary, no safety functions would have been adversely impacted. This is due primarily to Page 1 of.2
g.
e NLS940026 August 8,
1994 ATTACHMENT 2 a combination of design redundancy in the switch contacts and components that are not required to change position to perform their intended safety function.
' REC System On July 29, 1994, a pinhole leak was discovered in a 12 inch non-essential REC weld. A section of the weld containing the flaw was sent to General Electric for metallurgical examination. The examination determined that Intergranular Stress Corrosion Cracking (IGSCC) was the most likely cause.
The root cause was then determined to be nitrite induced cracking similar to that experienced in 1979 and 1980 at CNS.
Subsequently, a second leak was found in a 6 inch section of non-essential piping.
An inspection program was initiated using the methodology defined in NCIG-02 (revision 2),
" Visual Weld Acceptance Criteria, Volume 2:
Sampling Plan for Visual Reinspection of Welds."
The scope of the inspection eventually encompassed Ultrasonic Testing (UT) of 117 welds in the essential portians of the system piping.
Of the 117 welds examined, 5 were found to have crack-like indications. Of the 5 welds with indications, 4 were acceptable per IWB-3600.
All 5 wolds will be repaired prior to startup.
The remaining 112 welds had no crack indications.
The District also has performed a preliminary safety assessment of the as-found condition of the REC system.
Of the 5 flaws found, 4 were acceptable per IWB-3600 and did not represent a threat to piping integrity.
The remaining indication was within the critical flaw size and therefore, had it continued to propagate, would have leaked before the structural integrity decreased below acceptable limits.
The non-essential portions of the piping perform ne safety function and are isolated on a design basis event.
The only other safety related system in which nitrites are or were used is the Diesel Generator Jacket Water System.
The use of nitrites as a corrosion inhibitor in diesel generator jacket cooling water is common industry practice.
Per the Cooper-Bessemer "Model KSV Emergency Diesel Generator Lubricating Oil and Jacket Water Analysis Guidelines," (Revision 1 dated 1993), a nitrite based j
corrosion inhibitor program is recommended. Eight of nine current cwners follow l
this recommendation.
No leaks have occurred due to cracking in the Diesel Generator Jacket Water System at CNS and Cooper-Bessemer has no history of jacket water leakage as a result of nitrite use, d
Page 2 of 2
)
-