ML092650709
| ML092650709 | |
| Person / Time | |
|---|---|
| Site: | Palisades  |
| Issue date: | 09/24/2009 |
| From: | Entergy Corp |
| To: | NRC/RGN-III |
| References | |
| Download: ML092650709 (20) | |
Text
Palisades Substantive Cross Cutting Issue Status September 24, 2009
2 Agenda
Introductions
Issue Summary and Causal Analysis Results Root Cause / Contributing Cause Action Status Open Discussion and Feedback
3 Substantive Cross-Cut H.2.C Palisades received a substantive cross-cutting issue (SCCI) at the end of 2008, in the aspect of documentation / procedures (H.2.c). The SCCI was carried over because corrective actions were new or not yet implemented at the mid-cycle review.
4 Root Cause Plant personnel did not recognize the importance of high quality procedures / work instructions as evidenced by an inadequate focus on prioritizing, monitoring, scheduling, and implementing needed procedure changes.
5 Contributing Cause Procedure revision process did not support:
- timely revisions
- revision backlog prioritization
- efficient processing of revisions
6 Root Cause Actions Procedure Improvement Team Procedure / Work Instruction Need and Content Benchmarking Training Site Communications
7 Completed Actions - Root Cause
Procedure Improvement Team Charter
Multi-discipline team
Improve procedure quality
Provide procedure training (What Good Looks Like)
Provide tools for procedure revision management
Meets weekly
Monthly progress report to leadership team
8 Completed Actions - Root Cause
Procedure / Work Instruction Need and Content
Procedure writer peer group meetings
Work planning quality review team meetings
Review of procedure related condition reports
Checklist to assess procedure quality
9 Completed Actions - Root Cause
Benchmarking identified the following gaps:
No formal procedure user training
No formal procedure writer qualification program
Procedure reviews not targeted to experience level
No recurring procedure quality assessments
10 Completed Actions - Root Cause Site Communications Procedure improvement team web page Expectations to identify procedure revisions during training, walkdowns and usage.
11 Completed Actions - Contributing Cause Procedure Revision Management Established Document Revision Notice (DRN) screening team and criteria Screened backlogged DRNs Created performance indicators (PIs) to track DRN backlogs
12 Completed Actions - Contributing Cause 1654 Total 1187 Priority 5 - Enhancement 410 Priority 4 - Scheduled 57 Priority 3 - Required 0
Priority 2 - Vital 0
Priority 1 - Immediate Open DRNs Description Palisades August 2009 DRN Backlog Performance Indicator Summary
13 Completed Actions - Contributing Cause
Performance Indicator Summary
Risk informed by prioritization thru screening with multi-discipline team
Expect initial DRN backlog growth prior to reduction as station applies what good looks like
PIs used to monitor and manage DRN backlog
14 Remaining Actions - Root Cause
Need and Content
Evaluate gaps between task qualification and procedure content
Implement a work plan standard
Conduct an assessment of procedure and work instruction quality
Conduct work planner in-field observation of work instruction implementation
15 Remaining Actions - Root Cause
Need and Content
Audit routine station tasks to determine if additional procedural guidance is needed
Flow chart selected station processes to determine if station and fleet procedure guidance facilitate task performance
Review selected processes that are covered by both site and fleet procedures to identify overlap or conflicts
16 Remaining Actions - Root Cause
Training
Train site management on the importance of providing high quality procedures and work instructions
Conduct INPO Procedure Writer Seminar for procedure writers and work planners
Train site procedure users and reviewers on what good looks like
Conduct work order package walkdown training for maintenance supervisors and craft personnel.
17 Remaining Actions - Root Cause
Training
Establish 5-year work planner training matrix
Conduct EPRI work planner training
Establish qualifications for procedure writers and reviewers
Establish continuing training needs for procedure writers, reviewers, and users
18 Remaining Actions - Root Cause Communications Periodic site communications on procedure improvement team progress.
Outside of Procedure, Processes, Parameters-STOP (OOPS) Program
19 Sustainability
Procedure quality assessments
Work package quality reviews
Continuing training and qualification program
Procedure writer peer group
Management observations
20 Open Discussion and Feedback Open discussion and feedback