ML17227A121

NEI 16-07 Revision a, Draft Technical Report, Improving the Effectiveness of Issue Resolution to Enhance Safety and Efficiency, Public Meeting- Ne Presentation

ML17227A121
Person / Time
Site:	Nuclear Energy Institute
Issue date:	08/15/2017
From:	Nuclear Energy Institute
To:	Division of Policy and Rulemaking
Sanders S, NRR/DIRS, 301-415-2956
References
NEI 16-07
Download: ML17227A121 (28)

Text

Briefing for NRC Headquarters on NEI 16-07 Improving the Effectiveness of Issue Resolution to Enhance Safety and Efficiency August 16, 2017 1

Purpose of todays meeting

• Brief NRC stakeholders on the origins and contents of NEI 16-07

• Hear and respond to NRC stakeholder questions and concerns

• Discuss path forward and next steps

- For industry

- For NRC 2

Origins - The Haystack Problem

• CAP originally applied to conditions adverse to quality (a small haystack)

• In that small haystack, significant items were relatively easy to recognize and manage

• Over time, CAP became a catch-all for tracking everything that needed attention (a large haystack)

• In that overgrown haystack, important items were more difficult to recognize and accord the right level of attention and effort 3

Origins - CNO Recognition

• CNOs recognized the haystack problem

• The first effort to address it was INPO 14-004 (November 2014), aimed at improving screening and focus

• DNP Improvement Opportunity CAP-01 [EB 16-10, March 2016], said implement INPO 14-004

• DNP Improvement Opportunity CAP-02 [EB 17-14, May 2017], aims at standardizing terms and processes, simplifying tools and clarifying guidance for tailoring effort to significance 4

Origins - Charge to the CAP-02 Team

• Maintain low threshold for initial entry into CAP, to ensure employees report all conditions and concerns

• Maintain CAP focus on CAQ/SCAQ (Appendix B items)

• Maintain focus on regulatory matters of importance (items outside Appendix B)

• Tailor level of investigation and causal analysis to the significance of the problem

• Address business-risk issues through other appropriate systems 5

Industry Milestones

• Release NEI 16-07 May 2017

• Brief utility and NRC stakeholders

- RUG II - Completed June 20

- RUG IV - Completed July 12

- NRC Headquarters - August 16

- RUG III - October 24

- RUG I - November 28

• Update NEI 16-07 with feedback from briefings and comments and reissue as Final - early 2018

• Implement DNP EB 17 May 2018 6

CAP-02 Development Team

• Executive Sponsors

• Industry Members

- Danny Bost - Southern - Wally Beck - Exelon

- Dan Stoddard - Dominion - Brad Castiglia - NextEra

- Kelvin Henderson - Duke

- Nick Conicella - FENOC

• Industry Lead - Dan Crofoot - Xcel

- John Grabnar - FENOC

- Joel Duhon - Duke

• INPO - Sharon Peavyhouse - Duke

- Gary Waldrep - Reiko Perleberg - Southern

• IBEW - Rex Putnam - Entergy

- Anna Jerry - Lanny Ratzlaff - Wolf Creek

• NEI - Jim Schleser - Dominion

- David Young, Jim Slider

- Tim Steele - Southern 7

Guiding Philosophy Achieving the highest levels of safety and reliability requires high levels of efficiency and effectiveness

• Maintain low threshold for condition reporting and feedback to originators

• Improve timeliness and effectiveness of problem resolution by eliminating low-value process controls and administrative requirements

- Promote greater focus on conditions affecting safety and operational performance

- Standardize reporting, screening and processing to reduce administrative and management review time

- Afford leaders with more time to spend in the field observing work and coaching improvements 8

Related Work

• As noted earlier, NEI 16-07 builds on previous CAP initiative (DNP CAP-01)

• CAP-01 was about improving screening efficiency to highlight the safety significant needles in a smaller hay stack

• CAP-02 standardizes around a common language and investigation tools - its the next logical step 9

What Will Change for Licensees

• Population of items in CAP will be better defined

• Many items will be addressed at find-and-fix level, depending on perceived risk

• CARC protects and maintains industry commitments underlying the ROP (e.g., SECY-99-007 and NRC Enforcement Policy section 2.3.2)

• Industry-wide templates will be used for Equipment Failure, Human Performance, and Organizational issues

• Conditions outside the scope of CAP will be addressed through management action 10

What Will Not Change for Licensees

• Low threshold for reporting remains unchanged

• Safety-related and important-to-safety equipment conditions and issues of regulatory significance will continue to be managed in CAP

• CAQs must be identified and corrected

• SCAQs must have cause determined corrective actions taken to preclude repetition

• Information system(s) for tracking CAP entries will remain as the central clearinghouse for status 11

What May Change for NRC

• Inspectors may need to look outside CAP data system to confirm screening has been appropriate and that CAQ and CARC are appropriately addressed

• With the emphasis on find and fix, inspectors may find less documentation of formal investigation and analysis of items of lesser significance 12

What Should Not Change for NRC

• Effectiveness of the licensees CAP program

• Basis for crediting licensees CAP in NRCs decision-making processes (e.g., Enforcement Policy and ROP-based supplemental inspections) 13

CAP Process Changes All Is sues CAP Issues Non-CAP Issues Si gni fi cant Condi tions Adver se to Qua li ty Appendi x B Conditi ons Adver se to Qua li ty Conditi ons Adver se to Reg ul atory Com pl ia nc e 14

Definitions

• Significant Condition Adverse to Quality (SCAQ): A condition adverse to quality that, if left uncorrected, could have a serious effect on nuclear safety.

• Condition Adverse to Quality: A failure, malfunction, deficiency, deviation, defect, or nonconformance associated with the performance of an activity affecting the safety-related function of a structure, system or component.

• Condition Adverse to Regulatory Compliance: A condition where the licensee is not in conformance with NRC regulations, inspection or enforcement processes (such as the Reactor Oversight Process), a failure to comply with a docketed commitment made to the NRC, a non-compliance with the licensee Quality Assurance program that does not consequently affect nuclear safety. Conditions Adverse to Regulatory Compliance are addressed with licensee corrective action programs. Appendix A provides some examples to enhance understanding.

15

Issue Resolution Process 16

Issue Resolution Process 17

Criteria for an Approved Process

• A program document or procedure describes the process

• The process identifies conditions that require generation of a CR

• Process controls:

- Provide for identifying conditions that require a prompt review by Control Room staff (e.g., for operability, functionality and reportability determinations)

- Prioritize and track work based on risk to nuclear safety and equipment reliability

- Ensure that the work performed is traceable

- Ensure that canceling, extending or changing the intent of work that is a corrective action includes the same level of review as established the original action

- Provide for generation and retention of action/work completion documentation suitable for QA record purposes

• Management oversight is in place to monitor performance of the process 18

Graded Approach to Investigations Cause Uncertainty Cause is Clear Cause is Ambiguous or Complex High

• Issue Investigation

• Root Cause Analysis Consequence

• Correct Condition

• Correct Condition and Cause and Cause Medium

• Document Known

• Issue Investigation Consequence Cause Risk

• Correct Condition

• Correct Condition and Cause Low

• No Investigation

• Investigation Consequence Optional

• Correct Condition

• Correct Condition 19

General Guidance on Conducting Root Cause Investigations

• We expect the numbers of root cause investigations to be reduced - removing business items

• Format is largely unchanged - there are reasons why we did what we did in the past (Extent of Condition, Safety Analysis, Nuclear Safety Culture, etc.)

• Can use existing tools and techniques

• Root Causes will be required for White or greater 20

Investigation Templates

• Equipment Reliability Checklist -

- Developed by ERWG, INPO

- Base Template does not include ICES tags but user templates do

• Human Performance Checklist -

- Developed by HU Working Group, INPO

- Based on TWIN model and others 21

Investigation Templates

• Organizational Effectiveness Checklist

- Developed by OR Working Group, INPO

- Based on Management Systems model and INPO 15-005 Leadership and Teamwork Effectiveness

- There is intentional overlap between HU and OR checklists

• Maintenance Rule Checklist

- Special Case and developed by MRWG 22

Management Action

• N-CAP issues

• Allows for resolution within a tool but outside of CAP

• Business-type issues at manager level discretion 23

Appendix A - Defines some Examples

• Significant Condition Adverse to Quality

• Condition Adverse to Quality

• Condition Adverse to Regulatory Compliance

• Non-Corrective Action Program Conditions 24

Change Management

• Utilities should evaluate their current QA program definitions to determine if changes need to be made

- CAQ, SCAQ

• Screening process changes - procedure changes, evaluate roles / responsibilities

• Software changes should NOT be required

• Communications to key audiences (General Workforce, CAP Screening, Supervisors and Managers)

• Discussions with Resident Inspectors 25

Other NRC Concerns

• Active discussion with regulators at HQ and regions

- Concerns about protecting the SCWE and reporting culture

- Concerns about supervisory engagement and action (for N-CAP issues)

- Concerns about definitions (SCAQ)

- Concerns about investigations for important issues 26

Questions 27

For More Information

• John Grabnar - FENOC, CAP-02 Team Lead

- jjgrabnar@firstenergycorp.com

• Tim Steele - Southern, Subject Matter Expert

- tssteele@southernco.com

• Jim Slider - NEI, Senior Project Manager

- jes@nei.org 28