ML20113G484
| ML20113G484 | |
| Person / Time | |
|---|---|
| Site: | Vogtle  |
| Issue date: | 11/29/1989 |
| From: | Bochhold J GEORGIA POWER CO. |
| To: | |
| Shared Package | |
| ML20092F288 | List:
|
| References | |
| CON-IIT05-227-90, CON-IIT5-227-90, RTR-NUREG-1410 00414-C, 414-C, NUDOCS 9202210422 | |
| Download: ML20113G484 (15) | |
Text
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Proc %ure No.
Approval Vogtl3 Electric Geerating Plent A
00414-c NUCLEAR OPERATIONS Laton No, y
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1 of 15 092.2'7-70 OPERATING EXPERIENCE PROGRAM 1.0 PURPOSE R;'s' procedure establishes organizational recpontibt,lities and implementation instructions to assure that :perating experience information pertinent to plant-safety and reliable operation, originating both within-and outside VEGP, is supplied to appropriate plant personnel and that pertinent industry operating experience information is purposely evaluated and appropriately _ incorporated into plant procedures and programs.
This procedure' addresses-the requirements for an Operations Assessment Program established by NUREGs 0660 and 0727, Item I.C.S.
2.0 DEFINITIONS, 2 ~.1 OPERATING EXPERIENCE REPORT (GER).
Any_ document. designated for review and response action l
as:part of the Operating Experience Program.
OEks may
- be from event.s occurring at - other' plants in the 11ndustry,'from-in-house events or vender reports and
_normally include " lessons learned" that are of value to Plant Vogtle safety and_ reliability.
- e 2;2 INDUSTRY EVENT REPORTS Industry Event Reports concidered for evaluation are described-below, a.
- Licensee Event Reports (LERs) - Operational experiences that are reported to the Nuclear
' Regulatory-Commission (NRC) as delineated in 10CFR50.73 and in the Plant Technical Specifications.
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d PRoCEDJ3E NC REvtSloN PAGE No.
lADGP 00414-C 7
2 of 15 b.
These reports provide brief technical descriptions of-events having generic safety implications and ongoing analyses, Significant Operating Experiene Reports (SOERs) c.
SOERs are formal written reports discributed by INPO.
Each SOER is color-coded to indicate sugggated priority for review red (immediate attention), yellow (prompt attention), and green (normal attention).
The standard SOER contains (1)
The event report reference (i.e., the LER or other sources which document the event)
I (2)
A summary description of the event (3)
A statement as to why the event is considered significant l
t (4)
Any generic recommendations developed as a result of the analysis, i
d.
Operations and Maintenance Reminders (OMRc) 1 This report is used by the INPO Analysis Department staff to present operations and maintenance reminders (OMRs) generated primarily from the review of LERs.
The OMRs do not have the safety significance of SERs, but do contain valuable operations and maintens.nce information.
The OMRs are purposely.brief to allow Operations and Maintenance personnel to review them at-a-l L
glance.
NRC Event Reports of significant operating e.
experiences, as disseminated by the NRC.
Those considerad for review and evaluation are:
(1)
NRC Bulletins (IEBs),
(2)
NRC Information Notices (IENs),
(3)
NRC Generic Letters (G.L.s) 1
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QEVISloM VEGP 00414-C
-7
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2.3-
-NUCLEAR NETWORK A computerized international electronic cor.municetion system.
Network provides a megns for_regaesting-and exchanging Nuclear -Power Plant relateu experience
-information with other-participating industry members.
For Vogtle,linformation can be requested or else responses are solicited for Network entries involving any one of the-following topic categories:
- Design, Construction, Emergency Planning, Ffre Protection, Plant Security, Human Performance, Records Management, Operations, Maintenance, Chemistry, Quality Assurance, Radiolog. cal Protection, and Staffing.
Other functions of Training,stwork includes Nuclear N (1) _ Utilization by INPO for~ distribution of SERs and OMRs
.(2)
'Provides compilations of notifications of plant events as reported to=the NRC since the last receipt of Network information, (3) 'Provides a means to input deceriptions of
">otentially-significant Vogtle events for the senefit of other-participating-industry members.-
2.' 4 VENDOR REPORTS
-_ Reports identifying prob' ems and recommended corrective actions associated with vendor equipmpnt systems and services.
Vendor reports are processed on an "as-
- received basis". Examplha-of Vendors Reports are-Westinghouse-Technical Bulletins (WTBs), GE Service c
Information Letters (GESIL);and--GE Technical Information Letter (GETIL).
I 2.5
=IN-HOUSE EVENT REPORTS Reports.of significant operating experiences occurring et VEGP are classified as In-house Event Reports.
For the purpose of this procedure, significant-In-house Event Reports are considered to-include Vogtle LER's and Event Critique Reports for events not reportable under 10CFR50.7a.
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PQoCEDUW3 No.
REVISJoN PAGE Geo.
VEGP 00414-C-7 4 of 15 3.0 RESPONSIBILITIES NOTE
' Actions performed by an individual mentioned in this procedure may be performed by that individual'a designee.
I 3.1 MANAGER TECHNICAL SUPPORT The Manager Technical Support (MTS) has everall I
responsibility for direction, control and administration of the Operating Experience Program.
These responsibilities include the following Coordination of program requirements with other a.
department managers and offsite groups as i
applicable.
b.
Approval of reports of significant Vogtle operating experiences for.2ntry en the Nuclear Network System.
3.2 DEPARTMENT MANAGERS i
i Department managers assure performance of the following requirements for OERs affecting their area of responsibility:
3.2.1 Ensure that assigned OER information has been i
distributed to the appropriate personnel for their information.
I 3.2.2 Reviewing and providing department approval of OER evaluations.
3.2.3 Screening of completed evaluations prior to dissemination to ensure personnel do not receive information that is conflicting or contradictory with existing procedural directions or training programs until resolution is reached.
3.2.4 Completion of department OEP action items in a timely manner.
I 3.2.5 Appointing a department OEP Coordinator to interface with the OEP Coordinators concerning OER evaluations and the feedback of Departmental In-house Events Reports to the OEP Coordinators.
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PAGE NO.
'PAocEDURE No..
REVISION NVEGPJ
!00414-C-
!7 5.of 15
3.3 OPERATING
EXPERIENCE PROGRAM (OEP) COORDINATORS
.(Technical' Support and-Independent Safety Enginearing Group)
IThe OEP Coordinators, have responsibility for coordinating the Operating Experience Program.
The Technical Support OEP Coordinator will coordinate I
OEP activities related to NRC Event Reports and the ISEG OEP Coordinator will coordinate OEP activities I
related to INPO Event Paports.
3.3.1 The 0EP Coordinators aru the focal point for receiving OERs.
3.3.2 OERs.-recel'ved by'the OEP Coordinators should be reviewed and-recorded in appropriate-loge.-
13.3.3.
The OEP Coordinators will identify appropriate
-departments.for distribution of OERs.-
3.3.4_
The OEP Coordinators will select OERs.for evaluation purposes ar.d assign priority for-performing such cvaluations.
- 3.3.5-
.The;0EP. Coordinators will ensure a quality review of completed evaluations is performed.
3. 3.' 6 The Technical 1 Support.0EP_ Coordinator screens and I
ensures distribution of1 Network information.
NOTE The Independent. Safety Engineering Grcup functionally su? ports'the
- Operating Experience.?rogramc(OEP) but_ organizationally reports 1offsite to_the_ Manager Safety-Audit and Engineering Review.
This functional support does not negate its-organizationalHor regulatory Eresponsibilities.
4.0 INSTRUCTIONS 4 ~.1 OPERATING EXPERIENCE PROGRAM DESchIPTION n
'Thefoverall objective of the Operating Experience Program =isi o ensure' Industry and'In-house-significant t
lessons-T(earnedLare translated into appropriateexperiences a peratin l-o correctivesactions and' control programs for enhancement p
i of-plant safety and reliability.
Specific program objectives: are summarized below.
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PQoCEDURE No.
REvlStoN PAGE No VEGP 00414-C 7
6 of 15 NOTE Significant In-house operating
_ experiences are evaluated and appropriate corrective actions are det rmined in accordance with the requirements of Procedure 00057-C, " Event Investigation".
4.1.1 Program implementation includes a screening process to determine the relative importance a..d applicability of OERs considered for evaluation.
4.1.2 The program provides a decision -' king process to ensure:
(1) The results of evaluation are disseminated to appropriate departments in a timely manner Personnel do not routinely eceive a large volumu#
(2) of OERs which might obscure priority information or otherwise detract from overall job performance and proficiency.
4.1.3 The program ensures significant OERs and attendant corrective actions are reviewed and approved by experienced technical personnel.
4.1.4 The program provides a method for documenting the disposition of operating experience information received and resultant actions taken.
4.1.5 The program provides for evaluation of actions taken to implement lessons learned from OERs.
4.',6 The program provides a method for identifying and evaluating In-house events as described by Procedure 00057-C.
4.1.7 The program provides periodic reports to plant and corporate management on the status of OER screening, evcluation and corrective actions.
4.1.8 The program provides for approval of OERs results and recommended corrective actions by appropriate plant management personnel.
4.1.9 The program establishes communication channele via Nuclear Network for exchange of operating experience information with other utilities.
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PQocEDUAE No.
PEVIStoM PaGE No VEGP 00414-C 7
7 of 15 4.2 RECEIPT OF 0PERATING EXPERIENCE REPORTS 4.2.1 The OEP Coordinttors will be the focal ooint for I
receipt of industry and significant In-house event reports.
4.2.?
Industry event reports may be received through normal company mail or through Nuclear Network.
4.2.3 A copy of Vogtle LERs will be obtained by the Technical Support OEP Coordinator after submittal to the NRC and a copy of Vogtle Event Critique Reports will be obtained after all corrective actions are determined.
4.2.4 heceipt o[ OERs should be recorded in the OEP electronic database.
4.3 SCREENINC AND PROCESSING OF OPERATING EXPERIENCE REPORTS 4.3.1 Screening And Selection For Evaluation The OEP Coordinators are responsible for screening and the sel.ection of OERs for evaluation.
The objective of the screening process is to identify the appropriate departments for receipt of OERs and to select for evaluation those reported industry events having potential impact on the safety and reliability of the 11 ant.
Deaartments for OER distribution are identified sased on t2e relative importance and applicability of the exaerience informar'en to the various job functions of eaca department.
4.3.1.1 Categorizing Industry Event Reports The OEP Coordinator should perform a preliminary review of Industry Event Reports and Vendor Reports.
The categories of the preliminary review are as follows:
has direct impact on Applicable Specific (AS) a.
VEGP.
could be of generic b.
Applicable General (AG) impact or could indicate trends.
i contains supporting c.
As Future Reference (AFR) information relevant to the design and operation of VEGP.
does not apply.
d.
Not Applicable (N/A)
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NoCEDURE No.
GEVISloN PAGE No.
VEGP 00414-C
-7 6 of 15 4.3.1.2 Screening.for Significance The following minimal criteria may be used to determine significance of industry OERs The OER identifies a potential for degradatrar of a.
a safety-related system to the extent that tr could not meet design performance requireat' s for accident functions.
b.
The OEK identifies a potentially unreviewed safety question.
c.
Occurrence of the OER could result in the implementation of an emergency operating procedure or abnormel operating procedure, d.
The OER indicates inadequacies in plant procedures or programs.
The OER identifies a potential for an uncontrolld'd e.
or unanticipated release of radioactivity or
.. personnel exposure, f.
Occurrence of the OER could cause a forced catage, The OER indicates a needed change in the Tevhnical g.
Specifications of the plant.
h.
-Important " lessons learnod" or safety benefits would result from evaluation of the OER.
If the screening process indicates an OER may he significant, the OER should be assigned for evaluation:
e otherwise, the OER should be considered for I
department distribution and review only.
I 4.3.1.3 Screening for Urgent Department Staff Notificacien If the OER indicates a need for urgent plant oraff action, then copies of the report will be promptly forwarded to appropriate department staff superutsion and a preliminary evaluation performed.
Reports selected by the reviewer for urgent plant staff notification.should be immediately brought tS tha attention of the OEP Coordinators.
4.3.2 Results of the screening process should be resa:-dad in the OEP clectronic data base.
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PRoCEDUPE No.
HEWStoM PAGE No.
VEGP 00414-C 7
9 of 15 4.3.3 OERs selected for department distribution should have I
the distribution copy stamped with an "0EP" stamp to distinguish these items from cther operating experience information.
Also, indication should be made to note whether the OER has been assigned to a technical evaluator for further evaluation purposes.
4.4 DEPARTMENT SCRE12.NING AND REVIEW l
4.4.1 On receipt of OERs and OER evaluation summaries forwarded by the OEP Coordinators, the Department i
OEP Coordinator will perform a further screening of these itegs.
The objective of this screening process will be to identify the departmental personnel that should be made aware of the experience information provided by the OER or the applicability determination (s) and/or corrective actions as stated in the evaluation summary.
4.4.2 In determining the appropriate dissemination of OEP information, the Department OEP Coordinator should I
assure that personnel do not routinely receive extraneous or relatively unimportant information in such volume that it might obscure priority experience information or otherwise detract from overall job performance and proficiency.
Also, it should be assured that personnel do not receive information that is conflicting or contradictory with existing procedural directions or training requirements until resolution is reached.
4.4.3 If OEP information has been determined to be " URGENT" per step 4.3.1.3, or should the lessons learned information otherwise appear to be of sufficient importance, the Department OEP Coordinator should i
ensure that affected personnel are made aware o_' and
-undetstand the information in a timely manner (i.e. it does not wait for emphasis through routine training or retraining programs).
4.4.4 Normal dissemination of OEP information to identified personnel may be made by use of Deoartment required I
reading programs or by other suitable mechanisms which will ensure a proper level of awareness and understanding is attained.
4.4.5 Results of the department screening should be recorded i
or logged appropriately and a record of the department personnel that actually reviewed or were made aware of OEP information should be maintained sufficient such that this information can be retrieved.
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UROCEDUQE No.
GEVISION VEGP 00414-C 7
10 of 15
'4.5 OER EVALUATIONS 4.5.1 Obj ective Of OER Evaluations The object'ive of performing an OER evaluation for Industry Events is to determine che implicar. ions the OER might have for the plant and to propose corrective actions as appropriate.
4.5.2 The OEP Coordinators will assigu OERs requiring I
evaluation to a technical evaluator for performance of the evaluation.
The evaluator is en experienced individual in the area of nuclear power plant operations.
4.5.3 The technical evaluator will review the OER for specific and/or generic applicability to Vogtle and identify all.of the concerns contained in or implied by the OER.
4.5.4 The technical evaluator will determine the status of implementation of each OER concern in plant programs, procedures and practices.
The Department OEP Coordinators should provide a department interface to t
appropriate procedures and personnel.
4.5.5 The technical evaluator will recommend what, if any, immediate corrective action is needed and identify such immediate corrective action to his Supervisor.
4.5.6 The technical evaluator should conduct investigations, interviews and research as necessary for a thorough evaluation. Typical sources of technica] information to be considered are plant and corporate staff members, vendors, architect / engineers, INPO snd EPRI.
The technical evaluator should_ request any special expertise needed to conduct investigation.
4.5.7 Formulating / Reviewing Corrective Action 4.5.7.1 In formulating the proposed corrective action for Industry Events, the following areas should be considered:
Changes to operating, maintenance, surveillance
- a..
and emergency response procedures.
b.
Changes to the emergency plan.
Changes to training, radiation protection, c.
inspection, and administrative control programs.
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e PROCEDURE No.
REVISloM PAGE No.
VEGP 00414-C 7
11 of 15 d.
Changes to plant or equipment design.
4.5.7.2 The proposed corrective actions and findings should be completed _to a level of detail that contains equipment tag numbers, procedure numbers, training requirements, etc.
4.5.7.3 Department Review of Proposed Corrective Actions All Departments whose area of responsibility may be impacted by proposed corrective actions will be contacted by the technical evaluator to gain concurrence with the proposed corrective actions and schedule.- (See Figure 1 for an example: of Summary Sheet to be used for. Department review and concurrence.)
The Department OEP Coordinator should provide the interface with the OEP Coordinators to ensure the Department review is completed in a timely I
manner and questions and misunderstandings concerning the evaluation are clarified.
4.5.7.4 Resolution of Disagreement Disagreement between a technical evaluctor and a department concerning an OER evaluation and/or proposed corrective actions should be attempted to be resolved before proceeding to the Coordinator level.
A conference type meeting may be used for this.
If resolution is not reached between the technical evaluator and the involved department (s), then the items in disagreement will be reviewed by the next level of management, i.e., NSAC Suaervisor or ISEG 1
Supervisor, and a meeting will be held for discussion / resolution of the items.
A continuing disagreement will proceed to the Manager and Gener: 1 Manager - Nuclear Plant level.
l 4.5.8 OEP Coordinators Review The OEP Coordinators perform a quality review of completed evaluations to determine their acceptability and disposition for continued processing.
4.5.8.1 Evaluation Acceptability The OEP Coordinators review : n accordance with the following criteria Does the evaluation apaear to be complete and of a.
-sufficient depth for the event described?
b.
Is the technical content well conceived and correct?
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REVISloN PAGE No.
VEGP 00414-C 7
12 of 15 4
Have organizations and individuals of appropriate c.
technical knowledge and experience been consulted for response input?
d.
Are appropriate and sufficient proposed corrective actions specified along with projected dates for completion?
Does the response address both specific and e.
generic applicability?
4.5.8.2 Evaluation Disposition Completed, evaluations may be dispositioned as closed with action or without action.
The criteria for evaluation disposition are as follows:
When the evaluation findings and conclusions meet a.
the following conditions, then the evaluation may be dispositioned as closed, no further action needed:
(1)
Within the concerns of the OER no inadequate problems exist in plant design, procedures, components, training or operating practices.
(2)
NONE of the procedures or programs that may already implement the concerns of the OER for VEGP have significant information that should be tracked to ensure it recains implemented, b.
If evaluation findings and conclusions disclose inadequacies or problems associated with plant design, procedures, components, trainir.g or operating practices and corrective action is required, the evaluation may be dispositioned as closed with action.
Also, the evaluation may be dispositioned as closed with action where significant concerns have previously been incorporated'in plant procedures or programs but assurance is needed that the pertinent information remains implemented, Actions identified in " closed with action" c.
evaluations will be tracked through Procedure 00409-C "Open Item / Commitment Tracking".
" Closed" Commitment Tracking items may be used to ensure implementation remains in plant documents.
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VEGP 00414-C 7
13 of 15 4.5.8.3 Distribution of Completed Evaluations The OEP Coordinator will identify appropriate l
departments for receiat of OER Evaluation summaries.
Distributibn copies should be stamped with an "0EP" stamp to distinguish these items from other operating experience information.
4.5.9 Evaluation And Status Control 4.5.9.1 Status Records and Information The Operating Experience Program Coordinators maintain records rgflecting status and disposition of OER evaluations and their associated corrective actions.
Collectively, the records should provide sufficient documentation for determining the information listed
- below, Identification of reports and source material a.
screened by the OEP Coordinator to select OERs.
b.
The departments who were identified as recipients
'of OERs through the screening process Department review and acceptability of proposed c.
corrective actions.
d.
Identification of individuals having performed the evaluation.
Disposition of closed items.
e.
f.
Identification of groups assigned implementing actions.
g.
Overall plant position for each OER.
'4.5.9.2 Completion status and follow-up verification status of completed action should be entered into the OEP electronic data base to provide a record of implementation status.
4.6 OEP MANAGEMENT REPORTS The Operating Experience Program status shall be periodically reported to Plant Management.
Program status should be by written report and should include, as a minimum, significant OERs under evaluation, received and closed, and recent significant problems and accomplishments of the program.
OEP status will be reported separately by Technical Support and by ISEG for their respective areas of responsibility, wo
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LEVISi N PAGE NO.
- VEGP 00414-C 7
14 of 15 4.7 OEP EFFECTIVENESS OEP offectiveness' reviews will be are performed by Technical. Support and ISEC in accordance'with the
{
requirements of their departmental instructions.
Reports _of_ effectiveness evaluations may include the status information described in step 4.6.
5.0-REFERENCE 5.1' NUREG - 0737,Section I.C.5
.5.2 INPO_ Good Practice, OE 901 5.3 INPO Good Practice, OE 902
-PROCEDURES 5.4 5.4.1 Procedure 00057-C, " Event Investigation" 5.4.2 Procedure 00409-C, "Open Item / Commitment Tracking" l
E 5.4.3
_ Procedure 81050-C, " Operating Experience Program I
Coordination" END OF PROCEDURE TEX 1
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PROCEDU, E NO.
- EVI3 ION VEGP 00514-C 7
15 of 15 OPERATING EXPERIENCE PROGRAM EVALtJATION
SUMMARY
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OER CONCERN / RECOMMENDATION:
f COFEENT/ DISCUSSION:
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