ML20148C940
| ML20148C940 | |
| Person / Time | |
|---|---|
| Site: | South Texas  |
| Issue date: | 01/02/1997 |
| From: | Rosen S HOUSTON LIGHTING & POWER CO. |
| To: | |
| Shared Package | |
| ML20148C938 | List: |
| References | |
| 0PGP02-ZA-0003, PGP2-ZA-3, NUDOCS 9705290307 | |
| Download: ML20148C940 (17) | |
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i ATTACHMENT I l
COMFREHENSIVE RISK MANAGEMENT PROCEDURE 1
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9705290307 970522 +
c:\wp\n!\nrc-wk\ misc-97\5658. doc STI: 30290784
SoI 637C6' SOUTH TEXAS PROJECT ELECTRIC GENERATING STATION D0527 KWPWPPROVEIN0PWr14rl.MIRO.02M ..
-- Rev.2 Page 1 of 16 Pnm Time / Dar: 12.% PM 12f31/96 OPGP02-ZA-0003 Comprehensive Risk Management Quality Safety-Related Usage: Available Effective Date: 01/02/97 l s L Rosen C. R. Grantom R. J. Rehkugler Industr.y Relations PREPARER TECHNICAL USER . , CoGNrZANroRGANIZATloN Table of Contents
1.0 Purpose and Scope
. . . . . . . . . . . . . . . . . . . . . . . . . . . .. . . . . . . . . . .........2 2.0 References. . . . . .. .. .. . . . . . . . . . . . . . . .. .. .. . . . . .. 2 3.0 Definitions.. . . . . . . . . . . . . . . . . . . ... ...... . . . . . . . .2 4.0 Responsibilities. .... . . . . . . . . . .. ...... . . . . . .. . ... ......2 5.0 Requirements . . .... . . . . . . . . . . . . . . . . . . . . . .. . . . . . .4 l
6.0 Process . .. .. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. . .. . . .... . . . . . . . .. 5 7.0 Records ..... .. . . ..... . . .................................................. ... . .... .. . . . . ... 6 8.0 Support Documents.. .... . . . . . . . . . . .. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . ..6 Addendum 1 Graded Quality Assurance.... .. .. ....... . .... .. .... ............ . . . . . . . . . . . ......... .. 7 Addendum 2 Graded Quality Assurance Program Levels and Descriptions . ... ........ ..... ..... .... ........ . ..12 Addendum 3 Categorization of Plant Systems, Components, and Activities.. ... ... ........ ................... ... .15 Addendum 4 Motor Operated Valve Program...(LATER)............... . .... . . . . . . . ..........................16 Addendum 510 CFR 50 Appendix J Local Leak Rate Testing (LLRT) Program...(LATER). . . . . .. . .. . . 17 i
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OPGP02-ZA-0003 Rev.2 Page 2 of 16 _
l Comprehensive Risk Management
1.0 Purpose and Scope
l 1.1 To establish and provide guidance to the Expert Panel and associated Working Groups on l the implementation of a risk informed, performance based Comprehensive Risk l Management program at STP, l
l This procedure is approved for use in categorization of plant structures, systems and l l components (SSCs); however, implementation of revisions to QA requirements is on hold I pending approval of an Operations Quality Assurance Program revision. l 2.0 References l
2.1 Operations Quality Assurance Plan (OQAP) l l l 3.0 Definitions 3.1 COMPREHENSIVE RISK MANAGEMENT (CRM) l A process by which the change in risk to station personnel, the public's health and safety, and station economics are evaluated as a result of changes in commitments, processes, activities, and human and equipment performance.
1 3.2 GPADED QUALITY ASSURANCE (GQA)
The process by which risk-based methodology (i.e., Probabilistic Safety Assessment (PSA)]
and deterministic anc' performance-based information analyses are combined to establish appropriate levels of programmatic controls for SSCs and appropriate levels of first line and independent oversight needed to provide the necessary assurance that SSCs will operate safely.
3.3 EXPERT PANEL A multi-disciplinary group of individuals whose purpose is to guide the implementation of Comprehensive Risk Management activities at STP.
3.4 WORKING GROUPS Multi-disciplinary groups of individuals who provide risk-informed, performance-based recommendations to the Expert Panel.
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OPGP02-ZA-0003 Rev.2 Page 3 of 16 Comprehensive Risk Management l 3.5 INITIATING EVENT -
! Any event that can cause a plant trip or otherwise initiate a seque'nce of events with a significant probability of core damage. l l
3.6 OPERATING EXPERIENCE GROUP (OEG) l An STP organization that is responsible for the review of in-house and industry operating l experience. i 1
4.0 Responsibilities I l
4.1 EXPERT PANEL '
l 4.1.1 Approve the criteria for categorization of SSCs.
4.1.2 Review and approve the categorization of SSCs.
4.1.3 Approve the criteria for assignment of Quality Assurance (QA) measures for l
SSCs.
l l 4.1.4 Review and approve the assignment of QA measures for SSCs. I 4.1.5 Maintain cognizance over the implementation of the CRM program and adjust program criteria, as appcopriate.
4.1.6 Forward approved categorizations of SSCs and approved assignments of the I j associated QA measures to the Plant Change Committee for action.
4.1.7 Appoint Expert Panel Working Groups j 4.2 WORKING GROUPS 4.2.1 Analyze performance information.
4.2.2 Consider risk insights and risk ranking of SSCs.
t l 4.2.3 Consider the application of proces'ses/ work activities / work organizations to SSCs
! relative to risk.
4.2.4 Inject deterministic knowledge / insight.
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OPGP02-ZA-0003 .Rev.2 Page 4 of 16 l Comprehensive Risk Management
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4.2.5 Develop recommendations, as prescribed in the addenda to this procedure, and ,
provide them to the Expert Panel. -
4.3 STATION MANAGEMENT 1
4.3.1 Nominate and provide guidance to members of the Working Groups. l l
4.3.2 Implement the decisions of the Expen Panel.
l 4.4 PLANT CHANGE COMMITTEE 4.4.1 Integrates categorizations of SSCs and assignments of the associated QA i
measures approved by the Expert Panel into the STP Business Plan.
4.5 CHANGE MANAGEMENT TEAM (CMT) 4.5.1 Provide support and peer review for station management as Expert Panel decisions are implemented.
4.6 SENIOR MANAGEMENT TEAM (SMT) l 4.6.1 Maintain strategic level oversight of the CRM Program activities.
l 4.6.2 Provide resolution of any Expert Panel dissenting opinions.
! 5.0 Requirements 5.1 The Expert Panel is composed of the Managers of Design Engineering, Systems
- Engineering, Nuclear Licensing, Risk Management & Industry Relations, the Administrator l of Risk and Reliability Analysis, the Director of Quality and a General Manager from Generation. The Manager, Risk Management & Industry Relations is chairman of the l Expert Panel. Changes to the Comprehensive Risk Management Expert Panel membership l require approval of the Executive Vice President and General Manager, Nuclear.
5.2 Working Groups shall be comprised ofindividuals as listed on the appropriate addenda to this procedure.
5.3 Expert Panel and Working Group personnel shall be trained to this procedure, associated i PSA procedures and station performance reporting procedures. They shall additionally receive (or have received) familiarization training to 10 CFR 50.59 and Root Cause Analysis.
5.4 The Expert Panel identifies activities, processes, commitments and requirements to be evaluated by the working groups.
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i 0PGP02-ZA-0003-. - Rev. 2 Page 5 of 16, ,
Comprehensive Risk Management f ,
l 6.0 Process 6.1 Working Groups , , ,
6.1.1 Working Groups shall convene at frequencies as established in addendum 1.
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6.1.2 Minimum quorum requirements for Working Group meetings are the chairman and at least three regular members.
6.1.3 Working Group recommendations shall be arrived at by consensus. Dissentions shall be documented for Expert Panel resolution.
6.1.4 Using the criteria established in the addenda, the Working Groups shall analyze performance data, consider available risk information and their own detenninistic insight, and shall develop recornmendations.
6.1.4.1 Recommendations shall be documented, and shall include rationale !
and risk ranking / performance information that forms the bases for the l recommendations. I 1
6.1.4.2 Recommendations shall be forwarded to the Expert Panel. l 1
6.2 Expert Panel 6.2.1 The Expert Panel shall convene, at a minimum, at the same frequencies as established for Working Groups in addendum 1. )
6.2.2 Minimum quorum requirements for Expert Panel meetings are the chairman and l at least three regular members, one of whom must be the Administrator of Risk and Reliability Analysis. There shall be no short term designee representation.
1 6.2.3 Decisions shall be arrived at by consensus. Dissenting opinions shall be documented. Any dissenting opinions shall be forwarded to the Senior Management Team (SMT) for resolution.
6.2.4 The Expert Panel shall use the same criteria as the Working Groups in reviewing recommendations and shall inject their own deterministic insight as appropriate.
Dissenting opinions from the Working Groups shall be resolved.
6.2.5 The Expert Panel shall accomplish the tasks defined in 4.1 of this procedure and l
shall document its decisions. These shall be disseminated to the SMT and the l Change Management Team (CMT).
- 63 The SMT shall resolve any dissenting opinions that require resolution.
Rev.2 Page.6pf 16 OPGP02-ZA-0003 -
i Comprehensive Risk Management 6.4 The CMT shall provide support and peer review for station management as Expert Panel decisions are implemented. -
7.0 Records 7.1 Records of Expert Panel decisions shall be retained as Quality Assurance records in STP-RMS, and shall consist of:
7.1.1 Expen Panel decisions.
7.1.2 Working Group recommendations / analyses.
7.1.3 PS A inputs.
7.1.4 Performance information/ analyses.
7.1.5 Other detenninistic insight / rationale.
7.1.6 Dissenting opinions and resolutions.
8.0 Support Documents 8.1 Addendum 1 Graded Quality Assurance 8.2 Addendum 2 Quality Assurance Program Levels and Descriptions 8.3 Addendum 3 Categorization of Plant Systems, Components, and Activities 8.4 Addendum 4 Motor Operated Valve Program 8.5 Addendum 510 CFR 50 Appendix J Local Leak Rate Testing (LLRT) Program
OPGP02-ZA-0003 Rev.2 Page 7 of,16 Comprehensive Risk Management Addendum 1 Graded Quality Assurance Page 1 of 5 This addendum describes the Graded Quality Assurance (GQA) process, prescribes the performance reponing of the Operating Experience Group (OEG), and prescribes the activities of the GQA Working Group. It also prescribes the thought processes / criteria to be applied in formulating recommendations to the Expert Panel. The Expert Panel shall use these same processes / criteria in considering Working Group recommendations when arriving at decisions.
I Figure I for this Addendum depicts a high level process flow chan for GQA. l PSA RISK RANKING
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. : % GOA WORKING GROUP l
. _d - mes w-
- consders rak rw*ng
- Irgects detemwuste know4 edge / hmghi
- Devekms recommenomons regardng j levels of programmanc mnted and I
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l STATION & INDUSTHY PERFORMANCE l
l Documerded remmmendabans
& rationale to Empert Panel 11
- Prograrn cartrots are established or modfted EXPERT PANEL e Remews W. G. pertomiarco data analyses
- Consders risk rankhg DOCUMENTED E.XPERT
- Insects detemurustc knowledgehnsk/s -
PANEL DECISIONS Lavees of oversight are estatAshed or modred 2 -
l ONGOING FEfDBACK l: :
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l OPGP02-ZA-0003 Rev.2 Page 8 of 16 Comprehensive Risk Management Addendum 1 Graded Quality Assurance Page 2 of 5 GRADED QUALITY ASSURANCE: . . ,
Addendum 2 describes the application of the Quality Assurance (QA) Program to SSCs.
Figure 1 on Addendum 3 defines the logic and criteria the . Working Group and Expert Panel shall use in determining the appropriate level of program controls to be applied to SSCs. The QA Program is implemented in three graded levels: " Full", " Basic" and " Targeted" levels of program control.
" Full" program controls are applied to safety mlated SSCs determined to have "high" risk significance.
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" Basic" program controls are applied to safety-related SSCs that, have either " medium" or " low" risk significance.
" Targeted" program controls are applied to either of the following sets of SSCs:
1)Non-safety related SSCs that have either "high" or " medium" risk significance, or I
2)Non-safety related but quality related SSCs that have either " low" risk significance or are not determined to be risk significant.
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l OPGP02-ZA-0003 Rev. 2 Page 9 of 16 Comprehensive Risk Management Addendum 1 GRADED QUALITY ASSURANCE Page 3 of 5 OPERATING EXPERIENCE GROUP REPORTING: , , ,
The OEG compiles and analyzes performance of plant equipment and activities in accordance with OPGP02-ZA-0004. On a biannual basis,in coordination with Working Group schedules, the OEG shall l provide performance reports to the Working Group. These reports shall provide performr.nce information for the current and two prior six months periods, by organization and attributes.
l These reports include both positive and negative indicators that are graded on a scale of one to five using I the following criteria:
- 1) Sustained excellence l
- 2) Good with an improving trenc
- 3) Good performance l 4) Good with a declining trend
- 5) Poor performance I
For any performance attribute with a rating of four or five, the OEG shall provide accompanying backup l information along with the report, for Working Group and Expert i'anel analysis purposes.
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OPGP02-ZA-0003 Rev.2 Page 10 of 16 l
Comprehensive Risk Management Addendum 1 GRADED QUALITY ASSURANCE Page 4 of 5 GQA WORKING GROUP:
The GQA Working Group shall be chaired by the representative from Systems Engineering and have members from Design Engineering, Quality, Risk and Reliability Analysis, Operating Experience, l Licensing, Operations and Maintenance / Work Control. This membership will be augmented as needed, l
depending on the topics under consideration.
The GQA Working Group members shall be senior level personnel with backgrounds'that enable them to render logical recommendations. GQA Working Group membership shall be endorsed by the Expen Panel.
The GQA Working Group shall meet, as a minimum, biannually, to establish and/or adjuu levels of programmatic control and oversight.
The GQA Working Group shall consider SSCs in accordance with Addendum 3. They sha'l consider plant performance provided by the OEG, as applicable. Specific attention shall be afforded to anas of poor or l declining performance, with special attention to activities which have or can have direct eff:ct on plant systems and components. These considerations, as they may be augmented by group members' deterministic insights, form the bases for recommendations regarding the levels of programmatic controls to be imposed on SSCs . They also form the basis for recommending the levels of oversight (both line and independent).
Recommendations developed by the GQA Working Group shall be documented and shall be forwarded to the Expert Panel for their consideration and concurrence. Documentation shall include, as a minimum, the following: .
Detailed recommendations for SSCs categorization (i.e., full, basic or targeted levels of control).
The bases for making those recommendations (i.e., including PSA inputs, performance analysis results, details regarding any other deterministic inputs).
SSCs not within the scope of the PSA, including balance of r mt performance,instmmentation, mode transition and shutdown operations, or not completely modeled must be considered from a deterministic bases. Addendum 3 lists appropriate questions to be applied to items meeting the l above criteria to determine if funher significance assessment should be applied. As appropriate, the
- significance identified pursuant to these questions shall be assessed by the Working Group using i expert solicitation techniques such as a Delphi method where key deterministic attributes (e.g.
seismic, EQ, II/I, electrical separation, etc.) are evaluated by the Working Group members to establish the overall deterministic significance ranking (i.e. high, medium, low).
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3 OPGP02-ZA-0003 Rev.2 Page 11 of 16 Comprehensive Risk Management i
j Addendum 1 Graded Quality Assurance Page 5 of 5 l
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The GQA Working Group shall specifically consider, a.c a minimum,' uncertainties caused by :
- 1. PSA model assumptions j 2. Common cause or common mode failure rates i
- 3. Treatment of support systems
- 4. Level of definition of cut sets and cut set truncation
- 5. Model assumptions relative to repair and restoration of failed equipment
- 6. Human error rates used in the PSA
- 7. Limitations in the meaning ofimportance measures Any dissenting opinions.
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OPGP02-ZA-0003 .
Rev.2 Page 12 of 16 Comprehensive Risk Management j Addendum 2 Graded Quality Assurance Program Levels and Page I of 3 Descriptions l
GRADED QA PROGRAM CONTROLS: , . ,
FULL: )
l Full Program Controls are defined as the highest levels of program controls and oversight. These programmatic controls are in full compliance with the requirements of 10 CFR 50 Appendix B, and additionally represent compliance with the applicable STP commitments relative to USNRC Regulatory Guides and ANSI Standards which they endorse. Other recognized industry standa cds are applied, as appropriate. These controls shall be prescribed in implementing procedures.
1 SSCs categorized to receive Full Program Controls are afforded multi-tiered levels o:' oversight consisting of independent / dual line verification as appropriate plus focused independent oversight in the form of ;
audits, performance monitoring, assessment, evaluation, inspection, and/or testing, as appropriate. These l SSCs shall remain in this category, regardless of performance, due to their high level of risk significance /importance.
In the event that OEG performance reports indicate a declining trend in performance for two consecutive reporting periods, a "CAQ-S" Condition Report shall be initiated in accordance with OPGP03-ZX-0002, to determine the apparent cause and initiate appropriate corrective actions. If poor performance is indicated, ;
a "S-CAQ" Condition Report shall be initiated to effect a root cause investigation and appropriate corrective actions.
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OPGP02-ZA-0003 Rev.2 Page 13 0f 16 -
Comprehensive Risk Management Addendum 2 Graded Quality Assurance Program Ixvels and Page 2 of 3 Descriptions GRADED QA PROGRAM CONTROLS (Continued) . . ,
BASIC:
Basic Program controls are defined as good business practices which reflect the most economical and efficient means af conducting business while maintaining compliance with the basic requirements of 10 CFR 50 Appendix B. They do not necessarily reflect the strict controls as depicted in USNRC Regulatory Guides and the ANSI standards they endorse. Other industry standards are applied, as appropriate. These controls shall be prescribed in implementing procedures.
SSCs categorized to receive Basic Program controls shall be afforded minimal levels of oversight. The primary means of verification shall be by the line organization, with periodic selected independent oversight in the form of audits, performance monitoring, assessments, evaluations, inspection, and/or testing as appropriate.
Any time OEG performance reports indicate declining or poor performance, the Working Group shall revisit the program controls and oversight applied to confirm that the decisions made were appropriate.
Adjustments shall be made, as necessary. These considerations shall be documented and included in the recommendations to the Expen Panel.
TARGETED:
SSCs categorized to receive Targeted Program Controls are subjected to " Full" program controls applied in a selected manner and specifically " targeted" at those characteristics / attributes which placed it into that category. This requires a detailed analysis by the Working Group to determine its critical characteristics / attributes. This analysis shall be documented, along with the basis for selection of the full program attributes determined to be appropriate. Until such time as this analysis is completed, Full Program controls shall be maintained. These SSCs shall also be afforded multi-tiered levels ofline and independent oversight targeted to those characteristics / attributes which placed them into this category.
Any time performance reports indicate declining or poor performance, the Working Group shall additionally revisit the program controls and oversight applied to confirm that the decisions made were appropriate. Adjustments shall be made, as necessary. These considerations shall be documented and included in the recommendations to the Expen Panel.
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1 L OPGP02-ZA-0003 Rev. 2 Page 14 of 16 Comprehensive Risk Management Addendum 3 Categorization of Plant Systems, Page1of I Components,and Activities FIGURE 1 ---
GOA SCREENING PSA Hgh No PSA Med No PSALow No+ Not Modeled Yes Yes
- Yes Y E E o .l nE Mode change Megates Codd fad or shutdown safety Used in EOPs? acodent or dere cause nsk sgnefcant u sagrwhcLW7 . systern? ,y,,,
Assess nsk sagrufscance based on PSA ranlongs and/or detsamnste evaluabon +
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Hgh No Med No Low No S t
.%s Yes Yes
- No- Safety related? -No Safety Related? Safety Aslated? No Qualty Related?
No Yes Y" Yes Yes ii G
pyg ; Base Target No OA 1' 1r l
I OPGP02-ZA-0003 - Rev. 2 - Page 15 of 16 l
{ Comprehensive Risk Management i Addendum 4 Motor Operated Valve Program Page1of I J l
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l TO BE SUBMITTED AT A LATER DATE -
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