ML20198J750
| ML20198J750 | |
| Person / Time | |
|---|---|
| Site: | Crystal River  |
| Issue date: | 01/10/1998 |
| From: | Holden J FLORIDA POWER CORP. |
| To: | |
| Shared Package | |
| ML20198J675 | List:
|
| References | |
| NUDOCS 9801140202 | |
| Download: ML20198J750 (10) | |
Text
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Power
@ Florida C O R P QR AT ION CRYSTAL RIVER U N IT 3 1
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CORRECTIVE ACTION PROGRAM OVERVIEW !
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l ho(/J J. J/fioiden, Director l Site Nuclear Operations I
l 9801140202 900110 3 PDR ADOCK 05000302 P _ PDR . _
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Key issue How does FPC have reasonable assurance that site personnel are properly focused on aggressively identifying, evaluating, and correcting significant problems to preclude recurrence; demonstrating a healthy questioning attitude; are selfoitical; and have the proper tools and management controls in place to ensure an effective Corrective Action Program?
Executive in November 1996, florida Power Corporation approved and began implementation of a revamped Corrective Action Program. This Summary revamped program consolidated numerous site methods for reporting problems and lowered the threshold for reporting problems. The Crystal River 3 management team communicated program expectations and accountabilities for identifying, analyzing, and resolving issues, regardless of significance level.
The new Corrective Action Program has a lower threshold for reporting conditions adverse to quality and uses a graded approach to determine significance level and commensurate cause analysis techniques.
Significant conditions adverse to quality receive root cause analyses to ensure that effective corrective actions are prescribed to preclude
! recurrence in accordance with 10CFR50 Appendix B, Criterion XVI.
Less significant issues, as determined via criteria contained in compliance procedures, receive apparent cause analyses and corrective actions to resolve issues.
Key CAP New FPC Corrective Action Program requirements and expectations Accomplishments were defined in a single compliance procedure that governs the reporting, evaluation, and resolution of all problems identified. This procedure change and related training have resulted in an effective Corrective Action Program at CR-3. CR-3 implemented the following changes to improve the Corrective Action Program to a level that meets management expectations.
. Established an organization (Nuclear Safety Assessment Team) that functions as a single point of contact for corrective action and operating experience administration e Replaced a confusing corrective action process which had two vehicles for identifying problems (a problem reporting system for more significant issues and precursor cards for less significant items) with a single graded system e implemented trend codes for event and cause code trending e Reinstituted and enhanced a structured corrective action process interface for operating experience information 2
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e e Establis ed a Corrective Action _ Review Board (CARB) comprised lof - !
, " director level personnel to validate quality of root cause ana. lyses and - ,l validate prescribed corrective actions j
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~ ,M htehrated l !inddstryfoperatind . experience:into the corrective action 1 process:
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-e Integrated system readiness reviews-into the process for reviewing d
_ prescribed corrective actions for potential mode restraint to restart - :i t
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e1; Required1 higher level rnanagement approval ? to extend problem J evaluations and/or corrective action due dates
- _ Developed a set of indicators and management _ controls to' monitor j department performance -
e - Introduced la ; new-- graded approach _ for determining level of d significance; . level A for . significant problems having high:
consequence at complexity (root cause analysis required); level B for i 4
significant _ consequences or complexities (root ' cause analysis required); level C for-problems of moderate consequence (apparent cause required);-level D for minor conditions adverse to quality (fix and trend) ;
e' Established aggressive goals for resolution of problems l
r The lower threshold for. reporting has increased - the employees' identification of minor problems as evidenced by approximately 5600 grade level D Precursor Cards _ (PCs) written in 1997. In 1997, approximately 8800 PCs have been written as compared to a total of approximately 6300 written in 1996 under the former process. Of the '
1997_ total, approximately 7000 have been dispositioned and closed because of higher management expectations to resolve problems. -i
. MCAP ll The Management Corrective. Action Plan Phase 11 (MCAP 11) was developed in August 1996, prior to the current outage, to address several long-term issues which had been the focus of discussions between CR-3 and the regulator during the previous year. These broad issues were:
- Leadership Oversight and involvement ,
Le : Engineering Management
- . Configuration Management and Design Basis
- ' ; Regulatory Compliance
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- EOperations Performance
- Root-causes were performed in each of these five areas and 148
- corrective ~ action's'were developed. Further evaluation of the corrective actions against restart criteria resulted in 32 being designated as required -
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- for-restart.1Demonstra. ion of satisfactory progress in completing these 3
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i action items was included as a part of the March 4,1997, Confirmatory ;
i Action Letter, A performance indicator, related to completion of MCAP l
!! action items, was developed and subsequently demonstrated steady i progress in accomplishing MCAP 11 action items during the course of the outage. -
4 Performance Indicator
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i An effectiveness assessment of MCAP 11 was conducted in August 1997 using a nine-person team which included three outside members with extensive industry experience. The team concluded that all significant issues identified by MCAP ll were being effectively addressed and that, ,
while some items remained to be completed, all remaining items were being satisfactorily tracked to conclusion. '
1 An NRC inspection team also evaluated MCAP 11 in September 1997 and determined progress in all five areas was adequate. Further, this team l stated their belief that the site had done a good effectiveness assessment. j MCAP ll was completed on December 31,1997. All action items were either completed, contained as actions in the 1998 Long Range Business Plan, or continued as corrective action under the appropriate MCAP 11 precursar. Less than ten of the original 148 action items were not completed by the end of 1997.
Continuing follow-up of MCAP ll issues will be provided by Quality Assessments; a follow-up effectiveness assessment is scheduled as a special interest item in the August 1998 audit.
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Programmatic Lin an. effort toward. continual improvement and excellence, FPC has - ;
l improvements : made iterative enhancements to the Corrective Action Progam over the l {
last year.1The following enhancements and progammatic improvements ; 1 have been implemented at Crystal River F
. - e JAn interactive electronic database was implemented on October 1, 1
1 1997 which allows for owners of Precursor Cards to update, track,1
- and disposition their respective issues, i-
- 1 A single significance grade (level X) was implemented to distinguish ithose issues which are improvement:ltems but are 'not conditions' ,
adverse to' quality ;
eA methodology ifor - dispositioning ' material and equipment nonconformances was developed to address continued operations'in accordance with NRC Generic Letter 91-18, Revision 1
-.e Operational review classifications were developed to identify those
= PCs which require resolution prior to plant operational status-
. A review process and tracking mechanism was developed: for .
corrective actions which are potential mode rrstraints during outages--
- CAP communications were improved utilizing various media including a Corrective Action Program Fact -Sheet -(periodic ;
newsletter); weekly Operating Events Digest; monthly ' Operating ,
Experience Outlook, Corrective Action Program brochures, and
" quick reference" cards for users of the CAP information system
. Training on the corrective action' process and CAP information system was completed ,
e CAP Owners' hip . The FPC Corrective Action Program involves all nu: lear employees, both contractors and direct company employees. Site management has placed emphasis on line department ownership of the program. Some of
. the key activities performed by the line organizations include:
- Daily- review and discussion -of Precursor Cards by -the senior
. management team
_e: A screening committee comprised of representatives from various site
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- v departments r toi review - all; new--issues daily for. determining.
significance level and ownership assignment .
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el Participation of line department directors on.the Corrective Action
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- Review Board:
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-e" Establishment of department work group coordinators to administer and coordinate the process for their respective department 5
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- E Selection of individuals within each department with specific trainin' g .
to serve as root cause investigators (approx. 60 personnel trained _in -
Lroot cause fundamentals, human error reduction techniques, and: .
' organizational / programmatic crror analysist Collectively, these initiatives were designed to support _ FPC management's philosophy for line ownership and accountability of the Corrective Action f Program _ to ensure the effective identification, evaluation, and timely. resolution of problems. Line department ownership of problems is key to effective self-identification of problems,
- resolution of those problems, and the healthy ability to be self-critical.
- Independent Independent assessments of the Corrective Action' Program have been
-Assessments. conducted by the NRC, Quality Programs, MCAP ll Effectiveness .
Assessment, and a Pre-OSTI Assessment which identified improvement .
opportunities that the CR-3 management team has addressed.
e In previous reports, the NRC indicated concerns with the screening of PCs. CR 3 management took corrective measures to improve the PC screening process by ech. ding grading criteria in the governing compliance procedure at establishing a screening committee. NRC Inspection Report 97-17 dLed 12/29/97 stated that " inspectors have not identified any significant errors in screening of PCs since those observations."
. The Pre-OSTI Assessment identified a weakness in the area of trending. The Corrective Actien Group has created two trend analyst positions, purchased statistical process control trending software, and established event and cause coding. The corrective action program has begun to idemify and evaluate potential adverse trends, and will publish the first collective analysis trend report in January. 1 e in the area of root cause quality, NRC Inspection Report 97-16 dated 9/24/97 stated that the level and detail of CARB reviews continue to be thorough and - the quality of root cause investigations and corrective action recommendations continue to improve.
- - NRC Inspection Report 97-16 also stated that .the recently implemented new Corrective Action Program database was a "very good improvement" over the previous system which contains searchable and trendable data fields, such as mode restraint, cause codes, location, and affected systems.
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-e in the area of self-identification of problems, NRC Inspection Report 97-17 : stated that "the licensee consistently encouraged self-identification of problems and focused on the solution to prevent recurrence of problems."
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-future. :While these improvements to the Corrective Action Program have been - -
' Enhancements' Limplemented to support the Crystal- River 3 restart effort,' : more ---
enhancements are planned and funded via the Long Range Business Plan for implementation in-1998 to support sustained ~ operations of CR 3,-
including:
e- Qualifying the CAP information system as a record retention' database in order to move to a "pa aless" process e Introducing on line o'eability and reportability evaluations in the .-
CAP information systrs m to complete the"paperless" process e implementing- enhancements to the CAP information- system fot
" user-friendliness"
- - Further streamlining of Corrective Action Program procedures and policies
- Developing a more refined trending capability in the area of human performance-
. Continuing to consolidate programs and procedures to assure a fully integrated Corrective Action Program
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The FPC management 1nitiatives'have promoted and nurtured culture change with respect to the Corrective Action Program. Line department managers have program ownership and the new CAP information contains the management controls necessary to monitor the program.
Indicators gauge quality, quantity, timeliness, backlog, and performance.
The trend program reveals and analyzes areas for improvement in the human performance arena, The Carrective Action. Program will continue to undergo iterative 4 4 improvements as we: strive toward achieving excellence. The FPC management team is committed to providing the proper level of oversight, emphasis, and focus on the Corrective Action Program to ensure the timely and effective identification, analysis, and resolution of
. problems as we move forward to operate CR-3.
Corrective Action :
Program Results Lowered Implementation;of a _new graded approach to problem reporting has Threshofd /or yielded an increase in minor conditions adverse to quality while Reporting- . dispositioning more significant issues as compared to 1996. This Problem:. evidence of a lower threshold for reporting has resulted in about 40%
. more; problems identified in 1997. _ Overall to date in 1997,
.approximately 8800 PCs have been written, as compared to a total of approximately 6300 written in 1996 under the former process. Of the 7-
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H 1997 total, approximately 7000 have been dispositioned and closed. i Problem identificaHon 1996 ss 1997 utpos piw.mm pm a precw.oicea a 1987 orases m.cew cae
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improved Quafity The improved Corrective Action Program has fostered ownership of the o/ Cause problems identified within CR-3, Root cause investigations at CR-3 Determinations consist of extent of conditions reviews for generic implications, safety significance or consequences, root and contributing causes, industry operating experience, and prescribed corrective actions 'o preclude recurrence. Despite the increased volume of issues identified, the quality of root causes has improved consistently throughout the period due to the extent of training provided and high standards enforced by the Corrective Action Review Board as shown below, a .my.,n qavete.e A. .i.c seres ... ev.i..n...
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Declining Trend The organization' has demonstrated ownership by focusing on the
- o/ Backlogged resolution and closure of problems, improved management controk Issues - have facilitated the planning and completion of actions, to correct identified problems to reduce the CAP backlog. As indicated in the graphs below, the focus on resolution of restart issues and mode restraints has rmulted in the closure rate of PCs to level off in recent 4
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. Conclusion . The proyammatic enhancements and improvements discussed have !
- streamlined the Corrective' Action Progam procesf. ' t facilitate an j improved culture allowing for more effective identiheatic ., evaluation, !
and reglution of problems. . These initiatives - have _ promoted line i department ownership of the Corrective Action Propam as a positive ;
. tool for resolving issues. The r.ew process has provided effective i management controls to ensure focus and quality of problem evaluations and corrective actions. l These initiatives taken, along with the results achieved, provide- l reasonable assurance that CR 3 personnel have a questioning attitude, !
are _ self<ritical, and hold themselves accountable for. prompt !
identification and resolution of problems. As a result, FPC concludes !
that the Corrective Action Progam is ready to facilitate restart of CR 3 l and to support safr. reliable, economic, and environmentally sound
. sustained operations. ;
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