ML20209H315
| ML20209H315 | |
| Person / Time | |
|---|---|
| Site: | South Texas  |
| Issue date: | 06/23/1999 |
| From: | Chackal R, Moldenhauer A, Rosen S HOUSTON LIGHTING & POWER CO. |
| To: | |
| Shared Package | |
| ML20209H296 | List: |
| References | |
| 0PGP02-ZA-0003, PGP2-ZA-3, NUDOCS 9907200186 | |
| Download: ML20209H315 (25) | |
Text
-
i i
l SOUTil TEXAS PROJECT ELECTRIC GENER ATING STATION D0527 I n m ruenouve.rmm-. m
~~-~2-Pnni Tune / Date to 20 AM Ou29m OPGP02-ZA-0003 Rev.4 Page1 of25 Comprehensive Risk Management
! Quality Safety-Related Usage: Available Effective Date: 06/23/99 l
R. J. Chackal A. C. Moldenhauer s. L Rosen Risk Mgmt & Industry Relations l l PRI: PARER TI:CllNICAL USLR COGNIZANT ORGANIZATION l
l Table of Contents
1.0 Purpose and Scope
. .. .. . . . . . . . . .2 l
2.0 References. . .. ... . . . . . . . . . . . . . . .. . .. . . . .2 l
3.0 Definitions.. .... .. . .. . . . . . . .2 4.0 Responsibilities . .. . . .. . . . .3 ,
1 5.0 Requirements.. . . . . . .. ... . . . . . .. . . . . . . .. ... .5 6.0 Process.. . . . . . .. . . . .. . .. . . .5 i k
7.0 Records.. . .. .. . .... . . . . . . . . .. . .7 8.0 Support Documents.. .. .. .. . .... . . . . . . . . . ... . . . . .. . . .. . 7 Addendum 1 - Graded Quality Assurance . . . . .. . .8 Addendum 2 - Graded Qua'ity Assurance Program Levels and Descriptions.. . 13 Addendum 3 - Graded Quality Assurance Flow Chart . . . .. . . 15 Addendum 4 - Motor Operated Valve Program. .. . .. . .. . .. . .16 Addendum 5 - Air Operated Valve Program . .. . . . . . . . .21 9907200186 990713 PDR ADOCK 05000498 P pg i
I. -
l 0PGP02-ZA-0003 Rev.4 Page 2 of 25 I Comprehensive Risk Management i
1.0 Purpose and Scope
1.1 To establish and provide guidance to the Expert Panel and associated Working Groups on the implementation of a risk informed, performance based Comprehensive Risk Management program at STP, This procedure is approved for use in assessing the risk significance of plant structures, systems and components (SSCs) and determining the appropriate levels of controls and .
oversight.
2.0 References 2.1 Operations Quality Assurance Plan (OQAP).
2.2 OPGP04-ZA-0604, Probabilistic Risk Assessment Program.
I 2.3 OPGP01-ZA-0304, Probabilistic Risk Assessment Risk Ranking. I 3.0 Definitions 3.1 COMPREHENSIVE RISK MANAGEMENT (CRM)
A process by which the risk to station personnel and the risk to the publics health and safety are evaluated based on reviews of commitments, processes, activities, and human and equipment performance.
3.2 GRADED QUALITY ASSURANCE (GQA)
The process by which risk-informed methodologies and deterministic and perform?nce-based information analyses are combined to establish appropriate levels of progranuaatic controls for systems, structures and components in order to provide necessary assurance that items will operate safely and activities are accomplished as prescribed.
3.3 EXPERT PANEL A multi-disciplinary group ofindividuals whose purpose is to guide the implementation of Comprehensive Risk Management activities at STP.
3.4 WORKING GROUPS Multi-disciplinary groups ofindividuals who provide risk-informed, performance-based recommendations to the Expert Panel.
OPGP02-ZA-0003 Rev.4 Page 3 of 25 i
Comprehensive Risk Management 3.5 INITI ATING EVENT Any event that can cause a plant trip or otherwise initiate a sequence of events with a quantified probability of core damage .
3.6 OPERATING EXPERIENCE GROUP (OEG)
An STP organization that is responsible for the review ofin-house and industry operating experience.
3.7 INTENT CHANGE A change to the contents of a Risk Significance Basis Document which changes the purpose, scope, methodology, general recommendations, or dissenting opinion (s) provided in the document. Configuration control changes made to the document to maintain it up-to-date with new or revised reference data are not considered intent changes.
4.0 Responsibilities 4.1 EXPERT PANEL 4.1.1 Approve the criteria for assessing the risk significance of SSCs.
4.1.2 Review and approve the risk significance assigned to SSCs.
4.1.3 Approve the criteria for assignment of QA grade levels for SSCs.
4.1.4 Review and approve the assignment of QA grade levels for SSCs.
4.1.5 Maintain cognizance over the implementation of the CRM program and adjust program criteria, as appropriate.
4.1.6 Approve and issue for plant use the Risk Significance Basis Documents.
4.1.7 Approve other recommendations by the Working Groups 4.1.8 Appoint Working Groups.
4.1.9 Assess the overall station risk impact due to SSC performance and all implemented risk-informed programs after each plant-specific data update of the PRA.
OPGP02-ZA-0003 nev.4 Page 4 or25 Comprehensive Risk Management 4.2 WORKING GROUPS 4.2.1 Analyze performance information.
4.2.2 Consider risk insights and risk ranking of SSCs.
4.2.3 Consider the application of processes / work activities / work organizations to SSCs relative to risk.
4.2.4 Inject deterministic knowledge / insight.
4.2.5 Develop recommendations, as prescribed in the addenda to this procedure, and provide them to the Expert Panel in the form of a Risk Significance Basis Document or other appropriate means as specified in the Addendum for that Working Group.
4.2.6 Coordinate with other Working Groups to ensure consistency in evaluation results. Where results cannot be reconciled between the Working Groups, they shall be identified to the Expert Panel for resolution.
4.3 STATION MANAGEMENT 4.3.1 Nominate and provide guidance to members of the Working Groups.
4.3.2 Implement the decisions of the Expert Panel.
4.4 CHANGE MANAGEMENT TEAM (CMT) 4.4.1 Implements categorizations of SSCs and assignments of the associated QA grade levels approved by the Expert Panel into applicable plant processes and the STP Business Plan.
4.4.2 Provide support and peer review for station management as Expert Panel decisions are implemented.
4.5 SENIOR MANAGEMENT TEAM (SMT) 4.5.1 Maintain strategic level oversight of the CRM Program activities.
4.5.2 Provide resolution of any Expert Panel dissenting opinions.
l t
. 1 i
0PGP02-ZA-0003 Rev.4 Page 5 or25 1
Comprehensive Risk' Management l
- i 1 i 5.0 Requirements 5.1 The Expert Panel is composed of the Manager of Design Engineering, Manager of Risk Management & Industry Relations, Administrator of Risk and Reliability Analysis, Director of Quality and Licensing, Director of Nuclear Fuels & Analysis, Chainnan of the GQA Working Group, and a Manager from Generation. The Manager, Risk Management
& Industry Relations is chairman of the Expert Panel. Changes to the Comprehensive Risk Management Expert Panel membership require approval of the President and Chief l Executive Officer.
5.2 Working Groups shall be comprised ofindividuals as listed on die appropriate addenda to this procedure.
5.3 Alternate Chairmen may be designated to enable Expert Panel and Working Groups' functions to continue if the respective chaimian is not on site. In addition. an alternate may be designated for the Administrator of Risk and Reliability Analysis. Alternates must be l
j designated in writing.
5.4 Expert Panel members, Working Group personnel, and any designated alternates shall be trained to this procedure, the PRA procedures referenced in Section 2.0, and the station performance reporting process. They shall additionally receive (or have received) familiarization training to 10 CFR 50.59 and Root Cause Analysis.
5.5 The Expert Panel identifies plant systems, activities, processes, commitments and '
requirements to be evaluated by the working groups.
6.0 Process i 1
6.1 Working Groups 6.1.1 Working Groups are establisL;d as required to evaluate the risk significance of the various programs identified in the addenda to this procedure.
6.1.2 Working Groups shall convene at frequencies as established in their respective Addenda.
6.1.3 Minimum quorum requirements for Working Group meetings are the chairman or alternate chairman and at least three members, unless otherwise specified in the Addendum for that Working Group.
6.1.4 Working Group recommendations shall be arrived at by consensus. Dissentions shall be documented for Expert Panel resolution.
. 1 OPGP02-ZA-0003 Rev.4 Page 6 of 25 Comprehensive Risk Management 6.1.5 Using the criteria established in the addenda, the Working Groups shall analyze performance data, consider available risk information and their own deterministic insight, and shall develop recommendations.
6.1.5.1 Recommendations shall be documented and shall include rationale and risk ranking / performance information that form the bases for the recommendations.
6.1.5.2 The documented recommendations shall be forwarded to the Expert Panel.
6.1.6 Following Expert Panel approval of the Working Group recommendations, any changes to these approved recommendations shall receive the same level of review by t.he Working Group as the original. Changes shall be forwarded to the Expert Panel Chairman and indicated as intent or non-intent changes.
6.2 Expert Panel 6.2.1 The Expert Panel shall convene, at a minimum, at the same frequencies as established for the Graded Quality Assurance Working Group in Addendum 1.
6.2.2 Minimum quorum requirements for Expert Panel meetings are the chairman or alternate chairman and at least three members, one of whom must be the Administrator of Risk and Reliability Analysis or alternate. No more than one alternate is allowed. There shall be no short term designee representation.
6.2.3 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.
6.2.4 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.
6.2.5 The Expert Panel shall perform the tasks defined in 4.1 of this procedure and shall document its decisions. These shall be disseminated to the SMT and the Change Management Team (CMT).
6.2.6 The Expert Panel Chairman shall indicate the Panel's approval of the Working Groups' documented recommendations by signing the corresponding document and authorizing its issue for plant use.
l
OPGP02-ZA-0003 Rev.4 Page 7 of 25 Comprehensive Risk Management 6.2.7 Intent changes to previously approved Working Group recommendations shall receive the same level of Expert Panel review and approval as the original.
Non-intent changes need only the Expert Panel Chairman's review and approval.
6.3 The SMT shall resolve any dissenting opinions that require resolution.
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 and supporting documents shall be retained as Quality Assurance records in STP-RMS, and shall consist of:
7.1.1 Expert Panel decisions.
7.1.2 Expert Panel meeting minutes .
7.1.3 Risk Significane): Basis Documents or other recommendations by the Working Groups.
7.1.4 Dissenting opinions and resolutions.
8.0 Support Documents 8.1 Addendum 1 Graded Quality Assurance.
8.2 Addendum 2 Graded Quality Assurance Program Levels and Descriptions.
8.3 Addendum 3 Graded Quality Assurance Flow Chart.
8.4 Addendum 4 Motor Operated Valve Program.
8.5 Addendum 5 Air Operated Valve Program l
I l
l l
l OPGP02-ZA-0003 Reve 4 Page 8 of 25 Comprehensive Risk Management Addendum 1 Graded Quality Assurance Page1Or 5 This addendum describes the Graded Quality Assurance (GQA) process, prescribes the performance reporting of the Operating Experience Group (OEG), and prescribes the activit.ies 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.
Figure 1 for this Addendum depicts a high level process flow chart for GQA.
PSA RISK RANKING _ _ _ .
- hgh GQA WORKING GROUP Medium Low e Anatyres performance cara Not Modeled e Considers risk rankng e infects determnsic knowledge /nsght e Develops recommendations regarding lovels of pro 0rammatc control and oversght STADON & lNDUSTRY PERFORMANCE Generates Rek Sqndcance Bases Doctment l
Program controis are estabhshed or modded EXPERT PANEL e Revows Rok Sgnicance Base DOCUMENTED EXPERT I e Consdors Resk Hankng -
PANEL DECISIONS l
e insects Determostc Knowledge /Insght Levels of oversght are i established or modded l ONGOING FEEDBACK l FIGURE 1
OPGP02-ZA-0003 Rev.4 Page 9 of 25 Comprehensive Risk Management Addendum 1 Graded Quality Assurance Page 2 of s j GitADED QUALITY ASSURANCE:
Addendum 2 describes the application of the Quality Assurance (QA) Program to FNs. i i
Figure 1 on Addendum 3 defines the logic and criteria the Working Group v.a 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 related SSCs determined to have "high" risk significance.
" Basic" program controls are applied to safety-related SSCs that have " medium" or " low" risk significance or are determined to be non-risk significant.
" Targeted" program controls are applied to either of the following sets of SSCs: l
- 1) Non-safety related SSCs that have either "high" or " medium" risk significance, or
- 2) Non-safety related but quality related SSCs (Quality Class 7) that have either " low" risk significance or are determined to be non-risk significant. ,
OPGP02-ZA-0003 Rev. 4 Page 10 of 25 Comprehensive Itisk Management Addendum 1 Graded Quality Assurance Page 3 or 5 OPEllATING EXPEllIENCE GROUP REPORTING:
The OEG compiles and analyzes performance of plant equipment and activities in accordance with the Station Performance Iteporting Process. On a biannual basis, in coordination with Working Group schedules, the OEG shall provide performance reports to the Working Group. These reports shall provide performance information for the current and two prior six months periods, by organization and attributes.
These reports include both positive and negative indicators that are graded on a scale of one to five using the following criteria:
- 1) Sustained excellence
- 2) Good with an improving trend l l
- 3) Good performance 1
- 4) Good with a declining trend i
- 5) Poor performance For any performance attribute with a rating of four or five, the OEG shall provide accompanying backup information along with the report, for Working Group and Expert Panel analysis purposes.
I
. 1 OPGP02-ZA-0003 Rev.4 Page 11 of 25 Comprehensive Risk Management Addendum i Graded Quality Assurance Page 4 or 5 GQA WORKING GROUP:
The GQA Working Group shall consist of members from Systems Engineering, Design Engineering, Quality, Risk and Reliability Analysis, Operating Experience, Licensing, Operations and Maintenance / Work Control. This membership will be augmented as needed, depending on the topics under consideration.
The GQA Working Group members shall be senior level personnel with background: v enable them to l render logical recommendations. GQA Working Group membership, including the ch. . man, shall be endorsed by the Expert Panel.
The GQA Working Group shall meet, as a minimum, semi-annually, to establish and/or adjust levels of programmatic control and oversight.
The GQA Working Group shall consider SSCs in accordance with Addendum 3. They shall consider i plant performance provided by the OEG, as applicable. Specific attention shall be afforded to areas of l poor or declining performance, with special attention to activities which have or can have direct effect on plant systems and components. These considerations, as augmented by the group members' deterministic insights, form the bases for recommendations regarding the levels of programmatic controls to be imposed on SSCs . They also fonn the basis for recommending the levels of oversight (both line and independent).
Recommendations developed by the GQA Working Group shall be documented in a Risk Significance Basis Document and shall be forwarded to the Expert Panel for their consideration and concurrence.
Documentation shall include, as a minimum, the following:
Detailed recommendations for the risk significance of SSCs.
Detailed recommendations for the categorization of SSCs (i.e., full, basic or targeted levels of control).
The bases for making those recommendations (i.e., including PRA inputs, performance analysis results, details regarding any other deterministic inputs).
SSCs not within the scope of the PRA, including balance of plant performance, instrumentation, mode transition and shutdown operations, or not completely modeled must be considered from a deterministic basis. Addendum 3 lists appropriate questions to be applied to items meeting the above criteria to determine if further significance assessment should be applied. As appropriate, the significance identified pursuant to these questions shall be assessed by the Working Group using expert solicitation techniques such as a Delphi method where key deterministic attributes
S OPGP02-ZA-0003 Rev.4 Page 12 of 25 Comprehensive Risk Management Addendum 1 Graded Quality Assurance Page 5 of 5 (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, or not risk significant).
Any dissenting opinions.
The GQA Working Group shall specifically consider, as a minimum, uncertainties caused by .
- 1. PRA model assumptions
- 2. Common cause or common mode failure rates
- 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. 11uman error rates used in the PRA
- 7. Limitations in the meaning ofimportance measures
OPGP02-ZA-0003 Rev.4 Page 13 or25 Comprehensive Risk Management Addendum 2 Graded Quality Assurance Program Levels and Page 1 of 2 Descriptions GRADED QA PROGRAM CONTROLS:
FULL:
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 l Guides and ANSI Standards which they endorse. Other recognized industry standards are applied, as appropriate. These controls shall be prescribed in implementing procedures.
SSCs categorized to receive Full Program Controls are afforded multi-tiered levels of oversigit consisting I ofindependent/ dual line verification as appropriate plus focused independent oversight in the form of l
audits, performance monitoring, assessment, evaluation, inspection, and/or testing, as appropriate. These 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 l l
reporting periods, or if a Category 4, ' Good with a declining trend' grade is received, 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.
i l
I
)
i i
J
OPGP02-ZA-0003 Rev.4 Page 14 of 25 Comprehensive Risk Management Addendum 2 Graded Quality Assurance Program Levels and Page 2 of 2 Descriptions GRADED QA PROGRAM CONTROLS (Continued)
IIASIC:
Basic Program controls are defined as good business practices which reflect the most economical and efficient means of 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 l Guides and the ANSI standards they endorse. Other industry standards are applied, as appropriate. These controls shall be prescribed in implementing piocedures.
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 Expert Panel.
TARGETED:
SSCs categorized to receive Targeted Program Controls are subjected to specific program controls which are consistent with applicable portions of the " Full" and " Basic" program controls, applied in a selected I 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. 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 apphed 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 Expert Panel.
OPGP02-ZA-0003 Rev. 4 Page 15 of 25 Comprehensive Risk Management Addendum 3 Graded Quality Assurance Flow Chart Page1or i GQAIHOCIES 4
, ISAlldi m+ ISAhid m+ ISAlav N> + Nt hield 4
Y. Y. Y.
Y n
V IfIM%htwem 10& 100 m lI y
& FV4.005,see M1e ! E Y 4 U Assess risksigificxxxhral hiaOrgyor g hitigres Guldfailrisk Quiddrtuly [1 atPSAraidreandir 4- shutdansafay 4- g7 4- aaidrasa 4- sigsfiart 4-areinitiaing [
dtmtinisticewlutim significrt? tranierts? s>mstf eset? T U
4 IEdi m hid m Lov w+
K 4
- v. v. v.
>V V I'4
-m- Safaynitd -* Safayrelated Safdyrelad
- Onlityrelaed l
_ 1. ~,
- v. 4
- s. v. y y g )
V rul V
asic h Taqu g
bbot $
E 4
Note 1: Non-safety related components with a Risk Achievement H' orth (RA 11') between 10 and 100 and a Fussell-Vesely (FV) value < 0.005 are to have Full QA applied to the critical attributes associated with that RAIL'and/or FV Note 2: PRA risk rankings are developed utili:ing the process described in Reference 2.3 i
FIGURii 1 1
1
OPGP02-ZA-0003 Rev.4 Page 16 or25 Comprehensive Risk Management Addendum 4 Motor Operated Valve Program Page i of 5 This addendum describes the implementation of the STP Motor Operated Valve (MOV) Program within the Comprehensive Risk Management program consistent with the Graded Quality Assurance (GQA) process. MOV categorization criteria, test strategy implementation, and performance indicators for the Operating Experience Group (OEG) are described. Also prescribed is the thought processes / criteria to be applied in formulating recommendations by the MOV Working Group. The Expert Panel will use the same or similar processes / criteria in considering Working Group recommendations. j Figure 1 for this Addendum depicts a high level process flow chart for MOV Program GQA. A detailed description of this methodology is provided in the Methodology for a Risk-informed, Performance Based j Periodic Testing Program for Motor Operated Valves report as co-authored by STP and ERIN '
Engineering.
GL 89-10, GL 96-05 and CURRENT {
TESTING PLAN )
i 4
MOV SCOPING EVALUATION I I l
u u 1 DETERMINISTIC PROBABILISTIC EVALUATION EVALUATION
- p--- -------
ASSESSMENT OF ASSESSMENT OF l PERFORMANCE RISK g i i MARGINS SIGNIFICANCE i I I l l l 4 l 1 OTHER ENGINEERING. WORKING GROUP 1 I LICENSING, and : EVALUATION and I i ECONOMIC IMPACTS RECOMENDATIONS I I I l 1 I 1 I COMPREHENSIVE I I RISK MANAGEMENT I l EXPERT PANEL i i REVIEW and APPROVAL I I I I h i I
I OPTIMEED MOV I
I TESTING STRATEGY I i 1 i l INTEGRATED EVALUATION I j Figure 1
- Includes Graded QA final risk determination, where available i
OPGP02-ZA-0003 Rev.4 Page 17 of 25 Comprehensive Itisk Management Addendum 4 Motor Operated Valve Program Page 2 of 5 MOV TEST PROGRAM CONTROLS FULL:
Full Program Controls are defined as the highest levels of program controls and oversight. These i programmatic controls are in full compliance with STP commitments to USNRC Generic Letter 89-10 f and 96-05. Other recognized industry standards are applied, as appropriate, including the American !
Society of Mechanical Engineers (ASME) Code for the Operation and Maintenance of Nuclear Power Plants. These controls are prescribed in implementing procedure, OPGP03-ZE-0037.
l l
MOVs categorized to receive Full Program Controls shall be periodically tested in accordance with the l performance based model. A mix of more precise performance-based diagnostic static and dynamic performance testing consistent with criteria specified in procedure OPGP03-ZE-0037 shall be used. Full ;
program MOVs shall also be subject to a non-diagnostic exercise test at a frequency no greater than one fuel cycle.
BASIC:
Basic Program controls are defined as good business practices which reflect the most economical and ;
efficient means ofconducting business while maintain:ug compliance with the basic requirements of 10 CFR 50 Appendix B. They do not necessarily reflect S TP commitments to USNRC Generic Letter 89-10
{
and 96-05. Other industry standards are applied, as appropriate, including the American Society of Mechanical Engineers (ASME) Boiler and Pressure Vessel Code,Section XI and the ASME Code for the Operation and Maintenance of Nuclear Power Plants. These controls are prescribed in implementing procedure, OPGP03-ZE-0037.
MOVs categorized to receive Basic Program controls shall be periodically tested in accordance with the performance based model using less precise performance-based static only diagnostic testing consistent with criteria specified in procedure OPGP03-ZE-0037. Basic program MOVs shall also be subject to a non-diagnostic exercise test at a frequency no greater than one fuel cycle. i TARGETED:
MOVs categorized to receive Targeted Program Controls are subjected to applicable portions of the " Full" and " Basic" program controls, applied in a selected manner and specifically " targeted" at those characteristics / attributes which placed it into that category. In general, these MOVs will be periodically tested in accordance with the performance based model using only static testing. Diagnostic equipment consistent with the specific situation shall be used. This requires a detailed analysis by the MOV Working Group to determine the critical characteristics / attributes. This analysis shall be documented, along with the basis for selection of the full program attributes determined to be appropriate.
OPGP02-ZA-0003 Rev.4 Page 18 or25 Comprehensive Risk Management Addendum 4 Motor Operated Valve Program 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 as described in Addendum 1 to this procedure. MOV Performance Attributes are described below.
- 1. MOV Test Results Within Accepted Criteria
- 2. MOV Operability Maintained
The MOV Working Group will be chaired by a representative from Design Engineering and have j members from Design Engineering MOV's, Operations (SRO), Risk and Reliability Analysis (PRA),
Maintenance MOV's, System Engineering, Nuclear Fuels & Analysis, Quality Assurance, Licensing,Section XI, Operating Experience Group, and Component Reliability. The MOV Working Group {
members are senior level personnel with backgrounds that enable them to render logical recommendations. MOV Working Group membership will be endorsed by the Expert Panel.
Working Group Members:
- 1. DED Chairman *
- 2. DED MOV Engineer *
- 3. Operations (SRO)
- 4. RR&A Engineer * ,
- 5. Maintenance MOV Technician *
- 6. System Engineering
- 7. Nuclear Fuels & Analysis
- 8. Quality Assurance
- 9. Licensing l
- 10.Section XI
- 11. Operating Experience Group l
- 12. Component Reliability
- denotes voting members who are required for quorum
OPGP02-ZA-0003 Rev.4 Page 19 or25 Comprehensive Risk Management Addendum 4 Motor Operated Valve Program Page 4 or 5 Charter :
MOV Working Group membership may be augmented as needed, depending on the topics under l I
consideration.
MOV Working Group meeting minutes will be communicated to all MOV working group members for concurrance and acceptance of all decisions prior to making final recommendations.
The MOV Working Group shall meet at least annually to establish and/or adjust levels of programmatic control and oversight.
The scope of review for the MOV working group is linrted to those valves as identified in the MOV GL 89-10 program and other selected valves.
The MOV Working Group will use plant knowledge, operating experience, and engineeringjudgment to perform the following tasks:
. verify MOV functional failure modes e establish risk-informed rankings for MOVs not modeled in the PRA l
. concur with the qualitative deterministic criteria e address all significant safety and operational concerns e validate MOV rankings e resolve questions relative to PRA model completeness e resolve all questions raised during the review process The MOV Working Group will consider the following factors in addition to the combination of risk significance and deterministic margins rankings:
. MOV performance history
. important design basis functions not reflected in the risk ranking
. impact of PRA scope limitations, assumptions, and model simplifications, such as exclusion of shutdown states e importance of release states less severe than large early releases that are not explicitly reflected in the risk ranking scheme e confidence in MOV design basis capability l
. feasibility of performing the indicated test l
. design features of the MOV such a flow assisted operation
. flow characteristics of the system in relation to risk significant failure modes l l
. effects of strenuous testing for risk significant failure modes
OPGP02-ZA-0003 Rev.4 Page 20 of 25 Comprehensive Risk Management Addendum 4 Motor Operated Valve Program rage 5 or 5 The MOV Working Group will also consider MOV performance provided by the OEG. Specific attention will be afforded to areas of poor or declining performance. Consideration will be given to recommending a more frequent or more effective test strategy for MOVs with sustained poor or declining performance.
The MOV Working Group will also consider as part of their evaluation the uncertainties caused by:
. PRA model assumptions e common cause or common mode failure rates e treatment of support systems e level of definition of cut sets and cut set truncation
+ model assumptions relative to repair and restoration of failed equipment
. human error rates used in the PRA e limitations in the meaning ofimportance measures Documentation:
Final testing strategy as recommended by the Working Group will be determined by reviewing the initial testing strategy and relating it to the combination of risk significance and deterministic margins rankings and by taking into account other factors that are not reflected in these rankings.
Documented recommendations developed by the MOV Working Group and forwarded to the Expert Panel shall include:
e detailed recommendations for MOV categorization and test strategy (i.e., full, basic or targeted levels of control) e the bases for making those recommendations (i.e., including PRA inputs, performance analysis results, details regarding any other detenninistic inputs) e identification of MOVs not within the scope of the PRA, including MOVs supporting balance of plant operations, mode transition and shutdown operations The Expert Panel approves the final testing strategy and proposed changes to the MOV test program by reviewing and concurring with the recommendations of the MOV Working Group.
Proposed changes, as approved by the I'xpert Panel will be forwarded to the appropriate organization for s incorporation into the program.
T .
I OPGPU2-ZA-0003 Rev. 4 Page 21 of 25 Comprehensive Risk Management Addendum 5 Air Operated Valve Program Page i or 5 m
This addendum describes the implementation of the STP Air Operated Valve (AOV) Program wittan the Comprehensive Risk Management program consistent with the Graded Quality Assurance (GQA) process.
I AOV categorization criteria and associated test strategy implementation are described. Also prescribed is the thought prccesses/ criteria to be applied in formulating recommendations by the AOV Working Group.
The Expert Panel will use the same or similar processes / criteria in considering AOV Working Group recommendations.
Figure I for this Addendum depicts a high level process flow chart for AOV Program GQA. A detailed description of this methodology is provided in the Methodology for a Risk-informed, Performance Based Pe-iodic Testing Program for Motor Operated Valves report as co-authored by STP and ERIN Engineering.
~C T5G RI A~TION and TESTING PLAN 4
E L I l
I b I DETERMINISTIC PROBABILISTIC EVALUATION EVALUATION r--------------,,------------- u -----i l l ASSESSMENT OF ASSESSMENT OF l
, PERFORMANCE RISK i
, MARGINS SIGNIFICANCE i l l l 4 l t OTHER ENGINEER!NG' WORKING GROUP i ;
i LICENSING, and EVALUATION and I l i ECONOMIC IMPACTS FlCOMENDATIONS i I a .
I ,
1 I l l . i e COMPREHENSIVE i RISK MANAGEMENT I I EX?ERT PANEL I e REVIEW and APPROVAL 8 t 1 I h i I OPTIMlZED AOV '
I TESTING STRATEGY '
i 1
! INTEGRATED EVALUATION !
Figure 1
OPGP02-ZA-0003 Rev. 4 Page 22 of 25 Comprehensive Risk Management Addendum 5 Air Operated Valve Program Page 2 of 5 AOV WORKING GROUP Hasis Procedure OPOP03-ZE-0074, Air Operated Valve (AOV) Program, provides specific requirements for AOV program implementation to optimi7e the resources used to maintain AOVs with safety significant functions. Included in the program are references to an AOV Working Group. This adc'endum describes the AOV Program Working Group charter, members and duties. It also prescribes the processes / criteria to be applied in formulating recommendations to the Expert Panel.
Charter The AOV Working Group is chartered to meet, discuss and reach consensus on AOV Program valve classification based on industry accepted definitions, support resolution of AOV issues at STPNOC, develop plans of action to resolve specific valve problems and provide recommendations to the Expert Panel, as required.
AOV Working Group Membership The AOV Working Group is composed of representatives from Design Engineering, System Engineering, Maintenance, Operations, Operating Experience Group, Quality Assurance and Risk Management and Industry Relations departments.
The members will be personnel with backgrounds that tender them capable of providing logical recommendations. The Expert Panel endorses the AOV Working Group members.
The AOV Working Group may select guest status authorities on specific issues. The guest status is provided fo~ site or industry experts who may possess information not available to the AOV Working Group. Guest status personnel cannot vote or represent i her AOV Working Group merabers in obtaining a consensus.
The ~ 'esign Engineering representative will be the chainnan and point of contact (POC) for all AOV Working Group meetings. It is the only position that maintains an alternate member. Any representative group may initiate a meeting through the POC, Any aspect of the AOV Program may be discussed and acted upon by the Chairman and three Working Group members which meets the requirement for consensus. However, valve classification and the associated testing strategy requires representatives from each identified department be present. Classification requires documented results that will be captured by a Condition Not Adverse to Quality (CNAQ) Action defined by the Corrective Action Program (CAP).
Engineering shall then issue a Engineering Report prepared under the Condition Report Engineering Evaluation (CREE) Program to document the basis of the valve categorization. An Action in the CREE will require Expert Panel approval prior to CREE issuance. After CREE approval, Design Engineering will enter the valve classification itselfinto the Master Equipment Data field.
1
(
)
OPGP02-ZA-0003 Rev. 4 Page 23 of 25 Comprehensive Risk Management Addendum 5 Air Operated Valve Program Page 3 of 5 Definitions The Air Operated Valve Program is a long-tenn program involving activities to ensure AOV capability to j meet safety significant functions over the life of the plant. )
Categories:
Category 1 AOVs at STP are valves which are safety related and are identified as having a "high" risk significance by the Graded Quality Assurance (GQA) / Risk Significance evaluation process. These valves will receive " Full" prograrh controls fbr oversight and performance.
Category 2 AOVs are valves which are safety related, active valves having a " medium" risk significance; non-safety related valves having a "high"or " medium" risk significance"; AOVs having had an occurrence ,
of a Repetitive Maintenance Preventable Functions Fai;ure (RMPFF) which could indicate a common I caase / common mode failure issue, as identified and added by the AOV Working Group. !
Category 3 AOVs are valves that have " low" risk or are non-risk significant. These valves require the least amount of resource allotment for testing and maintenance. These valves will maintain a Category 3 identification in the MED and are not included in the '.JV Testing Program. The valves will maintain Code requirements, Environmental Qualifications, and required testing under other plant specific programs, as applicable.
In those instances where the GQA risk significance is not available, the Probabilistic Risk Assessment (PRA) risk ranking will be used, if the valve has been modeled by the PRA. Otherwise, the AOV Working Group will categorize the valves based on the Joint Owners' Group AOV program criteria.
Program Exclusions an:1 Houndaries- l i
)
The AOV circuit envelops all components and assemblies required to make an entire AOV loop functional. j 4
AOV Program valve exclusion are those components which may have air assisted operators but are described as check valves or HVAC dampers in sheet metal ducting. ;
i l
l t
o .
i OPGP02-ZA-0003 Rev.4 Page 24 of 25 Comprehensive Risk Management Addendum 5 Air Operated Valve Program Page 4 of 5 Instructions The AOV Working Group will categorize all AOVs by reviewing each system. The System engineer will ;
identify and present AOV's by TPNS, component description, system, recommended AOV category <
classification and basis for the classification. The recommendations will be discussed, reviewed, compared with risk ranking thresholds and deterministic insights and approved by the AOV Working l Group. The recommendations for categorization will be submitted to the Expert Panel for approval.
Design Engineering will be responsible for capturing the AOV categorization in the MED.
Each panel participant should be prepared to provide a deliverable for the meeting, such as:
Maintenance -
Maintenance history, special training, diagnostic equipment, spare parts, valve setup requirements Operations -
System and component operatic,n insights and concerns Design Engr. -
Design basis review, safety analysis, capability margins d Component Engr. -
Tracking, test evaluation, valve issues, Maint. Rule R&RA -
Provide risk ranking for valves contained in the plant risk models in accordance with OPGP01-ZA-0304 I
OEG -
Provide program input for repeat maintenance failures QA -
Provide program overview and program implementation verification The AOV Working Group, comprised of Operations, Risk Management, Maintenance, Quality Assurance, Operating fixperience Group, and Design Engineering will be formed to determine the initial i AOV categorization. The AOV Working G.oup may determine or change the classification of AOV's l requiring testing based on resolution of design / operation issues, new or obsolete designs or a continued trend ofimprovement or degradation. Dissentions in consensus detennination of the Working Group on valve classification and resultant testing requirements are identified and provided to the Expert Pnel for disposition.
OPGP02-ZA-0003 Rev. 4 Page 25 of 25 l
Comprehensive Risk Management Addentium 5 Air Operated Valve Program Page 5 of 5 l
l All AOV's with TPNS identified in the MED and installed in the field will be categorized in one of three categories using industry definitions derived from the AOV Joint Owners Group (JOG) AOV Program document. These definitions are provided in the AOV Program procedure.
The discussion of valve categorization may include the AOV's function in the system; a review of the P&lD's, control logic and electrical schematics; commitments in the site licensing documents, including a j Folio search; a review of the EOP's; risk ranking at the system and component level; Maintenance Rule repetitive functional failure, (RMPFF) review ; review by the Graded Quality Assurance (GQA) Working Group; and, a review of NSSS supplier informction, if required. For AOVs that do not have GQA risk ranking, deterministi methods and AOV Working Group consensus on risk ranking will be used. A reconciliation of risk ranking would then occur when the GQA Working Group has made a formal determination.
Using a CREE defined by the Corrective Action Program, Design Engineering will capture AOVs that are identified to be excluded from the AOV Program.
AOV technical issues may be resolved through development of a plan of action and implementation through a consensus of the chairman and at least three Working Group members. These actions do not ,
require Expert Panel approval. l l
The AOV Working Group cannot change the Risk Ranking of any AOV. l