ML17227A121

08/16/2017 NEI 16-07 Revision a, Draft Technical Report, Improving the Effectiveness of Issue Resolution to Enhance Safety and Efficiency, Public Meeting- Ne Presentation

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

Text

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

Purpose of today's meeting

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

-07 *Hear and respond to NRC stakeholder questions and concerns

• Discuss path forward and next steps

-For industry

-For NRC 2 Origins - The Haystack Problem

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

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

• Over time, CAP became a catch

-all for tracking everything that needed attention (a large haystack)

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

Origins - CNO Recognition

• CNOs recognized the haystack problem

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

-01 [EB 16-10, March 2016], said implement INPO 14

-004 *DNP Improvement Opportunity CAP-02 [EB 17-14, May 2017], aims at standardizing terms and processes, simplifying tools and clarifying guidance for tailoring effort to significance 4

Origins - Charge to the CAP

-02 Team *Maintain low threshold for initial entry into CAP, to ensure employees report all conditions and concerns

• Maintain CAP focus on CAQ/SCAQ (Appendix B items) *Maintain focus on regulatory matters of importance (items outside Appendix B)

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

• Address business

-risk issues through other appropriate systems 5

Industry Milestones

• Release NEI 16

-07 May 2017

• Brief utility and NRC stakeholders

-RUG II - Completed June 20

-RUG IV - Completed July 12

-NRC Headquarters

- August 16 -RUG III - October 24

-RUG I - November 28

• Update NEI 16

-07 with feedback from briefings and comments and reissue as "Final"

- early 2018

• Implement DNP EB 17 May 2018 6 CAP-02 Development Team

• Executive Sponsors -Danny Bost - Southern -Dan Stoddard

- Dominion -Kelvin Henderson

- Duke *Industry Lead -John Grabnar - FENOC *INPO -Gary Waldrep *IBEW -Anna Jerry

• NEI -David Young, Jim Slider 7 *Industry Members -Wally Beck

- Exelon -Brad Castiglia - NextEra -Nick Conicella - FENOC -Dan Crofoot - Xcel -Joel Duhon - Duke -Sharon Peavyhouse

- Duke -Reiko Perleberg

- Southern -Rex Putnam

- Entergy -Lanny Ratzlaff - Wolf Creek

-Jim Schleser - Dominion -Tim Steele

- Southern

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

• Maintain low threshold for condition reporting and feedback to originators

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

-Promote greater focus on conditions affecting safety and operational performance

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

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

Related Work

• As noted earlier, NEI 16

-07 builds on previous CAP initiative (DNP CAP

-01) *CAP-01 was about improving screening efficiency to highlight the safety significant needles in a smaller hay stack *CAP-02 standardizes around a common language and investigation tools

- it's the next logical step 9

What Will Change for Licensees

• Population of items in CAP will be better defined

• Many items will be addressed at find

-and-fix level, depending on perceived risk

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

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

• Conditions outside the scope of CAP will be addressed through management action 10 What Will Not Change for Licensees

• Low threshold for reporting remains unchanged

• Safety-related and important

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

• CAQs must be identified and corrected

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

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

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

• With the emphasis on "find and fix", inspectors may find less documentation of formal investigation and analysis of items of lesser significance 12 What Should Not Change for NRC

• Effectiveness of the licensee's CAP program

• Basis for crediting licensee's CAP in NRC's decision

-making processes (e.g., Enforcement Policy and ROP

-based supplemental inspections) 13 CAP Process Changes 14 All IssuesNon-CAP IssuesCAP IssuesSignificant Conditions Adverse to QualityAppendix B Conditions Adverse to QualityConditions Adverse to Regulatory Compliance Definitions

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

• Condition Adverse to Quality:

A failure, malfunction, deficiency, deviation, defect, or nonconformance associated with the performance of an activity affecting the safety

-related function of a structure, system or component.

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

. 15 16 Issue Resolution Process 17 Issue Resolution Process Criteria for an Approved Process

• A program document or procedure describes the process

• The process identifies conditions that require generation of a CR *Process controls: -Provide for identifying conditions that require a prompt review by Control Room staff (e.g., for operability, functionality and reportability determinations)

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

-Ensure that the work performed is traceable -Ensure that canceling, extending or changing the intent of work that is a corrective action includes the same level of review as established the original action -Provide for generation and retention of action/work completion documentation suitable for QA record purposes

• Management oversight is in place to monitor performance of the process 18 Graded Approach to Investigations 19 Cause Uncertainty Cause is Clear Cause is Ambiguous or Complex Risk High Consequence

• Issue Investigation

• Correct Condition and Cause *Root Cause Analysis

• Correct Condition and Cause Medium Consequence

• Document Known Cause *Correct Condition

• Issue Investigation

• Correct Condition and Cause Low Consequence

• No Investigation

• Correct Condition

• Investigation Optional *Correct Condition

General Guidance on Conducting Root Cause Investigations

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

• Format is largely unchanged

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

• Can use existing tools and techniques

• Root Causes will be required for White or greater 20 Investigation Templates

• Equipment Reliability Checklist

- -Developed by ERWG, INPO

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

• Human Performance Checklist

- -Developed by HU Working Group, INPO

-Based on TWIN model and others 21 Investigation Templates

• Organizational Effectiveness Checklist

-Developed by OR Working Group, INPO

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

-There is intentional overlap between HU and OR checklists

• Maintenance Rule Checklist

-Special Case and developed by MRWG 22 Management Action

• N-CAP issues

• Allows for resolution within a tool but outside of CAP *Business-type issues at manager level discretion 23 Appendix A

- Defines some Examples

• Significant Condition Adverse to Quality

• Condition Adverse to Quality

• Condition Adverse to Regulatory Compliance

• Non-Corrective Action Program Conditions 24 Change Management

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

-CAQ, SCAQ *Screening process changes

- procedure changes, evaluate roles / responsibilities

• Software changes should NOT be required

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

• Discussions with Resident Inspectors 25 Other NRC Concerns

• Active discussion with regulators at HQ and regions -Concerns about protecting the SCWE and reporting culture

-Concerns about supervisory engagement and action (for N

-CAP issues)

-Concerns about definitions (SCAQ)

-Concerns about investigations for important issues 26 Questions 27 For More Information

• John Grabnar - FENOC, CAP

-02 Team Lead

-jjgrabnar@firstenergycorp.com

• Tim Steele

- Southern, Subject Matter Expert

-tssteele@southernco.com

• Jim Slider

- NEI, Senior Project Manager

-jes@nei.org 28