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Strategies for Implementing Risk-Based Oversight

Fall 2005 Nuclear Oversight Conference

Risk-Based Oversight
In This Presentation:
Excerpts from the St. Lucie Nuclear Assurance Business Plan: Department Areas of Emphasis Administrative Letter 17, Risk Based Oversight Daily process used for assigning oversight Results
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Fall 2005 Nuclear Oversight Conference

St. Lucie Nuclear Assurance Organization


Rob De La Espriella
Site Quality Manager

Kathi Butler
Staff Technician

Mike Snyder Audit Supervisor Areas = Operations, RP / CHM Ed Armando SRO (PWR, BWR)

Dom Fuca Technical Reviews and Assessements Supv. Areas = Engineering, Fire Protection Kathy Getty ISI/IST, ENG QC Inspector (Mech I) Lead Auditor John Luchka Chem, Ops QC Inspector (Mech II) Lead Auditor Jim McNey Security QC Inspector (Mech I) Lead Auditor Doug Melody QC Level III Elec/IC QC Inspector (Mech II) Lead Auditor Bob Carroll Engineer

Greg Pustover Quality Control Supervisor Areas = Maintenance, Work Management George Ingram QC Level III Mech QC Inspector (Elec/IC II) Lead Auditor Mike Meiley QC Level III Civil QC Inspector (Mech I)

Bruce Parks SRO (PWR) Lead Auditor QC Inspector (Mech II) John Hauger SRO (PWR)

Jim Norman QC Inspector (Mech II) QC Inspector (Elec/IC I) QC Inspector (Coatings II) Lou Panessa QC Inspector (Elec/IC II) QC Inspector (Mech II) QC Inspector (Civil II) VACANCY QC Inspector

Bob Eavenson Chem Tech QC Inspector (Mech I)

VACANCY Radiation Protection

Fall 2005 Nuclear Oversight Conference

Risk-Based Oversight
Areas of Emphasis*:

Nuclear Safety

Plant Reliability
Risk Significant Activities
*Established in 2000
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Fall 2005 Nuclear Oversight Conference

Risk-Based Oversight

Nuclear Safety
RCS Pressure Boundary SSCs required to mitigate the consequences of an accident SSCs required to shutdown and maintain the plant in a safe condition

Areas of Emphasis:

Fall 2005 Nuclear Oversight Conference

Risk-Based Oversight

Plant Reliability
Processes and Procedures that support equipment reliability
System Health Reports Plant Health Committee Maintenance Rule Work Management Process Outage Management PM Optimization Critical Spare Parts Program 6

Areas of Emphasis:

Fall 2005 Nuclear Oversight Conference

Risk-Based Oversight

Risk Significant Activities


Risk = Probability + Consequences
(Error Rate) (Defense in Depth)

Areas of Emphasis:

Error Rate: Work Preparation Work Performance Work Feedback

Defense-in-Depth: ENGd Controls ADMIN Controls Oversight Controls

KEY: Focus on CRITICAL TASKS


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Fall 2005 Nuclear Oversight Conference

Risk-Based Oversight
Administrative Letter 17, Risk Based Oversight
SCOPE: Risk-management is a fundamental component of maintaining safety at operating nuclear power plants. The guidance in this AL defines how the Quality Department evaluates the risk associated with plant activities on a daily basis, and how Quality Department Supervisors will establish the appropriate oversight plan based on relative risk, department priorities and available resources.
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Fall 2005 Nuclear Oversight Conference

Risk-Based Oversight
Administrative Letter 17 Risk Based Oversight
INPUTS: St. Lucie Nuclear Plant Daily Status Reports for both units (including operational focus items and unplanned control room annunciators) Configuration Risk Management Program Implementation (ADM-17.16) Daily Configuration Risk Management Program (CRMP) calculations (Modes 1, 2, 3) CRMP / Shutdown Safety Assessments (Modes 4,5,6, defueled) Operations control room logs for both Fall units 2005
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Nuclear Oversight Conference

Risk-Based Oversight
Administrative Letter 17 Risk Based Oversight
INPUTS: The Top Ten Equipment Issues list for the station The list of Operator Work-Arounds and Burdens The list of control room deficiencies for both units The list of Red and Yellow PWOs being worked for the week The list of Maintenance Rule systems in a(1) status The list of System Health Reports with RED systems Fall 2005
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Nuclear Oversight Conference

Risk-Based Oversight
Administrative Letter 17 Risk Based Oversight Nuclear Safety Elements 1. Operations Conservative Decision Making Culture Use of OLRM/Shutdown Safety Assessments Involvement in Work Management & Equipment Reliability 2. Configuration Management Design (e.g. TEDB, Drawings & Plant) Operational Margin (e.g. GL 91-18 evolutions) Regulatory Control ( e.g. Tech Specs) 3. Equipment Reliability System Health Monitoring Maintenance Rule Program 4. On-site / Offsite Safety Review Committees Oversight Fall 2005
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Nuclear Oversight Conference

Risk-Based Oversight
Administrative Letter 17 Risk Based Oversight
Plant Reliability Elements 1. Work Management Daily Scheduling & Planning Outage Scheduling & Planning Metrics & Process Improvements 2. Maintenance Corrective Elective On-line Maintenance (CMMs) Predictive Preventative Modifications 3. Corrective Action Program Problem identification Problem resolution Self Assessments Significant Events/Root Cause 4. Chemistry Controls Primary (SG tubes) Secondary (e.g. Secondary Pipe Walls) ODCM controls
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Fall 2005 Nuclear Oversight Conference

Risk-Based Oversight
Administrative Letter 17 Risk Based Oversight Other Risk Significant Activities 1. Personnel Safety Industrial (e.g. PPE, Fall Protection, Confined Space, Electrical Shock) Radiological Protection 2. Emergency Preparedness 3. Security 4. Fire Protection 5. Training (e.g. Qualifications & Safety Culture)
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Fall 2005 Nuclear Oversight Conference

Risk-Based Oversight
Administrative Letter 17 Risk Based Oversight
DAILY ASSIGNMENTS: Assessment of individual risk Assessment of aggregate risk Assignments based on skills available Tracking assignments to conclusion

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Fall 2005 Nuclear Oversight Conference

Risk-Based Oversight
Risk Based Oversight for Wednesday 9/1/04
Protected Train: B
Unit 0 Condition or Activity Reactivity Management oversight group meetings RCS Leak Rate -30 Day LCO started 8/23/04 1A ICW Pedestal Risk Aggregate Risk Secondary systems that can affect reactivity not being properly maintained Problems with RCS leak detection equipment in containment Backlog and Lack of funding for level 2 PWOs Issues or Concerns Plant Sched ule Oversight Task Assignee Products CNO DNA SQM Lack of oversight = Potential for Reactivity Mgmt event Potential RCS pressure boundary leak Is the Reactivity Management Oversight group operating effectively/adequately Flange downstream of V-1452 (top of Pzr) leaking 1330 meeting Access station's sensitivity to Reactivity Management CR / DQS / QR

Leak repair activities QR - Panessa Developing V1452 repair plan

CR / DQS

Seismic Integrity of Level 2 Structures ORLM contributor

Continual long term degradation with no repairs on corrective actions Critical Maintenance Management could result in exceeding LCO and a unit shutdown Fire seals do not meet 10 CFR App R and licensing basis

Meeting @ 1000

Surveillance of Storm Action Plan development

DQS

1A ECCS on line maintenance

Preps & Execution of CMM (dependent of Hurricane Frances) 10/31 Inspect Fire Seals LER inspection commitment for QC from QA Finding

DQS

CNO

Fire Seals do not match design

Hurricane approaching - Severe Weather Preps

A fire could spread and affect systems needed for safe (App R) shutdown Emergency Preparedness maintaining the ERO intact

Security Fire watches were falsifying logs

DQS

Low number of qualified people in some positions

Hurricane Frances Hurricane Jeanne

9/1 9/21

Ensure storm preps are adequately implemented

DQS

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Fall 2005 Nuclear Oversight Conference

Risk-Based Oversight
Results:

Area
Boric Acid Corrosion Controls Configuration Management Reactivity Management

Issues Identified
Significant weakness in process for addressing active leaks - Breakdowns in control of mods - Lack of control of EQ panels Lack of sensitivity to secondary systems affecting reactivity

Equipment Reliability Longstanding equipment reliability issues linked to weaknesses in corporate longFall 2005 16 range planning Nuclear Oversight Conference

Questions or Comments?
Fall 2005 Nuclear Oversight Conference