Transcript Responding to an NRC Supplemental Inspection – 95002 (and

Presented by Dorian Conger
General Manager
Conger-Elsea, Inc.
2000 Riveredge Parkway, Suite 740
Atlanta, GA 30328
800-875-8709
[email protected]
Revised July 1, 2009
2009 Human Performance, Root Cause, and Trending Conference
Toronto, Canada
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Column 1 – Licensee Response (85)
Column 2 – Regulatory Response (16) - 95001
Column 3 – Degraded Cornerstone (2) - 95002
Column 4 – Multiple/Repetitive Degraded Cornerstone (1) 95003
Column 5 – Unacceptable Performance
Numbers as of 7.1.2009
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Column 2 - $1 - $2 Million
Column 3 - $10 - $20 Million
Column 4 - $100 - $300 Million
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Most frequently through a failed corrective action program (PI&R*)
High
?
Level of Effort in
Cause Analysis
-----------CAP
Low
Col 1
Col 2
Col 3
Col 4
Col 5
- - - NRC expectation for a high quality, high performing CAP
* Problem Identification and Resolution
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1.
Extent of Condition
2.
Extent of Cause
3.
Safety Culture
4.
Management System and Programmatic Considerations
5.
Inadequate cause evaluations (depth and breadth)
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Back to the drawing board – Redo the related event investigations
 Establish new investigation teams for each of the events related to the 95002
 Train the investigation teams to meet the root cause analysis expectations defined in
95002
 Reinvestigate each of the events to the new expectations (with expert mentoring)
 Prepare new root cause reports to the expected, elevated level of thoroughness required
(with expert mentoring)
 Train station managers to the elevated standards for root cause analysis and the proper
behavioral expectations for Corrective Action Review Board members
 CARB review and approve the upgraded root cause reports with related corrective
actions (with expert mentoring)
 Implement the corrective actions prior to the NRC inspection where possible
 Develop a clear plan for implementing the remaining corrective actions, including
provisions for funding and staffing (unresourced promises will not work)
MAKE THE NECESSARY CHANGES TO THE CORRECTIVE ACTION PROGRAM TO MAKE THE
UPGRADED PROCESS REPEATABLE.
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MOCK NRC 95002 Inspection – Establish a team of experts to
perform a MOCK 95002 Inspection
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NRC Executive experience
NRC Team Leader experience
NRC Inspector experience
Root Cause and Corrective Action Program expertise
Safety Culture expertise
Administrative support
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MOCK NRC 95002 Inspection – Perform the MOCK 95002
Inspection
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Two weeks onsite
One week for report preparation
Deliver the report to the plant management
Provide advice and counsel to plant management regarding
NRC expectations and the need to communicate importance
to the entire plant staff
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Training –
1 week for elevated root cause team training
1 or 2 weeks for manager training
Reinvestigate to the new standard and process –
6-9 weeks
CARB review and comment integration –
1 week
Implement corrective actions prior to the MOCK inspection –
4-5 weeks
Conduct MOCK inspection and report –
3 weeks
Implement corrective actions prior to the NRC 95002 inspection –
4-8 weeks
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1. Understanding the magnitude of the problem
2. Top management commitment and active participation
3. Resource commitment to properly perform the upgraded CAP
process
4. Demonstrate commitment by implementing corrective actions
5. Demonstrate that the new CAP process can be repeated
successfully
6. Demonstrate the upgraded processes and safety culture to the
NRC inspection team
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