Presented by Dorian Conger Conger-Elsea, Inc. 2000 Riveredge Parkway, Suite 740 Atlanta, GA 30328...

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Responding to a PI&R Substantive Crosscutting Area

Presented by Dorian CongerConger-Elsea, Inc.

2000 Riveredge Parkway, Suite 740Atlanta, GA 30328

800-875-8709 phone770-926-8305 fax

[email protected]

2009 Human Performance, Root Cause, and Trending ConferenceDel Ray Beach, FL

Copyright 2014 Conger-Elsea, Inc.

PI&R is the most important program at the plant from a regulatory standpoint. A PI&R Substantive Crosscutting Area results from a failed Problem Identification and Resolution (PI&R) process; most frequently a failing or seriously flawed corrective action program.

Copyright 2014 Conger-Elsea, Inc. 2

HOW DID IT HAPPEN?

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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 (root and apparent)


FIVE KEY AREAS FOUNDMISSING OR INSUFFICIENT

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Column 1 – Licensee Response (86)

Column 2 – Regulatory Response (15) - 95001

Column 3 – Degraded Cornerstone (2) - 95002

Column 4 – Multiple/Repetitive Degraded Cornerstone (1) - 95003

Column 5 – Unacceptable Performance


BASIC INFORMATION ABOUT THE NRC

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Column 2 - $1 - $2 Million




ESTIMATED COST OF RECOVERY

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Back to the drawing board – Restructure the Corrective Action Program (CAP)

MAKE THE NECESSARY CHANGES TO THE CORRECTIVE ACTION PROGRAM TO MAKE THE UPGRADED PROCESS REPEATABLE AND SUSTAINABLE.

Detailed evaluation of the existing program Rewrite the governing procedures (near state-of-the-art; final changes to follow) Train the plant staff, as appropriate:

Root Cause Analysts (Team Leaders) Apparent Cause Analysts Management Alignment training – Executives and Managers; Supervisors Familiarize remaining plant staff

Conduct root cause evaluations using the new procedures with expert mentoring (two rounds recommended; may also include team leader skills training)

Train station executives and managers to the elevated standards for root cause analysis and the proper behavioral expectations for Corrective Action Review Board (CARB) members

CARB review and approve the upgraded root cause reports with related corrective actions (CARB observed and mentored/coached as needed)

Implement the new PI&R process with 2-4 months of run time


HOW DO WE GET OUT OF THIS MESS?

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MOCK NRC PI&R Inspection – Establish a team of experts to perform a MOCK PI&R Inspection

NRC Team Leader experience NRC Inspector experience Root Cause and Corrective Action Program

expertise Safety Culture expertise


HOW DO WE GET OUT OF THIS MESS? (Continued)

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Perform the MOCK PI&R Inspection

Two weeks onsite One week for report preparation (if needed) Deliver the report to the plant management Provide advice and counsel to plant management

regarding NRC PI&R expectations and the need to communicate importance to the entire plant staff


HOW DO WE GET OUT OF THIS MESS? (Continued)

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Evaluate current program – 2 weeks involving two or three senior consultants/principals

Rewrite CAP procedures – 4-6 weeks for the drafting and editing 2 weeks for the reviews and approvals

Training – 1 week - Root Cause Analysts (Team Leaders) - fully mentored; 5-day class 1 week - Apparent Cause Analysts – two 2-day class sessions 2 week - Management Alignment training – Executives and Managers (two 2-day

sessions; Supervisors (two 4-hours sessions; plus video) 1 week - Familiarize remaining plant staff (all hands meetings as needed)

Conduct Cause Evaluations per the new standard and procedures – 8-12 weeks for conducting mentored cause evaluations to assure competence

and readiness of the personnel to sustain the process CARB review and approval of reports –

As completed Implement the new process prior to the MOCK PI&R inspection –

Allow 2-4 months run time Conduct MOCK inspection and report –

2 weeks for performing the on-site inspection and writing the report with recommendations


TIMING THE RELATED ACTIVITIES

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1. Understanding the magnitude of the problem2. Top management commitment and active

participation3. Resource commitment to properly perform the

upgraded CAP process4. Demonstrate commitment by implementing

corrective actions5. Demonstrate that the new CAP process can be

sustained without intervention6. Ultimately, demonstrate the upgraded processes to

an NRC inspection team to clear the PI&R Substantive Crosscutting Area


KEYS TO SUCCESS

Presented by Dorian Conger Conger-Elsea, Inc. 2000 Riveredge Parkway, Suite 740 Atlanta, GA 30328...

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Transcript of Presented by Dorian Conger Conger-Elsea, Inc. 2000 Riveredge Parkway, Suite 740 Atlanta, GA 30328...