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Margin Management

Margin Management. Plant Shutdowns. Late 1990’s – numerous “surprise” long-term plant shutdowns Shutdowns resulted when a history of events (equipment failures / complicated transients) lowered confidence in plant and raised scrutiny by external organizations

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Margin Management

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  1. Margin Management

  2. Plant Shutdowns • Late 1990’s – numerous “surprise” long-term plant shutdowns • Shutdowns resulted when a history of events (equipment failures / complicated transients) lowered confidence in plant and raised scrutiny by external organizations • General lack of “rigor” in evaluating and correcting problems

  3. Plant Shutdowns • Design issues evident shortly before or after shutdown • Resolution and extent of condition extended shutdown considerably • Key issues included • Accident analysis – translation into operation • Operating margin • Physical condition of plant not in conformance

  4. Plant Shutdowns Similar issues and causes and contributors are evident in plants today • Palo Verde • Kewaunee • Point Beach • Others?

  5. Basic Approach • INPO does: • Encourage more systematic consideration • Look for margin contributors to performance • Promote identification and resolution of “latent problems: • Promote site-wide approach to MM • INPO does not: • Dictate how much margin was acceptable • Prescribe how to manage • Push plants to build another complicated infrastructure • Push utilities to quantify unknown margins unless there was a risk / need.

  6. Status Today • Higher awareness and consideration of margins • Margin preservation and improvement is more explicitly considered during • Prioritization of equipment improvements • Design change options • Reconstitution of design basis, calculations, etc.

  7. Gaps Today • No industry consensus on: • Attributes/principles of margin management • Which margins are of most concern (i.e. critical equipment functions) • Some stations elected not to establish a “program” but normal processes don't have explicit standards and expectations • Most “programs” focus on identification & prioritization – little guidance that describes the desired site-wide management and organizational behaviors • At some stations – MM still viewed as an engineering activity – not embraced by the full management team • May not be rigorous if BOP

  8. CM & EN Evaluation Results Data Through 3/31/2008

  9. Guidance Document Development • Industry working group meeting at INPO April 2008 • 25 attendees • Current schedule to publish the document is end of 2008. • NX-1068 Exelon Margin Management

  10. Key Elements • Understanding margin • Identifying margin concerns • Evaluating margin concerns • Prioritizing margin issues • Resolving margin issues • Roles and responsibilities • Process considerations • Periodic assessment and communications

  11. Understanding margin • Objective • The concept of design and operating margin are defined, communicated, and understood by station personnel • Attributes • The definition of various margins is provided to plant personnel • Concepts understood by appropriate personnel • Location of limits and their bases are communicated to plant personnel • Training tools developed at plants

  12. Identifying margin concerns • Objective • Margin concerns are identified and documented by station personnel • Attributes • Scope of SSCs covered by program defined • Cross disciplinary input used • Existing processes identify margin concerns • Corrective Action Program • Self Assessments • Latent Issues Review • System Health Reports • Margins are identified when new plant configurations are implemented

  13. Evaluating Margin Concerns • Objective • Margin concerns are sufficiently understood to allow for proper prioritization • Attributes • Operating and design requirements are known • SSC capability is known • The resulting margin is assessed • The aggregate impact of margin issues is evaluated, as required • The associated risk to plant safety and reliability is established

  14. Prioritizing margin issues • Objective • Conditions that result in unacceptable design and operating margins are prioritized commensurate with the associated risk to plant safety and reliability • Attributes • Prioritization based on safety and reliability • Cross-disciplinary reviews determine priority • The prioritization scheme correlates to site prioritization • Management reviews, validates priority, and provides sponsorship

  15. Resolving Margin Issues • Objective • Plans are comprehensive and address interim compensatory measures and contingencies • Attributes • Plans developed • Associated actions are captured and tracked in the appropriate station work process • Interim actions and contingencies developed as req’d

  16. Roles and Responsibilities • Objective • Roles and responsibilities for monitoring, protecting, and resolving operating and design margins are defined and understood by plant personnel • Attributes • Site management sponsors the disposition of margin concerns and provides effective oversight of margin management implementation • Engineering is the champion of margin management and owns design margins • Operations owns operating margin • Maintenance ensures equipment maintained and tested to ensure performance requirement are met

  17. Process Considerations • Objective • Sufficient station processes exist to allow margin concerns to be identified, prioritized and dispositioned • Attributes • Station personnel are aware and consistently apply the process(es) designated to identify, prioritize and disposition margin issue • Processes revised to drive consideration (institutionalized)

  18. Periodic assessment and communications • Objective • The effectiveness of margin management decisions is periodically evaluated and communications reinforce the importance of effective margin management • Attributes • Periodic oversight reviews by station leadership • Periodic communications reinforce the importance of effective margin management

  19. Examples of Margin Areas for Improvement • Weaknesses in identifying and resolving low operating and design margin issues are affecting equipment that is important to safety. • Compensatory measures for low operating and design margins are affecting plant operations. • Power uprates reducing BWR power-to-flow map operating region and operation outside the design basis • Excessive cooler flows erode coils and cause unplanned LCOs • EDG loading margin and voltage response

  20. Examples of Margin Assistance Recommendations • Improve awareness of margin shortfalls during high-risk and emergent events. • Improve communications and understanding of margin issues. • Improve pathways of highlighting margin issues in existing plant processes. • Develop clear margin issues and follow a systematic process to resolve shortfalls.

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