Evaluation Improvement Initiative A New Evaluation Approach

1. Evaluation Improvement InitiativeA New Evaluation Approach Institute of Nuclear Power Operations Suite 1042 700 Galleria Parkway Atlanta, GA 30339 DAVID M. FARR Manager Configuration Management 770-644-8432 Farrdm@inpo.org 0616 CMBG Discussion on Revised Evaluation Approach.PPT

2. RROP - A “Risk Based Approach” • NRC’s Mission: To protect the health and safety of the public. • Desired end states: • Minimize core damage frequency • Avoid a large, early radioactive release • Manage risk through ensuring the health of these cornerstones: • Initiating events • Mitigating system performance • Containment and fission barrier performance • Emergency Preparedness • Security • Cross cutting issues: • Human performance • Safety conscience work environment

3. Shouldn’t INPO be “Risk Informed?” What is INPO’s “risk model?” (What is it that INPO is charged with avoiding?) • A significant operational event such that the continued viability of the unit is challenged or one that challenges the ongoing operation of other units in the industry. • The undetected degradation of a major component or equipment such that safety margins are significantly compromised. • A unplanned, long-duration shutdown requiring substantial upgrades to station programs, processes and/or people to recover the unit. • Operation outside of plant design and safety margins. • Withdrawal of accreditation of one or more training programs. • Long-term poor performance of a station, as measured by INPO assessments and the WANO performance indicators.

4. INPO’s Mission – Excellence! • INPO is not about “risk avoidance” or even “risk management.” • INPO is about plants “striving for operational excellence.” • ERG input: • INPO should modify the risk model (the avoidance end states) to focus on desired outcomes.

5. Operational Excellence Outcomes

6. Why look at Configuration Management? Plant safety degraded, long-term shutdowns caused by problems with: • Inadequate operating and design margins • Problems with design basis validity • Deficiencies in plant status and configuration control • Poor design product quality • Inadequate oversight of engineering programs

7. Well Managed Margins OR.5 Station leadership establishes a culture that thoughtfully manages safety, design, & operational margins An “Enabler” CM.1 Plant equipment configuration is rigorously maintained and performance is consistent with design and licensing requirements CM.4 Processes that are used to control plant design bases are defined and validated The “Outcome” Well-Managed and Understood Safety, Design, and Operational Margins CM.2 Roles and responsibilities for establishing and maintaining licensing and design basis are understood and applied consistently CM.3 Day-to-day activities are conducted in a way that ensures operational and design margins are maintained

8. Design and Operating Margins Model Functional/Design Failure Greater than design basis range Design margin ( This is a prohibited range of operation and represents the additional conservative margin to account for uncertainties in design and construction ) Design or Tech Spec Basis Limit Analyzed transient range ( Design allows operation in the transient range. However operating restrictions consistent with the design, such as the magnitude and frequency of excursions into this range apply) Operating Point Limit Operating margin Allowed operating range ( The allowed operating range provides the normal margins operators use without violating setpoints ) Normal Operating Point

9. Margin Examples • Turbine lube oil TCV found almost fully closed during operation. • Safety Related Service Water throttle valve position changed, reducing EDG starting margin. • Power uprates.

10. Reduced Operating Margin Example

11. ER Programs & organizational behaviors are focused on the prevention of unanticipated or repeat equipment failures OR Leaders emphasize nuclear safety and establish core values that drive organizational behaviors OR Station leadership has a vision of excellence and acts to keep station on a continuous path of improvement ER Station processes and practices effectively support day-to-day activities and result in high levels of equipment reliability and availability OR An accountable, engaged, and motivated workforce that achieves station goals OF Integrated processes promote teamwork and align resources to common goals and priorities that support safe and reliable operation High Levels of Plant Performance Sustainable, High Levels of Plant Performance

12. OF #8 Plant activities are controlled to manage risks and provide compensatory actions PI The frequency and consequences of human errors are minimized by the application of individual and organizational error reduction and mitigation techniques Sustainable, Event-Free Operations ER Programs & organizational behaviors are focused on the prevention of unanticipated or repeat equipment failures OF #7 Station leadership promotes and uses sound operational decision-making ER Station processes and practices effectively support day-to-day activities and result in high levels of equipment reliability and availability Sustainable, Event-Free Operations OF #6 Operators recognize and respond correctly to plant conditions PI Station personnel are committed to and accountable for achieving performance improvement by identifying and correcting problems, applying lessons learned from industry operating experience, and comparing station standards and performance to industry standards of excellence

13. PI Station personnel are committed to and accountable for achieving performance improvement by identifying and correcting problems, applying lessons learned from industry operating experience, and comparing station standards and performance to industry standards of excellence OR #14 The organization and leadership team inspires stakeholder confidence in their ability to address problems Avoidance of Unplanned, Long-Duration Shutdowns OR #15 Station staff and infrastructure are capable of responding to emerging problems without adversely affecting routine station activities ER Vulnerabilities to the long-term reliability and availability of important plant equipment are recognized and mitigation and contingency plans have been developed OR #16 Effective change management plans that consider unintended consequences Avoidance of Long-Duration Shutdowns

14. High Levels of Worker Safety RP Station personnel exhibit ownership for industrial and radiation safety RP Station leaders establish and promote a culture that supports worker safety High Levels of Plant Worker Safety RP Radiological and industrial safety hazards are anticipated, recognized and managed RP Plant conditions and processes promote health and safety

15. Highly Skilled Workforce PI Training is used as a strategic tool to provide highly skilled and knowledgeable personnel for safe, reliable operations and to support performance improvement OR Management executes a long-term human resource strategy Highly-Skilled, Knowledgeable and Collaborative Workforce PI The frequency and consequences of human errors are minimized by the application of individual an organizational error reduction and mitigation techniques PI Management and leadership skills are systematically developed and reinforced

16. Evaluation Timeline

17. Analysis Group Functions • Plant Information Center (PIC) Data • Event history • Indicators • Plant Specific CAP database • Plant Specific Information on Engineering Programs • Self assessments • “Conduct of”

18. Analysis Group Output • Identifies areas of focus • “High value” enablers and attributes • Targets EN programs for review • Based on performance data from plant • Based on self-assessment information • Targets systems or components for “vertical slice” • Based on performance data from plant • Consolidate with ER review • Makes Team Augmentation Recommendation

19. CM Questionnaire • Used to gain insight into roles & responsibilities (CM-2) • Questionnaire is sent in hard copy format as part of the advance information request. • Target audience is: • No more than 60 people. Distributed equally between: • Maintenance supervision and craft • Operations supervision and RO/NLO • Engineering supervision and individual contributors • CM evaluator analyzes results during prep-week

20. Evaluating Operational Excellence Six Outcomes: Sustainable high levels of performance Configuration and margin management Sustainable event free operation Avoidance of extended shutdowns High levels of worker safety Highly skilled workforce Five Cross Functional Areas: Equipment Reliability (ER) Configuration and Margin Management (CM) Operational Focus (OF) Performance Improvement (PI) Personnel and Organizational Performance (OR)

21. Advance information gathering PED/Analysis Division (3-4 months) Analyze data and determine focus areas TM/ORTM/Analysis (1-2 months) TM/ORTM/Site Leadership (1 month) Cross-Functional Evaluation team (12 total) NRC PIs, inspections, reports and public meetings Team Manager Self-Evaluation and Learning Organization (PI) Data analysis of station CAP Special evolution observations Equipment Performance (ER - MA) • Analyze data considering: • Operational • Excellence • Outcomes • Operating • Experience (TBD) • Framework • Document • Lessons Learned • from S/Ds Operational Focus Reactor Safety (OF - OP) SARC minutes • Develop evaluation plan in conjunction with station leadership • Functional areas • OEO building • blocks • Cross-function • focus areas • Output: team focus areas Design, Configuration and Engineering Program (CM - EN) Previsit Information Request OR and Personnel Performance (ORTM) OR/CC questionnaires Industry Advisor Discriminate areas that are functioning well from those that are questionable or unknown Previous evaluations Host Peer Station Self assessment in “conduct of” 3 Industry Peers (OF, CM, ER) Special INPO reviews 1-2 Functional Evaluators Department specific indicators PIs, PIC and events Deciding how to focus INPO resources

22. Discussion on outcomes of interest • -Tools to Evaluate Outcome • -Analysis • -Second Week Meeting • -Report Week Discussion • -DM review during report week Executive Summary Audience: CEO Owner: TM Check: Pre-exit • APS • 1. Operational Focus (Goddard) • 2. Performance Improvement (Hamlin) • 3. Configuration Management (Farr) • 4. Equipment Reliability (P. Wagner) • 5. Organizational Effectiveness (Link) • 6. Personnel Safety (Moss) • 7. Events (Heublein) Audience: CNO Owner: DM Check: TM SOER and Operating Experience Use Status and Any AFI’s Audience: SVP Owner: ORTM Check: TM • AFI’s & Strengths • Cross-functional • Functional Based on Significance and Consequence • (Would require utility response) Audience: SVP Owner: Team Check: DMs Audience: SVP/PM Owner: Evaluators Check: DM/TM • Appendix • One page per functional area (OP,TR,CY,MA,EN,RP,WM) • Items for CAP (previously lower level AFI) • Strengths • Additional Perspective (No Utility Response Required) Revised Report Structure

23. Evaluation References

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26. Evaluation References