presented by dorian conger general manager conger-elsea, inc. 2000 riveredge parkway, suite 740...

Responding to an NRC Supplemental Inspection – 95002

(and Beyond)

Presented by Dorian CongerGeneral Manager

Conger-Elsea, Inc.2000 Riveredge Parkway, Suite 740

Atlanta, GA 30328800-875-8709

[email protected] July 1, 2009

2009 Human Performance, Root Cause, and Trending ConferenceToronto, Canada

Copyright 2014 Conger-Elsea, Inc. 1

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 PerformanceNumbers as of 7.1.2009

BASIC INFORMATION ABOUT THE NRC


Column 2 - $1 - $2 Million



ESTIMATED COST OF RECOVERY


High

Level of Effort in Cause Analysis------------CAP

Low

?

Col 1 Col 2 Col 3 Col 4 Col 5

HOW DID IT HAPPEN?

* Problem Identification and Resolution

Most frequently through a failed corrective action program (PI&R*)

- - - NRC expectation for a high quality, high performing CAP


1. Extent of Condition

2. Extent of Cause

3. Safety Culture

4. Management System and Programmatic Considerations

5. Inadequate cause evaluations (depth and breadth)

FIVE KEY AREAS OFTEN FOUND MISSING OR INSUFFICIENT


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.

HOW DO WE GET OUT OF THIS MESS


MOCK NRC 95002 Inspection – Establish a team of experts to perform a MOCK 95002 Inspection

NRC Executive experience NRC Team Leader experience NRC Inspector experience Root Cause and Corrective Action Program expertise Safety Culture expertise Administrative support


(Continued)


MOCK NRC 95002 Inspection – Perform the MOCK 95002 Inspection

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


(Continued)


Training – 1 week for elevated root cause team training1 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

TIMING THE ACTIVITIES


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

KEYS TO SUCCESS


presented by dorian conger general manager conger-elsea, inc. 2000 riveredge parkway, suite 740...

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