Rob De La Espriella DLE Total Quality Management, LLC

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Rob De La EspriellaDLE Total Quality Management,
LLC
Risk-Based Oversight
In the Right Place at the Right Time
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Goals for this Discussion

• Consider three crucial areas that deserve heavy
  oversight focus
• Understand the INPO model for RISK
• Explore methods to use Risk to shape the conduct
  of oversight at the plants

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Oversight Focus Areas

• Nuclear Safety
• Plant Reliability
• Risk Significant Activities

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Oversight Focus Areas

• Nuclear Safety
• RCS Pressure Boundary
• SSCs required to mitigate the consequences of an
  accident
• SSCs required to shutdown and maintain the plant
  in a safe condition

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Oversight Focus Areas

• Plant Reliability
• Processes and Procedures That Support Equipment
  Reliability
• Plant Health Committees
• System Health Reports
• Maintenance Rule
• Work Management Process
• Outage Management
• PM Optimization
• Critical Spare Parts Program

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Oversight Focus Areas

• Risk Significant Activities
• INPO Model
• Risk Probability Consequences
• of an event of an event
• (Error Rate) (Defense
  in Depth)

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Oversight Focus Areas

• Risk Significant Activities

• Error rates are largely governed by
• Work Preparation
• Work Performance
• Work Feedback

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Oversight Focus Areas

• Risk Significant Activities

• Defense-in-Depth consists largely of
• Engineered Controls
• Administrative Controls
• Oversight Controls

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Oversight Focus Areas

• Risk Significant Activities

• To Properly Focus Oversight
• The key is to focus on CRITICAL TASKS for areas
  that pose risk to plant equipment, plant
  personnel or the public.
• The highest risk activities should be provided
  oversight on a daily basis.
• In simple terms strive to be at the right place
  at the right time!

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Risk-Based Oversight

• The following are examples of Critical Tasks that
  should be evaluated
• to reduce error rates in the area of
• Nuclear Safety
• Operations
• Conservative Decision Making
• Use of On-Line Risk Monitors/Shutdown Safety
  Assessments
• Involvement in Work Management Equipment
  Reliability
• Design Controls
• Configuration Management
• Operational Margin
• GL 91-18 Evaluations
• Safeguards Testing
• Equipment Reliability
• System Health Reports
• Maintenance Rule Program
• On-site / Offsite Safety Review Committees

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Risk-Based Oversight

• The following are examples of Critical Tasks that
  should be evaluated
• to reduce error rates in the area of
• Plant Reliability
• Work Management
• Daily Scheduling Planning
• Outage Scheduling Planning
• Metrics Process Improvements
• Maintenance
• Tagging
• Corrective Maintenance
• Elective Maintenance
• On-line Maintenance (CMMs)
• Predictive Maintenance
• Preventative Maintenance
• Maintenance Modifications

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Risk-Based Oversight

• The following are examples of Critical Tasks that
  should be evaluated
• to reduce error rates in the area of
• Plant Reliability
• Corrective Action Program
• Problem identification
• Problem resolution
• Self-Assessments
• Significant Events/Root Causes
• Chemistry Controls
• Primary (SG tubes)
• Secondary (e.g. Secondary Pipe Walls)
• ODCM controls

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Risk-Based Oversight

• Examples of Programs/Activities to evaluate on a
  continual basis because they protect
• plant equipment/personnel/public from
• Risk
• Industrial Safety
• Human Performance Program
• Radiological Protection Program
• Reactivity Management Program
• Boric Acid Corrosion Controls
• Training and Qualification Programs
• Emergency Preparedness Program
• Fire Protection Program
• Security

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Risk-Based Oversight

• Examples of reports to review on a frequent
  basis because they provide insights on
• Risk
• Operating logs
• Daily Status Reports
• Configuration Risk Management Programs
• Shutdown Safety Assessments
• The Top Ten Equipment Issues list for the station
• The list of Operator Work-Arounds and Burdens
• The list of control room deficiencies
• The list of Maintenance Rule systems in a(1)
  status
• The list of RED System Health Reports
• The list of PWOs that are keeping M-Rule systems
  in Yellow or Red

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Risk-Based Oversight

• Daily Routines
• Oversight should provide real-time
  oversight/evaluations of daily activities that
  pose a risk to the station or the public.
• Surveillances, assessments and audits should be
  flexible enough to accommodate oversight of high
  risk activities.
• Individual risk as well as the aggregate risks of
  an activity should be assessed, as other plant
  conditions may add to the risk. (For example, at
  one station, the Refueling Water Tank overflowed
  while being refilled because Operators did not
  consider that the high level alarms were out of
  service.)
• Oversight should also be evaluating whether the
  line organization understands which are the
  critical tasks, and whether the right human
  performance tools are being applied to minimize
  risk.

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Take-Aways

• Evaluate whether your oversight organization
  is considering risk in its daily routine
• Ask line management if oversight is usually at
  the right place at the right time.
• Ask oversight management how Risk is factored
  into their surveillance and audit programs.
• If the answers point to an organization that
  is not providing sufficient oversight of risk
  significant activities, its time to explore
  different oversight models.

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Summary
To get more value from your oversight
organizations, ensure the surveillance and audit
programs are taking into account what is going on
at the stations, such that they can place
themselves at the right place at the right time.
The INPO Risk model can be used as a guide to
help minimize the risk of certain activities to
the station and the public. Oversight should be
looking frequently at what is scheduled at the
plants, evaluate the relative risk of those
activities, and, given an understanding of the
risks, establishing a proactive oversight plan or
making adjustments to existing plans to provide
oversight of Critical Tasks associated with those
activities.
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DLE Total Quality Management (a Limited
Liability Company)
Contact Information
For more information on Risk-Based Oversight,
please contact Rob De La Espriella at
4634 SW Long Bay DrivePalm City, FL 34990Office
No. [phone]Fax No. [phone]Cell
No. [phone]Email robdelae_at_adelphia.net
Rob De La EspriellaPresident