fpl foundations of quality nuclear policy

8/3/2019 FPL Foundations of Quality Nuclear Policy

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Purpose: This document sets forth the foundations for quality for the FPL Nuclear

Division.

Responsibilities:A. Safety

Safety is our number one priority. FPL is committed to the safe,

reliable and cost effective operations of our nuclear units.

B. Quality is everyone's responsibility

The term "Quality" includes all those actions that are necessary to

achieve safety, reliability, availability, and economy. Quality is

the responsibility of everyone working in the Nuclear Division. It is

not the exclusive responsibility of Nuclear Assurance or any other

particular work group or department. Management and every

employee must understand these basic premises and adhere to

them to achieve safety, reliability, availability, and economy. Quality

means acting in the long term best interests of the company by doing

the following:

1. Defining the right job

2. Doing it right the first time

3. Adhering to all valid requirements

4. Serving the needs of the customer

C. Management Accountability

Every member of supervision is responsible to have a general

understanding of regulatory requirements (i.e. 10CFR50 Appendix B)and industry or INPO guidelines pertaining to their area of

responsibility, and should continuously assess their organizations

compliance with those requirements to identify and correct their own

problems. The line organization should not rely on the Nuclear

Assurance Department to tell them what the requirements are.

However, Nuclear Assurance independently evaluates the

compliance of the line organization to those requirements. Our

quality system will not function properly unless line management is

accountable for applicable quality requirements.

D. Nuclear Assurance Department

The Nuclear Assurance (QA) Department assesses and reports onthe quality of programs, processes, and products through formal

audits, surveillance, independent technical reviews, and quality

control inspections. However, quality cannot be assessed or

inspected into a program, process, or product. Rather, the Nuclear

Assurance Department enhances quality through its influence on the

behavior of nuclear personnel and how they conduct business. The

Nuclear Assurance Department shall:


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1. Advise line management, including the Chief Nuclear Officer, on

the status of quality, significant quality trends, and the principal

threats to quality.

2. Consult line management as requested in areas where the

Nuclear Assurance organization can provide independent

insights.

3. Promote the principals of quality, safety, and self-assessment in

all of our communication opportunities.

4. Improve the way we do business by keeping abreast of the

technological advances in the industry.

5. Produce quality assessments that clearly identify performance

issues, using available information such as performance trending

results and probabilistic safety analyses to focus department

resources on activities important to safety.

Building Blocks

of Quality:A. Self-Assessment Philosophy

Individuals are expected to find and correct their own problems

through self-assessment. It is the policy of Nuclear Division

management to proactively pursue continuous improvements in

products and services through the performance of self-assessment

activities in each department. Self-assessment activities are a

proactive part of the corrective action process whereby the

responsible individuals and organizations assess their own products

and services, to identify and correct their own problems. The

expected results of high quality self-assessment activities are

measurable reductions in the frequency and severity of problems or

events, and a reduction in deviations from established requirements.

Modifications, new personnel, shifted responsibilities, new suppliers,

new contractors, new and revised procedures, and policies can be

the precursors of quality problems. Since change is such a

pervasive and necessary part of our work environment, we put

particular emphasis on monitoring the thoroughness of change

control measures through pre-emptive or periodic self-assessments.

Change must be effectively controlled so that all aspects of the

change are done with appropriate foresight and with skeptical

monitoring.

Independent assessments conducted by Nuclear Assurance are tobe primarily directed toward evaluating the effectiveness of the

audited organization's self-assessments. In order to do this, Nuclear

Assurance needs to check some of the specific attributes of their

activities, processes, programs, and services. The first two levels of

defense of quality should be fully capable of assessing their own

quality. When Nuclear Assurance finds a problem the organization

itself did not find, it is an indication of weakness within the

organization's self-assessment.


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B. Four levels of defense-in-depth:

1. Individuals and Work Groups: The first level of defense is

provided by individual and work group activities. This is the only

level of defense which provides real-time, 100% exposure to

conditions adverse to quality. Individuals and work groups

contribute by adhering to procedures, training, meticulous andsystematic self-checking, implementation of the Quality Program

and providing feedback to management. They also inform

management of potential and actual conditions adverse to quality

as well as opportunities for raising standards of excellence. This

requires maintaining a critical questioning perspective as part of

every task. Every individual owns the first level of defense.

Problems effectively surfaced at this first line of defense are

most economically addressed. Problems that are identified by

the third and fourth levels of defense or by a self-disclosing event

are typically more expensive to solve, may result in equipment

damage, and disrupt the organization.

2. Supervision and Management: The second level of defense ismade up of all levels of supervision and management from the

task leader to senior management. A condition adverse to

quality detected by the second level of defense is usually

indicative of at least two conditions adverse to quality - the

detected condition and a self-assessment weakness in the first

level of defense. The second level of defense is responsible for

first level performance by ensuring that the first level:

a. Understands the standards of performance

b. Is appropriately staffed and trained

c. Has up-to-date and approved procedures

d. Has required tools and equipment

e. Receives meaningful coaching and instruction at the job site

f. Performs self-assessment and supports a culture of self and

independent assessment

g. Implements the corrective action process

3. Independent Assessment: The third level of defense,

independent assessment, consists of Nuclear Assurance and the

site safety review committees: Plant Nuclear Safety Committee

(PNSC), Facility Review Group (FRG), and Station Operating

Review Committee (SORC). The contribution of the third level of

defense is to provide sampling checks of the processes,

programs, products, and services of the first and second level,

and assess the effectiveness of self-assessment efforts. Any

condition adverse to quality detected by the third level of defenseis usually indicative of at least three conditions adverse to

quality: the detected condition and self-assessment weaknesses

in the first two levels of defense.

4. External Observation: The fourth level of defense is made up of

non-company organizations such as NRC and INPO. They

assess the first three levels, especially with respect to the

effectiveness of self-assessment efforts, and provide feedback.


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Any condition adverse to quality detected by the fourth level of

defense is usually indicative of at least four conditions adverse to

quality; the detected condition and self-assessment weaknesses

in the first three levels of defense. The Company's Nuclear

Review Board (CNRB) members act as if they are part of the

fourth level of defense when performing their function of

objective assessment from an independent and externalperspective.

C. Assessing Quality

Nuclear Assurance does not directly measure quality. Instead, they

identify conditions adverse to quality, as well as practices which

enhance quality. Assessments should clearly state the effectiveness

of the audited organization in meeting applicable requirements and

management expectations, as well as the organizations success in

finding and correcting its own problems in a timely manner.

When serious performance problems are uncovered by Nuclear

Assurance, they will provide the factual basis for any conclusions,and share the process by which those conclusions were arrived at.

Additionally, Nuclear Assurance is to appropriately state whether the

organization is effectively implementing the Quality Assurance

Program.

D. Corrective Actions

1. Conditions adverse to quality: Truly isolated conditions adverse

to quality are rare. Seldom does anything go wrong due to a

single causal factor. We should be skeptical of event

investigations reporting only one causal factor. In rare cases in

which an event of interest can be attributed to a single causal

factor, we should ask whether the fact that there was only a

single barrier is another causal factor (inadequate defense-in-

depth). The causal factors of significant events are the same as

the causal factors of non-significant events. The greater the

significance of an event, the larger the number of independent

causal factors that could have contributed to it, and the larger the

number of precursors that should have alerted the accountable

personnel.

2. Management prerogative in accepting risk: Management has the

responsibility to expend or reduce the resources consistent with

the value added. It is a function of management to decide, within

the bounds of its regulatory commitments, which risks it willaccept and which it will address. When events have multiple

causes, it is frequently effective to correct some, but not

necessarily all of the casual factors. Management is expected to

justify the quality and risk rationale for their decisions.

3. Resources applied commensurate with significance: Problems

should be characterized as to their quality and risk impact so

resources can be applied prudently in a manner commensurate

with the potential impact on the mission of the Nuclear


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Division. It is important to determine the quality impact, the

pervasiveness, and the potential safety risk of conditions

adverse to quality.

4. Human performance: Nuclear Division personnel abide by high

standards and strive to complete every task without errors.

However, except for the results of sabotage, natural phenomena,and risk-based decisions, adverse events at nuclear power

stations are caused, in part, by personnel errors. Personnel

errors usually cannot be readily corrected, but their underlying

causes may be addressed, if known. The majority of personnel

errors are indicative of a breakdown in the plants defense-in-

depth. It is generally more productive to focus on how the

system failed the individual, rather than how the individual failed.

Management is expected to focus on failed barriers and

underlying causal factors, to find effective ways of addressing

the causes of personnel errors.

Management Commitment

to Quality:Quality is not achieved merely by the correction of identified conditions

adverse to quality and their causal factors. Rather, quality is achieved by

a solid understanding of quality, and a firm commitment to quality and the

corrective action program on the part of management and every member

of the nuclear organization. Corrective actions for conditions adverse to

quality must address the broader (generic) implications of the identified

symptoms and causal factors. Management is expected to understand

the self-assessment weakness that prevented timely detection of the

problem; correcting a self-assessment weakness has the potential for

future prevention or early detection of a host of similar conditions

adverse to quality.

Acknowledgment:

This document is based on "Nuclear Quality Assurance Operational

Philosophy," dated 05/30/95 by William R. Corcoran, PhD, PE, and

modified by Nuclear Assurance for application at FPL's Nuclear Division.

Approval: Signature on fileChief Nuclear Officer

fpl foundations of quality nuclear policy

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