CNE Cernavoda Experience in developing and implementing an Integrated Management System - N. Florescu Department of Developing and Monitoring ...
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CNE Cernavoda Experience in
developing and implementing an
Integrated Management System
N. Florescu
Department of Developing and
Monitoring Management
System
1
Content
Introduction
How we started (practical examples; difficulties
encountered)
Where we are (strategies to overcome those
difficulties)
What remained to be done (use lessons learned)
Grading
Conclusion
2
SOCIETATEA NATIONALA NUCLEARELECTRICA (SNN) SA
SNN SA 2 units in operation
CNE CERNAVODA UNITS Nuclear Fuel Manufacturing
1 and 2
FCN PITESTI
3
3INTRODUCTION
Construction of the Cernavoda units started early in 1980.
5 CANDU units (work for the first reactor started in 1982, and
each year a new unit was started). Cernavoda was considered
the biggest site during Ceausescu regime.
At the beginning of the 1990 the most advanced status was
attained at units 1 and 2, the other 3 units were in a different
stage of civil work. The work was stopped or drastically
reduced.
In 1992 there was restarted the work to Unit 1 and in 2002 to
U2.
U1 was finished in 1996 and unit 2 in 2007 by a consortium
consisting from AECL, ANSALDO and Nuclearelectrica.
U3 and U4 continued to wait decision for restarting the work. 4How we start?
Being a CANDU Design, for the project realization
there was applied the requirements from Canadian
QA Standards from series N286 and Z299.
In 1982 there was issued specific
legislation/regulation related to QA based on
Canadian QA standards. The regulation was changed
in 2003 when there was issued a new set of Quality
Management Norms aligned to IAEA QA standards
(13 QM Norms).
In accordance with Romanian regulations, all
documents describing QM System shall be approved
by Romanian RB.
5How we started?
From the beginning, all the activities
performed during construction and later
during commissioning and operation were
done in accordance with QM Systems rules.
Procedures were prepared for each areas of
activities such as Safety; QA; Technical;
Administrative, Human Resources, Economic,
etc.
6How we started?
The documents were issued under 4 levels:
1. QAM /QMM first level
2. RD’s – Governance level
3. SI’s – Administrative procedures
4. Working level procedures.
As per Romanian norms all level 1 and 2 and
part of the level 3 documents shall be
approved by RB.
7How we started?
There were times when the approval by RB
took more than 1 year.
In 1999 Station Manager required QA
Department to start a project for restructuring
QA documentation and to reduce the number
of documents which required approval by RB.
This was the starting point for addressing a
new idea related to integration.
8How we started?
Adherence of SNN to FORATOM gave the
opportunity to access the information and
started modernization of Cernavoda MS.
Also, the creation of ROMATOM (SNN being at
the base of foundation of the Romanian
forum) gave the opportunity to SNN to force
CNCAN to change the Romanian Norm and to
align them to IAEA Standards.
9How we started?
In 2002, there was advanced the idea for
adhering to the requirements of ISO14001.
The idea was accepted by the Station
Management.
Quality management department plays the key
role for integrating the ISO 14001 requirements
in existing Quality Management System.
A team was established in order to review and
understand the standards requirements.
10How we started?
A gap analysis was performed by the team
against the existing QMS requirements.
The gap identified was incorporated in the
existing management system documentation
and in the Quality Management Manual.
The auditors were trained in 2003 and
qualified as internal auditors for environment.
11How we started?
The application for certification was done when we
considered that the requirements were appropriately
implemented.
We found a big problem with certification companies
in making them understand the structure of the
Management System developed based on the norms
for nuclear field.
In 2004 we migrated from QM System to IMS, this
being accepted by RB.
In parallel, all MS documentation were organized
based on the process concept. 12How we started?
For developing the process there was issued a
model, appropriate to those used by BNFL.
In 2004 we started to focus on integrating U2 so
that the progress done on the process development
was reduced.
In 2005 proceeding similarly with ISO 14001 we
started preparation with integrating requirements
from OHSAS 18001. The OHSAS certification was
obtained in 2007.
13How we started?
In 2009 CNE Cernavoda started the process of
integrating the requirements of ISO 27001.
A consultant was employed to prepare the
organization for adherence to the new standard
taken in consideration that several requirements
addressed IT aspects. The certification for ISO
27001 was obtained in 2010.
14How we started?
In accordance with Romanian norms an operation
License is issued by RB for operating organization.
The license is issued if the operating organization
developed and implemented an Approved Quality
Management System. The license, in accordance
with law requirements, shall be renewed every two
years. Hence, QMS is reviewed by operating
organization every two years against last
requirements of RB. In 2007 RB requested CNE
Cernavoda IMS to integrate GSR3 requirements.
15How we started?
A gap analysis was conducted and the GAP was thus
identified.
All the Gaps identified were addressed through AT
System.
The main deficiency that was identified was that
one related to processes definition and
responsibilities for process so that in 2007 there was
restarted the program for process development.
A new proposal was issued by Quality Management
Department and submitted to the management for
16
approval.How we started?
New proposal was focused on managing the
processes as per IAEA recommendation from GSR3
and associated guides. We have redesigned the
process and defined:
Process Sponsor
CNE Cernavoda Process Coordinator;
Process Owner;
Single Point of Contact
The responsibilities for development were allocated
to QM department.
17How we started?
Acceptance of the new proposal was difficult:
Lobby was done at the level of the top
management;
Practical example was prepared by the team
responsible with the development of the new
approach;
Benefits of transition to the new model was
presented to top management.
The resistance was not fully removed.
18Where we are?
All the processes are identified;
CNE Process model was defined;
The process owners were assigned;
The diagram of majority of processes was issued
(only diagrams for two process have not yet been
defined). The process model was improved with
the support of IAEA experts during assistance
provided during Norway project.
Over 80% of general procedures was prepared
and over 60% issued; 19Where we are?
The structure of the IMS was evaluated by
an international team within Norway
project and the recommendation for
improve already addressed and
implemented;
A new revision of IMS Manual is ready to
be submitted to RB for approval.
20CNE CERNAVODA PROCESSES CHART
- MODEL -
MANAGEMENT PROCESSES
1) Process Management and Leadership; 3) External Interfaces Control;
2) Management Systems Assessment; 4) Maintaining Operation Licenses
5) Manage and direct the business
KEY PROCESSES
Operation and Monitoring Maintenance and Repair Configuration Changes
Work
6) Operation Control and Monitoring; 14) Design Configuration Control
7) Chemistry Control; 10) Maintenance Programs;
8) Radioactive Material Control; 11) Planning;
9) Reactivity Control; 12) Maintenance Implementation;
13) SSCE Reliability Upholding;
SUPPORT PROCESSES
15) Human Resources and Organizational Development 19) Personnel Radiation Exposure Control; 25) Station Actions and Nonconformance Control;
16) Environmental Management; 20) Emergency Response Preparation;
26) Fire Protection;
17) Station Personnel Training Concept; 21) Documents and Records Control;
18) Physical Protection; 22) Material Purchase and Management; 27) Informational System Control;
23) Financial Services; 28) Projects Management.
24) Personnel Health and Safety Program;
21What remained to be done?
Issue all the process procedures as established in
transition plan for IMS;
Redefined SA process in order to migrate from SA
process based on functional areas (as defined in
WANO/INPO Guide) to SA focused on processes;
Integrate the requirement of Internal Managerial
Control with existing IMS including new process
related to risk management.
22What remained to be done?
Reevaluate the internal oversight function in
order to increase the role of oversight;
Increase the efficiency of IMS by more involving
at the management level in sustaining the
implementation of the IMS requirements.
23Grading
It is requirement of the Romanian Norms related to Quality
Management System (NMC-02) to have classified the SSC in 4
safety class (as per IAEA standard):
“The licensee shall establish a list of SSC and clasify them
on a scale from 1 to 4 based on imprtance to safety and
radiological risk.
The classification procedure and list of SSC shall be submitted
to RB for approval;
The list shall be submitted to participants for use”
24Grading
Also Norm establish that participants or contractors shall
prepare specific procedures related to gradual application of
the QMS based on Safety Classification of the SSC received
from the licensee, and shall submitted the to RB for approval.
Note: This requirements was never implemented .
CNE Cernavoda has been prepared procedure related to
establishing Safety class of SSC and list of SSC with their
classification in 2006, but the procedures was not yet
approved. CNE Cernavoda use initial design classification
list based on Canadian concept.
25Grading
CNE Cernavoda has a procedure for establishing Quality Level
of items and Services for procurement purpose based on NMC
13
5 different level (class 1 to 4 and Best Commercial)
For class 1 to 4 is required selection process and qualification of
suppliers based on different level of evaluation.
For BC is required only ISO certificate.
Related to other operational activities we have declaration in
the IMSM that the requirements will be applied gradual based
on importance of the activities for Safety.
26Grading
Each procedures describing processes or activities contain
information related to gradual application e.g.:
Abnormal condition Report (RCA):
RCA-Root cause
RCA-important with investigation
RCA – important with evaluation
RCA – minor with evaluation
RCA – minor with record for training.
27Grading
Improvement action report close-up approval:
Station Manager – if is recommendation from RB, or other improvement
programs.
Senior Superintendents if is from Observation Program, Human
Performance or other departmental evaluation.
Process Owner if is an improvement for process which not involve
resources or major change in process.
Document approval:
Station Manager for RD/SIs;
Department managers for IDPs,
Etc.
28Conclusion
SNN CNE Cernavoda even started the
implementation of an IMS over 7 years
ago, has not yet finalized the process of
transition.
Small groups initially involved in developing
transition process;
The project objectives were not well defined
from the beginning, and a low support was
received from management;
29Conclusion
The project was delayed by the effort done
to integrate operation of the U2 with U1.
Success of integration is demonstrated by
results of operation of the U2.
It is essential to be sustained by the top
management;
An aggressive communication into
organization is essential for the success of
the project. 30RESULTS
CAPACITY FACTOR (%)
100
90
80
70
60
50
40
30
20
10
0
since
1997 1998 1999 2000 2001 2002 2003 2004 2005 2006 2007 2008 2009 2010 2011 in
serv.
FPI U1 87.27 86.19 84.51 88.3 88.25 89.37 79.52 89.71 90.08 91.37 97.62 84.8 100.10 91.53 99.67 89.94
31
FPI U2 93.23 96.92 90.6 97.24 91.07 93.94Questions?
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