Ken Lowery is passionate about two things: vintage cars and Southern Nuclear’s corrective action program. Whether he’s fixing up an old car or reviewing a condition report, Ken approaches his work with the same goal: to find, analyze and fix potential problems.
Q: How is the Corrective Action Program (CAP) used in the nuclear industry and why is it important?
Lowery: CAP is used to find, analyze and fix problems. The importance of this quality assurance program is stressed to employees from day one, and anyone who finds a deficiency is encouraged to submit a condition report so that management can determine how to appropriately resolve the issue. “Conditions” can range from a broken door handle in the bathroom to a broken valve in a plant, and both are fixed immediately or subjected to further causal analysis. We analyze the more significant issues to determine what the problem is, why it occurred and what we can do to keep it from happening again. The less significant problems account for the majority of the 35,000 condition reports that we see on average each year across our fleet. All conditions, regardless of their significance, are corrected.
CAP is required under federal regulation and is an excellent tool for addressing and resolving conditions and problems early. It is also an indispensable business tool that allows utilities to continuously improve performance.
Q: How did you become involved with the CAP and how have you seen the program evolve?
Lowery: I started at Southern Company 24 years ago as a design engineer for Plant Farley and later for Plant Vogtle. I became involved with CAP after doing project management and licensing work for Plant Vogtle, and was asked to become the company’s first corporate CAP coordinator. CAP had traditionally been a program that existed just at the actual nuclear energy facilities, but Southern Nuclear wanted to become more involved with the program at the corporate level and improve operations across the fleet. For the past two years, I managed the nuclear development CAP, which is a new program that upholds safety culture principles in nuclear project construction.
CAP has evolved to become a program that is applied throughout Southern Nuclear’s departments. In addition to having on-site CAP managers and staff, there are dedicated positions across the whole nuclear organization.
Conditions can be reported from any department, ensuring that no issue with potential safety or security implications slips through the cracks.
Q: How soon is management made aware of a potential condition and what oversight tools are in place to ensure that it is resolved effectively?
Lowery: All CAP staff and management receive a daily report detailing everything that was reported the previous day. On-site inspectors from the Nuclear Regulatory Commission (NRC) also review the reports on a daily basis and evaluate our analysis of a given condition, creating an additional level of oversight. They’re interested in what we find, and for significant conditions they want to know not just that we analyzed it, but how we analyzed it, what was fixed and how well it was fixed.
CAP has grown and become more rigorous over the years. The industry, the Institute of Nuclear Power Operations (INPO) and the NRC have all become more involved with the program and are committed to ensure not only that the process is robust, but that it is implemented effectively.
Q: What is the biggest misconception about CAP?
Lowery: Sometimes it’s hard to see the impact of CAP because it’s a program that prevents things from happening, rather than producing an end-product.
For this reason, some people don’t perceive CAP as real work, when in fact it is a core business tool, without which we wouldn’t be able to maintain our impressive safety record and build new facilities.
Q: How do utilities work together and with the Institute of Nuclear Power Operations on the CAP?
Lowery: INPO identifies and evaluates performance improvement programs, including CAP. Operating experience is an element of improving performance at nuclear energy facilities, and INPO helps utilities share lessons learned through an active operating experience database. Utilities enter reports into this database, and these reports help our colleagues find similar problems or conditions that could affect safety at their own facilities. INPO also facilitates an annual workshop for CAP leaders in the industry, which is another opportunity for shared learning and helps us maintain a strong safety culture.
Q: How are utilities using CAP to respond to the events at Fukushima and to make their nuclear energy facilities even safer?
Lowery: We used CAP to help us assess issues associated with the incident at Fukushima and strengthen our operations. Following Fukushima, INPO issued four incident event reports that required utilities to assess each facility’s ability to manage flooding and seismic events, spent fuel pool cooling capability, the effectiveness of operator fundamentals and training programs and the ability to cope with an extended loss of power. The utilities classified these directives from INPO as operating experience reports and are analyzing them through their respective CAPs and pursuing recommended corrective actions to enhance safety.
Q: How does CAP work for new construction and development, and what is the benefit of having a program like this in place as Southern Co. begins to build a new reactor?
Lowery: The nuclear development CAP uses the same process as the CAP that resolves conditions at existing nuclear energy facilities; it’s just focused on construction instead of operations.
The lessons we are learning through our construction activities on the new reactors at Plant Vogtle will inform nuclear development projects across the industry. The nuclear development CAP will make new nuclear reactors safer than ever.
If you think about the way that CAP evolved, first we built the plants and then we developed a corrective action program. Now, however, we have a highly evolved CAP that is helping us resolve issues every step of the way.