Opportunities are areas where Trends are monitored, and if you see that a certain product is consistently having an issue, a piece of machinery causes an anomaly, any opportunity for improvement is reason to start a CAR (I changed mine from CAPA to CAR for the AS9100 rollover)
I have done a SWOT analysis, and used that for my rollover, especially where risk and improvements section 9 and 10 of the AS9100
Hope that helps
Marie Cavanaugh
Quality Systems Manager.