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ASQ Energy and Environmental Conference

Opportunities for Safety Performance Improvement in the DOE Complex

Stephen M. SohinkiDirector

Office of Price-Anderson Enforcement

September 12-15, 2004

“Fools you are…

to say you learn by your experience.

I prefer to profit by others’ mistakes

and avoid the price of my own.”

Otto von Bismarck19th Century Prussian Chancellor

Nuclear Power Technology Inc.

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Legislative

Price-Anderson Amendment (PAAA) Act (1988)–Extended nuclear liability coverage, required DOE to establish and enforce nuclear safety rules.

Bob Stump Act (2002)–Reauthorized PAAA to December 2004. Required DOE to establish Occupational Safety and Health (OSH) rule. Made PAAA-indemnified contractors subject to civil penalties.

Draft legislation proposes PAAA reauthorization until 2006, with no substantive changes

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Regulations

10 CFR 820 – Procedural Rules and Enforcement Policy

10 CFR 830 – Nuclear Safety Management (Quality Assurance and Safety Basis)

10 CFR 835 – Occupational Radiation Protection

10 CFR 708 – Contractor Employee Protection

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Regulations (cont’d)

10 CFR 851- Worker Safety and Health Program (draft)

10 CFR 712 – Human Reliability Program

(being reviewed for PAAA enforceability)

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Enforcement Philosophy

Relationship with contractors different from NRC’s arms-length relationship with regulated utilities

Use of program as a tool to promote proactive contractor behavior resulting in safety performance improvement

Emphasis on promoting contractor timely identification, reporting, and correction of noncompliances

Noncompliance Tracking System

Mitigation

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Contractor Performance Concerns

Poor Safety Culture Lack of questioning attitudes Safety not everyone’s responsibility Perceived tension: working safely or meeting cost and schedules

Ineffective Corrective Actions Underlying problems not identified

Poor causal analysis Failure to look across a site for applicability

Extent-of-condition Corrective actions not always maintained

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INPO Safety Culture Principles

Nuclear safety is everyone’s responsibility. Leaders demonstrate commitment to safety. Trust permeates the organization. Decision-making reflects safety first. Nuclear is recognized as different. A “what if” approach is cultivated. Organizational learning is embraced. Nuclear safety undergoes constant examination.

Performance Assessment-

The Key To Safety Improvement

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The Problem

DOE Complex is Event-Driven

Too Many Recurring Events/Violations

Senior Management has not Consistently Demonstrated Commitment to Performance Assessment Excellence Have not bought into belief that performance assessment is beneficial – belief that assessments take time away from production/the bottom line Have not required rolling assessments into regular

schedule – no integration with regular activities

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The Challenge

Get consistent, demonstrable support by senior management for achievement of excellence in assessment practices

Become predominantly Assessment-Driven within the next several years Find precursors before they blossom into safety events When an event occurs, one of first questions should be

“Where did our assessment process go wrong?”

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Why Focus on Assessment Programs?

Biggest bang for the buck—avoids piecemeal approach to problem solving

Institutionalizes culture in workforce at all levels to have a questioning, cautious approach toward potentially hazardous work done in the Complex

Emphasizes that best safety performers are also the best schedule and cost performers

Allows resolution of problems on your own schedule rather than under pressure after adverse event

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Why Focus on Assessment Programs? (cont’d)

Good business practice-a dollars and cents issue Stand downs Facility shut-downs Project delays Lost work days, uptakes Investigations, external reviews Adverse publicity, public confidence Performance award hits Future business DOE program impacts

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Why Aren’t We There Yet?

Checklist Mentality

Failure to go beyond checklist to evaluate performance and effectiveness Lack of inquisitiveness

Lack of Objectivity

Willingness to be self-critical Real independence from group being assessed

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Job evolution vs. more global look-rad safety, electrical safety, etc.

Where else do I have the problem-people, procedures, and processes Nuclear vs. non-nuclear nexus

Stovepipes

Why Aren’t We There Yet? (cont’d)

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Why Aren’t We There Yet? (cont’d)

Willingness to criticize colleagues Observations vs. findings Assessment findings gather dust on the shelf, rather than being action-forcing

Quality over quantity - don’t let indicators get lost in a sea of papers

Failure to connect the dots- incident equals failure of assessment program

Cultural/Social Niceties

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What Can We do to Fix This?

Management buy-in and support

Management must provide proper incentives for organizational excellence in assessment practices Do you reward the problem finders or shoot the

messenger? Getting the straight scoop? What is the perception of your employees?

Need for increased focus on assessment methods and expectations

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What Can We do to Fix This? (cont’d)

Need to evaluate: Adequacy and effectiveness of controls (big picture) Safety culture/behaviors, practices,

organizational/supervisory influences Trending/ID of programmatic issues

Requirements for personnel conducting assessments Ability/willingness to convey constructive criticism and

to be self-critical Technical inquisitiveness - asking why? Training in the conduct of assessments

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Senior management support and expectations are clearly defined and communicated

Proactive behavior in finding issues is incentivized

Program is formally defined through policy and procedures

Adequate human resources are provided

Attributes of an Effective Assessment Program

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Attributes of an Effective Assessment Program (cont’d)

Assessors are adequately trained

Assessments are planned and prioritized as regularly scheduled activities

Assessment planning is integrated with issue identification and tracking system

Management assessments focus on effectiveness of management systems rather than solely on specific work evolutions

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Assessment results are integrated with your corrective action management process

Assessment results are communicated to affected personnel in a timely manner

Assessment results are evaluated for broader site-wide implications

Assessment program is periodically evaluated to assure effectiveness

Attributes of an Effective Assessment Program (cont’d)