DLE Strategies for a Strong Quality Culture

8/3/2019 DLE Strategies for a Strong Quality Culture

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SBA 8(A) VETERAN OWNED SMALL BUSINESS MINORITY OWNED BUSINESSEstablishing a

StrongQualityCultureProven Strategies for Line Management and

Independent Oversight Organizations

WHITE PAPER

Corporate Office4634 SW Long Bay Drive

Palm City, FL 34990

(772)341-1093 - Phone

(866)271-5199 - Fax

[email protected]

www.dle-services.com

Prepared:

September 1, 2011


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Introduction

Strategies for a Strong Quality Culture

This white paper is an introduction to a set of strategies for establishing a

strong Quality Culture at nuclear power plants and Department of Energy

(DOE) facilities. The strategies described herein were developed, used and

refined through trial and error over the past 20 years by the founder of DLE

Technical Services, a recognized industry subject matter expert in Nuclear

Assurance, Rob De La Espriella. Rob spent over 15 years implementing

QA Program requirements, developing advanced oversight strategies and

coaching line managers on the principles for a strong quality culture at

nuclear power plants, both as an inspector with the Nuclear RegulatoryCommission and as a Site Quality Manager. The resulting approach took

existing oversight organizations and transformed them into High Performing

Organizations (HPO). Robs oversight groups were praised by the Institute

of Nuclear Power Operations (INPO) in 2003 and 2005, and benchmarked

by many other oversight groups in the US.

In the next few sections well describe how to unlock the keys to

transforming your Quality Culture by using proven strategies that include

Deming Quality Principles, Juran Quality Control Principles, Balridge criteria

for high performing organizations and others industry standards of

excellence. The author added his own risk-informed, graded approach to

conducting oversight that makes the most effective use of oversight

resources, drives line ownership of quality and provides a significant cost-benefit to the company by creating a proactive organization that anticipates

and prevents issues, rather than documenting events after they took place.


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Quality Management Systems

The Evolution of QMS and Oversight in the Nuclear Industry

Quality Management Systems (QMS) include all of the programs,

processes and procedures that flow down from Quality Assurance

Program requirements in applicable regulations. It also includes additional

standards and expectations put in place by management to achieve a

desired level of performance and quality (the latter being driven by

customer expectations). Since World War II there have been many

advances in Quality Management Systems, driven by industry giants such

as Deming, Juran, Balridge and Ishikawa. They established methods to

help strengthen Quality Management Systems such as Total Quality

Management (TQM), Quality Circles, Quality Control Practices and High

Performing Organization Principles. In the past few decades TQM has

given way to Six Sigma and Lean Manufacturing.

In the commercial nuclear power industry, the Three Mile Island accident

triggered billions of dollars of improvements in programs, processes and

equipment and the establishment of the Institute of Nuclear Power

Operations (INPO) to self-police the industry. Since the accident in 1979,

nuclear industry processes and programs have evolved tremendously,

arguably surpassing most other heavily regulated industries. However, one

area has not evolved as rapidly as others: the Quality Culture and the

oversight provided by Quality Assurance (QA) organizations.

The Authors Footprint on QMS/Oversight

The author entered the nuclear industry in 1983 as a Navy nuclear

powered submarine officer. Since that time, the author has assessed

performance at over 20 nuclear plants and DOE facilities. One of the

common characteristics at the majority of sites was the lack of

understanding of Quality Program requirements by line management. In

addition, the Nuclear Assurance organizations (Audit groups, Quality

Control, Surveillance departments) were not operated in a manner that

resulted in adding significant value to the organization (far beyond meeting

regulatory requirements for having an independent oversight organization).

To this day, line managers frequently criticize their independent oversight

organizations for adding little value, for being historians (documenting

events after the fact) and circling bullet holes (pointing out the obvious).

In 1990, Florida Power & Light (FPL) became the first corporation outside of

Japan to win the Deming Prize, for outstanding Total Quality

Management (TQM) practices. The author was on that Deming team and

through extensive training and certifications as a Quality Improvement

Team Leader and Root Cause Instructor, he developed a greater

understanding of Quality at regulated nuclear power plants. In 1990 the

author became an Audit Team Leader and root cause analyst for the

Since the TMI

accident in 1979,

billions have been

spent on

improving the

commercial

nuclear industry


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oversight organization at FPL. In 1992 he began a four-year tour of duty at

the US Nuclear Regulatory Commission and was responsible for

conducting oversight at the Millstone Nuclear Plant in CT. While at theNRC, the author collected a TQM Award, several other performance

awards, a Meritorious Service Award nomination and was selected as a

Role Model for the NRC in 1995.

In 1996 the author returned to FPL and in three years rose from Audit

Team Leader to Independent Safety Engineering Group Supervisor to Audit

Supervisor to Site Quality Manager. As a key player in oversight

organizations for over 15 years, the strategies developed by the author

resulted in high performing oversight organizations that proactively

identified issues, drove performance improvements and dramatically

increased the value of the independent oversight organizations.

In 2003 and 2005, the Institute of Nuclear Power Operations (INPO) graded

the Quality Management System and oversight strategies the author put in

place at FPL as Strengths for overall effectiveness. Following the 2003

and 2005 INPO reports, many industry peers benchmarked the authors

oversight organization.

In 2005, the World Association of Nuclear Operators (WANO) enlisted the

author to participate in an assist visit to Slovenia at the Krsko Nuclear Plant

as a Nuclear Assurance expert from the US. Additionally, WANO

requested the author to coach and mentor a Quality Manager from South

Africa for six weeks in response to a request from Eskom to send their new

Quality Manager to one of the strongest Nuclear Assurance programs in

the US.

In 2007, the author (now the President of DLE Technical Services) wascontracted to bring these oversight strategies to the Department of

Energys (DOE) Quality organization at the Yucca Mountain Project (YMP).

After the 24 month Organizational Development engagement at the YMP,

the DOE formally recognized the author for a night and day difference in

performance in the oversight organizations, and for contributions towards

improving Nuclear Safety and Quality cultures at YMP.

In 2008, DLE Technical Services was contacted by Eskom to help establish

the Nuclear Assurance organization for the new construction of the first

ever Pebble Bed Modular Reactor project. (Unfortunately Eskom tabled

the project in late 2008 for economic reasons).

In 2009, after a national search, CH2M Hill offered the author the position

of Director of Nuclear Quality and Culture for the new construction of 10nuclear reactors in the United Arab Emirates, to establish the QMS for that

project (the author declined the offer).

In 2010, DLE Technical Services was contracted by Uranium Disposition

Services to evaluate the Quality Assurance Program for the new Depleted

Uranium Hexafluoride Conversion Facility in Paducah, KY.

In 2011, DLE Technical Services was contracted to develop a strategy for

diagnosing the QMS at Atomic Energy of Canada Limited (AECL).


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Strategies for Establishing a StrongQuality Culture

After decades of developing, implementing, assessing and overseeing

Quality Management Systems, the author has summarized some of the

more important strategies that he developed for strengthening an

organizations Quality Culture and establishing high performing

independent oversight organizations.

Adopt and standardize Principles for a Strong Quality Culture

Define managements commitment to Quality.

Define workers commitment to Quality.

Define the defense-in-depth approach to identify and correct

conditions adverse to quality.

Lay out expectations for line management ownership of quality.

Define the Quality Assurance organizations roles and responsibilities

for providing value-added quality.

Reinforce that improving quality can lower overall operating costs.

The principles must also be translated into a policy or procedure such

that management can be held accountable for the contents. The performance appraisal system must also evaluate line ownership

of quality.

Define the criteria for High Performing Quality Management Systems

Leadership

Customer Focus

Strategic Planning

Organizational Structure

Process Management and Control

Leader and Worker Development

Performance Management

Continuous Improvement

Strengthen Performance Improvement Processes

Corrective Action Programs

Human Performance and Error Prevention Programs

Operating Experience and Lessons Learned Programs

Root Cause & Apparent Cause Tools & Techniques

Change Management

Establish Top Management Support & Infrastructure for Quality

Management

must live up to its

commitment to

Quality in every

decision they

make


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Strategies for Establishing a StrongQuality Culture (Contd)

A. Establish a clear target for independent oversight resources:

Nuclear Safety

Equipment Reliability

Risk to Workers and Equipment

Regulatory Risk

B. Use a Risk-Informed Approach for QA Activities: Establish initial and

continuing training for oversight personnel on understanding the

components of RISK (in practical terms, rather than in Probabilistic

Risk Assessment terms), and how to use these practical risk concepts

in daily applications. For example:

1) Focus on critical tasks that impact error rates:

Work preparation

Work performance

Work feedback

2) Focus on critical programs, processes and procedures that

maintain a defense-in-depth for preventing events or mitigating

consequences of an event:

Engineered controls

Administrative controls

Oversight controls

3) Focus on critical programs and processes that affect nuclear

safety:

Conduct of Operations

Equipment Reliability Program

Design Control/Configuration Management

Programs and processes that maintain facilities and equipmentIntegrated Work Management Systems

Corrective and Preventive Maintenance

Corrosion Controls

Re-focus the Independent Oversight Organization

Oversight

organizations can

focus on Risk and

adding value

while meeting its

regulatory

requirements


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Strategies for Establishing a Strong

Quality Culture (Contd)

B. Use a Risk-Informed Approach for QA Activities: (Contd)

4) Focus on programs and processes that manage risk to workers:

Integrated Safety Management System (ISMS)

Human Performance and Error Prevention

Emergency Preparedness

Training and Qualifications

5) Focus on programs and processes that capture problems and

drive continuous improvement:

Corrective Action Program/Trending

Self-assessment Program

Operating Experience/Lessons Learned

Causal factors and root cause analysis tools

6) Focus on assessing the risk of multiple activities in the aggregate,

not just the risk for each individual activity.

7) Focus on assessing line managements capabilities of assessing

risk on a real time basis and implementing appropriate

countermeasures and management oversight.

8) Establish Routines that Focus on Risk: Establish planning and

scheduling strategies that place oversight personnel in the right

place at the right time, focused on the most valuable activities at

any given time:

Merge audits, assessments and inspections into a hybrid

approach that is flexible enough to follow the facility schedule,

and efficient enough to meet all oversight requirements without

duplication of effort.

Shape checklists and inspection plans to focus the various

oversight groups on the high risk activities at any given time,

avoiding oversight that does not have a specific purpose or goal.

With the proper

focus,

independent

oversight groups

add significant

value to the

facility


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Strategies for Establishing a Strong

Quality Culture (Contd)

C. Define and Implement Proactive Oversight: Establish guidelines for

management and oversight personnel to prevent rather than react to

events. Provide guidance on conducting oversight at the most optimal

time such that issues are identified before they can result in more

serious consequences (in the right place at the right time). For

example:

1) Establish plans for managing high-risk contributors to the sitesEquipment Reliability Index.

2) Establish oversight approach for high-risk logic ties on the site

schedule for outages and operations (Primavera 6 or equivalent)

and management of any changes to the logic.

3) During refueling outages, establish specific plans to oversee

maintenance and verify functionality for critical components whose

failure during the startup can result in extending the outage.

4) Continually evaluate line managements oversight of construction,

installation, operation and maintenance of safety-related

structures, systems and components, or any activities that could

jeopardize the equipments ability to perform its intended safety

functions.

D. Daily Use of Causal Analysis Tools: Personnel that routinely evaluate

problems or address Condition Reports must be trained to focus on

identifying and addressing underlying causes, rather than addressing

just the symptoms. However, experience has shown that the training

provided on causal analysis and problem solving tools and techniques

must be simple enough such that the techniques can be readily

learned and used on a routine basis (and without requiring forms,

computer software or manuals). The following small set of causal

analysis tools can help personnel analyze data and identify underlyingcauses for the vast majority of problems encountered:

Pareto Diagrams

Affinity Diagrams

Barrier Analysis

Cause and Effect Analysis

Fault Tree Analysis

Events and Causal Factors Charting

Place oversight

personnel in the

right place at the

right time


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Strategies for Establishing a StrongQuality Culture (Contd)

E. Strengthen Working Relationships Between Oversight and Line

Organizations: Strive to establish excellent working relationships

between line and oversight organizations. The value of working

together is the establishment of a defense-in-depth model where all

groups work together to identify and address problems.

F. Improve the Communication of Issues to Line Management: Independentoversight organizations must effectively characterize and communicate

issues in terms that can be readily understood and acted on by

management (e.g., highlighting the specific risk to equipment and

personnel, identifying the liabilities incurred by the organization,

identifying challenges to scope, schedule and cost, and listing the

positive gains or competitive advantages of any recommendations).

Merely stating the infraction or the gap to compliance is not enough to

elicit the appropriate response.

G. Expect QA to Help Drive Performance: The nuclear industry has

established a continuous improvement philosophy to prevent

complacency. Continuous improvement is crucial to the industry as

any events experienced by the weakest link in the nuclear fleet canresult in dramatic impact and significant cost to the rest. (i.e. TMI

accident, Browns Ferry fire, Davis-Besse reactor vessel head

degradation). QA organizations should be an integral part of

continuous improvement by focusing on issues that drive

improvements in nuclear safety and quality, not merely on compliance

with minimum standards. By identifying the gaps to excellence,

oversight will help the organization to continually improve performance.

By identifying

gaps toexcellence,

oversight will

help the

organization to

continually

improve

performance


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Benefits of Strong Quality Cultures

Prevent significant events from occurring through

improvements in Quality and Nuclear Safety cultures

and high performing oversight organizations.

Enhance the Quality values and beliefs that drive

behaviors in all employees in the company.

Continuously improve Quality Management System

programs and processes.

Provide a competitive advantage to the company by

realizing the cost-benefits of a strong QMS.

Summary

The strategies outlined in this white paper can be seamlessly integrated

into existing Quality Assurance programs such as 10CFR50 Appendix B,

NQA-1 and DOE Order 414.1c. They are applicable to organizations thatare responsible for the Quality Program, and can also be used by

regulatory oversight organizations such as the Nuclear Regulatory

Commission and the Department of Energy. At the heart of these strategies

is a value system where all employees understand that Quality is an integral

part ofcore business, and that there is a direct correlation between quality

and cost & profitability. Also, where all employees are focused on quality

and the prevention of events through the proactive identification and

resolution of underlying causes for conditions adverse to quality.

Lastly, the changes brought about by the transformation to a strong quality

culture are sustainable. But a great deal depends on emotionally

intelligent, transformational leaders within the organization, and the

message they send such that employees value and believe in the

competitive advantage of a strong Quality Program.

Ultimately, the transformation to a strong Quality Culture enhances the

companys ability to protect the health and safety of the public, as well as

provides the company with a strong competitive advantage driven by

quality improvements and reduced operating costs.

Call DLE

Technical

Services and let

us help you with

transforming your

Quality Culture!


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WHY DLE Technical Services?

Who We Are: DLE Technical Services is a full-service project managementcompany with expert organizational development strategies fordiagnosing and addressing latent organizational weaknesses.

Our Mission: Our mission is to assist our clients in gaining a competitive advantagethrough cost effective solutions that drive Breakthrough Performanceand Cultural Transformations.

Our Core Values: We focus on the clientWe are passionate about our workWe move with speed and flexibilityWe are creative and innovativeWe care about our employeesWe trust and respect our clients and each other

Our Vision: "DLE Technical Services and its subsidiaries will be regarded as the bestand most sought-after Project Managers and OrganizationalDevelopment experts in the federal procurement system.

Differentiators: What makes us unique is that we bring proven industry standards ofexcellence to bear on all our projects; Leadership, Customer Focus,Strategic Planning, Organizational Structure, Workforce & LeaderDevelopment, Process Management & Control, PerformanceManagement and Continuous Improvement.


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CompanyData

Company Name: DLE Technical Services, LLC

Principal: Rob De La Espriella

Contact Information: 4634 SW Long Bay DrivePalm City, FL 34990(772) 341-1093 Office(866) 271-5199 Faxwww.dle-services.com

Small Business Status: SBA 8(a) Small Disadvantaged BusinessVeteran Owned Small BusinessMinority Owned BusinessSize Standard

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DLE Strategies for a Strong Quality Culture