Line Mgmt Responsiveness to Independent Oversight at Nuclear Facilities

8/12/2019 Line Mgmt Responsiveness to Independent Oversight at Nuclear Facilities

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Line Management Responsiveness to

Independent Oversight

Presented to:OCRWM Management Team

Presented by:

Larry NewmanDirector Office Quality Assurance


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2P-Name-Meeting_XX/XX/XX.ppt

Line Management Responsiveness toIndependent Oversight

Goals for this discussion:

Establish a Common Understanding of the Value

of Strong and Independent Oversight and the

NRC and INPO guidance in this area

Discuss the Shift in Approach to OCRWM

Independent QA Oversight

Discuss the Behaviors that Demonstrate thatOversight is Used Constructively to Strengthen

Safety and Improve Performance


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The Valuation of Independent Oversight

NRC Nuclear Safety Culture Principle #7:Self and Independent Assessments

The licensee conducts self- and independent

assessments of their activities and practices, asappropriate, to assess performance and identify

areas for improvement.


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NRC Nuclear Safety Culture Principle #8:Environment for Raising Concerns

Behaviors and interactions encourage free flow of

information related to raising nuclear safety issues,differing professional opinions, and identifying issues inthe CAP and through self assessments. Such behaviors

include supervisors responding to employee safety

concerns in an open, honest, and non-defensive manner

and providing complete, accurate, and forthrightinformation to oversight, audit, and regulatoryorganizations.


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INPO Nuclear Safety Culture Principle #8:

Nuclear Safety Undergoes Constant Examination

Oversight is used to strengthen safety and improve

performance. Nuclear safety is kept under constant

scrutiny through a variety of monitoring techniques,some of which provide an independent freshlook.

A mix of self-assessment and independent oversight

reflects an integrated and balanced approach. Thisbalance is periodically reviewed and adjusted as needed.

The insights and fresh perspectives provided by qualityassurance, assessment, employee concerns, and

independent oversight personnel are valued.


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Shift in Approach to Independent Oversight

QA completed a gap analysis of its practices andprocedures, and have taken steps to align itself

more closely with industry best practices.

The December 2006 assessment by the Nuclear

Energy Institute (NEI) of QA found that 6 of 8

areas were ineffective.

The October 2008 NEI assessment found that only

1 of 8 areas was ineffective (self-assessment),reflecting a significant turnaround in the

performance of the independent QA organization.


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Under the revised Oversight approach: QA is encouraging the line to take ownership of lower

level issues (symptoms) identified by oversight and take

the lead in documenting those issues in the CAP

Demonstrates responsiveness and ownership of Quality

QA is partnering with the line to evaluate the

underlying causes (UCFs) of the symptoms observed by

oversight

The identification and correction of UCFs would prevent futureevents generated by the same causal factors

(Recent example from an audit on the next slide)


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P-Name-Meeting_XX/XX/XX.ppt

Site Operations Functional Area Audit

Identified byQA anddocumentedby the Line

Developedwith linesupport anddocumentedby QA

Evaluatedandaddressedby the Line


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QA is Evaluating Performance of Cross CuttingAreas on a continuous basis:

Processes that support the License Application

Corrective Action Program

Self-Assessment Program

Trending

Key Performance Indicators

QA is Observing Behaviors (both in QA and the line)and Performing Safety Culture Assessments


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QA Continuously Communicates Oversight Results With the Line

Fu

nctionalAreas


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Behaviors that Demonstrate Oversight isUsed to Strengthen Safety and Improve

Performance Nuclear Leaders are proactive and responsive to

independent oversight concerns

Nuclear Leaders are not defensive whenpresented with adverse conditions

Nuclear Leaders are not overbearing when

discussing issues with lower level staff and do

not suppress independent thought

Low standards are not defended, even when

they are technically in compliance


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Performance Appropriate behaviors are monitored and

reinforced on a continual basis to strengthen the

nuclear safety culture

A healthy questioning attitude is encouraged

within each group, rather than acceptance and

enforcement of the status quo

The use of the problem reporting process isencouraged and never discouraged


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Performance Nuclear Leaders strive to eliminate problems

rather than analyzing them away

Take the lead in critically reviewing draftproblems brought forward by oversight

personnel, to ensure nuclear safety issues are

identified and addressed

Establish single point accountability foractivities important to Quality & safety

Explore underlying causes of events


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Performance

During the past 6 weeks, The OCRWM

Oversight organization observed less thanadequate line management behaviors in

each of the categories just outlined above.


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Line Management Responsiveness to

Independent Oversight

Open Discussion

Documents

Line Mgmt Responsiveness to Independent Oversight at Nuclear Facilities