Increasing the Impact of a Traditional Performance Based Audit Model Vijay D’Souza – NOS Audit Superintendent

Duke Energy 6 Operating Sites (9 PWR / 2 BWR units) 1 Decommissioned Unit (CR3) 2 New Plant COLAs 1 Corporate Office

Audit Staffing Model 3 Auditors per Site (excluding CR3) 2 Auditors in Corporate

The Challenge Increase the intrusiveness of the Audit Model while factoring: Decreased NOS staffing (audit and assessment) Decreased line SME participation in audits due to organizational reductions Changing regulatory commitments (Cyber, FP, FLEX) Delivering the Nuclear Promise Maximize impact of audit activities to support performance improvement.

Historical Audit Team Makeup

Strategy Efficiently Focus on “Core” Business Be smarter at “where to look” Strategic timing for “when” to look

Efficiently Focus on “Core” Business

What are the basic requirements? Development of an Audit System Design Matrix

Consolidation of Audits 30% reduction in the number of audits conducted across the fleet from an average of ~80/year (2015) to ~55/year (2019). Consolidation of site audits into single Fleet audits: CAP Document Control IT/SDQA Consolidation of RP/Chemistry Functional Audits Transferred RP Part 20 assessments back to the line. Consolidation of CR3 Audits.

Audit Checklist Optimization Reduce checklist size and eliminate unintended repetitive audit touch points. Utilize the Audit System Design Matrix to sufficiently satisfy the core audit requirements.

Audit Checklist Optimization Minimize the specificity of the checklists to empower auditors to be able to perform deep-dive reviews of areas of known vulnerability. Allow audit leads to determine the best way to satisfy the audit requirement (field observations, interviews, document reviews).

“Leaning” out Audit Products Common audit plan package Streamlined audit reports (< 10 pages) Typically report out on the day of the audit exit Digital audit closeout packages Contain objective evidence Use of Adobe PDF Packaging products Digital signatures Ability to word search NOS products

Be smarter at where to look

Vulnerability Reviews Interviews with individual contributors Use of the Certrec RegSource website for industry trends / Region II focus areas. Real time VR tracking Develop standard list of interview questions to determine line management areas of concern INPO Website NSRB Focus Areas NRC Website CFAM interviews and PI data Employee Concerns

Increased Intrusiveness PRA insights influence audit focus areas to maximize impact. Reduced checklists allow for sub-surface level reviews (VR influenced deep dives). Strategic audit staffing based on auditor/SME skill sets.

PRA Risk

Strategic timing for when to look

Strategic Scheduling of Audits Training audits 6 months prior to INPO ATVs FP audits prior to NRC Triennial FP Inspections Maintenance audits that leverage NOS observations performed during refueling outages Cooperation with Corporate Audit for leveraging specific skills sets outside of NOS (i.e.. Cyber Security CDA reviews)

The road ahead…

Performance Insights Challenging auditors to extract performance insights to share with the line Provide observed behavioral insights Focus on field observations Use Certrec industry aggregated data to paint a compelling picture for pre-cursor indicators

Discretionary Audits Conduct more discretionary audits based on performance gaps or vulnerabilities.

Results Significant improvement in quality / impact of audit related issues Audit reports that provide a meaningful “message” Positive feedback from COO, CNO, SVPs, and NSRB Significant improvement in auditor quality of life and perception of NOS Audit value to the organization Ability to absorb the impact associated with the loss of NOS Assessors

Questions? ?