1 ASQ Energy and Environmental Conference Opportunities for Safety Performance Improvement in the DOE Complex Stephen M. Sohinki Director 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 Bismarck 19 th Century Prussian Chancellor Nuclear Power Technology Inc.

3 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 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

4 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

5 Regulations (cont’d)  10 CFR 851- Worker Safety and Health Program (draft)  10 CFR 712 – Human Reliability Program (being reviewed for PAAA enforceability)

6 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

7 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

8 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

10 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

11 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?”

12 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

13 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

14 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

15  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)

16 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

17 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

18 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

19  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

20 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

21  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)