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

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

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

4. 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.

5. Historical Audit Team Makeup

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

7. Efficiently Focus on “Core” Business

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

10. 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.

11. 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.

12. 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).

13. “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

14. Be smarter at where to look

15. 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

16. 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.

17. PRA Risk

18. Strategic timing for when to look

19. 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)

20. The road ahead…

21. 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

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

23. 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

24. Questions? ?