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Line Management Responsiveness to Independent Oversight

Presented to:

OCRWM Management Team


Presented by:

Larry Newman
Director Office Quality Assurance

Line Management Responsiveness to Independent 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 that Oversight 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, as appropriate, to assess performance and identify areas for improvement.

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The Valuation of Independent Oversight 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 in the 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 forthright information to oversight, audit, and regulatory organizations.

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The Valuation of Independent Oversight


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 fresh look. A mix of self-assessment and independent oversight reflects an integrated and balanced approach. This balance is periodically reviewed and adjusted as needed. The insights and fresh perspectives provided by quality assurance, 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 and procedures, 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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Shift in Approach to Independent Oversight


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 future events generated by the same causal factors

(Recent example from an audit on the next slide)


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Site Operations Functional Area Audit


Identified by QA and documented by the Line

Developed with line support and documented by QA

Evaluated and addressed by the Line

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Shift in Approach to Independent Oversight


QA is Evaluating Performance of Cross Cutting Areas 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

Functional Areas

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Behaviors that Demonstrate Oversight is Used to Strengthen Safety and Improve Performance
Nuclear Leaders are proactive and responsive to independent oversight concerns Nuclear Leaders are not defensive when presented 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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Behaviors that Demonstrate Oversight is Used to Strengthen Safety and Improve 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 is encouraged and never discouraged

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Behaviors that Demonstrate Oversight is Used to Strengthen Safety and Improve Performance
Nuclear Leaders strive to eliminate problems rather than analyzing them away Take the lead in critically reviewing draft problems brought forward by oversight personnel, to ensure nuclear safety issues are identified and addressed

Establish single point accountability activities important to Quality & safety


Explore underlying causes of events
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for

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Behaviors that Demonstrate Oversight is Used to Strengthen Safety and Improve Performance
Encourage good communications and teamwork between groups that support the site (such as QA, the RAO, the M&O Contractor and the Lead Lab) Constructively challenge oversight conclusions using positive behaviors, such as understanding the complete problem before issuing a challenge Take actions that are commensurate with the relative significance of the issues
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Behaviors that Demonstrate Oversight is Used to Strengthen Safety and Improve Performance During the past 6 weeks, The OCRWM Oversight organization observed less than adequate line management behaviors in each of the categories just outlined above.

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Line Management Responsiveness to Independent Oversight

Open Discussion

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