Testimony of Jeffrey Allison

**Manager, U.S. DOE Savannah River Operations Office**

**Before the Defense Nuclear Facilities Safety Board Public Hearing**

**December 4, 2003**

# Contractor Oversight and Self-assessment Activities

I appreciate the opportunity to talk to you today concerning safety
oversight at the Savannah River Site. There is no more important subject
to me than the subject of safety. While I believe Savannah River has a
sound, mature safety program with an excellent safety record, I also
know that continuous improvement is necessary to maintain or improve
this performance. The safety of the federal and contractor workforce,
the public and the environment receives daily attention from my staff
and me. Today I will discuss how I ensure policies and procedures are in
place to safely execute the work processes at Savannah River Site.

This program begins with DOE Headquarters direction, which is
implemented through site procedures. At the Savannah River Site, I have
put in place a system of procedures which detail how we perform
oversight of the contractor. I have a mature program which emphasizes
strong field presence, detailed technical reviews and approval, and
independent reviews through our Environment, Safety, and Health (ES&H)
organization. A technical qualification process is in place for
personnel who perform each of these tasks. We have validated the
effectiveness of our administrative programs and our work performance
though readiness assessments, Integrated Safety Management System
reviews, and other external reviews. DOE Savannah River Operations
Office (SR) personnel have a professional relationship with the
contractor which sets clear expectations for performance. We are
organized and properly staffed for our assigned missions.

I will first briefly discuss the DOE Headquarters direction on the
subject of contractor oversight.

1.  DOE Policy 450.5, titled "Line Environment, Safety and Health
    Oversight" gives headquarters expectations for ES&H oversight. A key
    portion of the policy reads; "...DOE...Line managers must acquire
    and maintain sufficient knowledge of program activities in order to
    make informed decisions on safety resources for these activities."
    This policy gives substantial direction to work together with the
    contractor self-assessment program and I agree that the contractor
    self-assessment program can be relied upon as one source of
    information. As I discuss below I have other sources of information
    that I use to validate the contractor's self-assessment program.

2.  DOE Policy 411.1, titled "Safety Management Functions
    Responsibilities and Authorities Policy", states "The ultimate
    responsibility and accountability for ensuring adequate protection
    in the operation of DOE facilities, while meeting the requirements
    of national security and defense, rests with DOE line management.
    Where contractors are employed to plan and conduct work at DOE
    facilities, DOE line management fulfills this responsibility by
    establishing expectations, contractual requirements, overseeing
    compliance and managing contracts." This quote accurately captures
    the role of DOE at the Savannah River Site.

Next I will discuss direction for contractor oversight contained in SR
specific documents.

1.  Savannah River Operations Office, Human Resources Program Management
    Manual, DOE-SR Functions, Responsibilities and Authorities Procedure
    (FRAP) (SRM 300.1.1B) implements the directive of HQ Policy 411.1.

> The FRAP dictates clear lines of responsibility and authority for
> oversight of the contractor and DOE activities. The FRAP assigns
> overall leadership and direction for oversight of assigned contractor
> activities to the Assistant Managers, Chief Financial Officer, Office
> Directors and the Division Directors that work for them. Line
> Management Organizations have direct authority and responsibility for
> the safe, secure and efficient operation of DOE facilities and
> activities. Line managers demonstrate a personal commitment to the
> highest standards of safety, health and environmental protection and
> ensure that the day-to-day activities of the contractor reflect the
> existence of a pervasive safety culture. Line managers monitor the
> contractor's processes for identifying activity hazards and ensure
> that proper controls are developed and implemented to prevent or
> mitigate hazards to safety and health.
>
> The FRAP also formally charters the following groups to conduct
> activities associated with safety. The Executive Technical Management
> Board (ETMB), which is composed of members of my senior management
> team, sustains the culture of safety, security, competence and
> technical excellence, and oversees the principles of Integrated Safety
> Management (ISM). The ETMB provides guidance and direction for the
> implementation of contractor oversight to ensure consistency within
> the line organizations and enables effective site-wide integration in
> the area of ISM. The ETMB and its standing committees facilitate
> site-wide integration of programs in their areas of cognizance and
> advise me from that perspective. These committees include:

-   Facility Representative Council (FRC) -- Develops, recommends and
    facilitates activities that enhance the FR Program, including
    ensuring the effective integration of FR activities into the line
    ES&H contractor oversight.

-   Nuclear Safety Council -- Sustains progress in nuclear safety
    excellence. Integrates the efforts of the line management and
    support organizations in the implementation of nuclear safety

-   Technical Assessment Program Committee -- Develops, recommends, and
    facilitates activities that enhance the Technical Assessment Program
    and improves the conduct and integration of technical activities
    among all applicable organizations.

2.  I have promulgated my expectations for safety by issuing a policy
    statement (SRP 03-08). Savannah River Site Workplace Safety, Health,
    and Security Policy states the objective as "Operations on the
    Savannah River Site shall be conducted in a manner that protects the
    worker, the public, the environment and security assets and related
    materials. The objective of this policy is to establish a consistent
    site-wide approach to worker protection and security by
    incorporating safety, health, and security into daily activities." I
    am not willing to accept the status quo, but expect continuous
    improvement in site safety performance and the continued growth in
    the effectiveness of the ISM Program.

3.  The third site specific element I will discuss is the contract with
    the Westinghouse Savannah River Company that enforces and provides
    incentives for safe operation. The Performance Evaluation and
    Measurement Plan (PEMP) is a section of the Operating contract which
    provides a general overview of the contract, identifies the specific
    fee incentives under the contract, and provides information,
    guidance and processes for management and administration of the
    contract by my staff. The General Performance Requirements section
    contains the following provisions.

-   Under this contract, the principle of compliance with ES&H
    requirements is a precondition of operations and to earning of fee
    under the contract.

-   It is expected the contractor will establish and enforce management
    systems. The contractor is responsible for the conduct of its
    operations and of all its employees in the operation of this site.
    Fee reductions will not occur if the contractor stops an activity
    that it deems unsafe; unless, the alleged unsafe condition arose as
    a result of the contractor's actions.

Topics discussed thus far detail headquarters and Savannah River
specific documents concerning oversight of activities at SR. The federal
workforce at Savannah River Site implements these requirements. There
are three general groups of technically qualified personnel performing
independent assessment of the work performed by the contractor.

1.  The first group of people I will discuss is the Facility
    Representatives (FRs). An FR is an employee with full-time duties
    and responsibilities consisting of broad-based observation and
    assessment of facility operations and activities considered
    important to maintaining the safety of workers, the public and the
    environment. These individuals maintain knowledge of facility status
    and conditions on a real-time basis and serve as the working level
    SR point of contact with the contractor. At Savannah River we have
    further refined this position by defining a Senior FR position as an
    FR with expert knowledge of the assigned facility who provides the
    senior resident SR point of contact between the facility contractor
    and SR management on a day-to-day basis.

> FRs throughout SR share common responsibilities. They provide the
> major onsite SR presence and the \"on-the-scene eyes and ears\" for SR
> line management. This provides increased knowledge of conditions at
> the facility and direct observation of the M&O contractor\'s actions,
> thus improving SR\'s ability to respond quickly and effectively to
> facility problems. The FR performs review and assessment of assigned
> facilities to ensure that the facilities are operated safely and
> conform to DOE requirements and good industry practices. In this
> context: (1) the FR assesses performance and effectiveness of the
> operating contractor\'s personnel and procedures; (2) The FR provides
> useful feedback to the operating contractor through the appropriate
> channels established by SR line management; (3) the FR verifies the
> operating contractor\'s resolution of identified deficiencies and
> weaknesses by reviewing the closure of items in the corrective action
> program; (4) the FR coordinates with SR line management to assure
> acceptable closure of issues, and (5) the FR coordinates the
> communications of lesson learned at this site and across the complex.

2.  The next group of personnel I will discuss is the Technical
    Specialists assigned to the line organizations. These individuals
    perform in-depth reviews of technical documents and activities. They
    are qualified individuals with demonstrated experience and
    documented knowledge of a technical program area. Examples of
    Technical Specialist assessments include those pertaining to
    facility engineering and design as well as the review and approval
    of Authorization Basis documents, which form the license for
    operations of our facilities.

> SR technical assessments focus on performance and effectiveness,
> rather than simple compliance with requirements. The SR Technical
> Assessment Program strives for high-quality reviews with the
> flexibility to meet both base requirements and emerging needs. The SR
> Technical Assessment Program fulfills an important part of the
> "Feedback and Improvement" function of SR's ISM System, and the ISM
> System functions and principles provide the underlying foundation for
> this procedure.

3\. The third group of qualified personnel performing assessments is
those personnel assigned to the non-line management ES&H organization.
These are technically qualified personnel with demonstrated expertise
functional areas such as Transportation and Packaging, Fire Protection,
OSHA, Radiological Controls, Emergency Preparedness, and Safeguards and
Security. These individuals perform independent assessments of
facilities and programs and report the results of their reviews to me
and to the contractor through line management. The ES&H organization
also looks for sitewide trends and programmatic deficiencies. The ES&H
organization oversight and involvement provides the checks and balances
needed to oversee the work performed at SRS.

Line management reviews the results of these assessments for the
significance of the findings and to determine the overall operating
performance of the contractor. Put another way, all the information
concerning budget, schedule and operating performance comes together at
the site management level for review. This review provides operational
awareness through analysis of SR assessments, contractor performance
indicators, operational events, and feedback from my staff. My senior
management team then meets with the contractor line management in a
structured forum for summarizing assessment results, presenting
deficiencies, and addressing issues at the senior DOE and operating
contractor management level. These meetings also provide the operating
contractor management an opportunity to provide additional information
to SR regarding a deficiency or issue. The reports issued for these
meetings are the best performance indicator of the assessment program at
SR. The above outlined programs confirm the effectiveness of our current
oversight approach, however the effectiveness of this approach is
continuously reviewed.

I have reviewed the proposed DOE P 226.1 and returned comments to
headquarters. The proposed policy maintains an emphasis on reliance on
the contractor's feedback and improvement program. Based on a review of
the proposed policy and in consideration of the current programs
previously mentioned, I would not expect that significant changes would
be necessary to implement the policy.

Next I will discuss the technical staffing for SR. We currently have
defined 206 positions that require formal technical qualification. As a
result of the recent reorganization I put in place at SR to put
additional focus on closure activities, 152 of the 206 positions are
currently filled with qualified personnel. The remaining 54 personnel
are actively pursuing qualification. Twenty-three of these personnel
have been previously qualified in a different position. These staffing
numbers indicate 73% of identified positions are filled with qualified
personnel. All 29 SR FRs are currently qualified. We are also performing
a 5 year staffing review that will look at our staffing needs for the
future and ensure we have an adequate pipeline or recruitment strategy
for technical positions.

As the site manager, I have put in place a structure to facilitate the
flow of information from DOE oversight assessments and contractor
self-assessments. I meet weekly with my senior management team, which
includes all Assistant Managers and Office Directors. The purpose of
this meeting is to communicate issues and lessons learned across the
site. I have a Technical Assistant assigned to my staff, who is a former
facility representative, to ensure I am kept fully aware of the
operational issues in all facilities and work activities. I participate
in bi-weekly contractor meetings with the two main contractor line
organizations, review occurrences, and analyze for trends within
programs and facilities, or for commonality of causal factors. The
information from these meetings is used to validate the operational
status reported to me as well as to validate the contractor supplied
performance metrics. I meet weekly with the DNFSB site representatives
and ensure their issues are fully addressed. In addition, I am available
to all federal personnel to ensure that operational issues can be
addressed and so they know my personal involvement and commitment to
safe operation of DOE facilities. As a result of this direct
involvement, my senior management team and I write specific
correspondence to the contractor for immediate attention to safety
trends/events. I am personally involved and committed to the safe
operation of DOE facilities and an overall continuous improvement in
safety performance at the site.

On September 9, 2003, I transmitted information on and chapters from the
Columbia Accident Investigation Board's report to my senior management
team along with the expectation that they read the report, identify
lessons learned that are applicable to our operations at the SRS, and
determine how these can be applied to strengthen our safety culture at
the site. Similar to NASA, our mission is unique, complex, and highly
technical - often dealing with one of a kind technology.

I also tasked my ES&H organization with conducting an analysis of the
document and leading a session with my senior management team to
evaluate the organizational practices and cultural traits identified in
the AIB report that contributed to the accident for analogies at SR.
This session was conducted on October 8, 2003. The conclusion of this
analysis and evaluation session was that the SR senior management team
focus is clearly on continual improvement in safety performance while
accelerating clean up. SR has open lines of communication and good
technical qualifications. We are sending out a balanced message of
safely accelerating cleanup work. One of the areas that we are seeking
to improve is in the sharing of the lessons learned. After the October
8^th^ discussion, I requested that my operations line managers utilize
the senior management team meetings as a forum for airing well thought
out and analyzed lessons learned from their facilities.

I believe the Savannah River Operations Office has a very mature
oversight program that fully implements the guidance provided by DOE
headquarters. I have a technically qualified staff to enable me to
effectively conduct oversight. My senior management team is fully
engaged in the safety and operational aspects of the facilities under
their cognizance. Finally, I am personally involved in the review and
analysis of operational events and drive the preparation of feedback to
the contractors. I have created a culture that values safety and
recognizes the need for continuous improvement to maintain a mature
oversight program.

And now I would be glad to answer any questions you might have.