# Presentation: 937739

## Headquarters Biennial Review of Site Nuclear Safety Performance FR Overview

**May 14, 2008**
**Don Nichols**

**Notes:**
I am Don Nichols, I work for the NNSA Chief of Defense Nuclear Safety.  

In NNSA, our office reviews the implementation of nuclear safety requirements at NNSA site offices every two years.  We have just completed our first round of reviews and have started on a second round.  

## CDNS Biennial Reviews

**Biennial Review Overview**
**FR Review Criteria**
**Observations/Trends**
**Opportunities for Improvement**

**Notes:**
This morning I’ll tell you a little about how the NNSA Biennial Reviews of the site offices are put together, with a focus on our review of the FR functional area and what we have learned about the FR program.  

I want to end by providing you some input on the opportunities that exist for improving the overall performance of the program.

## Biennial Review Purpose

- Provide objective, value-added information for NNSA managers
- Site Office oversight capability
- Contractor implementation of nuclear safety requirements
- Promote continuous improvement where deficiencies are identified
- Encourage consistent application of nuclear safety requirements across NNSA

**Notes:**
We conduct Biennial Reviews to help site offices improve their performance and to provide senior NNSA management with a self assessment of how we are doing with respect to nuclear safety oversight. 

Our emphasis is to help sites identify the areas where opportunities for improvement exist, and, where necessary, help to get resources they need to improve.

Our reviews aren’t designed to be audits or to measure compliance.  

We look at whether sites are meeting the requirements, because that is one important, objective indicator of performance.

But, we also look at how well the site is meeting the requirements.  This is more subjective, but in terms of site effectiveness can be more important. 

## CDNS Reviews 18 Functional Areas

- Conduct of Engineering
- Conduct of Operations
- Contractor Training and Qualification
- Criticality Safety
- Facility Representatives
- Federal Training and Qualification
- Feedback and Improvement
- Fire Protection
- Integrated Safety Management

- Maintenance
- Nuclear Explosives Operations
- Packaging and Transportation
- Quality Assurance
- Radiation Protection
- Radioactive Waste Management
- Safety Basis, including nuclear safety delegations
- Special Interest Areas
- Startup and Restart of Nuclear Facilities, including nuclear safety delegations

**Notes:**
In our baseline reviews, we look at about 18 functional areas, give or take a few based on the needs of each site.  

The round of reviews we just completed finished the baseline, and the second round of reviews will be tailored for each site, focusing on the areas where the baseline indicated that improvements were needed.  

We staff our reviews mostly with subject matter experts from the field, not headquarters personnel.  That helps us to transfer good ideas that turn up in these reviews from one site to another.

But, we also have a core team of headquarters personnel that, depending on the review, covers roughly a third or so of the functional areas.  

We maintain the same senior advisor and team leader where possible.  

We rely on the team leader and senior advisor, the core team, and field personnel who have served on previous reviews to help maintain consistency between the reviews.

## FR Review Criteria* (slide 1 of 2) 

**Day-to-day FR operational oversight of contractor nuclear facilities is formalized**
**FRs have operational awareness and understand their assigned facilities**
**FRs periodically verify that nuclear facility DSA controls and conduct of operations programs are adequately implemented**

- *The criteria on these slides have been reformatted for this presentation.

**Notes:**
In the FR functional area, we have 5 criteria we evaluate.  They are summarized on these two slides. 

In general, we’re looking at the primary responsibilities of the FRs;

We look for a formal oversight  program that develops highly qualified FRs who understand and execute their responsibilities in a systematic and comprehensive manner.

## FR Review Criteria (cont)

**Involvement in Occurrence Reporting and Processing (ORPS) system is appropriate  **
**FRs report issues and safety concerns to the contractor and NNSA Site Office managers; appropriate action is tracked to closure **
**Staffing levels and formal training and qualification requirements are established**
**Competence and awareness responsibilities reflect key controls and programs**

**Notes:**
We also look at how the FRs are incorporated into the process of incident reporting and evaluation, and how they follow up on the reported incidents.

To be effective, FRs need to provide clear and useful communication to their management chain, and their management needs to demand appropriate action on the issues that the FRs raise.  

By ‘demand appropriate action’ I mean that management needs to follow issues to resolution and demand appropriate contractor response.  Obtaining appropriate contractor response may require the use of contract mechanisms or even stopping work until a significant problem is adequately addressed. 

Management also needs to be a demanding customer of the FRs, and demand quality products from them.

We also look at the numbers of personnel at each site and the level of qualification.  You can’t do your job if you are stretched too thin, and your credibility rests on your technical competence and the thoroughness of your research into issues.  

## Overall Observations

- Five sites “Met Expectations”
- “Most criteria are met, and the objective is met.  Some issues may be identified”
- Two sites “Need Improvement”
- “Objective is not met, but the site is able to address the issues without need for additional oversight”
- No sites were graded as “Exceeds Expectations” or “Does Not Meet Expectations”

**Notes:**
As for results of our first round of reviews, most sites met most of the criteria. That’s a good outcome, because it tells us that most sites have captured the elements of a healthy FR program.

However, we can do better.  Not all of our sites met expectations, and no one of our sites really stood out as an exceptional performer.  

One of the things we try to capture in our reviews are noteworthy practices—practices that one site has that other sites would benefit from learning about.  While all sites had strengths and weaknesses, none of the strengths stood out sufficiently to be considered a noteworthy practice.

## Opportunities for Improvement

- Systematize oversight to ensure all responsibilities are periodically assessed using an integrated schedule
**Work with your management to develop a common set of expectations for FR performance**
**Include the contractor activities FRs are expected to attend**
**Smart-sample (but don’t ignore) areas where contractor performance appears adequate**
- Keep your communications useful – filing a report for the sake of filing a report wastes time twice
**When you have to file, it’s up to you to make sure your reports convey useful information**
**When the utility of a reporting requirement could be improved, constructively recommend a change**

**Notes:**
So, how do we get better? 

Our reviews provided a number of opportunities for improvement at each site.  Many of these addressed specific issues at each site, but a number of these opportunities were found at more than one site.  

These next two slides provide a summary of some of the more generally applicable opportunities.  Some of these may already be in place at your individual site.

In general, the point is not to create more paper.  But, it is important to document what you do and the issues you identify—even if you communicate them verbally to the contractor.  It is important that the documentation is clear and meaningful.  

Consider training in effective written technical communication.

## Opportunities for Improvement

- Systematically track the issues you identify so you can                 follow up on how they were addressed
**A central database is ideal, but use a spreadsheet if you have to**
**Communicate status regularly with contractor and management**
**If you don’t track the issues you identify, you undermine your influence on the contractor and with your management**
- Periodically perform self assessments
**Develop a series of review criteria based on FR responsibilities**
**Include the self assessments in your overall assessment schedule**
- Have a systematic FR qualification/requalification plan and track your progress

## Conclusions

- Most Site-level FR programs are performing as required
- FRs are generally among the most knowledgeable NNSA personnel regarding assigned nuclear facilities, current activities, conditions, hazards and controls
- Work is needed for site FR programs to fully realize their potential as outstanding contributors to NNSA oversight

**Notes:**
The bottom line from the CDNS reviews of the FR program is that while we are generally meeting the mark and our FRs are generally the most aware NNSA personnel regarding their assigned facilities, we still have some work to do to make our FR programs live up to their full potential.