Tank Operations Contract AECOM Independent Assessment of WRPS CAS Effectiveness Results Michael Peloquin (509) 539-5357 Michael_G_Peloquin@rl.gov WRPS Contractor Assurance Manager November 7, 2017 1
Tank Operations CAS EFFECTIVENESS ASSESSMENT Contract • May 15 through May 22, 2017 • The Review Team was led by AECOM N&E Technical Services and included – 3 management representatives from other contractors – 3 internal functional area representatives • DOE-ORP was an invited observer for this review. • First AECOM assessment using EFCOG Best Practice. 2
Tank Operations PURPOSE Contract • The review was practically focused on front line performance where implementation of CAS processes occurs – CAS Effectiveness with respect to governance and transparency – Field Operations including • Operational drill and emergency preparedness drill and exercise program performance as implemented within field operations • Conduct of Operations program performance as implemented within field operations • The assessment examined practices and behaviors of performance at various levels of assurance • The assessment also allowed for a review of safety culture 3
Tank Operations LAYERS OF SUPPORT Contract Work/Project Delivery Workers/Technical Staff Supervisors/Line Managers Internal Functional/Support Organizations Audit/Assurance Organization Corporate External Client Regulator Performanc nce A Assur uranc nce La Layers of S Suppo upport 4
Tank Operations CAS EFFECTIVENESS CROSSWALK Contract 5
Tank Operations LINES OF INQUIRY Contract • Objectives 1-7 aligned with the CAS effectiveness attributes as defined in the best practice • Objective 8-10 added by corporate assessment team • Objective 9: – A routine operations drill program and an EP drill and exercise program have been established and implemented. – Records for each program are adequate to demonstrate the effectiveness of completed drills and exercises as well as planning for future drills and exercises. • Objective 10: The formality and discipline of operations are adequate to conduct work safely. 6
Tank Operations Contract LINES OF INQUIRY OBJECTIVE CE8: The CAS Effectiveness attributes and sub-elements are or will timely be effectively promulgated within WRPS. CRITERIA • The CAS Effectiveness attributes and sub-elements are documented in company programs, policies, an/or procedures and/or gap analyses have been performed, gaps have been identified and plans established to close gaps in a timely manner • WRPS Senior Management is sufficiently aware, understands, and supports implementation of the CAS Effectiveness attributes 7
Tank Operations RESULTS AND CONCLUSIONS Contract • The Assessment Team determined that all 10 Review Objectives were met – 9 noteworthy practices – 16 issues • None of the issues were considered to have sufficient safety significance to warrant immediate action and 2 of the 16 issues were for parent company consideration • WRPS demonstrates a mature and continually-improving Contractor Assurance System utilized by management to: – (a) reinforce expectations and drive improvement in focus areas and – (b) focus risk based decisions and actions on outcomes and performance optimization – thereby minimizing risk. 8
Tank Operations RESULTS AND CONCLUSIONS Contract • Senior WRPS managers were found to be directly involved with and fully attentive to current issues, their mitigation and their resolution. They were also found to fully support implementation of the CAS effectiveness attributes. • With respect to the emergency drill and exercise program, a healthy emergency preparedness program is being implemented and is focused heavily on continual process improvement and analysis of trends. • There were no significant concerns identified regarding sustainability of these two programs. 9
Tank Operations RESULTS AND CONCLUSIONS Contract • Formality and discipline of operations are generally adequate to conduct work safely – but do not currently meet management expectations based on recent lock/tag and procedure compliance issues – Management has been proactive in taking immediate actions to ensure the negative trend is mitigated. – The maturity of the contractor assurance system provides the foundation and tools necessary for monitoring Conduct of Operations health to ensure work is performed safely. – In particular, field oversight through the Management Observation Program provides an opportunity for management engagement in the field to continue reinforcement of expectations. 10
Tank Operations RESULTS AND CONCLUSIONS Contract • Noteworthy CAS practices such as: – The Management Observation Program; – The Trend Analysis and Collective Significance Review processes; – PER screening for immediate safety and non- compliance concerns; – Integration of risk management, internal audit, and contractor assurance; – Use of mockups and/or oral boards to establish and assure competency of involved personnel in response to some issues and events. 11
Tank Operations DISCUSSION FOR EFCOG CONSIDERATION Contract • Assessment activities are based on risk but do not specifically include scheduling of high consequence activities. • An assessment approach should consider consequence irrespective of the probability of occurrence for a defined list of high consequence activities. • The element of responsiveness consists of more than just timeliness; other factors should also be considered – Compensatory measures – Extent of Condition – Scope – Budget 12
Tank Operations DISCUSSION FOR EFCOG CONSIDERATION Contract • What is the definition of risk and risk informed within the context of 226.1 B • How do we leverage CAS processes to address risk – Operating experience/Lessons learned – Assessment program – Cause analysis – Trend & corrective action program – Performance indicators • Consider a best practice to address risk integration with CAS 13
Tank Operations DISCUSSION FOR EFCOG CONSIDERATION Contract • What kind of information is provided to the LLC Board to improve governance and their understanding of performance – Quarterly Risk Reports – Quarterly Performance Trends and Recurring Occurrence Analysis Report – Quarterly Performance Evaluation and Measurement Plan Critical Self-Assessment – Performance Indicators – Independent/External assessment results 14
Tank Operations DISCUSSION FOR EFCOG CONSIDERATION Contract • DOE-O-226.1B CRD states – “The contractor is responsible for flowing down the requirements of this CRD to subcontractors at any tier to the extent necessary to ensure the contractor’s compliance with the requirements. – Contractors must monitor and evaluate all work performed under their contracts, including the work of subcontractors, to ensure work performance meets the applicable requirements for environment, safety, and health, including quality assurance and integrated safety management; safeguards and security; cyber security; and emergency management.” • EFCOG should consider a best practice to address this language 15
Tank Operations LESSONS LEARNED Contract • Allow 2 weeks for the field assessment to provide better opportunity for follow-up reviews and management interviews for validation of results prior to the exit interview . • Assessment of the field activities in the early part of the assessment was a strength, however, assessment team needs to circle back to the program for context and clarity. • Documents should be provided prior to the review and then contract period of performance start date should be approximately one week prior to the on-site review in order to enable the Team to review documents before arriving on- site 16
Tank Operations LESSONS LEARNED Contract • Consideration should be given for using surveys prior to the assessment visit. – Questions prompting binary answers with room for comment could be used to find common themes to interview and document review lines of inquiry. – Potential to piggyback on existing organizational surveys (e.g. Safety Culture), analyzing the results for relevance or adding some applicable questions whenever possible. • Consideration should be given to combining Organizational Learning and Management Leadership given the extent of their overlap • Consideration should be given to addressing Work by Others corporately rather than project by project 17
Tank Operations Contract Thank You 18
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