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Safety Working Group

Safety Working Group. EFCOG Board of Directors Meeting Jan Preston, SWG Vice Chair Washington, DC February 11, 2019. Summary. Accomplishments: 5 SWG recommendations for regulatory burden reduction

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Safety Working Group

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  1. Safety Working Group EFCOG Board of Directors Meeting Jan Preston, SWG Vice Chair Washington, DC February 11, 2019

  2. Summary • Accomplishments: • 5 SWG recommendations for regulatory burden reduction • Influenced EM-1 “Freeze Code of Record” memo; EFCOG Board letter to EM-1 (11/06/18) endorsed approach • Minimal progress on other recommendations; will revisit strategically • 10CFR851 Technical Amendment Constructive Impacts • EFCOG Board elevated the SWG’s concern to DOE • Engagement resulted in an “Abatement Plan” implementation option, which encouraged consideration of risk, life cycle, costs, other factors • Implementation Plans were due 1/17/19 • CAS Effectiveness Approaches • Developed Assessment Plan Template and Effectiveness Validation LOIs • 2019 Annual Work Plan (AWP) on track • New EFCOG strategic initiatives to be proposed

  3. 2019 Annual Work Plan • SWG has good track record of completing AWP work scope each year • 2019 AWP has about 80 actions • No issues to report to date with 2019 AWP implementation • DOE would like to see more “strategic” initiatives • A broad sample of actions in the 2019 AWP, and proposed strategic initiatives, follows

  4. SWG 2019 AWP Highlights • ISM: Develop DOE National Training Center (NTC) HPI training for the DOE complex and provide input to revise the DOE HPI Handbook • Worker Safety & Health: Assist the NTC in their effort to build consistent radiological worker training programs to be used complex-wide • Regulatory & Enforcement: Assist the NTC and the DOE Office of Enforcement to convert the existing Enforcement Coordination classroom training to Computer Based Training • ISM: Develop a ‘Safety Culture Practitioner’s Guide”; a guide to improving safety culture competencies • Nuclear & Facility Safety: Provide a venue for training and mentoring early career nuclear safety analysts to enhance knowledge, skills, and career development

  5. SWG 2019 AWP Highlights (cont.) • Quality Assurance: Complete and finalize the EFCOG Commercial Grade Dedication Handbook and associated examples and best practices and develop associated training • Quality Assurance: Increase use of the Master Approved Supplier List (MASL) by continuing to implement recommendations from the 2017 joint EFCOG/DOE report • Worker Safety & Health: Develop a Best Practice for “DC Arc Flash Calculations” • Worker Safety & Health: Develop a consistent medical evaluation for the OSHA crystalline silica standards, offering workers the best medical surveillance program for the earliest detection of disease • Worker Safety & Health: Provide guidance on the application and implementation of the ACGIH Thermal Stress TLV 

  6. Proposed Strategic Initiatives • Integrated Safety Management Revitalization • Work jointly with DOE/NNSA to identify opportunities to raise visibility, improve collaboration (e.g., “ISM Champions”), and enhance sharing of lessons learned • Revisit previous efforts to enhance Work Planning & Control – the foundation of ISM – and determine next steps to improve • Conduct of Operations • Create new Joint (DOE/NNSA/EFCOG) Task Team for a fresh and wide-scope look at ConOps program design and implementation challenges in the context of recent events (e.g., radcon, electrical safety, hoisting/rigging, nuclear safety basis) that have had a ConOps breakdown as a contributing element • Include consideration of HPI factors, safety culture, work package design, training, and workforce turnover (i.e., influx of new workers)

  7. Proposed Strategic Initiatives (cont.) • Safety Culture • Establish formal interface between EFCOG and DOE/NNSA Safety Culture Improvement Panel • Jointly work to consolidate and align current (potentially competing) initiatives into a standard toolset (e.g., surveys, training, employee engagement) • CAS Effectiveness Next Steps • Building on the success of the 2017 Joint Task Team, facilitate discussions to integrate/evolve disparate DOE/NNSA CAS initiatives

  8. Proposed Strategic Initiatives (cont.) • Regulatory Reform • Revisit 2018 EFCOG SWG recommendations with DOE and identify next steps of DOE and EFCOG involvement (see example next page)

  9. Opportunity: Establish Process for Requirements Clarification • Establish a formal (simplified) process – which involves DOE Field, AU (as the Program owner), and the contractor – to resolve “differing opinions” on Program requirements implementation • Contractors are most knowledgeable of the risks/costs/benefits of requirements implementation • DOE Field oversight personnel have been known to mandate more rigorous interpretation/implementation approaches • DOE Program owners (e.g., AU) are not normally engaged in discussions on what would constitute a balanced implementation strategy • Prior to the EM-1 memo on “Freezing the Code of Record,” there was little formal encouragement to discuss reasonable, tailored, implementation of new contract requirements There currently is no formal forum for resolution of disagreements between contractors and DOE Field representatives

  10. Back up slides

  11. Freeze Original Contract Requirement Set • Original contract requirement set (i.e. orders, standards, requirements) should only be changed if new requirements increase unacceptable risk (not just make it “better”). • For other updated requirements, defer any implementation and associated costs to the next contract period. • Cost Savings: Medium (10-100M) • Difficulty: Easy • EFCOG POC: Jan Preston • EM-1 Letter

  12. Tailored Application of Requirements • Implementation of requirements should consider cost benefit and lifecycle stage to ensure cost effective contract application • DOE should routinely apply requirements using a tailored approach considering remaining life, scope and duration of duration of mission or facility, and potential for risk reduction as compared to cost • Cost Savings: Large (>$100M) • Difficulty: Easy (Tailoring is already an expectation, but is inconsistently applied) • EFCOG POC: Jan Preston • Status: No action

  13. Reduce Periodic Program Submittals • Eliminate periodic submittals of various program description and status documents, which eliminates processing for both the contractor and DOE (i.e., ISMS Description, ISMS Declaration, CAS, QAP, QAMP, VPP, WS&H Program, Quarterly and Annual CAS related Reports, Nuclear Safety Metrics); based on value added • Submit only one set of program description documents at the beginning of a contract • Program documents are available at any time to DOE • Cost Savings: Medium (10-100M) per year savings • Difficulty: Easy • EFCOG POC: Patricia Allen • Status: No action

  14. Reduce Hardcopy Record Requirements • Eliminate the requirement (OCRM) for maintenance of hard copy records (with minimal, HQ-approved exceptions) which allows for electronic format and backup/safe and secure retention • Cost Savings: Medium (10-100M) • Difficulty: Easy • EFCOG POC: Vince Grosso • Status: No action

  15. Establish Process for Requirements Clarification • Establish a formal (simplified) DPO process for requirement clarification • DOE staff have unlimited or absolute influence on how requirements are applied, not always completely considering acceptability of current practice, contract life cycle, and operational risk • Contractors do not have a safe forum for disagreeing with a DOE representative • Cost Savings: Medium (10-100M) • Difficulty: Medium • EFCOG POC: John McDonald • Status: No action

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