Nuclear Safety Culture and the Hanford Waste Treatment Plant: the Saga Continues

WTP at Hanford

In April 2018 the U.S. Government Accountability Office (GAO) released a report* on shortcomings in the quality assurance (QA) program at the Department of Energy’s (DOE) Waste Treatment Plant (WTP aka the Vit Plant) in Hanford, Washington.  QA problems exist at both Bechtel, the prime contractor since 2000, and the DOE’s Office of River Protection (ORP), the on-site overseer of the WTP project.

The report describes DOE actions to identify and address QA problems at the WTP, and examines the extent to which (a) DOE has ensured that all QA problems have been identified and will not recur and (b) ORP’s organizational structure provides sufficient independence to effectively oversee Bechtel’s QA program.

Why do we care about QA?  The GAO investigation did not target culture and there is only one specific mention of culture in the report.**  However, the entire report reflects the weak nuclear safety culture (NSC) at Hanford.

There is a lot of history here (GAO has been ragging DOE about the need for effective oversight at DOE facilities since 2008) but let’s begin with ORP’s 2012 stop work order to address WTP’s most significant technical challenges. Then, in 2013, ORP’s QA division issued two Priority One findings with respect to Bechtel’s QA program, viz., both the program and Bechtel’s Corrective Action Program to address QA problems were “not fully effective.” (p. 3)  This was followed by a DOE Office of Enforcement investigation which, in turn, led to a 2015 Consent Order and Bechtel Management Improvement Program (MIP).  The Order specified all corrective actions had to be implemented by April 20, 2016.  Currently, 13 of 52 total corrective measures have not been completed and some of the ones where Bechtel claimed completion are not yet completed.  In addition, “. . . in some areas where [Bechtel] has stated that corrective measures are now in place, ORP continues to encounter quality assurance problems similar to those it encountered in the past.” (p. 25)

Why doesn’t ORP stop work again?  Because ORP senior managers plan to evaluate the extent of Bechtel’s implementation of MIP corrective measures over the next year and have allowed work to continue because they believe Bechtel’s QA is “generally adequate.” (p. 22)  We’ll reveal the real reason later.

The shortcomings are not limited to Bechtel.  “ORP’s actions have not ensured that all quality assurance problems have been identified at the WTP, and some previously identified problems are recurring.” (p. 16)  “When and where problems have recurred, ORP has not always required [Bechtel] to determine the extent to which the problems may affect all parts of the WTP.” (p. 25)  Why not?  Here’s a hint: ORP’s “Quality Assurance Division is not fully separate and independent from the upper management of the WTP project, which manages cost and schedule performance.” (p. 22)

Our Perspective

An article*** in the local Hanford newspaper summarizes the report’s contents.  However, the problems described are not new news.  Technical, quality and culture problems have swirled around the WTP for years.  In 2011 we started reporting on WTP issues and the sluggish responses from both DOE and Bechtel.  Click on the Vit Plant label to see our previous posts.

Goal conflict (cost and schedule vs. QA and a strong NSC) has always been the overarching issue at the WTP.  Through fiscal year 2017, DOE spent $11 billion on WTP construction.  It will cost approximately $16.8 billion to complete the first phase of the WTP, which transfers low-level radioactive waste to the low-level vitrification facility.  No one knows how much it will cost to complete the WTP or when it will be functioning.

GAO gives their subjects an opportunity to respond to GAO’s reports and recommendations.  The DOE response is an unsurprising continuation of their traditional rope-a-dope strategy: concur with GAO recommendations, rationalize or minimize the current extent of condition, exaggerate current corrective actions, promise to investigate identified issues and do better in the future, wait for GAO’s attention to turn elsewhere, then continue with business as usual.  What DOE needs to do is issue a stop order for the money train—that would get the attention of everyone, especially Bechtel and ORP managers.

How does your QA department stack up?  Does it add value by identifying and helping to solve real problems?  Is it a distracting irritant, enamored of its own authority and administrivia?  Or is it simply impotent?


*  U.S. Government Accountability Office, “Hanford Waste Treatment Plant: DOE Needs to Take Further Actions to Address Weaknesses in Its Quality Assurance Program,” GAO-18-241 (April, 2018).

**  “One [ORP] quality assurance expert specified that ORP’s culture does not encourage staff to identify quality assurance problems or ineffective corrective measures. This expert said that people who discover problems are not rewarded; rather, their findings are met with resistance, which has created a culture where quality assurance staff are hesitant to identify quality assurance problems or problems with corrective measures.” (p. 24)  This quote exposes the core NSC issue at the WTP.

***  A. Cary, “Feds bash Hanford nuclear waste plant troubles, question DOE priorities,” Tri-City Herald (April 24, 2018).  Retrieved May 1, 2018.

Nuclear Safety Culture Under Assault: DNFSB Chairman Proposes Eliminating the Board

DNFSB headquarters

The Center for Public Integrity (CPI) recently published a report* that disclosed a private letter** from Sean Sullivan, the Chairman of the Defense Nuclear Facilities Safety Board (DNFSB) to the Director of the Office of Management and Budget in which the chairman proposed abolishing or downsizing the DNFSB.  The CPI is highly critical of the chairman’s proposals; support for their position includes a list of the safety improvements in the Department of Energy (DOE) complex that have resulted from DNFSB recommendations and the safety challenges that DOE facilities continue to face.

The CPI also cites a 2014 National Nuclear Security Administration (NNSA, the DOE sub-organization that oversees the nuclear weapons facilities) internal report that describes NNSA’s own safety culture weaknesses, e.g., lack of a questioning attitude toward contractor management’s performance claims, with respect to its oversight of the Los Alamos National Laboratory.

The CPI believes the chairman is responding to pressure from the private contractors who actually manage DOE facilities to reduce outside interference in, and oversight of, contractor activities.  That’s certainly plausible.  The contractors get paid regardless of their level of performance, and very little of that pay is tied to safety performance.  DNFSB recommendations and reports can be thorns in the sides of contractor management.

The Sullivan Letter

The primary proposal in the Sullivan letter is to abolish the DNFSB because the DOE has developed its own “robust regulatory structure” and oversight capabilities via the Office of Enterprise Assessments.  That’s a hollow rationale; the CPI report discusses the insufficiency of DOE’s own assessments.  If outright elimination is not politically doable then DNFSB personnel could be transferred to DOE, sustaining the appearance of independent oversight, and then be slowly absorbed into the larger DOE organization.  That is not a path to increased public confidence and looks like being assimilated by the Borg.***  The savings that could be realized from abolishing the DNFSB is estimated at $31 million, a number lost in the decimal dust of DOE’s $30+ billion budget.

Sullivan mentions but opposes transferring the DNFSB’s oversight responsibilities to the Nuclear Regulatory Commission.  Why?  Because the NRC is not only independent, it has enforcement powers which would be inappropriate for defense nuclear facilities and might compromise national security.  That’s a red herring but we’ll let it go; we don’t think oversight of defense facilities really meshes with the NRC’s mission.

His secondary proposal is to downsize the DNFSB workforce, especially its management structure, and transfer most of the survivors to specific defense facilities.  While we think DNFSB needs more resources, not fewer, it would be better if more DNFSB personnel were located in the field, keeping track of and reporting on DOE and contractor activities.

Our Perspective

Safetymatters first became interested in the DNFSB when we saw the growing mess at the Waste Treatment Plant (WTP, aka the Vit Plant) in Hanford, WA.  It was the DNFSB who forced the DOE and its WTP contractors to confront and remediate serious nuclear safety culture (NSC) problems.  We have published multiple reports on the resultant foot-dragging by DOE in its responses to DNFSB Recommendation 2011-1 which addressed safety conscious work environment (SCWE) problems at Hanford and other DOE facilities.  Click on the DOE label to see our offerings on WTP, other DOE facilities and the overall DOE complex.
 
We have reported on the NSC problems at the Waste Isolation Pilot Plant (WIPP) in New Mexico.  The DNFSB has played an important role in attempting to get DOE and the WIPP contractor to strengthen their safety practices.  Click the WIPP label to see our WIPP-related posts. 

We have also covered a report on the DNFSB’s own organizational issues, including board members’ meddling in day-to-day activities, weak leadership and too-frequent organizational changes.  See our Feb. 6, 2015 post for details.

DNFSB’s internal issues notwithstanding, the board plays an indispensible role in strengthening NSC and safety practices throughout the DOE complex.  They should be given greater authority (which won’t happen), stronger leadership and additional resources.

Bottom line: Sullivan’s proposal is just plain nuts.  He’s a Republican appointee so maybe he’s simply offering homage to his ultimate overlord.
  

*  P. Malone and R.J. Smith, “GOP chair of nuclear safety agency secretly urges Trump to abolish it,” The Center for Public Integrity (Oct. 19, 2017).  Retrieved Oct. 26, 2017.

**  S. Sullivan (DNFSB) to J.M Mulvaney (Management and Budget), no subject specified but described as an “initial high-level draft of [an] Agency Reform Plan” (June 29, 2019).  Available from the CPI in html and pdf format.  Retrieved Oct. 26, 2017.

***  The Borg is an alien group entity in Star Trek that forcibly assimilates other beings.  See Wikipedia for more information.

Nuclear Safety Culture (and Other) Problems in the U.S. Nuclear Weapons Complex

Los Alamos  Source: LANL

The Center for Public Integrity (CPI) has published a five-part report on safety lapses in the U.S. nuclear weapons complex—an array of facilities overseen by the Department of Energy (DOE).*  Overall, the report paints a picture of a challenged and arguably weak safety culture (SC).  Following is a summary of the report and our perspective on it.

Part I traces the history of radioactive criticality incidents (which have resulted in human fatalities) and near-misses at Los Alamos National Laboratory (LANL).  Analysis and production of plutonium pits, essential for maintaining the U.S. nuclear weapons inventory, has been halted for years because of concerns over safety issues.  In addition, almost all members of the site’s criticality analysis team quit over inadequate management support for the team’s efforts.

Part II discusses in more detail the impacts of the LANL shutdown.  Most significant, from our perspective, is a 2013 report that said “Management has not yet fully embraced its commitment to criticality safety.”  The 2013 report “also listed nine weaknesses in the lab’s safety culture that were rooted in a “production focus” to meet work deadlines. Workers say these deadlines are typically linked to financial bonuses.”

Speaking of bonuses, although the plant was not working, the contractors were judged to have exceeded expectations in getting ready to restart.  Accordingly, the contractors “received 74 percent or $10.7 million of the $14.4 million in profits available to them from the NNSA in the category that includes pit production and surveillance”

Part III covers incidents at other facilities and cultural shortcomings in the weapons complex.  It is the meatiest section of the report.  Most of the unfortunate events were industrial accidents (electric shocks, explosions, burns) but the nuclear hazard is always nearby because of the nature of the work.  Occasionally the nuclear factor is key, e.g., when LANL improperly packed a drum of waste they shipped to the Waste Isolation Pilot Plant where it exploded or when Nevada National Security Site personnel inhaled radioactive particles

This section captures the key point of the entire report: the DOE contractors make a lot of money ($2B in profit over the last 10 years), the financial rewards for safety are minimal and the financial penalties for accidents and such are minimal (1-3% of profits) and often waived.

Part IV details a 2014 incident in Nevada where over 30 personnel inhaled potentially cancer-causing uranium particles during laboratory experiments over a two-month period.  The researchers were annoyed by radiation alarms so they switched them off (which also turned off a safety ventilation system).  This was a self-inflicted wound that suggests a weak SC.

Part V focuses on a radiation exposure accident at the Idaho National Laboratory.  The accident occurred even though years before, the head of the safety committee had warned DOE managers about the hazards of handling the specific material involved in the accident.  The lab contractor made 92% of its contractually available profit that year.  The contractor has petitioned DOE to reimburse the contractor’s litigation expenses (including payouts to affected employees) associated with the accident.

NNSA’s Response

The National Nuclear Security Administration (NNSA) is a semi-autonomous agency within DOE that oversees U.S. nuclear weapons work.  In a statement** responding to the CPI report, the NNSA Administrator basically says the CPI report is incomplete and misleading with respect to LANL.  Unsurprisingly, he starts with “Safety is paramount . . . . [CPI] attacks the safety culture at . . .  (LANL) without offering all of the facts and the full context.”  However, he does not directly refute the CPI report, instead he provides the NNSA’s version of history: LANL paused operations because of concerns with the criticality safety program. Since then, “LANL has increased criticality safety staffing and demonstrated improvements in its performance of operational tasks.”  NNSA has withheld $82 million in fee payments to LANL.  Finally, LANL maintained its ability to fulfill its mission during the pause in operations.  Alternative facts?  You be the judge. 

Our Perspective 

The DOE says it wants safe production but is not willing to wield the hammer (higher financial incentives for safety and more penalties for unsafety) to drive that outcome.  In addition, DOE, constrained by Congress (which is bowing to their defense industry contributors), appears to deliberately understaff their own auditors and other procurement officials so they are unable to surface too many embarrassing problems. 

The contractors are rational.  They understand that production is the primary goal and they accept that bad things will occasionally happen in a hazardous environment.  They know they will make their profits no matter what happens, including facility shutdowns, because they can get paid for fixing problems they helped to create.

The CPI report is not shocking to us and it shouldn’t be to you.  (Click on the DOE label to see our many posts on DOE SC.)  It merely documents what has been, and continues to be, business as usual at nuclear weapons facilities.  If you can tolerate the overwrought writing, Part III is worth a look.           


*  The Center for Public Integrity, “Nuclear Negligence” (June 28, 2017).  Retrieved July 5, 2017.  According to Wikipedia, CPI “is an American nonprofit investigative journalism organization . . .”

The report describes problems at the Idaho National Laboratory and some NNSA facilities.  Overall, NNSA oversees eight sites that are involved with nuclear weapons: Kansas City National Security Campus (non-nuclear component manufacture), Lawrence Livermore National Laboratory (weapon design), Los Alamos National Laboratory (design and testing), Nevada National Security Site (testing), Pantex Plant (weapon assembly and disassembly), Sandia National Laboratories (non-nuclear component design), Savannah River Site (nuclear materials) and Y-12 National Security Complex (uranium components).

**  “Klotz Responds To Center For Public Integrity's Series On Safety Culture At NNSA Sites,” Los Alamos Daily Post (June 20, 2017).  Retrieved July 10, 2017

Nuclear Safety Culture at the Department of Energy—An Update

We haven’t reported on the U.S. Department of Energy’s (DOE) safety culture (SC) in awhile.  Although there hasn’t been any big news lately, we can look at some individual facts and then connect the dots to say something about SC.

Let’s start with some high-level good news.  In late 2016 DOE announced it had conducted its 100th SC training class for senior leaders of both federal and contractor entities across the DOE complex.*  The class focuses on teaching leaders the why and how of maintaining a collaborative workplace and Safety Conscious Work Environment (SCWE), and fostering trust in the work environment. 

Now let’s turn to a more localized situation.  In Feb 2014, a storage drum burst at the DOE’s Waste Isolation Pilot Plant (WIPP) in New Mexico, resulting in a small release of radioactive material.  The drum burst because a sorbent added to the waste had been changed without considering the difference in chemical properties.**  This has been an expensive incident.  The plant has been closed for over three years; it was authorized to reopen in Jan 2017 and shipments are scheduled to resume in April 2017.*** 

The drum that burst came from the Los Alamos National Laboratory (LANL).  The WIPP Recovery Plan envisions continuing the pre-incident practice of the waste generators being responsible for correctly packing their waste: “All waste generators will have rigorous characterization, treatment, and packaging processes and procedures in place to ensure compliance with WIPP Waste Acceptance Criteria [WAC].”****  As we said in our May 3, 2016 post: “For this approach to work, WAC compliance by the waste generators . . . must be completely effective and 100% reliable.”  In the same post, we reported the Defense Nuclear Facilities Safety Board (DNFSB) had recognized this weak link in the chain.  However, because DNFSB cannot force changes it could only recommend that DOE “explore defense-in-depth measures that enhance WIPP’s capability to detect and respond to problems caused by unexpected failures in the WAC compliance program.”

As described in the current WAC, WIPP’s “defense-in-depth” appears to be limited to the local DOE office and the WIPP contractor performing Generator Site Technical Reviews, which cover sites’ implementation of WIPP requirements.*****  These reviews are supposed to assure that deficiencies are detected and noncompliant shipments are avoided but it’s not clear if any physical surveillance is involved or if this is strictly a paperwork exercise.

The foregoing is important because it ties to SC.  Firstly, WIPP has had SC issues, in fact, a deficient SC was identified as contributing to shortcomings in the handling of the aftermath of the drum explosion.  (We reviewed this in detail on May 3 and May 5, 2014.)  WIPP SC is supposedly better now: “NWP [the WIPP contractor] has made continuous improvements in their safety culture and has really embraced the recommendations provided in the 2015 review, as well as subsequent reviews and surveys.”^  Secondly, other SC problems, too myriad to even list here, have arisen throughout the DOE complex over the years.  (Click on the DOE label to see our reports on such problems.)

Finally, we present a recent data point for LANL.  In DOE’s report on criticality safety infractions and program non-compliances for FY 2016, LANL had the most such incidents, by far, of the DOE’s 24 sites and projects.^^  Most of the non-compliances were self-identified.  Now does this evidence a strong SC that recognizes and reports its problems or a weak SC that allows the problems to occur in the first place?  You be the judge.

Our Perspective

Through initiatives such as SC training, it appears that at the macro level, DOE is (finally) communicating that minimally complying with basic regulations for how organizations should treat employees is not enough; establishing trust, mainly through showing respect for employees’ efforts to raise safety questions and point out safety problems, is essential.  That’s a good thing.

But we see signs of weakness at the operational level, viz., between WIPP and its constellation of waste generators.  Although we are not fans of “Normal Accident” theory which says accidents are inevitable in tightly coupled, low slack environments, e.g., a nuclear power plant, we can appreciate the application of that mental model in the case of WIPP.  Historically, one feature of the DOE complex that has limited problems to specific locations is the weak coupling between facilities.  When every facility with bomb-making waste is shipping it to WIPP, tighter coupling is created in the overall waste management system.  Every waste generator’s SC can have an impact on WIPP’s safety performance.  The system does need more defense-in-depth.  At a minimum, WIPP should station resident inspectors at every waste generator site to verify compliance with the WAC.

Bottom line: DOE is trying harder in the SC space but their history does not inspire huge confidence going forward. 


*  “DOE Conducts 100th Safety Culture Training Class” (Dec. 29, 2016).

**  Organic kitty litter had been substituted for inorganic kitty litter.  See this Jan. 10, 2017 Forbes article for a good summary of the WIPP incident.

***  “WIPP Road Show Early Stops Planned in Carlsbad & Hobbs,” WIPP website (Feb. 27, 2017).  Retrieved March 7, 2017. 

****  DOE, “Waste Isolation Pilot Plant Recovery Plan,” Rev 0 (Sept. 30, 2014), p. 24.

*****  DOE, “Transuranic Waste Acceptance Criteria for the Waste Isolation Pilot Plant,” Rev 8.0 (July 5, 2016), pp. 20-21.

^  DOE, “Department of Energy Operational Readiness Review for the Waste Isolation Pilot Plant” (Dec. 2016), p. 33.

^^   DOE, “2016 Annual Metrics Report to the Defense Nuclear Facilities Safety Board – Nuclear Criticality Safety Programs” (Jan. 2017), p. 3.

Nuclear Safety Culture is Improving at the Waste Isolation Pilot Plant—Maybe

The WIPP

On Feb. 14, 2014, a drum containing radioactive waste exploded at the Department of Energy (DOE) Waste Isolation Pilot Plant (WIPP) resulting in the release of americium and plutonium into the environment.  In our May 3, 2014 review of the DOE’s phase 1 accident report, a weak safety culture (SC) was deemed a significant contributing factor to the incident.  The plant has yet to resume normal operations.

Over the last two years, DOE and Nuclear Waste Partnership (NWP, the prime contractor) have made efforts to strengthen the SC at the WIPP.  Following are two data points we can use to infer how much progress they’ve made.

Incentive Payment to NWP

In FY2015 NWP earned a performance fee* based on both objective and subjective criteria.  Overall, NWP received 85.7% of the total potential fee ($11,714K out of $13,665K.)
 
The objective portion comprised 75% of the total potential fee and NWP was awarded 89.7% of that amount ($9,194K).  Only one objective criterion appears related to SC, viz., “reducing preventive and corrective maintenance backlogs” and NWP received the full fee possible, $550K out of $550K.

The subjective portion comprised 25% of the total potential fee and NWP was awarded 73.7% of that amount ($2,520K).  There is more information about SC in this portion of the award fee determination document.  DOE said NWP’s performance on improving its safety programs reflected “a maturing nuclear safety culture with continuous improvements.”  However, there were signs of SC weakness in the Areas for Improvement including “The contractor did not provide sufficient objective evidence of closure of all of the corrective actions it submitted as complete in FY2015”; “The small number of self-assessments by the contractor in FY2015 was inadequate to measure performance” and “Recent improvements in the nuclear safety culture are slowly being realized in the safe execution of work . . .”

DNFSB Critique of WIPP's Upgraded Documented Safety Analysis 

A recent Defense Nuclear Facilities Safety Board (DNFSB) staff report** reviews the WIPP Documented Safety Analysis (DSA) currently being updated by NWP under the oversight of DOE.  The DNFSB report identifies one significant issue for DOE management attention, summarized below:

The Feb. 2014 explosion occurred because Los Alamos National Laboratory (LANL) shipped ignitable waste to WIPP even though the existing Waste Acceptance Criteria (WAC) prohibited such action.  Currently, other LANL-generated drums containing potentially ignitable waste are securely stored at WIPP.

The draft DSA does not analyze the possibility that some similar accident could occur involving a container arriving at WIPP in the future.  Instead, DOE and NWP argue that improvements to the WIPP WAC and/or WAC compliance program will reliably prevent problems in future waste receipts.  In other words, something that happened before will not happen again because WIPP will be watching for it.  For this approach to work, WAC compliance by the waste generators and WIPP inspectors must be completely effective and 100% reliable.  DNFSB recommends that DOE and NWP management “explore defense-in-depth measures that enhance WIPP’s capability to detect and respond to problems caused by unexpected failures in the WAC compliance program.”

Our Perspective

The performance fee awards indicate that NWP needs to keep working to strengthen its SC to an acceptable level.

The DSA issue is more troublesome.  What kind of effective SC would blow off (pun intended) its responsibility to consider the possibility of recurrence of exactly the kind of problem that occurred before and caused the WIPP to be shut down for over two years?  We criticize other organizations for over-analyzing the specifics of individual accidents while ignoring other possibilities, especially systemic issues, but in this case, NWP and DOE are not even reaching the lowest perceptible bar of repeat incident prevention.

We’ll give the DNFSB points for raising the DSA issue but take away some points because they didn’t make a straightforward recommendation that NWP and DOE complete a more thorough analysis of the specific hazard of another drum of prohibited waste slipping through the system and into the underground.

At best, we can say the SC at the WIPP is incrementally improved.  DOE has always taken a half-hearted approach to SC and their lack of commitment is visible here.


*  T. Shrader (DOE) to P. Breidenbach (NWP), "Contract DE-EM0001971 Nuclear Waste Partnership LLC - Award Fee Determination for the Period October 1, 2014 through September 30, 2015, and FY2015 Fee Determination Scorecard for Total Earned Award Fee and Performance Based Incentives" (April 12, 2016).

**  J.L. Connery (DNFSB) to E.J. Moniz (DOE), letter with DNFSB Staff Issue Report “Waste Isolation Pilot Plant Documented Safety Analysis” dated Jan. 13, 2016 attached (Mar. 28, 2016).

DOE Inspector General Piles On: Bechtel CAP and DOE Oversight Deficient at the Vit Plant

The Department of Energy (DOE) Inspector General (IG) recently released an audit report* on deficiencies in Bechtel’s Corrective Action Program (CAP) at the Hanford Waste Treatment Plant (WTP aka the Vit Plant) where Bechtel is the prime contractor.  The report also described deficiencies in the DOE Office of River Protection’s (ORP) oversight of Bechtel.

With one exception, this IG report is not about safety culture (SC) per se, but it does discuss two key artifacts that reflect the strength of a SC: the effectiveness of the CAP and the size of backlogs.**

The audit found that the Bechtel CAP “was not fully effective in managing and resolving issues.”  Specifically, some required issues were not managed and tracked in the CAP, corrective actions were not implemented in a timely manner (Bechtel did not make any of its timeliness goals) and Bechtel failed to follow through on implementing or sustaining prior CAP improvement initiatives. (pp. 1-2, 5)

The findings were not news to the ORP.  In fact, they are consistent with ORP’s 2013 audit of Bechtel’s Quality Assurance program.  At that time ORP directed Bechtel to make CAP improvements but as of the current IG audit, such improvements had not been fully implemented. (p. 2) 

CAP backlogs are also a problem.  Backlogs of condition reports increased from 2013 to 2014, as did the age of corrective actions. (pp. 4-5)

The audit report does have one direct tie to SC, noting that Bechtel identified weaknesses in its SC in 2014, including concerns about management not valuing a rigorous CAP. (p. 6)

And the auditors didn’t let ORP off the hook, stating DOE “did not ensure that all technical issues and issues identified through self-assessments were entered into the [CAP].  Finally, [DOE] did not ensure that previous Bechtel initiatives to address [DOE] implementation problems were fully implemented or sustained.” (p. 6)

The report closed with three straightforward “fix-it” recommendations with which ORP management concurred.  In their concurrence letter, ORP reviews the actions taken to date and concludes “Bechtel has strengthened the WTP Project’s nuclear safety and quality culture.” (p. 11)

Our Perspective

The report does not inspire confidence that Bechtel can upgrade its CAP (while trying to move ahead with Vit Plant design and construction) or ORP will ride herd on them to ensure it happens.  In fact, the report is consistent with a bevy of earlier assessments and evaluations, many of which we have reviewed on Safetymatters.  (Click on the Vit Plant label for more details.)  ORP’s assertion that Bechtel has strengthened its culture is possibly true, but they began from an unacceptably low starting point.

Early in my career I was hired as a Quality Control manager for a telecom manufacturer.  The company had major problems with its flagship product and I was soon named to a task force to investigate them.  On my way to our initial meeting, I met up with a more senior employee and told him how I looked forward to our task force identifying and fixing the product’s problems.  He turned to me and said “The first three didn’t.”  Welcome to the world.


*  U.S. DOE Inspector General, “Audit Report - Corrective Action Program at the Waste Treatment and Immobilization Plant,” OAI-M-16-06 (Feb. 2016).

**  As we have discussed elsewhere, two other key artifacts are decision-making and compensation.  From the WTP history we have reviewed for Safetymatters, it appears Bechtel (and by extension, DOE) decision-making does not effectively address either the tough technical challenges or programmatic issues at the WTP.  The Bechtel contract now includes some modest incentive compensation for SC performance.  We discussed that program on Dec. 29, 2014.

DNFSB Hearing on Safety Culture Progress at the Waste Treatment and Immobilization Plant (WTP)

The WTP aka the Vit Plant

On August 26, 2015 the Defense Nuclear Facilities Safety Board (DNFSB) held a hearing in the Hanford area to receive testimony from senior DOE officials representing DOE Headquarters, the Office of River Protection (ORP) and the WTP project regarding the current status of DOE efforts to improve safety culture (SC) at the WTP.  A senior DNFSB staff member also testified on DOE’s SC improvement efforts.

There is a video of the meeting but no transcript is yet available.* 

The panel of DOE managers enumerated the work that has been undertaken to improve SC at the WTP.**  Based on their written submittals, it is predictable and not especially interesting material.  Selected excerpts follow:

G. Podonsky (DOE HQ) – “. . . positive turn in the safety culture.  However, much work remains . . . . As our assessments of safety culture indicate, management often has a more positive outlook on the state of the safety culture than do the workers.”

K. Smith (ORP Mgr) – This is mostly a laundry list of actions, initiatives and putative progress.  “. . . ORP’s safety culture today . . .  is improving and headed in the right direction. . . . But there are areas that still need work . . .”

W.F. Hamel Jr. (Federal Project Director WTP) – This focuses on more specific, project-level actions.  “We believe we have made significant strides. . . . sustaining a healthy safety culture requires persistence and consistency at all levels of the organization . . .”  He gave a shout out to Bechtel for progress in improving their SC and the Safety Conscious Work Environment (SCWE).

After the panel completed their presentation, the DNFSB staff member responsible for overseeing WTP (and other DOE) SC efforts had ten minutes to provide the staff perspective on DOE’s efforts.  He summarized the SC assessments that have taken place at the WTP and other facilities in the DOE complex.***  His testimony had more “howevers” than a Consumer Reports review of a mediocre automobile.  For example, DOE’s original plan was developed prior to the 2012 SC assessment and did not include the latter’s findings.  DOE modified their plan for Hanford but it was not applied to other DOE facilities.  The DOE themes did not address the root causes the DNFSB identified in their 2011 Recommendation.  He was also critical of the DOE’s extent of condition review.

He was asked one question by the meeting chair: “Is the bad (i.e., not supportive of SC) management behavior identified in 2011 still occurring?”  The answer was “It’s mixed. Some yes and some no.”  The chair was clearly not happy with that answer after four years of effort.

Our Perspective

The DOE bureaucrats identified a passel of SC-related improvement activities and claim progress is being made but there is still work to accomplish.  The testimony of the DNFSB staffer was less optimistic.  A statement contributed for the record by an anonymous “concerned engineer” includes examples that look like they came straight from the bad old days.****  We have reviewed most the DOE/WTP assessments, action plans and progress reviews on Safetymatters; click on the DOE or WTP label to see related posts.  Call us harsh, but we don’t believe there will be any substantive changes in the way business is conducted at Hanford until the bad stuff starts leaching into the Columbia River.

On a slightly brighter note, the DNFSB is back to full strength with five members, including a new chairman.  From looking at the press releases, it appears they have added folks with federal/military backgrounds and middling technical exposure.  The new chair is a career technical functionary whose last stint was at the White House.  It’s hard to get All-Stars for a toothless agency.  What they can contribute to oversight of DOE remains to be seen.  We wish them well.


*  The video is here.  Testimony and statements are available here but most are scanned copies which means quotes have to be retyped and may not totally accurate.  For an overview of the meeting see A. Cary, "National board hears safety culture is improving at Hanford vit plant," Tri-City Herald (Aug. 26, 2015).

**  Statement for the Record and Additional Information of G. Podonsky, Office of Enterprise Assessments (Aug. 26, 2015).  Testimony of K. Smith, Manager, Office of River Protection (Aug. 26, 2015).  Testimony of W.F. Hamel Jr., Federal Project Director, Waste Treatment and Immobilization Plant (Aug. 26, 2015).

***  Testimony of D.B. Bullen, Group Lead, Nuclear Programs and Analysis, DNFSB.  The question and answer are not verbatim but paraphrased from the exchange between Bullen and the chair that occurs from about 1:52 to 1:55 in the video.

****  Statement from concerned engineer (Aug. 26, 2015).

New Safety Culture Assessment at the Hanford Waste Treatment Plant

Hanford WTP

The Department of Energy (DOE) recently released the latest safety culture (SC) assessment report* for the Hanford Waste Treatment Plant (WTP or “vit plant”) project.  The 2015 report follows similar SC assessments conducted in 2011 and 2014, all of which were inspired by the Defense Nuclear Facilities Safety Board’s scathing 2011 report on SC at the WTP.  This post provides a brief overview of the report’s findings then focuses on the critical success factors for a healthy SC.

Assessment Overview

The 2011, 2014 and 2015 assessments used the same methodology, with multiple data collection methods, including interviews, Behavioral Anchored Rating Scales (BARS)** and a SC survey.  Following are selected highlights from the 2015 report.

DOE’s Office of River Protection (ORP) has management responsibility for the WTP project.  In general, ORP personnel feel more positive about the organization’s SC than they did during the 2014 assessment.  Feelings of confusion about ORP’s more collaborative relationship with Bechtel (the prime contractor) have lessened.  ORP management is perceived to be more open to constructive criticism.  Concerns remain with lack of transparency, trust issues and the effectiveness of the problem resolution process.

Bechtel personnel were more positive than in either previous SC assessment.  Bechtel has undertaken many SC-related initiatives including the promotion of a shared mental model of the project by senior Bechtel managers.  In 2014, Bechtel Corporate’s role in project decision making was perceived to skew against SC concerns.  The creation of a new Bechtel nuclear business unit has highlighted the special needs of nuclear work. (pp. 2, 39)  On the negative side, craft workers remain somewhat suspicious and wary of soft retributions, e.g., being blamed for their own industrial mishaps or having their promotion or layoff chances affected by reporting safety issues.

See this newspaper article*** for additional details on the report’s findings. 

Critical Success Factors for a Healthy SC

We always look at the following areas for evidence of SC strength or weakness: management’s decision making process, recognition and handling of goal conflicts, the corrective action program and financial incentives.

Decision Making

Both ORP and Bechtel interviewees complained of a lack of basis or rationale for different types of decisions. (pp. 9, 16)  Some ORP and Bechtel interviewees did note that efforts to clarify decision making are in process. (pp. 13, 32)  Although the need to explain the basis for decisions was recognized, there was no discussion of the decision making process itself.  This is especially disappointing because decision making is one of the possible behaviors that can be included in a BARS analysis, but was not chosen for this assessment.

Goal Conflicts

Conflicts among cost, schedule and safety goals did not rise to the level of a reportable problem.  ORP interviewees reported that cost and schedule do not conflict with safety in their individual work. (p. 6)  Most Bechtel interviewees do not perceive schedule pressures to be the determining factor while completing various tasks. (p. 23)  Overall, this is satisfactory performance.

Corrective Action Program

We believe how well an organization recognizes and permanently resolves its problems is important.  Problem Identification and Resolution was one of the traits evaluated in the assessment.  ORP interviewees said that current safety concerns are being addressed.  The historical lack of management feedback on problem resolution is still a disincentive for reporting problems. (pp. 8-9)  Some Bechtel interviewees said “issue resolution with management engagement was the single most positive improvement in problem resolution, . . .” (p. 24)  This performance is minimally acceptable but needs ongoing attention.

Financial Incentives

DOE’s contract with Bechtel now includes incentives for Bechtel if it self-identifies problems (rather than waiting for DOE or some other party to identify them).  ORP believes the incentives are a positive influence on contractor performance. (p. 8)  Bechtel interviewees also believe the new contract has had a positive impact on the project.  However, Bechtel has a goal to reduce legacy issues and some believe the contract’s emphasis on new issues distracts from addressing legacy problems. (pp. 24-25)  The assessment had no discussion of either ORP or Bechtel senior management financial incentives.  The new contract conditions are good; ignoring senior management incentives is unacceptable.

Safety Conscious Work Environment (SCWE)

We usually don’t pay much attention to SCWE at nuclear power plants because it is part of the larger cultural milieu.  But SCWE has been a long-standing issue at various DOE facilities, as well as the impetus for the series of WTP SC assessments, so we’ll look at a few highlights from the SC survey data.

For ORP, mean responses to five of the six SCWE questions were higher (better) in 2015 vs 2014, and 2014 vs 2011.  However, for one question “Concerns raised are addressed” the mean is lower (worse) in 2015 vs 2014, and significantly lower in 2015 vs 2011.  This may indicate an issue with problem resolution. (p. B-2) 

For Bechtel, mean responses to all six SCWE questions were significantly higher (better) in 2015 vs 2014.  However, the 2011 data were not included so we cannot make any inference about possible longer-term trends. (p. B-5)  What is shown is good news because it appears people feel freer to raise safety concerns.  Interestingly, Bechtel’s mean 2015 responses were 5-13% higher (better) than ORP’s for all questions.

Both ORP and Bechtel are showing acceptable performance but continued improvement efforts are warranted.

Our Perspective

The Executive Summary and Conclusions suggest ORP and especially Bechtel have turned the corner since 2014. (pp. v, 37)  This is arguably true for SCWE but we’d say the jury is still out on improvement in the broader SC, based on our look at the BARS data.

For ORP, the BARS data mean scores are higher for 4 (out of 10) behaviors in 2015 vs 2014, but only higher for 1 behavior in 2015 vs 2011. (p. B-1)  The least charitable interpretation is ORP’s view of itself has not yet re-achieved 2011 levels.  For Bechtel the BARS data shows a bit brighter picture.  Mean scores are higher for 6 (out of 10) behaviors in 2015 vs 2014, and higher for 4 behaviors for 2015 vs 2011. (p. B-4)

The format of the report is probably intended to be reader-friendly but it mixes qualitative interview data and selected quantitative data from BARS and the survey.  The use of modifiers like “many” and “some” creates a sense of relative frequency or importance but no real specificity.  It’s impossible to say how much (if any) cherry picking of the interview data occurred.****

We also wonder about the evaluation team’s level of independence and optimism.  This is the first time DOE has performed a WTP SC assessment without the extensive use of outside consultants.  Put bluntly, how independent was the team’s effort given DOE Headquarters’ desire to see improvements at WTP?  And it’s not just HQ; DOE is under the gun from Congress, the DNFSB, the Government Accountability Office, and environmental activists and regulators to clean up their act at Hanford.

We want to see a stronger SC at Hanford but we’ll go with Ronald Reagan on this report: “Trust, but verify.”


*  DOE Office of Enterprise Assessments, “Follow-up Assessment of Safety Culture at the Hanford Site Waste Treatment and Immobilization Plant” (June, 2015).  We have followed the WTP saga for years; please click on the Vit Plant label to see our related posts.

**  Behavioral Anchored Rating Scales (BARS) quantitatively summarize interviewees’ perceptions of their organization using specific examples of good, moderate, and poor performance.   There are 17 possible organizational behaviors in a BARS analysis, but only 10 were used in this assessment:  Attention to Safety, Coordination of Work, Formalization, Interdepartmental Communication, Organizational Learning, Performance Quality, Problem Identification and Resolution, Resource Allocation, Roles and Responsibilities and Time Urgency. (p. C-2)

***  A. Cary, “DOE: Hanford vit plant safety culture shows improvement,” Tri-City Herald (June 26, 2015).

****  The report also includes multiple references to the two organizations’ behavioral norms that were inferred from the survey data.  It’s not exactly consultant mumbo-jumbo but it’s too complicated to attempt to explain in this space.

More Evidence of Weak Safety Culture in DOE

DNFSB Headquarters

We have posted many times about safety culture (SC) issues in the Department of Energy (DOE) empire.  Many of those issues have been raised by the Defense Nuclear Facilities Safety Board (DNFSB), an overseer of DOE activities.  Following is a recent example based on a DNFSB staff report.*

The Radcalc Imbroglio

Radcalc is a computer program used across the DOE complex (and beyond) to determine the transportation package classification for radioactive materials, including radioactive waste, based on the isotopic content.  Radcalc errors could lead to serious consequences, e.g., exposure to radiation or explosions, in the event of a transportation accident.  DOE classified Radcalc as safety software and assigned it the second highest level of rigor in DOE’s software quality assurance (SQA) procedures.

A DNFSB audit found multiple deficiencies with respect to Radcalc, most prominently DOE’s inability to provide any evidence of federal oversight of Radcalc during the software's lifetime (which dates back to the mid-1990s).  In addition, there was no evidence DOE contractors had any Radcalc-related QA plans or programs, or maintained software configuration management.  Neither DOE nor the contractors effectively used their corrective action program to identify and correct software problems.  DNFSB identified other problems but you get the idea.

DNFSB Analysis

As part of its analysis of problems and causes, the DNFSB identified multiple contributing factors including the following related to organization.  “There is an apparent lack of a systematic, structured, and documented approach to determine which organization within DOE is responsible to perform QA audits of contractor organizations.  During the review, different organizations within DOE stated that they thought another organization was responsible for performing Radcalc contractor QA audits.  DOE procedures do not clearly delineate which organization is responsible for QA/SQA audits and assessments.” (Report, p. 4)

Later, the report says “In addition, this review identified potentially significant systemic [emphasis added] concerns that could affect other safety software. These are: inadequate QA/SQA requirement specification in DOE contracts and the lack of policy identifying the DOE organizations in charge of performing QA assessments to ensure compliance; unqualified and/or inadequate numbers of qualified federal personnel to oversee contract work; . . . and additional instances of inadequate oversight of computer work within DOE (e.g., Radtran).” (Report, p. 5)

Our Perspective

Even without the DNFSB pointing out “systemic” concerns, this report practically shouts the question “What kind of SC would let this happen?”  We are talking about a large group of organizations where a significant, safety-related activity failed to take place and the primary reason (excuse) is “Not my group’s job.”  And no one took on the task to determine whose job it was.  This underlying cultural attitude could be as significant as the highly publicized SC problems at individual DOE facilities, e.g., the Hanford Waste Treatment Plant or the Waste Isolation Pilot Plant.

The DNFSB asked DOE to respond to the report within 90 days.  What will such a report say?  Let’s go out on a limb here and predict the report will call for “improved procedures, training and oversight.”  The probability of anyone facing discipline over this lapse: zero.  The probability of DOE investigating its own and/or contractor cultures for a possible systemic weakness: also zero.  Why?  Because there’s no money in it for DOE or the contractors and the DNFSB doesn’t have the organizational or moral authority to force it to happen.

We’ve always championed the DNFSB as the good guys, trying to do the right thing with few resources.  But the sad reality is they are a largely invisible backroom bureaucracy.  When a refinery catches fire, the Chemical Safety Board is front and center explaining what happened and what they’ll recommend to keep it from happening again.  When was the last time you saw the DNFSB on the news or testifying before Congress?  Their former chairman retired suddenly late last year, with zero fanfare; we think it’s highly likely the SC initiative he championed and attempted to promulgate throughout DOE went out the door with him.


*  J.H. Roberson (DNFSB) to D.M. Klaus (DOE), letter (Mar. 16, 2015) with enclosed Staff Issue Report “Review of Federal Oversight of Software Quality Assurance for Radcalc” (Dec. 17, 2014).  Thanks to Bill Mullins for bringing this document to our attention.

Safety Culture at the 2015 NRC Regulatory Information Conference

NRC Public Meeting

The Nuclear Regulatory Commission (NRC) held its annual Regulatory Information Conference (RIC) on March 10-12, 2015.  As usual, safety culture (SC) played a minor supporting role: it was the topic of one technical session out of 37 total.  The SC session focused on assessing and/or measuring SC.  It featured a range of presentations—from NRC, Duke Energy, DOE and a SC consultant—which are summarized below.*

NRC

This presentation consisted of one (sic) slide recounting the NRC’s SC outreach program during the past year including the Trait Talk brochures, SC case studies and meetings with other nuclear regulatory bodies.

Duke Energy

The presenter provided a list of internal (CAP, Employee Concerns Program )and external (INPO, NRC) information, and management activities (Nuclear SC Monitoring Panel, Site Leadership team, Corporate Nuclear SC Monitoring Panel, Fleet Nuclear SC Monitoring Panel, Executive Nuclear Safety Council) that are used to assess equipment, processes and people across the Duke fleet.  There was no information on how these activities are integrated to describe plant or fleet SC, or if any SC issues have been identified or corrective actions taken; the slides were basically a laundry list.

Department of Energy (DOE)

The speaker was from DOE’s Office of Environment, Health, Safety and Security.  He reviewed the safety mission and goals related to DOE’s Integrated Safety Management program, DOE’s SC focus areas (leadership, employee/worker engagement and organizational learning) and SC-related activities (extent of condition reviews, self‐assessments, sustainment plans, independent assessments and the SC Improvement Panel.) 

The presentation covered the challenges in relating SC to safety management performance (mostly industrial safety metrics) and in implementing cultural changes.  Factors that make SC improvement difficult include production vs. safety goal conflict, fiscal pressures, leadership changes and internal inertia (resistance to change).

This presentation covered the basics of SC, as customized for DOE, but had no supporting details or any mention of the SC issues that have arisen at various DOE facilities, e.g., Hanford, Pantex and the Waste Isolation Pilot Plant.  We have posted many times on DOE SC; please click on the DOE label to retrieve these posts.

SC Consultant

The presenter was Sonja Haber.  She reviewed the fundamentals of the linkage between culture, behavior and ultimate performance, and the Schein three-level model of culture.

She also covered the major considerations for conducting SC assessments including having a diversity of expertise in assessing culture, using multiple methods of data collection, understanding how cultural complexity impacts performance and considering the interaction of human, organizational and technological factors.

Our Perspective

This was thin gruel compared to the 2014 RIC SC session (which we reviewed April 25, 2014).  Based on the slides, there was not much “there” there at this session.  The speaker who offered the most was Dr. Haber, not a surprise given that she has been involved in SC evaluations at various DOE facilities and testified at a Defense Nuclear Facilities Safety Board hearing on SC (which we reviewed June 9, 2014).

If a webcast of the SC technical session becomes available, we will review it to see if any useful additional information was presented or arose during the discussion.


*  The SC technical session presentations are available on the NRC website.

Congressional Panel Slices and Dices Culture in Report on DOE/NNSA

A U.S. congressional panel recently released a report* detailing its recommendations for improving the performance of the National Nuclear Security Administration (NNSA).  NNSA is an agency within the Department of Energy responsible for maintaining the U.S. nuclear weapons stockpile, reducing danger from weapons of mass destruction, providing the Navy with nuclear propulsion, and responding to nuclear and radiological emergencies.**

The panel’s report has a host of recommendations and action items for making NNSA more effective, including changing the agency’s management culture to be more mission performance oriented.  The report’s key points would fit on one page but of course they aren’t presented that way; this is a 188 page government report with a 16 page executive summary.

What caught our eye was how many different types of culture were mentioned in the report.  While the report’s focus was putatively on management culture, the authors also referred to DOE, civilian, enterprise, risk management, risk aversion, safety, entitlement, non-inclusion, governance, corporate, compliance, security, professional, organizational, reliability and generic “culture.”  I am not making this up.

With so many types of culture, one might think there must have been a significant effort to define culture.  Well, no.  I saw only one definition of culture: “A common definition of management culture is, “This is how things are done here.”” (p. 39)  Could they have done better?  You be the judge.

Lots of insight into culture?  Not really.  I saw one systemic observation about culture: “In a healthy organization, management practices and culture are mutually reinforcing in creating productive behaviors: management practices shape the culture; the culture shapes behaviors and reinforces the management practices.” (ibid.)  We’ll award E for Effort here because this can be true although not always.

So it’s culture this and culture that but it’s left as an exercise for the reader to determine what exactly culture is and how the various sub-cultures contribute to an understanding of the larger picture.

Our Perspective

Every member of the panel has an opinion of what organizational culture is.  However, without a precise definition and a representation of how culture relates to other organizational factors (including hard ones like practices and soft ones like leadership and trust) there is no shared mental model.  And without that, there is no clear appreciation of how their proposed interventions might leverage (or antagonize) the existing culture or even work at all.  This lack of effort on culture is especially disappointing given that one member of the panel was the NRC Chairman back when that agency was agonizing endlessly over the proper definition of safety culture.

But let’s look at the larger reality here.  Most people (myself included) will never take the time to wade through a report like this and that’s probably the way the serious stakeholders (DOD, DOE and their contractors) want it; they are willing to play along with Congress rearranging the lounge car chairs as long as the money train keeps running.


*  Congressional Advisory Panel on the Governance of the Nuclear Security Enterprise, “A New Foundation for the Nuclear Enterprise” (Dec. 2014).  Thanks to Bill Mullins for recommending this report. 

**  National Nuclear Security Administration website.

Financial Incentives to Promote Safety Culture at the Vit Plant

The Vit Plant

We have reported on safety culture (SC) issues at the Hanford Waste Treatment Plant (WTP, or “vit plant”) for years.  Some of these issues arose in the Department of Energy (DOE) organization at Hanford; other issues became evident at Bechtel, DOE’s prime contractor at Hanford.  But this post focuses on a bit of good news: recent Bechtel contracts have included financial incentives for good performance related to establishing and maintaining a strong SC.*

The incentives are very small potatoes in the overall scheme of things.  The WTP is an $11 billion plus project (so far); the semi-annual SC incentives have been in the $1-5 million range.  But it is the correct signal for the government to be sending to a contractor.  It’s also interesting how the incentives have been fiddled with during their brief existence, as shown in the following table.  To keep things simple, the table excludes incentive program components that are not related to SC, e.g., cost performance incentives.  Note that the dollar amounts shown are the maximum Bechtel can earn; published payouts to date have been less than the maximums.

From July 1, 2012 to June 30, 2013 the contract included a project management incentive (PMI) component.  Nuclear Safety and Quality Culture items (the Corrective Action Program, Employee Concerns Program, Differing Professional Opinion process, Safety Conscious Work Environment (SCWE) and Integrated Safety Management Systems) were 20-30% of the PMI.

Starting July 1, 2013 and continuing to the present a section was added to the incentive plan covering Self-Analysis/Assessment/Discovery/Action.  This basically means Bechtel will be rewarded for identifying and fixing its problems before outsiders tell them to.  The contract does not characterize this activity as part of SC but we do; fixing problems is an essential artifact of a strong SC.  In addition, the attributes under this section, including transparency and organizational learning, are also attributes of a strong SC.  Another new section on Environmental, Safety and Health is mostly about industrial safety but includes promoting a robust NSQC embracing INPO principles, including a SCWE.  The section on the Quality Assurance program includes supporting an effective CAP and, starting July 1, 2014, maintaining a robust quality culture.

Start	End	Project Management Incentive (PMI)	Nuclear Safety and Quality Culture (NSQC)
7/1/2012	12/31/2012	$3,150,000	$945,000	30% of PMI: NSQC inc. CAP, ECP, DPO, SCWE (25%), Integrated Safety Management Systems (5%)
1/1/2013	6/30/2013	$3,780,000	$756,000	20% of PMI: NSQC inc. CAP, ECP, DPO, SCWE (15%), Integrated Safety Management Systems (5%)
		Self-Analysis/ Assessment/ Discovery/Action	Environmental, Safety & Health	QA Program
7/1/2013	12/31/2013	$3,500,000	$1,000,000	$800,000
1/1/2014	6/30/2014	$3,500,000	$1,000,000	$800,000
7/1/2014	12/31/2014	$1,260,000	$1,260,000	$1,260,000

Our Perspective

For starters, let’s give credit where credit is due: Huzzah to DOE and Bechtel.  For a long time, we have been saying that organizational reward systems should include SC components.  Safety slogans and empty mantras are just that—empty.  If a government agency, or a nuclear plant owner, or a board of directors, or any other overseer truly values SC then they should put some money where their mouths are.

Enough cheering, let’s put our reality hat back on.  Could Bechtel (or any other contractor) game the incentive system to get rewarded without actually creating a strong SC?  Possibly.  Who would you bet on: government bureaucrats or a clever, financially motivated contractor?  But an official incentive plan like the one described above is a good start.

Now that DOE has figured out how to design a contract that aims to motivate a contractor to strengthen its SC, let’s turn the spotlight back on DOE itself.  How does DOE do on transparency, extent of condition and other SC attributes?  Not so good.  Over the last few years we have been reporting on the DOE effort to evaluate SC at other (i.e., non-WTP) sites to determine if WTP SC issues exist elsewhere.  We saw foot-dragging, an unorganized SC assessment program and deliberate opacity in the resultant reports.  DOE can and should do better.

*  The WTP Performance Evaluation and Measurement Plans used in this post are available here.  For prior related posts click on the Vit Plant label below.