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8/3/2019 DLE Strategies for a Strong Quality Culture
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SBA 8(A) VETERAN OWNED SMALL BUSINESS MINORITY OWNED BUSINESSEstablishing a
StrongQualityCultureProven Strategies for Line Management and
Independent Oversight Organizations
WHITE PAPER
Corporate Office4634 SW Long Bay Drive
Palm City, FL 34990
(772)341-1093 - Phone
(866)271-5199 - Fax
rob.dle@dle-services.com
www.dle-services.com
Prepared:
September 1, 2011
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Introduction
Strategies for a Strong Quality Culture
This white paper is an introduction to a set of strategies for establishing a
strong Quality Culture at nuclear power plants and Department of Energy
(DOE) facilities. The strategies described herein were developed, used and
refined through trial and error over the past 20 years by the founder of DLE
Technical Services, a recognized industry subject matter expert in Nuclear
Assurance, Rob De La Espriella. Rob spent over 15 years implementing
QA Program requirements, developing advanced oversight strategies and
coaching line managers on the principles for a strong quality culture at
nuclear power plants, both as an inspector with the Nuclear RegulatoryCommission and as a Site Quality Manager. The resulting approach took
existing oversight organizations and transformed them into High Performing
Organizations (HPO). Robs oversight groups were praised by the Institute
of Nuclear Power Operations (INPO) in 2003 and 2005, and benchmarked
by many other oversight groups in the US.
In the next few sections well describe how to unlock the keys to
transforming your Quality Culture by using proven strategies that include
Deming Quality Principles, Juran Quality Control Principles, Balridge criteria
for high performing organizations and others industry standards of
excellence. The author added his own risk-informed, graded approach to
conducting oversight that makes the most effective use of oversight
resources, drives line ownership of quality and provides a significant cost-benefit to the company by creating a proactive organization that anticipates
and prevents issues, rather than documenting events after they took place.
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Quality Management Systems
The Evolution of QMS and Oversight in the Nuclear Industry
Quality Management Systems (QMS) include all of the programs,
processes and procedures that flow down from Quality Assurance
Program requirements in applicable regulations. It also includes additional
standards and expectations put in place by management to achieve a
desired level of performance and quality (the latter being driven by
customer expectations). Since World War II there have been many
advances in Quality Management Systems, driven by industry giants such
as Deming, Juran, Balridge and Ishikawa. They established methods to
help strengthen Quality Management Systems such as Total Quality
Management (TQM), Quality Circles, Quality Control Practices and High
Performing Organization Principles. In the past few decades TQM has
given way to Six Sigma and Lean Manufacturing.
In the commercial nuclear power industry, the Three Mile Island accident
triggered billions of dollars of improvements in programs, processes and
equipment and the establishment of the Institute of Nuclear Power
Operations (INPO) to self-police the industry. Since the accident in 1979,
nuclear industry processes and programs have evolved tremendously,
arguably surpassing most other heavily regulated industries. However, one
area has not evolved as rapidly as others: the Quality Culture and the
oversight provided by Quality Assurance (QA) organizations.
The Authors Footprint on QMS/Oversight
The author entered the nuclear industry in 1983 as a Navy nuclear
powered submarine officer. Since that time, the author has assessed
performance at over 20 nuclear plants and DOE facilities. One of the
common characteristics at the majority of sites was the lack of
understanding of Quality Program requirements by line management. In
addition, the Nuclear Assurance organizations (Audit groups, Quality
Control, Surveillance departments) were not operated in a manner that
resulted in adding significant value to the organization (far beyond meeting
regulatory requirements for having an independent oversight organization).
To this day, line managers frequently criticize their independent oversight
organizations for adding little value, for being historians (documenting
events after the fact) and circling bullet holes (pointing out the obvious).
In 1990, Florida Power & Light (FPL) became the first corporation outside of
Japan to win the Deming Prize, for outstanding Total Quality
Management (TQM) practices. The author was on that Deming team and
through extensive training and certifications as a Quality Improvement
Team Leader and Root Cause Instructor, he developed a greater
understanding of Quality at regulated nuclear power plants. In 1990 the
author became an Audit Team Leader and root cause analyst for the
Since the TMI
accident in 1979,
billions have been
spent on
improving the
commercial
nuclear industry
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oversight organization at FPL. In 1992 he began a four-year tour of duty at
the US Nuclear Regulatory Commission and was responsible for
conducting oversight at the Millstone Nuclear Plant in CT. While at theNRC, the author collected a TQM Award, several other performance
awards, a Meritorious Service Award nomination and was selected as a
Role Model for the NRC in 1995.
In 1996 the author returned to FPL and in three years rose from Audit
Team Leader to Independent Safety Engineering Group Supervisor to Audit
Supervisor to Site Quality Manager. As a key player in oversight
organizations for over 15 years, the strategies developed by the author
resulted in high performing oversight organizations that proactively
identified issues, drove performance improvements and dramatically
increased the value of the independent oversight organizations.
In 2003 and 2005, the Institute of Nuclear Power Operations (INPO) graded
the Quality Management System and oversight strategies the author put in
place at FPL as Strengths for overall effectiveness. Following the 2003
and 2005 INPO reports, many industry peers benchmarked the authors
oversight organization.
In 2005, the World Association of Nuclear Operators (WANO) enlisted the
author to participate in an assist visit to Slovenia at the Krsko Nuclear Plant
as a Nuclear Assurance expert from the US. Additionally, WANO
requested the author to coach and mentor a Quality Manager from South
Africa for six weeks in response to a request from Eskom to send their new
Quality Manager to one of the strongest Nuclear Assurance programs in
the US.
In 2007, the author (now the President of DLE Technical Services) wascontracted to bring these oversight strategies to the Department of
Energys (DOE) Quality organization at the Yucca Mountain Project (YMP).
After the 24 month Organizational Development engagement at the YMP,
the DOE formally recognized the author for a night and day difference in
performance in the oversight organizations, and for contributions towards
improving Nuclear Safety and Quality cultures at YMP.
In 2008, DLE Technical Services was contacted by Eskom to help establish
the Nuclear Assurance organization for the new construction of the first
ever Pebble Bed Modular Reactor project. (Unfortunately Eskom tabled
the project in late 2008 for economic reasons).
In 2009, after a national search, CH2M Hill offered the author the position
of Director of Nuclear Quality and Culture for the new construction of 10nuclear reactors in the United Arab Emirates, to establish the QMS for that
project (the author declined the offer).
In 2010, DLE Technical Services was contracted by Uranium Disposition
Services to evaluate the Quality Assurance Program for the new Depleted
Uranium Hexafluoride Conversion Facility in Paducah, KY.
In 2011, DLE Technical Services was contracted to develop a strategy for
diagnosing the QMS at Atomic Energy of Canada Limited (AECL).
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Strategies for Establishing a StrongQuality Culture
After decades of developing, implementing, assessing and overseeing
Quality Management Systems, the author has summarized some of the
more important strategies that he developed for strengthening an
organizations Quality Culture and establishing high performing
independent oversight organizations.
Adopt and standardize Principles for a Strong Quality Culture
Define managements commitment to Quality.
Define workers commitment to Quality.
Define the defense-in-depth approach to identify and correct
conditions adverse to quality.
Lay out expectations for line management ownership of quality.
Define the Quality Assurance organizations roles and responsibilities
for providing value-added quality.
Reinforce that improving quality can lower overall operating costs.
The principles must also be translated into a policy or procedure such
that management can be held accountable for the contents. The performance appraisal system must also evaluate line ownership
of quality.
Define the criteria for High Performing Quality Management Systems
Leadership
Customer Focus
Strategic Planning
Organizational Structure
Process Management and Control
Leader and Worker Development
Performance Management
Continuous Improvement
Strengthen Performance Improvement Processes
Corrective Action Programs
Human Performance and Error Prevention Programs
Operating Experience and Lessons Learned Programs
Root Cause & Apparent Cause Tools & Techniques
Change Management
Establish Top Management Support & Infrastructure for Quality
Management
must live up to its
commitment to
Quality in every
decision they
make
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Strategies for Establishing a StrongQuality Culture (Contd)
A. Establish a clear target for independent oversight resources:
Nuclear Safety
Equipment Reliability
Risk to Workers and Equipment
Regulatory Risk
B. Use a Risk-Informed Approach for QA Activities: Establish initial and
continuing training for oversight personnel on understanding the
components of RISK (in practical terms, rather than in Probabilistic
Risk Assessment terms), and how to use these practical risk concepts
in daily applications. For example:
1) Focus on critical tasks that impact error rates:
Work preparation
Work performance
Work feedback
2) Focus on critical programs, processes and procedures that
maintain a defense-in-depth for preventing events or mitigating
consequences of an event:
Engineered controls
Administrative controls
Oversight controls
3) Focus on critical programs and processes that affect nuclear
safety:
Conduct of Operations
Equipment Reliability Program
Design Control/Configuration Management
Programs and processes that maintain facilities and equipmentIntegrated Work Management Systems
Corrective and Preventive Maintenance
Corrosion Controls
Re-focus the Independent Oversight Organization
Oversight
organizations can
focus on Risk and
adding value
while meeting its
regulatory
requirements
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Strategies for Establishing a Strong
Quality Culture (Contd)
B. Use a Risk-Informed Approach for QA Activities: (Contd)
4) Focus on programs and processes that manage risk to workers:
Integrated Safety Management System (ISMS)
Human Performance and Error Prevention
Emergency Preparedness
Training and Qualifications
5) Focus on programs and processes that capture problems and
drive continuous improvement:
Corrective Action Program/Trending
Self-assessment Program
Operating Experience/Lessons Learned
Causal factors and root cause analysis tools
6) Focus on assessing the risk of multiple activities in the aggregate,
not just the risk for each individual activity.
7) Focus on assessing line managements capabilities of assessing
risk on a real time basis and implementing appropriate
countermeasures and management oversight.
8) Establish Routines that Focus on Risk: Establish planning and
scheduling strategies that place oversight personnel in the right
place at the right time, focused on the most valuable activities at
any given time:
Merge audits, assessments and inspections into a hybrid
approach that is flexible enough to follow the facility schedule,
and efficient enough to meet all oversight requirements without
duplication of effort.
Shape checklists and inspection plans to focus the various
oversight groups on the high risk activities at any given time,
avoiding oversight that does not have a specific purpose or goal.
With the proper
focus,
independent
oversight groups
add significant
value to the
facility
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Strategies for Establishing a Strong
Quality Culture (Contd)
C. Define and Implement Proactive Oversight: Establish guidelines for
management and oversight personnel to prevent rather than react to
events. Provide guidance on conducting oversight at the most optimal
time such that issues are identified before they can result in more
serious consequences (in the right place at the right time). For
example:
1) Establish plans for managing high-risk contributors to the sitesEquipment Reliability Index.
2) Establish oversight approach for high-risk logic ties on the site
schedule for outages and operations (Primavera 6 or equivalent)
and management of any changes to the logic.
3) During refueling outages, establish specific plans to oversee
maintenance and verify functionality for critical components whose
failure during the startup can result in extending the outage.
4) Continually evaluate line managements oversight of construction,
installation, operation and maintenance of safety-related
structures, systems and components, or any activities that could
jeopardize the equipments ability to perform its intended safety
functions.
D. Daily Use of Causal Analysis Tools: Personnel that routinely evaluate
problems or address Condition Reports must be trained to focus on
identifying and addressing underlying causes, rather than addressing
just the symptoms. However, experience has shown that the training
provided on causal analysis and problem solving tools and techniques
must be simple enough such that the techniques can be readily
learned and used on a routine basis (and without requiring forms,
computer software or manuals). The following small set of causal
analysis tools can help personnel analyze data and identify underlyingcauses for the vast majority of problems encountered:
Pareto Diagrams
Affinity Diagrams
Barrier Analysis
Cause and Effect Analysis
Fault Tree Analysis
Events and Causal Factors Charting
Place oversight
personnel in the
right place at the
right time
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Strategies for Establishing a StrongQuality Culture (Contd)
E. Strengthen Working Relationships Between Oversight and Line
Organizations: Strive to establish excellent working relationships
between line and oversight organizations. The value of working
together is the establishment of a defense-in-depth model where all
groups work together to identify and address problems.
F. Improve the Communication of Issues to Line Management: Independentoversight organizations must effectively characterize and communicate
issues in terms that can be readily understood and acted on by
management (e.g., highlighting the specific risk to equipment and
personnel, identifying the liabilities incurred by the organization,
identifying challenges to scope, schedule and cost, and listing the
positive gains or competitive advantages of any recommendations).
Merely stating the infraction or the gap to compliance is not enough to
elicit the appropriate response.
G. Expect QA to Help Drive Performance: The nuclear industry has
established a continuous improvement philosophy to prevent
complacency. Continuous improvement is crucial to the industry as
any events experienced by the weakest link in the nuclear fleet canresult in dramatic impact and significant cost to the rest. (i.e. TMI
accident, Browns Ferry fire, Davis-Besse reactor vessel head
degradation). QA organizations should be an integral part of
continuous improvement by focusing on issues that drive
improvements in nuclear safety and quality, not merely on compliance
with minimum standards. By identifying the gaps to excellence,
oversight will help the organization to continually improve performance.
By identifying
gaps toexcellence,
oversight will
help the
organization to
continually
improve
performance
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Benefits of Strong Quality Cultures
Prevent significant events from occurring through
improvements in Quality and Nuclear Safety cultures
and high performing oversight organizations.
Enhance the Quality values and beliefs that drive
behaviors in all employees in the company.
Continuously improve Quality Management System
programs and processes.
Provide a competitive advantage to the company by
realizing the cost-benefits of a strong QMS.
Summary
The strategies outlined in this white paper can be seamlessly integrated
into existing Quality Assurance programs such as 10CFR50 Appendix B,
NQA-1 and DOE Order 414.1c. They are applicable to organizations thatare responsible for the Quality Program, and can also be used by
regulatory oversight organizations such as the Nuclear Regulatory
Commission and the Department of Energy. At the heart of these strategies
is a value system where all employees understand that Quality is an integral
part ofcore business, and that there is a direct correlation between quality
and cost & profitability. Also, where all employees are focused on quality
and the prevention of events through the proactive identification and
resolution of underlying causes for conditions adverse to quality.
Lastly, the changes brought about by the transformation to a strong quality
culture are sustainable. But a great deal depends on emotionally
intelligent, transformational leaders within the organization, and the
message they send such that employees value and believe in the
competitive advantage of a strong Quality Program.
Ultimately, the transformation to a strong Quality Culture enhances the
companys ability to protect the health and safety of the public, as well as
provides the company with a strong competitive advantage driven by
quality improvements and reduced operating costs.
Call DLE
Technical
Services and let
us help you with
transforming your
Quality Culture!
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WHY DLE Technical Services?
Who We Are: DLE Technical Services is a full-service project managementcompany with expert organizational development strategies fordiagnosing and addressing latent organizational weaknesses.
Our Mission: Our mission is to assist our clients in gaining a competitive advantagethrough cost effective solutions that drive Breakthrough Performanceand Cultural Transformations.
Our Core Values: We focus on the clientWe are passionate about our workWe move with speed and flexibilityWe are creative and innovativeWe care about our employeesWe trust and respect our clients and each other
Our Vision: "DLE Technical Services and its subsidiaries will be regarded as the bestand most sought-after Project Managers and OrganizationalDevelopment experts in the federal procurement system.
Differentiators: What makes us unique is that we bring proven industry standards ofexcellence to bear on all our projects; Leadership, Customer Focus,Strategic Planning, Organizational Structure, Workforce & LeaderDevelopment, Process Management & Control, PerformanceManagement and Continuous Improvement.
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CompanyData
Company Name: DLE Technical Services, LLC
Principal: Rob De La Espriella
Contact Information: 4634 SW Long Bay DrivePalm City, FL 34990(772) 341-1093 Office(866) 271-5199 Faxwww.dle-services.com
Small Business Status: SBA 8(a) Small Disadvantaged BusinessVeteran Owned Small BusinessMinority Owned BusinessSize Standard