Statement
By
The Honorable Joseph F.
Bader
Member
Defense Nuclear
Facilities Safety Board
Presented
at the
Department of Energy's
13th Annual Facility
Representative Workshop
May 16, 2006
Knoxville Convention
Center
Knoxville, TN
Good morning. It is good to be here for a second year at the
Thirteenth Annual Facility Representative Workshop. I was very happy to hear Dr. Inés Triay (Chief Operating Officer for the
Department of Energy (DOE) Office of Environmental Management and Keynote Speaker)
talk about one of my favorite subjects, MBWA or “Management By Walking Around,”
because it represents a clear indicator of senior field managers’ attention to
facility safety.
The Facility Representative Program
continues to be the “point of the spear” for safety and technical competence. I would like once again to extend my
compliments to Mark Whitaker, John Evans, and the others who help make this
forum possible. Right behind MBWA in importance
is the gathering of people like this to share their experiences from the field.
Let me first give sincere congratulations
to the 2006 Facility Representative of the Year, Mr. Dary
Newbry from the Idaho Operations Office. This is an honor and recognition among your
peers of your outstanding accomplishments out in the field! Well done! I saw Dary in action
out in Idaho in the Pu-238 Fuel Facility during one of my recent trips. Beth Sellers (DOE Idaho Operations Office
Manager) should be very proud with two winners in a row of the Facility Representative
of the Year.
About two years ago, the Defense Nuclear
Facilities Safety Board (Board) highlighted areas that warranted strengthening
in the Facility Representative Program, primarily a better evaluation of
Facility Representative staffing levels at the sites, and continuing training
directed at changing facility or activity conditions. Since the issuance of the Board’s letter, John
Evans and his team have done a good job in revising the Facility Representative
Program Standard and have addressed the bulk of the Board’s concerns. This is particularly true in determining appropriate
staffing levels and having rigorous continuing training. Now, you need to implement the standard
effectively at the sites. One area, in
particular, needs your attention and that is the aggressive hiring to fill
vacant Facility Representative positions to get to
staffing levels that site offices have determined are needed. The main source of Facility Representatives
should be technically capable personnel from within DOE and from relevant
external sources, such as Navy nuclear trained personnel, NRC inspectors, or
naval shipyard personnel. The DOE
Technical Intern programs, such as the National Nuclear Security Administration
(NNSA) Future Leaders Program, can be an effective supplemental source of
candidates, if the proper training, education, and mentoring occur. Senior Facility Representatives should be
expected, as part of their duties, to be assigned new Facility Representative candidates to coach, challenge, and mold, that is, “show
them the ropes.”
DOE has been busy working on its oversight
responsibilities and practices in response to Board Recommendation 2004-1. Facility Representatives play a large role in
the DOE field element line management oversight processes, such as inspections,
reviews, surveillances, surveys, operational awareness, and walkthroughs. So you collectively are an important key to determining
if the contractor organization is accomplishing work in a safe manner. As I mentioned last year, your position of
oversight responsibility requires careful balancing and prioritization of your
primary responsibilities in order to maintain the primary intent of this key position
. . . being the “eyes and ears” for DOE
and providing that valuable operational awareness. However, we have observed that some Facility
Representatives are still spending too much time on collateral or special
project duties, thereby leaving some facilities without a critical look. The improved staffing analysis methodology
should help to identify any workload imbalances, or point to the need to
re-assign certain collateral duties to others, or to add another Facility Representative
to the site. This issue will continue to
require a concerted effort by you and your management to ensure the balance is
maintained. Also, when I go from site to
site, I ask, “how many Facility Representatives have
been promoted to senior positions?” I noted that there has been a good
promotion rate of Facility Representatives.
The Board continues to keep a wary eye on
oversight activities at DOE and NNSA. You may have heard Ambassador Brooks announce
that a 2-year pilot of NNSA’s oversight model will begin in the near future at
Los Alamos. The thrust of the pilot is
stated as encouraging the contractor to establish a strong contractor assurance
system and to allow NNSA to reduce its direct oversight. There are three points that I would like to
make concerning the pilot. First, Ambassador
Brooks has stated that this initiative “does not apply to nuclear operations
or, for that matter, to security.” Therefore,
it should have no impact on much of the work that Facility Representatives
perform “in nuclear facilities.” Second,
consistent with 10CFR830, we view nuclear operations to be not only Hazard
Category 2 and 3 facilities, but also radiological facilities. Third and an important point to understand, we
are strongly interested in key support facilities and activities, such as
emergency operations, power supply systems and fire protection, that are typically
shared between nuclear and non-nuclear facilities and operations, but which are
vital to supporting nuclear safety.
At the public meeting in Los Alamos on
March 22 of this year, we heard testimony from Ambassador Brooks and from Ed
Wilmot, the manager of the Los Alamos Site Office. They said that nuclear operations should, in
fact, be strengthened by the oversight pilot because resources would be freed
from non-nuclear oversight activities. We are watching intently the new oversight
model. We are interested in how it
actually performs. Again, don't just
tell me how good it is, show me.
Last year, I discussed some of my thoughts
on how a Facility Representative’s expertise could help in facility design and
construction. So in answer to Dr. Triay’s
question on whether the Facility Representatives should be plugged into the
Federal Project Director’s portfolio - I say absolutely! Facility designers, project directors, and
safety system oversight personnel need to have the Facility Representatives’ thorough
understanding of operations to design facilities to operate safely. As an example of this already occurring, Ted
Sherry has Jerry Lipsky (who was the Facility Representative of the Year at Los
Alamos Site Office three years ago) working at HEUMF (Highly Enriched Uranium
Materials Facility at Y-12). Projects,
including substantial refurbishments, need the experienced operational presence
of a Facility Representative on each Integrated Project Team. The Facility Representative’s experience is
unique in DOE and prepares you to bring knowledge of operations to the
development of newly designed facilities. In the commercial nuclear industry, getting
operational personnel in the design phase was critical. Such experience is critical to the success of
future design projects, in particular when reviewing design deliverables to
ensure that operational safety requirements are addressed. Only through a thorough understanding of
operations can effective engineered safety controls be incorporated into the design.
As I said last year and I’ll say it
again, the best way to design and build a facility which can be operated safely
is to design safety into it from the beginning. That is a mantra with the Board, and starting
to be a mantra with DOE, which is a good thing.
The operationally-oriented perspective of
DOE Facility Representatives should also play a major role in the oversight of
quality in nuclear facility construction. As DOE undertakes an increasing number of
large complex nuclear construction projects, there is an increasing need to ensure
that the requisite quality is rigorously constructed into these facilities. Proper design and construction relies on
personnel being trained in and adhering to established methods and procedures
of nuclear facility construction and on proper execution of quality
requirements and quality control inspections. However, the substantial skill base and
supplier base in the commercial nuclear industry do not exist as they did in
the past. Nuclear design and construction
experience is however painfully being gained at DOE sites. It will be a challenge for DOE to maintain
these skill bases and suppliers as the commercial nuclear industry revives.
Right now, Facility Representative roles, responsibilities, and qualifications are well-defined
for operating facilities. DOE should
explore and better define the Facility Representatives’ roles and any specific
training needed such as building codes, construction practices, concrete, new
industrial hazards, QA, welding, startup testing for design and construction. New facility projects such as the Waste
Treatment Plant at Hanford or the Highly Enriched Uranium Materials Facility at
Y-12, may serve as good case studies to review in helping to determine the role
and training needs for Facility Representatives in reviewing design deliverables
to ensure that operational safety requirements are addressed and in overseeing construction
of new facilities. I am not advocating
pulling Facility Representatives away from their assigned operating facilities,
nor should this type of job be a collateral duty. Instead, DOE needs to consider factoring into
your staffing analysis dedicated Facility Representative billets during the
planning phase for new facilities. It
will fall to personnel such as DOE Facility Representatives to perform as part
of the “demanding owner” function of DOE in establishing quality nuclear
construction through insisting that the quality requirements, procedures and practices
are maintained and improved upon.
As a whole, the Facility Representative
community continues to enjoy a well-deserved reputation for excellence. The challenge is not to become complacent with
this status but to strive to improve your technical capability in all
dimensions of your job. It is always
advisable to get more technical education and formal technical training such as
advanced technical degrees and professional certifications. The Board is in the same business of oversight
and 96% of our technical staff have advanced technical
degrees (the remaining 4%, which amounts to two technical staff members, are
enrolled in graduate degree programs). 21% of our technical staff have
PhDs. Opportunities to get advanced
technical degrees exist in several different venues (local universities to
online graduate degree programs), so take advantage of them. DOE is a highly technical organization,
involved in unique and hazardous work activities-many are a first-of-a-kind. You can and should continue to lead in
striving for technical excellence. The Board
encourages DOE to sustain the vigor of the current Facility Representative
Program and look for ways to transfer lessons learned to build technical
competence throughout the DOE workforce. One final note, the Facility Representatives serve as a good pool for future managers in the DOE Complex.
Thank you.