ML20017A086

NEI Presentation- Best Practice for Issue Escalation_012220

ML20017A086
Person / Time
Site:	Nuclear Energy Institute
Issue date:	01/17/2020
From:	David Gudger Exelon Corp, Nuclear Energy Institute
To:	Office of Nuclear Reactor Regulation
Govan T, 415-6197, NRR/DRO
References
Download: ML20017A086 (7)

Text

Best Practice for Issue Escalation Dave Gudger, Exelon NEI ROP Task Force January 22, 2020

Objective Establish and Communicate a formal step-wise escalation process seeking the common goal of issue resolution at the lowest level practical.

©2019 Nuclear Energy Institute 2

Issue Escalation Process

• Drives streamlined resolution of issues at the lowest level

• Resolution is based on objective information and sound regulatory principles.

• Parallel escalation: both sides agree on the need to escalate, as well as the salient points of concern

©2019 Nuclear Energy Institute 3

What does good look like?

Five Principles:

1. All parties agree when escalation becomes necessary

2. Due diligence, including all relevant facts, is applied at every step

3. Escalation occurs systematically one level at a time

4. Basis for final decision is fed back to all levels

5. Lessons learned are captured for organizational or process improvements

©2019 Nuclear Energy Institute 4

Recommended Approach

• DEFINE THE GAP: After all relevant information has been presented by all parties and a robust and candid dialogue occurs, all parties recognize specific points of disagreement and the escalation is warranted

• DOCUMENT AND ELEVATE: Using the recommended template and after an impartial assessment of the facts, each party elevates the issue internally (Template become the traveler for the issue)

• RESOLVE: Template is updated at each step of elevation to include new information or insights gained as well as any decisions

• CLOSE THE LOOP: Document and feed back the final decision, decision makers, and the basis for the decision

©2019 Nuclear Energy Institute 5

Desired Behaviors CURRENT COMMON BEHAVIORS: DESIRED BEHAVIORS:

• We believe we do not have a

• We dont agree with this finding common understanding and escalation may be warranted to increase how this issue is

• If the finding is included in the understood inspection debrief, we will be

• We believe this issue should be contesting escalated based on our remaining concern with these specific points

• The Site VP will be contacting the

• We recommend that you escalate Regional Administrator the issue to your management and explain where we disagree as we intend to do the same.

• Would you like to schedule a follow up with our managers or should we schedule?

©2018 Nuclear Energy Institute 6

Implementation NEI has provided the issue escalation process to licensees as a best practice Licensees are encouraged to compare their current approach to the best practice, and conform their approach to the best practice as much as practical NRC feedback to NEI or licensees is encouraged and welcome

©2019 Nuclear Energy Institute 7