Management Process and Programs Assessment
(MPPA)

Sample Approach
to a
Nuclear Facility
MANAGEMENT TOP-DOWN ASSESSMENT

Project and Facility Knowledge

Staff Recruitment, Qualifications, and Training

Management Control System

Performance of Management Processes and Programs

Operations Organization and Administration

Shift Routines and Operating Practices

Control Areas

Communications

Control of On-Shift Training

Investigation of Abnormal Events

Notifications

Control of Equipment and System Status

Lockouts and Tagouts

Independent Verification

Logkeeping

Operations Turnover

Chemistry and Unique Processes

Required Reading

Timely Orders to Operators

Operations Procedures

Operator Aid Postings

Equipment and Piping Labeling

Resource Allocations

Nuclear Safety Culture

2A. Do headquarters, field offices, and contractor personnel have adequate and current knowledge of the design, operation, material condition, and hazards of their nuclear facilities?

Line managers must have current and complete knowledge of the nuclear facilities for which they are responsible. Effective oversight and control of the nuclear safety aspects of facility operations cannot occur without management knowledge and understanding of facility designs, the hazards associated with their facilities, and the current operational status and material conditions. Question 2A derives from the basic principles enunciated in INSAG-3, as amplified by ASCOT, and by DOE 5480.23.

Line managers must be aware of facility design and operations, material conditions, and any hazards associated with operations of the facilities for which they are responsible. Although the extent of this knowledge is less detailed at successively higher levels of management, all levels need to know enough about their facilities to provide effective oversight. This facility knowledge can be ensured only with adequate documentation, including a Safety Analysis Report, Technical Safety Requirements, if appropriate, a facility hazards assessment, facility as-built drawings, and procedures governing facility operations. These documents must be current and provisions made to ensure that they are reviewed periodically and maintained up to date. Reports on facility operations, and particularly reports on safety-significant events, should be provided to line management routinely.

2A.1.1 Is the current design of the facility accurately documented?

2A.1.1.1 Is there an up-to-date Safety Analysis Report for the facility?

2A.1.1.2 Are there accurate system descriptions of all significant safety systems?

2A.1.1.3 Are the facility technical manuals up to date and accurate?

2A.1.1.4 Are the as-built drawings accurate and up to date?

2A.1.2 Are the current operating conditions of the facility accurately documented?

2A.1.2.1 Are the Technical Safety Requirements (TSRs) up to date?

2A.1.2.2 Are there current procedures for routine facility operations?

2A.1.2.3 Are there emergency operating procedures for the facility?

2A.1.3 Are the current material conditions of the facility accurately documented through the use of a material history, and is the history up to date?

2A.1.4 Are the facility hazards accurately documented?

2A.1.4.1 Is there a current hazards assessment of the facility?

2A.1.4.2 Is there a current risk assessment of the facility?

Line managers and oversight groups must be provided current and accurate information about the facilities for which they are responsible. This can be ensured only if a document control and distribution system exists, which regularly provides this information to the appropriate personnel on a timely basis. The distribution and control system should reflect that the amount and detail vary of the information each manager needs, and ensure that each manager receives the information necessary to discharge his or her responsibilities effectively. In addition to providing basic facility documentation and periodic updates, the distribution and control system should ensure the report on such matters as facility status, operations, safety concerns, and potential facility improvements, as well the dissemination of event reports and technical safety appraisals.

2A.2.1 Is there a document control and distribution system in effect to ensure that line managers have access to current editions of the documents specified in 2A.1, above?

2A.2.2 Do line managers receive regular reports on safety performance, potential facility improvements, and other aspects of the status of the nuclear facilities for which they are responsible?

2A.2.3 Is there a system that brings to the attention of line managers significant reports on safety issues (e.g., event reports, technical safety appraisals, safety-related documents)?

Effective oversight and control of facility operations require that someone be responsible for each facility. At any site, immediate contract managers are knowledgeable about the facilities for which they are directly responsible. However, responsibilities for different portions of a facility often are divided among different program offices. Thus, each facet of the responsibilities carried out at a given facility may not be immediately clear, and the overall pattern consisting of each facet is less and less likely to be known the higher up a manager is in the organizational hierarchy. Further, the large number of facilities make it possible for upper management to overlook an entire facility occasionally. Such a lapse may lead eventually to ineffective oversight activities or even a complete lack of oversight. Each facility and portion thereof must be the acknowledged responsibility of a line manager, and without conflicting overlap. Each line manager should be familiar with and should have ready access to the documents that describe the facility for which he or she is responsible. Further, reports on facility operations and, in particular, reports on safety-significant events should be received and reviewed by each line manager. Particular attention must be paid to adequate facility support during change-over of responsibility from one PSO to another, (e.g., transfer from DP to EM). Periodic, firsthand inspections of each facility, coordinated with the other demands on each line manager's time, should be carried out to confirm facility status as presented in periodic reports and to demonstrate continuing management interest in each facility.

2A.3.1 Which facilities, and/or portions thereof, are each line manager's responsibility?

2A.3.2 Which documents does the line manager rely on to describe the safety envelope for the facility?

2A.3.3 Does the line manager know the location of each document that describes the safety envelope for the facility?

2A.3.4 Does the line manager know the location of each document specified in 2A.1, above?

2A.3.5 Which reports on safety-significant events and activities does the line manager routinely review?

2A.3.6 How often does the line manager visit the facilities for which he or she is responsible to discuss or observe the conduct of safety-related activities?

Nuclear facility safety is critically dependent on a facility staff with adequate numbers of highly qualified personnel. Not only do the operators and technicians responsible for the facility operation need to demonstrate high-level qualifications, but so do the technical staff members and managers, who support and oversee facility operations. Adequate staffing is a continuing process involving the initial recruitment of high-quality personnel, the careful match of individual qualifications to job requirements, and the provision of training as necessary to ensure that individual qualifications are adequate to perform the tasks assigned. Periodic retraining is another component included in the staffing process in order to ensure that personnel retain their capabilities and are kept aware of facility status and changes as they occur. The basic safety principles that Question 2B addresses derive from INSAG-3 and are amplified by ASCOT, HSE, and INPO.

The recruitment program must ensure the hire of new employees and the reassignment of existing staff members at levels sufficient and appropriate to conduct safe facility operations. Potential new hires must be screened to ensure that they are fully qualified to fill the positions for which they may be hired, or that they are capable of being trained to fill these positions. Potential new hires must possess personal attitudes and professional skills that reasonably ensure they will fit into the organization as contributing members of the team.

2B.1.1 Do the PSO, field offices, and contractor organizations coordinate facility staffing requirements?

2B.1.2 Is the recruitment program effective in procuring qualified staff?

2B.1.2.1 What percentage of authorized positions is currently filled?

2B.1.2.2 What is the average time between a position becoming vacant (or being authorized) and recruitment being initiated to fill the vacancy?

2B.1.2.3 What is the average time between initiating recruitment and filling a vacant position?

2B.1.2.4 What percentage of vacancies is advertised off-site and on-site?

2B.1.2.5 What percentage of vacancies is filled through on-site recruitment?

Individual qualifications must be compared against position requirements to ensure that assigned personnel are qualified to perform their jobs. This includes personnel recruited from within the organization when they are transferred to different positions. In addition to technical competence, assigned personnel must also possess high standards of personal and professional excellence and the commitment and discipline required to perform their assigned tasks and conform to a consistently high standard.

2B.2.1 Are the required skills and capabilities for each position documented?

2B.2.2 Is there a specified process for reviewing and updating job requirements?

2B.2.3 Is there a specified process for documenting the judgment that an individual's qualifications meet the job requirements?

2B.2.4 Are there specific cases where personnel do not meet job requirements?

2B.2.5 Where personnel do not meet job requirements, have actions been scheduled to upgrade their qualifications?

A training program must produce adequate numbers of personnel with the requisite skills to perform the tasks required at each facility. Each facility also should train managers and technical support personnel as necessary for them to do their jobs. Assigned personnel should be retrained to maintain their familiarity with facility status, to be made aware of any facility changes, to obtain refresher general employee training, as appropriate, and to sharpen and reinforce skills required by their particular jobs. Training must be a priority program, not subject to cancellation or postponement unless there are overriding operational considerations. Thus, overall staffing must be sufficient to allow for personnel to be assigned to training duties just as they are assigned to operational duties.

2B.3.1 Is there an approved and documented training program for facility nuclear activities?

2B.3.1.1 Does the training program include a review of national and international standards for design, construction, operation, and decommission of nuclear facilities and activities?

2B.3.1.2 How many training courses are offered?

2B.3.1.3 Have line managers had an active role in defining the training requirements?

2B.3.2 What is the total number of enrollments in all training courses?

2B.3.3 How many training courses are directly related to the requirements of a specific job?

2B.3.4 What is the number of those enrolled in training courses specifically to meet the requirements of a job?

2B.3.5 Does the training program include classroom studies, simulation, on-the-job-training, and plant familiarization, all of which lead to a formal process for facility nuclear operator approval?

2B.3.6 What is the number of those whose enrollment in training courses results in certification of individual qualifications to perform a specific job or task?

2B.3.7 What data are used to analyze the effectiveness of the training program?

2B.3.8 Is there a program for retraining operations and maintenance personnel?

2B.3.9 Does the training program for nuclear operators include the principal results of any probabilistic safety assessments of the facility, and facility accident management?

2B.4.1 Is there a training program for personnel consistent with the needs of the programs served and requirements of the heads of field organizations?

An organization must have a comprehensive system of policies, directives, and guidance, which clearly establishes organizational relationships, responsibilities, and authorities. The documents contained in the system should amount to an integrated, coordinated set, which is easily understandable and clearly sets forth the roles and missions of the various components of the organization. Each facet of responsibility for safe operation of a facility should be assigned to a particular organizational component or individual without overlap of responsibility and the system must include provisions to maintain accountability. The system should ensure that organizational components and individuals know their responsibilities and understand them.

Management involvement and accountability must be defined so that nuclear safety requirements are met and individual responsibilities are well understood by all parties. Management processes and programs must be in place to accomplish the required objective of ensuring nuclear safety.

The key questions developed for this program element are based on the delegated responsibilities and organizational alignments that ensure proper implementation of the various management functions of the program managers, field offices, and contractors.

2C.1.1 Does each PSO establish policy, program goals, and objectives for the administration/management of facility programs and associated funding?

2C.1.2 Does each PSO provide programmatic and technical direction, as defined in management implementation agreements with the field offices, approve program implementation plans, and assess the status and quality of program implementation?

2C.1.3 Does each PSO concur in the selection and appraisal of field office senior managers?

2C.1.4 Does each PSO implement nuclear safety activities?

2C.1.5 Does each PSO comply with the provisions incorporated into the DOE "Manual of Functions, Assignments and Responsibilities (FAR) for Nuclear Safety" (Rev. 0, December 22, 1992)?

2C.2.1 Is the Lead PSO responsible for coordinating and resolving institutional and cross-cutting issues?

2C.2.2 Does the Lead PSO serve as the focal point to coordinate and resolve with headquarters organizations those activities that may have a significant impact on the other PSO programs as carried out by the field offices?

2C.2.3 Does the Lead PSO keep other PSOs informed of commitments and advise on possible impacts on the field offices?

2C.2.4 Has the Lead PSO negotiated with each field office a primary Memorandum of Agreement (MOA) defining roles, responsibilities, reporting relationships, and conflict resolution procedures?

2C.2.5 Do appendixes to the primary MOA specify any tri-party agreements (among the other PSOs, field offices, and the Lead PSO) which establish an understanding of work to be performed for other PSOs?

2C.2.6 Does the MOA define the role of the FPM, who reports to the FOM, but who is also accountable to the affected PSO?

2C.2.7 Does the MOA address budgeting and accounting responsibilities?

2C.2.8 Does the Lead PSO implement the activities that pertain to nuclear safety?

2C.2.9 Does the Lead PSO comply with the provisions incorporated into the DOE "Manual of Functions, Assignments and Responsibilities (FAR) for Nuclear Safety" (Rev. 0, December 22, 1992)?

2C.3.1 Is the FOM aware of the goals and objectives established by the PSO?

2C.3.2 Is the FOM accountable to the Lead PSO on institutional and cross-cutting issues?

2C.3.3 Does the FOM provide administrative support for programs?

2C.3.4 Does the FOM serve as the DOE Contracting Officer and Fee Determining Official and conduct Laboratory appraisals.?

2C.3.5 Does the FOM integrate the DOE's outreach and compliance activities with respect to states and regions where work is performed?

2C.3.6 Does the FOM delegate contractual authority to the contracting office representatives (CORs)?

2C.3.7 Does the FOM implement the DOE activities that pertain to nuclear safety activities?

2C.3.8 Does the FOM comply with the provisions incorporated into the DOE "Manual of Functions, Assignments and Responsibilities (FAR) for Nuclear Safety" (Rev. 0, December 22, 1992)?

2C.4.1 Is the FPM accountable to the appropriate PSO, as defined in management agreements?

2C.4.2 Does the FPM direct and guide contractors, oversee contractor activities, and develop and coordinate implementation plans for approval by the PSO?

2C.4.3 Does the on-site staff have contracting office representatives (CORs), who are line officials with contractual authority as delegated by the FPM ?

2C.4.4 As the overall implementation and verification agents for DOE, do the CORs provide on behalf of the FPMs direct, day-to-day oversight of the management and operating (M&O) contractors?

2C.4.5 Does the FPM implement the DOE activities that pertain to nuclear safety activities?

2C.4.6 Does the FPM comply with the provisions incorporated into the DOE "Manual of Functions, Assignments and Responsibilities (FAR) for Nuclear Safety" (Rev. 0, December 22, 1992)?

2C.5.1 Does the Manager/Director ensure day-to-day implementation, verification, and reportage of program activities, and manage/direct the on-site staff?

2C.5.2 Does the Manager/Director implement the DOE activities that pertain to nuclear safety activities?

2C.5.3 Does the Manager/Director comply with the provisions incorporated into the DOE "Manual of Functions, Assignments and Responsibilities (FAR) for Nuclear Safety" (Rev. 0, December 22, 1992)?

2C.6.1 Are the contractors the day-to-day operators of the facilities, or do they provide for other special work under FO direction?

2C.6.2 Do the FPMs direct, guide, and oversee the contractors, and develop and coordinate implementation plans for approval by PSOs?

2C.6.3 Do contractors receive direction and guidance, and oversight on their compliance with the provisions of the DOE "Manual of Functions, Assignments and Responsibilities (FAR) for Nuclear Safety" (Rev. 0, December 22, 1992)?

Establishment of a comprehensive managerial system of directives, policies, and guidance on the conduct of operations is only the first step to ensure that a facility is operated safely. There also must be provisions for effective and continuing management oversight of the execution of the plans that have been put in place. This requires that there also be a system to assess how these plans are being implemented, that provides for periodic review and update of these plans, where indicated, and that includes provisions to assess how individuals and groups are performing in light of management expectations.

Effective execution of PSO responsibilities involves actions by the PSO and his or her staff, and requires that the PSO responsibilities be clearly and properly defined. Question 2D.1 and the questions subordinate to it are posed to determine whether management processes and programs are in place to effectively implement PSO responsibilities. Each of the responsibilities listed on page PSO-1 of the DOE "Manual of Functions, Assignments, and Responsibilities for Nuclear Safety" is treated separately below.

2D.1.1 Does the PSO have management processes and programs to implement responsibilities for personnel selection, qualification, training, and staffing at DOE reactor and nonreactor nuclear facilities?

DOE 5480.20, "Personnel Selection, Qualification, Training and Staffing Requirements at DOE Reactor and Non-Reactor Nuclear Facilities," establishes the basic requirements related to these aspects of a PSO's responsibilities. The DOE "Manual of Functions, Assignments and Responsibilities for Nuclear Safety" summarizes the requirements on page PSO-32. Each of these basic requirements is addressed in a major question, below, which in most cases is followed by generic assessment questions, formulated to elicit objective or factual findings.

2D.1.1.1 Does the PSO assume line management responsibility and accountability for reactors and nonreactor nuclear facility personnel qualification programs?

2D.1.1.1.1 Does the PSO issue policies, directives, and guidance, which define expectations for the development, implementation, and maintenance of reactor and nonreactor nuclear facility personnel qualification programs?

2D.1.1.1.2 Does the PSO develop programs to determine if programs and processes for personnel qualification, training, and staffing are producing accountable results?

2D.1.1.2 Does the PSO review in conjunction with ASEH and approve the Training Implementation Matrixes (TIMs) submitted by the MFOs for Category A reactors and nonreactor nuclear facilities?

2D.1.1.3 Does the PSO ensure that assigned personnel responsible for training are proficient in the personnel training process and requirements and that their expertise enables them to cover nuclear and occupational safety issues?

2D.1.1.3.1 Does the PSO require certification of proficiency in nuclear and occupational safety subjects by personnel responsible for training?

2D.1.1.3.2 Has the PSO audited the training program in the past 2 years to determine the proficiency of the training staff?

2D.1.1.3.3 Does the PSO review the results of proficiency audits of the training staff performed by the FO?

2D.1.1.4 Does the PSO ensure that resources are provided to develop, implement, and maintain facility personnel qualification programs?

2D.1.1.4.1 Do the budgets submitted for PSO review contain line items that address resources for developing, implementing, and maintaining facility personnel qualification programs?

2D.1.1.4.2 Does the PSO have a program or process to provide feedback on the adequacy of resources provided in developing, implementing, and maintaining facility personnel qualification programs?

2D.1.1.5 Does the PSO serve as a member of the Committee on Technical Recruitment, Training, and Professional Staff?

2D.1.1.6 Does the PSO identify and communicate PSO training needs and those of the MFO by forwarding a copy of each TIM to the Director, Office of Training and Development?

2D.1.2 Does the PSO have management processes and programs to implement the responsibilities for maintenance management established in DOE 4330.4A?

DOE 4330.4A, Maintenance Management Program, establishes the basic requirements related to this area of the PSO's responsibilities. The DOE "Manual of Functions, Assignments and Responsibilities for Nuclear Safety" summarizes those requirements on page PSO-13. Each of these basic requirements is addressed in a major question below, which in most cases is followed by generic assessment questions, formulated to elicit objective or factual findings.

2D.1.2.1 Has the PSO implemented programs to ensure that DOE nuclear facilities are maintained to support short-term and long-term goals and missions?

2D.1.2.1.1 Has the PSO issued policies, directives, and guidance to define objectives and expectations in the development and implementation of maintenance programs for nuclear facilities?

2D.1.2.1.2 Does the PSO routinely receive reports that indicate the level of performance achieved in the maintenance programs at nuclear facilities?

2D.1.2.2 Does the PSO ensure that resources are provided to maintain nuclear facilities in a safe and economic manner and to reduce maintenance backlog to a manageable level consistent with DOE goals and objectives?

2D.1.2.2.1 Do the budgets submitted for PSO review identify the resources requested for maintenance and repair programs?

2D.1.2.2.2 Does the PSO routinely receive reports on maintenance backlog and the potential effect on the safety performance of nuclear facilities?

2D.1.2.3 Does the PSO require maintenance programs that are inconsistent with the specified requirements of DOE 4330.4A to be submitted for PSO approval, or to be otherwise certified to the PSO as fulfilling the intent of the Order?

2D.1.2.4 Has the PSO provided written guidance to lower levels of management that maintenance issues that cannot be resolved at those levels in a timely manner should be brought to the PSO for resolution?

2D.1.2.5 Does the PSO review and approve or concur in the MFO's schedule of appraisals of contractor maintenance programs to evaluate implementation of the requirements of DOE 4330.4A?

2D.1.2.6 Does the PSO review the results of Facility Condition Inspections and Condition Assessment Surveys provided by MFOs and take appropriate action when conditions exist that might significantly affect site-level or DOE-wide safety?

2D.1.2.7 Does the PSO use the site contractor Annual Maintenance Plans provided by the MFOs to establish the budget requests for the facilities?

2D.1.2.8 Does the PSO ensure that inspections of nuclear facilities are performed consistent with paragraphs 5.(d) and 5.(e) of DOE 4330.4A?

2D.1.3 Does the PSO have management processes and programs to implement the responsibilities for fire protection requirements at DOE reactor and nonreactor nuclear facilities?

DOE 5480.7A, Fire Protection, establishes the basic requirements related to the fire protection responsibilities of the PSO. Each of these basic requirements is addressed in a major question, below, which in most cases is followed by generic assessment questions, formulated to elicit objective or factual findings.

2D.1.3.1 Does the PSO direct fire protection programs that apply to personnel and property for which he or she is responsible?

2D.1.3.1.1 Has the PSO delineated responsibilities for implementing a fire protection program to meet the objectives and program requirements of the Order?

2D.1.3.1.2 Does the PSO receive reports on MFO fire protection program activities routinely?

2D.1.3.1.3 Does the PSO participate actively in required responses to major fire emergencies?

2D.1.3.2 Does the PSO evaluate and assess in accordance with DOE 5480.7A the adequacy of contractor fire protection programs to ensure that contractor responsibilities are fulfilled (paragraph 8h of the Order) and that fire protection program requirements are incorporated (paragraph 9 of the Order)?

2D.1.3.2.1 Does the PSO review and approve/concur in contractor fire protection programs?

2D.1.3.2.2 Does the PSO have an audit program to assess whether contractor programs fulfill their fire protection responsibilities and implement fire protection requirements of the Order?

2D.1.3.2.3 Does the PSO act promptly to correct any deficiencies found?

2D.1.3.3 Does the PSO review and define each vital program and inform the MFO as to the maximum acceptable impact on each program, if a property within the field organization is lost during a fire, including the maximum acceptable downtime, if less than 6 months, and the fire loss, if less than $150M?

2D.1.3.4 Does the PSO maintain a system to ensure that the DOE fire protection program is documented and incorporated into plans and specifications for new facilities and into major modifications of existing ones? Does a qualified fire protection engineer oversee plans, specifications, and testing of fire protection features?

2D.1.3.4.1 Does the PSO audit MFO oversight and direction of contractor fire protection programs?

2D.1.3.4.2 Does the PSO audit contractor fire protection plans and specifications for new facilities to ensure that the objectives of the Order are being met?

2D.1.3.4.3 Does the PSO audit contractor fire protection plans, specifications, and modifications to ensure that the objectives of the Order are being met?

2D.1.3.4.4 Does the PSO require the MFO to act promptly to correct any deficiencies found?

2D.1.3.5 Does the PSO review field organization requests for fire protection exemptions? Does the PSO obtain EH-1 approval for proposed actions on exemption requests and coordinate with NS-1 when nuclear fire safety issues are involved?

2D.1.3.6 Does the PSO have access to an adequate fire protection staff, including one or more qualified fire protection engineers? Does the PSO have a program of continuing education and training to maintain and enhance the level of competency of the fire protection staff?

2D.1.3.6.1 Do job descriptions exist for each fire protection staff position?

2D.1.3.6.2 Are all positions described in the job descriptions filled by persons that have the requisite qualifications?

2D.1.3.6.3 How are qualified persons recruited to fill vacancies on the fire protection staff?

2D.1.3.6.4 Does a program exist to educate and train persons filling fire protection positions, who do not have the requisite qualifications?

2D.1.3.6.5 What programs are in place to enhance the level of competency of the fire protection staff?

2D.1.4 Does the Program Secretarial Officer (PSO) have access to management processes and programs to carry out operational responsibilities at DOE facilities under his or her cognizance?

DOE 5480.19, Conduct of Operations Requirements for DOE Facilities, establishes the basic requirements related to this area of the PSO's responsibilities. The DOE "Manual of Functions, Assignments and Responsibilities for Nuclear Safety" summarizes the requirements for all PSOs on page PSO-31. In addition, certain of the PSOs are assigned responsibility for specific matters as detailed on pages SPSO-7 and 26, ASEH-19, and DNS-3 and 4. Each of these basic requirements is addressed in a major question, below, which in some instances is followed by generic assessment questions, formulated to elicit objective or factual findings.

2D.1.4.1 Does the PSO direct the MFO conduct of facility operations that are under the purview of the PSO?

2D.1.4.2 Does the PSO ensure the preparation, review, and approval by the MFOs of contractor documentation that demonstrates compliance with DOE 5480.19 by programs under the PSO's cognizance?

2D.1.4.3 Does the PSO oversee the performance of operations in accordance with DOE 5480.19 at those facilities for which he or she is responsible?

2D.1.4.5 Does the Assistant Secretary, Defense Programs (ASDP), ensure, in conjunction with appropriate PSOs and the M-SRFO, that the necessary resources and attention to contractors are provided at the DOE Savannah River Field Office (SRFO) to accomplish the tasks that fall under the cognizance of other PSOs?

2D.1.4.6 Does the Assistant Secretary, Nuclear Energy (ASNE), develop, promulgate, and maintain policies necessary to operate DOE facilities and associated equipment and systems?

2D.1.4.7 Does the ASNE develop, promulgate, and maintain guidance materials and train line managers to implement DOE policies and procedures?

2D.1.4.8 Does the ASNE monitor appraisal reports on the conduct of operations at DOE facilities to evaluate compliance with DOE 5480.19 and identify any additional requirements needed?

2D.1.4.9 Does the Assistant Secretary, Environment, Safety, and Health (ASEH), appraise compliance with DOE 5480.19 as it relates to ASEH responsibilities for environmental health?

2D.1.4.10 Does the Director, Office of Nuclear Safety (DNS), coordinate with PSOs on their briefings to the Defense Nuclear Facilities Safety Board (DNFSB) concerning the status of defense nuclear facilities under cognizance of the DNFSB?

2D.1.4.11 Does the DNS coordinate with PSOs on their development of schedules for startup and restart activities?

2D.1.4.12 Does the DNS monitor and appraise compliance with DOE 5480.19 related to nuclear safety?

2D.1.5 Does the PSO have management processes and programs to carry out responsibilities for developing safety analyses, which are used to evaluate the adequacy of the safety bases at DOE reactor and nonreactor nuclear facilities?

DOE 5480.23, Nuclear Safety Analysis Reports, establishes the basic requirements related to this area of the PSO's responsibilities. The DOE "Manual of Functions, Assignments and Responsibilities for Nuclear Safety" summarizes the requirements on page PSO-33. Each of these basic requirements is addressed in a major question, below, which in most cases is followed by generic assessment questions formulated to elicit objective or factual findings.

2D.1.5.1 Does the PSO require contractors to prepare and update Safety Analysis Reports for each nuclear facility and all nuclear operations under its cognizance (unless exempted) in accordance with DOE 5480.23?

2D.1.5.2 Does the PSO review and approve SARs and SAR revisions on all nuclear facilities and operations?

2D.1.5.3 Does the PSO issue a SAR that documents the basis on which approvals of other SARs have been made?

2D.1.5.4 Does the PSO ensure that all commitments made in an approved SAR are fulfilled by the contractors for the nuclear facilities and nuclear operations?

2D.1.5.5 Does the PSO issue permanent exemptions from DOE 5480.23 to nonreactor nuclear facilities under its cognizance at which hazards are of low magnitude, (i.e., for Hazard Category 3 facilities)?

2D.1.5.6 Does the PSO submit a formal request to the Secretary after obtaining the concurrence of D-NS, ASEH, and ASNE, to grant permanent exemptions from DOE 5480.23 to Hazard Category 1 and Hazard Category 2 facilities under its cognizance?

2D.1.5.7 Does the PSO approve temporary exemptions from DOE 5480.23 for up to 1 year to any activity under its cognizance?

2D.1.5.8 Does the PSO provide guidance and assistance to field organizations in applying the graded approach to their facilities and in performing safety reviews, appraisals, and similar measures to ensure contractor compliance with DOE 5480.23?

2D.1.5.9 Does the PSO perform appraisals to ensure contractor compliance with DOE 5480.23?

2D.1.5.10 Does the PSO forward to responsible program managers and field organizations the results of appraisals, together with any instructions as to subsequent actions to ensure compliance with DOE 5480.23?

2D.1.5.11 Does the PSO inform D-NS and ASEH of any nuclear safety, occupational safety and health problems, deficiencies, needs, and actions taken under DOE 5480.23?

2D.1.5.12 Does the PSO appoint individuals to inform the contracting officers of each procurement within the scope of DOE 5480.23?

2D.1.5.13 Does the PSO identify in writing the design, construction, or operations contractors responsible for preparing a SAR for each nuclear facility or nuclear operations?

2D.1.5.14 (SPECIAL FOR ASEH)

Does ASEH monitor and appraise implementation of DOE 5480.23 as it relates to nonnuclear and occupational safety and health, including line and field organization and contractor performance in these areas?

2D.1.5.15 (SPECIAL FOR ASEH and ASNE)

Do ASEH and ASNE concur on requests for permanent exemptions from DOE 5480.23?

2D.1.5.16 (SPECIAL FOR D-NS)

Does D-NS monitor and appraise the implementation of all aspects of DOE 5480.23 related to nuclear safety, including field organization and contractor performance?

Effective execution of MFO responsibilities involves actions by the contractor, the field office staff, as well as by the MFO, and requires that the responsibilities of the contractor and the staff be clearly and properly defined. Question 2D.1 and the questions subordinate to it are posed to determine whether management processes and programs are in place to effectively implement MFO responsibilities. Each of the responsibilities listed in the Responsibilities Manual is treated separately.

2D.2.1 Does the MFO have access to management processes and programs to carry out responsibilities for personnel selection, qualification, training, and staffing at DOE reactor and nonreactor nuclear facilities?

DOE 5480.20, "Personnel Selection, Qualification, Training and Staffing Requirements at DOE Reactor and Non-Reactor Nuclear Facilities," establishes the basic requirements related to these aspects of an MFO's responsibilities. The Responsibilities Manual summarizes the requirements. Each of these basic requirements is addressed in a major question, below, which in most cases is followed by generic assessment questions, formulated to elicit objective or factual findings. The manual does not address the MFO responsibilities for selecting, qualifying, and training field office staff, which are addressed under Question 2B.

2D.2.1.1 Does the MFO review each TIM prior to contractor implementation?

2D.2.1.1.1 Does the MFO review and timely submit to the PSO for approval TIMs for Category A reactors and for high-hazard, nonreactor nuclear facilities?

2D.2.1.1.2 Does the MFO review and timely approve TIM(s) for Category B reactors and low- and moderate-hazard nonreactor nuclear facilities?

2 D.2.1.1.3 Are there documented results of any audit by the MFO to determine if the existing status of compliance with DOE 5480.20 is consistent with the TIM, including any previously approved schedule for achieving compliance?

2 D.2.1.2 Does the MFO ensure that contractors to which DOE 5480.20 applies implement the requirements in Chapters I through IV of that Order?

2 D.2.1.2.1 Does the MFO establish requirements for contractor compliance with DOE 5480.20, Personnel Selection, Qualification, Training, and Staffing Requirements at DOE Reactor and Non-Reactor Nuclear Facilities?

2 D.2.1.2.2 Are there documented results of any audit by the MFO to determine the existing status of contractor compliance with DOE 5480.20?

2 D.2.1.3 Are contractor procedures established to grant individual exceptions to specific training or qualification requirements where approved by the MFO?

2 D.2.1.3.1 Does the MFO assign qualified personnel to review contractor procedures established to grant exceptions to specific training or qualification requirements?

2 D.2.1.3.2 Does the MFO have established, internal procedures and/or standards by which to review contractor procedures for granting exceptions to specific training or qualification requirements?

2 D.2.1.4 Are certification extensions approved by the MFO on a case-by-case basis?

2 D.2.1.4.1 Does the MFO assign qualified personnel to review certification extensions?

2 D.2.1.4.2 Does the MFO have internal procedures and/or standards for review of certification extensions?

2 D.2.1.5 Are all temporary deviations from facility Safety Analysis Reports (SARs), technical specifications, or Operational Safety Requirements (OSRs) regarding facility staffing requirements approved by the MFO?

2 D.2.1.5.1 Does the MFO assign qualified personnel to review temporary deviations from facility SARs, technical specifications, or OSRs regarding facility staffing requirements approved by the MFO?

2 D.2.1.5.2 Does the MFO have internal procedures and/or standards for review of temporary deviations from facility SARs, technical specifications, or OSRs regarding facility staffing requirements approved by the MFO?

2 D.2.1.6 Does the MFO review and decide on contractor assessments of the need for a simulator at Category A test and research reactors?

2 D.2.1.6.1 Does the MFO assign qualified personnel to review contractor assessments of the need for a simulator at Category A test and research reactors?

2 D.2.1.6.2 Does the MFO have internal procedures and/or standards to review contractor assessments of the need for a simulator at Category A test and research reactors?

2 D.2.1.7 Does the MFO review the certification and recertification of shift supervisors, senior reactor operators, and fissionable material handlers at Category A reactors and high-hazard nonreactor nuclear facilities?

2 D.2.1.7.1 Does the MFO assign qualified personnel to review the certification and recertification of shift supervisors, senior reactor operators, and fissionable material handlers at Category A reactors and high-hazard, nonreactor nuclear facilities?

2 D.2.1.7.2 Does the MFO have internal procedures and/or standards to review the certification and recertification of shift supervisors, senior reactor operators, and fissionable material handlers at Category A reactors and high-hazard, nonreactor nuclear facilities?

2 D.2.1.8 Does the MFO identify and submit resource requests to the cognizant PSO to provide for adequate implementation of qualification programs?

2 D.2.1.8.1 Does the MFO require contractors to provide specific cost and budget data for qualification and training programs?

2 D.2.1.8.2 Does the MFO submit to the PSO specific cost and budget data for qualification and training programs?

2 D.2.1.9 Does the MFO ensure that his or her staff includes an adequate number of persons with expertise in personnel training?

2 D.2.1.9.1 What functions does the MFO perform that require personnel with expertise in personnel training?

2 D.2.1.9.2 Are appropriately qualified personnel assigned to the MFO functions that require expertise in personnel training?

2 D.2.1.10 Does the MFO forward to the D-TD copies of TIMs for Category B reactors and low- and moderate-hazard nonreactor nuclear facilities?

2D.2.2 Does the MFO have management processes and programs to implement the responsibilities for maintenance at DOE reactor and nonreactor nuclear facilities?

DOE 4330.4A, Maintenance Management Program, establishes the basic requirements related to this area of the MFO's responsibilities. The DOE "Manual of Functions, Assignments and Responsibilities for Nuclear Safety" summarizes those requirements on page MFO-9. Each of these basic requirements is addressed in a major question below, which in most cases is followed by generic assessment questions, formulated to elicit objective or factual findings.

2D.2.2.1 Do the contracts signed by the MFO provide for the contractors to implement the requirements of DOE 4330.4A, paragraph 11, and Chapters I and II?

2D.2.2.2 Does the MFO review, comment on, and approve contractor-generated nuclear facility Maintenance Implementation Plans and all subsequent modifications to those plans for all nuclear-related activities within the MFO's scope of responsibility?

2D.2.2.3 Are the MFO-approved Maintenance Implementation Plans consistent with the provisions of DOE 4330.4A?

2D.2.2.4 Does the MFO monitor, evaluate, and report to the PSO on the performance of sites in the areas of maintenance and repair?

2D.2.2.5 Does the MFO review and concur with the maintenance backlog and establish plans for the timely reduction of the backlog consistent with DOE nuclear safety goals and objectives?

2D.2.2.6 Does the MFO submit reports to the PSO on the maintenance backlog and plans for its reduction ?

2D.2.2.7 Does the MFO submit reports to the appropriate PSOs and the D-PR on the results of nuclear facility inspections and condition assessment surveys of nuclear facilities, which might have a significant site-level safety impact, or DOE-wide safety implications?

2D.2.2.8 Does the MFO ensure that contractor maintenance programs are evaluated to determine if their implementation is proper and consistent with the requirements of DOE 4330.4A?

2D.2.2.9 Does the MFO develop, approve, and submit to the D-PR and appropriate PSOs site contractor Annual Maintenance Plans, which support the FY+2 maintenance budget submittal?

2D.2.2.10 Does the MFO compare the Annual Maintenance Plan submitted in FY-2 with the current Maintenance Implementation Plan to assess whether the program appropriately reflects the difference (if any) between the resources allocated to maintenance and the requested resources?

2D.2.2.11 Are inspections being performed consistent with paragraphs 5.d and 5.e of DOE 4330.4A at facilities within the MFO's scope of responsibility?

2D.2.3 Does the MFO have access to management processes and programs to ensure compliance with fire protection requirements at DOE reactor and nonreactor nuclear facilities?

DOE 5480.7A, Fire Protection, establishes the basic requirements related to the fire protection responsibilities of the PSO. Each of these basic requirements is addressed in a major question, below, which in most cases is followed by generic assessment questions, formulated to elicit objective or factual findings. The DOE Order does not address responsibilities for MFO selection, qualification, and training of field office staff, which is addressed under Question 2B.

2D.2.3.1 Does the MFO ensure a level of fire protection adequate to meet the objectives of the Fire Protection Order as it applies to personnel and property for which he or she is responsible? Where an Area Office exists, does the MFO delineate fire protection responsibilities in a clear and formal way?

2D.2.3.1.1 Does the MFO audit contractor fire protection to ensure that the objectives of the Order are being met?

2D.2.3.1.2 Does the MFO act promptly to correct any deficiencies found?

2D.2.3.2 Does the MFO maintain a system to ensure that the DOE fire protection program is documented and incorporated into the plans and specifications for all new facilities and into major modifications of existing ones? Does a qualified fire protection engineer oversee the system and test fire protection features?

2D.2.3.2.1 Does the MFO audit contractor fire protection plans and specifications for new facilities to ensure that the objectives of the Order are being met?

2D.2.3.2.2 Does the MFO audit contractor plans and specifications for new facilities and modifications to existing ones to ensure that the objectives of the Order are being met?

2D.2.3.2.3 Does the MFO act promptly to have the deficiencies corrected?

2D.2.3.3 Does the MFO review action plans for compliance with recommendations resulting from fire protection assessments, and does the MFO forward to the PSO copies of compliance plans, exemption requests, equivalency determinations, compliance schedule approvals, and other requested data?

2D.2.3.4 Does the MFO approve contractor requests for fire safety equivalencies?

2D.2.3.5 Does the MFO maintain a list of facilities/contractors for which he or she has fire protection appraisal responsibility under the Fire Protection Order, and does this list indicate the assessment frequency for each?

2D.2.3.6 Does the MFO conduct fire protection assessments of facilities and/or contractors according to the frequency and scope established by DOE 5480.7A to ensure that :

2D.2.3.7 Does the MFO provide fire protection technical assistance to contractors?

2D.2.3.8 Does the MFO submit an annual summary to the Office of Safety and Quality Assurance (EH-30) through the PSO covering the fire protection program and loss experience of the previous year, as required by DOE 5484.1?

2D.2.3.9 Does the MFO forward requests for exemptions prepared by the contractor to the PSO, including recommendations for approval where, in the judgment of the MFO, compliance with specific program elements is not attainable and where an acceptable level of safety is provided? Is the cognizant Headquarters fire protection engineer consulted on such issues as appropriate?

2D.2.3.10 Does the MFO have access to an adequate fire protection staff, including one or more qualified fire protection engineers, to accomplish the fire protection objectives specified in paragraph 4 of DOE 5480.7A? Does the MFO have a program of continuing education and training in order to maintain and enhance the level of competency of the fire protection staff?

2D.2.3.10.1 Have job descriptions been developed for each fire protection staff position?

2D.2.3.10.2 Are all positions described in the job descriptions filled by persons having the requisite qualifications?

2D.2.3.10.3 How are qualified persons recruited to fill vacancies on the fire protection staff?

2D.2.3.10.4 Does a program exist to educate and train persons filling fire protection positions, who do not have the requisite qualifications?

2D.2.3.10.5 Are programs in place to enhance the level of competency of the fire protection staff?

2D.2.3.11 Does the MFO have a method to relay fire protection information to and from Headquarters and the contractors?

2D.2.3.12 Does the MFO assume the responsibilities of the PSO in those cases where there is no PSO, as stipulated in paragraph 8a of DOE 5480.7A? Does the MFO assume the responsibilities of the contractor in those cases where there is no contractor, as stipulated in paragraph 8h of the same Order?

2D.2.4 Does the Manager, Field Office (MFO), have management processes and programs to carry out responsibilities for the conduct of operations at the DOE facilities under his or her cognizance?

DOE 5480.19, Conduct of Operations Requirements for DOE Facilities, establishes the basic requirements related to this area of the MFO's responsibilities. The DOE "Manual of Functions, Assignments and Responsibilities for Nuclear Safety" summarizes the requirements for all MFOs on page MFO-27. In addition, specific responsibilities are assigned to the DOE Facility Representative (FR), the Director, Site Office (DSO), and the Manager, Area Office (MAO) on pages OFE 4, 5 and 9 of the manual. Each of these basic requirements is addressed in a major question, below, which in some instances is followed by generic assessment questions, formulated to elicit objective or factual findings.

2D.2.4.1 Does the MFO ensure that adequate contractor plans, procedures, and programs are in place, and evaluate the effectiveness of contractor implementation of them at sites under the MFO's cognizance, consistent with DOE 5480.19?

2D.2.4.2 Does the MFO approve documentation prepared by contractors to demonstrate conformance to the guidelines in Attachment 1 of DOE 5480.19?

2D.2.4.3 Does the MFO assign monitoring tasks to Site Safety Representatives (SSRs)?

2D.2.4.4 Does the MFO ensure that SSRs are assigned responsibility for a major facility or group of lesser facilities and that they oversee day-to-day conduct of operations at these facilities in accordance with DOE 5480.19 and direction received from the PSO?

2D.2.4.5 Does the MFO take direction from the PSO on implementation of programs in accordance with the goals and objectives established by the PSO?

2D.2.4.6 Does the DOE Facility Representative (FR) monitor the performance of the facility and its operation as assigned by the MFO?

2D.2.4.7 Does the FR serve as the primary point of contact with contractors?

2D.2.4.8 Does the Director, Site Office (DSO), receive direction from the appropriate PSO as defined in the management agreements applicable to the DSO site?

2D.2.4.9 Does the DSO ensure day-to-day implementation, verification, and reporting of program activities and manage the on-site staff?

2D.2.4.10 Does the Manager, Area Office (MAO), receive direction from the appropriate PSO as defined in the management agreement applicable to the MOA's office?

2D.2.4.11 Does the MAO ensure day-to-day implementation, verification, and reporting of program activities and manage the on-site staff?

2D.2.5 Does the MFO have management processes and programs to carry out responsibilities for developing safety analyses, which are used to evaluate the adequacy of safety bases at DOE reactor and nonreactor nuclear facilities?

DOE 5480.23, Nuclear Safety Analysis Reports, establishes the basic requirements related to this area of the MFO's responsibilities. The Responsibilities Manual summarizes the requirements, each of which is addressed in a major question, below, which in most cases is followed by generic assessment questions formulated to elicit objective or factual findings.

2D.2.5.1 Does the MFO review and make recommendations to the PSO on the adequacy of all new SARs, as well as on all SAR revisions?

2D.2.5.2 Does the MFO oversee contractor preparation and review of safety analyses, including nuclear criticality, hazards classification, and safety evaluations, and other changes to the analyses, consistent with DOE 5480.23 and other DOE Orders?

2D.2.5.3 Does the MFO inform appropriate Headquarters program organizations, the D-NS, and field and area offices of nuclear safety problems or deficiencies, and of any actions taken under DOE 5480.23?

2D.2.5.4 Does the MFO designate an individual to inform contracting officers of each procurement within the scope of DOE 5480.23?

The primary responsibilities of a contractor are specified in a contract. The requirements may be specified by reference to other documents, including DOE policies, directives and guidance, such as DOE Orders. Fulfillment of the contractual responsibilities requires that a contractor establish and implement policies, directives, and guidance (including procedures) consistent with the terms of the contract and any referenced documents. Question 2D.3 and the questions subordinate to it are posed on the assumption that each contract contains, at a minimum, requirements to ensure fulfillment of the PSO and MFO responsibilities. Consequently, the questions below are directly related to Questions 2D.1 and 2D.2.

2D.3.1 Does the contractor have management processes and programs to implement the personnel selection, qualification, training, and staffing requirements specified in DOE 5480.20?

DOE 5480.20, Personnel Selection, Qualification, Training, and Staffing Requirements at DOE Reactor and Non-Reactor Nuclear Facilities, establishes the basic requirements in these areas of a contractor's responsibilities. Each of these basic requirements is addressed in a major question, below, which in most cases is followed by generic assessment questions, formulated to elicit objective or factual findings.

2 D.3.1.1 Does the contractor have written procedures that clearly define the qualification requirements in terms of education, experience, training, and any special requirements necessary to perform assigned responsibilities by personnel at each functional level?

2 D.3.1.2 Does the contractor establish and submit for MFO approval procedures for granting individual exceptions to specific training or qualification requirements?

2 D.3.1.3 Does the contractor use written procedures to govern the program leading to certification and recertification of the satisfactory achievement of a person's qualification for a position?

2 D.3.1.4 Does the contractor request MFO approval of each certification extension on a case-by-case basis?

2 D.3.1.5 Does the contractor have a DOE-approved TIM for each training requirement pursuant to DOE 5480.20?

2 D.3.1.5.1 Does the contractor's TIM(s) reflect the existing status of compliance with the requirements of DOE 5480.20, and include a schedule to achieve full compliance, if full compliance has not been achieved?

2 D.3.1.5.2 Does the contractor's TIM(s) clearly define the organization, planning, and administration of the qualification program and set forth the responsibility, authority, and methods to be used to conduct training?

2D.3.1.5.3 Does the level of detail and content of each TIM reflect the hazards involved and the risks associated with the operation or activity?

2D.3.1.5.4 Are the qualifications and training requirements based on analyzed needs, (e.g., an analysis of job requirements or position responsibilities)?

2D.3.1.5.5 Does each TIM include managerial and supervisory training requirements in accordance with DOE 5480.20, Chapter 1, paragraph 7i?

2D.3.1.5.6 Does each TIM cite all existing needs to train personnel that are not employees of the contractor, (e.g., subcontractors or DOE personnel)?

2D.3.1.6 Does the contractor's training program include written procedures for written and oral examinations, and operational evaluations (as required) to demonstrate that certified operators and supervisors possess the knowledge and skills required for certification?

2D.3.1.7 Does the contractor use written procedures to maintain training, qualification, and certification records that meet the format and content requirements of DOE 5480.20, Chapter 1, paragraph 16?

2D.3.1.8 Is there a training organization within the line management organization consistent with the size and complexity of the training requirements?

2D.3.1.8.1 Are the responsibilities and authorities of the training organization managers clearly defined and documented?

2D.3.1.8.2 Are the responsibilities, qualifications, duties, and authority of the training personnel clearly defined and documented?

2D.3.1.9 Does the contractor request MFO approval of all temporary deviations from facility Safety Analysis Reports (SARs), technical specifications, or Operational Safety Requirements (OSRs) regarding facility staffing requirements?

2D.3.1.10 Does the contractor perform and submit for MFO approval assessments of the need for a simulator at Category A test and research reactors?

2D.3.1.11 Are the contractor's budget and expenditures consistent with the resource requirements reflected in the TIM?

2D.3.1.11.1 Does the contractor's accounting system specifically identify costs for qualification and training?

2D.3.1.11.2 Do the contractor budget submissions and operating reports specifically identify funds for personnel qualification and training?

2D.3.2 Does the contractor have management processes and programs to implement the maintenance management requirements specified in DOE 4330.4A?

DOE 4330.4A, Maintenance Management Program, establishes the basic requirements for contractor maintenance management programs. Each of these basic requirements is addressed in a major question, below, which in most cases is followed by generic assessment questions, formulated to elicit objective or factual findings.

2D.3.2.1 Does the contractor have an MFO-approved Management Implementation Plan for the facilities under the contractor's scope of responsibility?

2D.3.2.2 Does the contractor's Management Implementation Plan differ from the Annual Maintenance Plan submitted in FY-2 to support the budget for the current FY in a way that is consistent with the difference (if any) between the resources requested and the resources allocated for maintenance in the current FY?

2D.3.2.3 Does the contractor's maintenance program clearly differentiate the budgeting and accounting for "classical maintenance and repair" from that for other craft work done on the facilities, (e.g., custodial work, fabrication, rearrangements, improvements, equipment installation)?

2D.3.2.4 Does the contractor's Management Implementation Plan reflect a graded approach to maintenance, (i.e., one which allocates maintenance resources commensurate with the importance of the equipment)?

2D.3.2.5 Does the contractor's Management Implementation Plan and associated policies, procedures, and guidelines constitute a clear and coherent program for governing and implementing maintenance activities?

2D.3.2.6 Does the contractor's maintenance program plan address each of the 32 elements for which an objective is stated in Chapter I, Section 3, of DOE 4330.4A, and/or does the plan provide a justification for each element not addressed?

2D.3.2.6.1 Do the elements of the contractor's maintenance program reflect the objectives specified in Chapter I, Section 3, of DOE 4330.4A?

2D.3.2.6.2 Do the elements of the contractor's maintenance program reflect the criteria specified in Chapter I, Section 3, of DOE 4330.4A?

2D.3.2.7 Does the contractor's maintenance program give appropriate attention to the additional maintenance management requirements specified in Chapter I, Section 4, of DOE 4330.4A, Self-Assessment, Seasonal Facility Preservation, Maintenance Standards and Workmanship Standards, and Warranty/Guarantee Information?

2D.3.2.8 Is the contractor's maintenance program consistent with the implementation guidance in Chapter II of DOE 4330.4A?

2D.3.2.8.1 Does the contractor's maintenance program address each of the implementation objectives stated in the Introduction subsections of Sections 2 through 19 of Chapter II?

2D.3.2.8.2 Does the contractor's maintenance program reflect the guidance in the Discussion and Guidelines subsections of Chapter II?

2 D.3.3 Does the contractor have access to management processes and programs to implement the fire protection requirements specified in DOE 5480.7A?

DOE 5480.7A, Fire Protection, establishes the basic requirements related to this area of the contractor's responsibilities. Each of these basic requirements is addressed in a major question, below, which in most cases is followed by generic assessment questions, formulated to elicit objective or factual findings.

2D.3.3.1 Does the contractor provide and maintain a level of fire protection that meets the objectives of the Order (paragraph 4) and the fire protection program requirements specified in paragraph 9 of the Order?

2D.3.3.1.1 Does the contractor's fire protection program specify the criteria and program requirements of DOE 5480.7A?

2D.3.3.1.2 Has the contractor implemented a program of self-assessment to ensure that the objectives and program requirements are met?

2D.3.3.2 Does the contractor maintain a system to ensure that the requirements of the DOE fire protection are documented and incorporated into the plans and specifications for all new facilities and into major modifications of existing ones? Does a qualified fire protection engineer review plans and specifications, and test procedures and results for fire protection features?

2D.3.3.3 Does the contractor assist DOE to coordinate fire safety assessments at those facilities included in the survey program, establish action plans for compliance with recommendations resulting from assessments, and forward compliance plans, exemption requests, and other requested data to DOE field organizations?

2D.3.3.4 Does the contractor maintain a list of facilities for which it has fire protection assessment responsibilities?

2D.3.3.5 Does the contractor conduct fire protection assessments of facilities according to the scope and frequency established by DOE 5480.7A?

2D.3.3.6 Does the contractor provide fire protection technical assistance to DOE?

2D.3.3.7 Does the contractor submit requests for exemptions and fire protection equivalencies to the Head of the Field Organization for those facilities where compliance with specific program elements is not attainable and where an acceptable level of safety has been achieved?

2D.3.3.8 Does the contractor maintain an adequate fire protection staff, including qualified fire protection engineer(s)? Does the contractor offer a program of continuing education and training to maintain and enhance the level of competency of the fire protection staff?

2D.3.3.8.1 Do job descriptions exist of each fire protection staff position?

2D.3.3.8.2 Are all positions described in the job descriptions filled by persons having the requisite qualifications?

2D.3.3.8.3 How are qualified persons recruited to fill any vacancies on the fire protection staff?

2D.3.3.8.4 How does the contractor educate and train persons filling fire protection positions, who do not have the requisite qualifications?

2D.3.3.8.5 What programs are in place to enhance the level of competency of the fire protection staff?

2D.3.4 Does the contractor have management processes and programs to implement each of the requirements related to conduct of operations as specified in the contract?

The primary responsibilities of a contractor are specified in a contract. The requirements may be specified by reference to other documents, including DOE policies, directives, and guidance, such as DOE Orders. A contractor must establish and implement policies, directives, and guidance (including procedures) consistent with the terms of a given contract and any referenced documents. Question 2D3.4 and the questions subordinate to it are posed based on the assumption that a contract contains, at a minimum, requirements to ensure fulfillment of the PSO and MFO responsibilities. Consequently, the questions below are directly related to Questions 2D.1.4 and 2D.2.4.

2D.3.4.1 Does the contractor have procedures or other definitive documentation that specifies the policies that apply to operations?

2D.3.4.2 Does the contractor have adequate resources in materials and personnel to accomplish assigned tasks without requiring excessive overtime by the operations staff?

2D.3.4.3 Does the contractor document and evaluate operating problems and take corrective action to improve performance based upon these evaluations?

2D.3.4.4 Does the contractor hold workers and their supervisors accountable for their operating performance?

2D.3.4.5 Is formalized supervisory and managerial training incorporated into the contractor's training program?

2D.3.4.6 Is the responsible operator promptly notified of all changes in facility status, abnormalities, or difficulties encountered in performing assigned tasks?

2D.3.4.7 Do operations personnel adhere to the requirements of the facility industrial safety program?

2D.3.4.8 Are operator tours conducted in sufficient detail to ensure that the status of equipment is known?

2D.3.4.9 Do operators use round inspection sheets to record key equipment parameters during their tours?

2D.3.4.10 Are operators appropriately qualified to follow good personnel protection practices and to maintain personnel exposure as low as reasonably achievable (ALARA) to radiation, chemicals, electromagnetic fields, toxic materials, or other personnel hazards?

2D.3.4.11 Do operators believe instrument readings and treat them as accurate unless proven otherwise?

2D.1.4.12 When a protective device is tripped (e.g., circuit breaker, fuse, or reactor protection channel where multichannel logic exists), do operators attempt to understand the cause before the device is reset?

2D.3.4.13 Are all power or process rate changes approved by the person accountable for safe operation (e.g., the shift supervisor, control room lead operator, or the cognizant manager for a test and research facility)?

2D.3.4.14 Do operations managers ensure that only trained and qualified personnel operate plant equipment?

2D.3.4.15 Is an operating base (i.e., a facility area where an operator returns when not performing in-plant duties) established for each shift position?

2D.3.4.16 Does the contractor prohibit on-duty operations personnel from using material that might distract them from their responsibilities, (e.g., entertainment devices)?

2D.3.4.17 Is control area access limited to those persons on official business only?

2D.3.4.18 Is professional behavior displayed in the control area at all times?

2D.3.4.19 Are operators alert and attentive to control panel indications and alarms? Do they monitor control panel indications frequently, take prompt action to determine the causes of abnormalities, and correct them?

2D.3.4.20 Are operators assigned ancillary duties that might interfere with their ability to monitor facility parameters?

2D.3.4.21 Is the operation of control area equipment limited to only those persons specifically authorized by the administrative procedures?

2D.3.4.22 Are methods implemented to ensure that all facility personnel are promptly alerted to facility emergencies?

2D.3.4.23 Is use of the facility public address system (page) administratively controlled to ensure it retains its effectiveness in contacting plant personnel?

2D.3.4.24 Are methods implemented to ensure that control area personnel can quickly contact on-shift operators or supervisors?

2D.3.4.25 Is the use of portable radios prohibited in facility areas where electronic interference with plant equipment may result?

2D.3.4.26 Are the acronyms and abbreviations used in facility communications (both written and spoken) limited to those on an approved list?

2D.3.4.27 Are oral instructions clear and precise, and must the receiver repeat a sender's instructions to the extent necessary to ensure that the instructions are correctly understood?

2D.3.4.28 Is on-shift training conducted in accordance with training programs that specifically identify items the trainee must accomplish on shift?

2D.3.4.29 Is on-shift training conducted by qualified operators?

2D.3.4.30 When a trainee operates equipment, is it under the observation of a qualified operator serving as an on-shift instructor?

2D.3.4.31 Is the operator qualification program approved by the operations supervisor and are changes to the program coordinated with the training department?

2D.3.4.32 Is the completion of the operator qualification program formally documented?

2D.3.4.33 Is trainee operation of equipment immediately suspended during unanticipated or abnormal events, accident conditions, or whenever the operations personnel or on-shift instructor believes suspension is necessary to ensure safe and reliable facility operation?

2D.3.4.34 Has consideration been given to the maximum number of trainees allowed to simultaneously participate in any particular training evolution?

2D.3.4.35 Are events that occur in the facility that adversely affect operations, personnel safety, or DOE requirements (DOE 500.3A) thoroughly investigated?

2D.3.4.36 Is the operations supervisor or another manager responsible for event investigations?

2D.3.4.37 Are event investigators technically knowledgeable and well respected by the facility staff?

2D.3.4.38 As soon as possible after an abnormal event, is an individual assigned to collect information to reconstruct and analyze the event?

2D.3.4.39 Is each abnormal event subjected to a structured review upon completion of the data collection?

2D.3.4.40 Does the responsible authority establish a time frame for completion of the investigative report of an abnormal event?

2D.3.4.41 Are in-house events evaluated by the operations supervisor to determine if the events should be included in the training program for operations personnel?

2D.3.4.42 Are patterns of deficiencies, such as operator errors or inadequate procedures, identified and compared with periodic summary reports submitted to department heads, the facility manager, and other appropriate managers? Is information from these summary reports included in the training program?

2D.3.4.43 Are acts of known or suspected sabotage subjected to a special-event investigation to determine the condition of the affected system(s), to decide if continued operation is justified or if systems are available to support safe facility shutdown, and to minimize the impact of the discovered acts and deter future acts of sabotage?

2D.3.4.44 Are procedures in place to address appropriate notifications?

2D.3.4.45 Does the operations supervisor ensure that all appropriate personnel receive notification when required?

2D.3.4.46 Are the names, telephone numbers, and page codes of primary and alternate contacts readily available to the person assigned to make the notifications?

2D.3.4.47 Are all notifications documented?

2D.3.4.48 Is adequate communication equipment maintained in the main control area to meet the notification objectives?

2D.3.4.49 Is the operations supervisor responsible for maintaining proper facility configuration, and does he or she authorize status changes to be made to major equipment and systems?

2D.3.4.50 Are individual components of facility equipment and systems checked for proper alignment before placing them into operation?

2D.3.4.51 Are locks and tags used on components that require special administrative control for safety or other reasons?

2D.3.4.52 Are administrative controls established to document compliance with operational limits (limiting conditions of operation)?

2D.3.4.53 Do facility operating personnel identify equipment deficiencies noted in the work control system?

2D.3.4.54 Does the operations supervisor or designee authorize all shift activities (including maintenance) involving equipment important to safety, that affects operations, or that changes control indications or alarms?

2D.3.4.55 Is equipment tested following maintenance to demonstrate that it is capable of performing its intended function?

2D.3.4.56 Is the status of control panel and/or local panel alarms readily available to appropriate operating personnel?

2D.3.4.57 Are administrative control systems established to accommodate temporary modifications, such as electrical jumpers, lifted leads, pulled circuit boards, disabled annunciators/alarms, mechanical jumpers/bypasses, temporary setpoint changes, installed or removed block flanges, disabled relief or safety valves, installed or removed filters or strainers, plugged floor drains, and temporary pipe supports?

2D.3.4.58 Is there a system to ensure that operations personnel use the latest revisions of engineering drawings and specifications?

2D.3.4.59 Are locks and tags placed on controls when necessary for safety or other special administrative reasons?

2D.3.4.60 Are lockout and tagout procedures properly implemented?

2D.3.4.61 Are the lockout and tagout devices singularly identified, durable, and standardized within the facility, and do tagout devices contain an appropriate warning legend?

2D.3.4.62 Does a lockout/tagout program exist, consisting of procedures to control potentially hazardous energy and materials? Does the program include personnel training?

2D.3.4.63 Are lockout/tagout procedures developed, documented, and validated, and are they used to control potentially hazardous energy and materials?

2D.3.4.64 Do procedures for implementing lockout/tagout cover all of the required elements and actions in the correct sequence?

2D.3.4.65 Is the temporary removal of lockout/tagout devices discouraged?

2D.3.4.66 Do authorized personnel periodically assess whether lockout/tagout procedures are being followed and correct any deviations or inadequacies observed?

2D.3.4.67 Do the procedures prohibit use of caution tags where it is appropriate to use a lockout/tagout device, (e.g., for personnel protection)?

2D.3.4.68 Is training provided and documented to ensure that all personnel understand the purpose and function of the lockout/tagout program and that they have the knowledge and skills to safely apply, use, and remove lockouts and tagouts?

2D.3.4.69 Is lockout/tagout accomplished only by authorized, qualified personnel?

2D.3.4.70 Does the supervisor or appropriate manager notify affected personnel of the application and removal of lockout/tagout devices?

2D.3.4.71 When outside service personnel are engaged in activities covered by the lockout/tagout program, do the facility and outside contractor inform each other of their respective lockout/tagout procedures to ensure that all personnel are aware of any discrepancies?

2D.3.4.72 When service or maintenance is performed by a crew, craft, department, or other group, does it use a procedure that provides for safety equivalent to that provided by the personal lockout or tagout device?

2D.3.4.73 Are specific procedures used during shift or personnel changes to ensure the continuity of lockout or tagout protection?

2D.3.4.74 Is independent verification of the positions of critical components required when circumstances warrant to ensure safe and reliable operation?

2D.3.4.75 Is independent verification of components required when the equipment they serve must be available and when a reasonable possibility exists that the components may be mispositioned?

2D.3.4.76 Are operators trained in the appropriate techniques to verify the positions of all facility components?

2D.3.4.77 Are narrative logs used at all key shift positions?

2D.3.4.78 Is information promptly recorded in the logs?

2D.3.4.79 Does the operations supervisor provide written guidance to define the type and scope of entries to be made in each log and the format for making entries?

2D.3.4.80 Are log entries easily read and understood?

2D.3.4.81 Is a standardized method used to correct any erroneous log entry?

2D.3.4.82 Does the operations supervisor systematically review the control area logs? Does the control area operator or an appropriate supervisor review the logs kept by operators outside the control area?

2D.3.4.83 Is there written guidance on the disposition of completed logs?

2D.3.4.84 Is a shift turnover checklist used by operators and supervisors?

2D.3.4.85 Do oncoming operators and supervisors review documents specified on their checklists before assuming responsibilities for their shifts?

2D.3.4.86 Does each shift watchstander conduct walkdowns of appropriate control panels?

2D.3.4.87 Do shift turnover procedures require full discussion of plant conditions, and is assumption of responsibility for the upcoming shift documented by an entry into the log?

2D.3.4.88 Does the operations supervisor brief the crew after he or she accepts responsibility for the shift?

2D.3.4.89 When an exchange of personnel occurs during a shift, (e.g., control supervisory function exchange) do provisions ensure that the oncoming person is at least as knowledgeable of plant conditions as he or she would be if a complete shift turnover took place?

2D.3.4.90 Does the operations supervisor define each operator's specific responsibilities with respect to process control?

2D.3.4.91 Are operators knowledgeable about aspects of facility processes and safety that affect operation and are they capable of analyzing off-normal situations and taking appropriate action to correct the cause(s) of problems?

2D.3.4.92 Is each operator capable of correctly interpreting the chemistry and process parameters for which he or she is responsible, and able to provide appropriate, timely, corrective action when required?

2D.3.4.93 Do operators inform appropriate process personnel before commencing evolutions, which may affect facility processes or require action from support technicians?

2D.3.4.94 Does the contractor maintain a list of the types of documents to be included in the required reading file, including procedure changes, equipment design changes, related industry and in-house operating experience information, and other information necessary to keep operations department personnel aware of current facility activities?

2D.3.4.95 Is a method in place to designate which documents need to be read by individuals filling each position? Is the reading file readily available to these individuals?

2D.3.4.96 Is a required completion date designated for reading each document?

2D.3.4.97 Is completion of reading assignments documented?

2D.3.4.98 Is the reading file periodically reviewed to ensure that all department personnel complete readings by the required dates?

2D.3.4.99 Are orders clearly written, dated, and maintained in the control room?

2D.3.4.100 Are operator orders issued by the operations supervisor or his/her designee whenever necessary to communicate instructions to the shift personnel?

2D.3.4.101 Are orders that are no longer applicable, or that are outdated, promptly removed or canceled?

2D.3.4.102 Are there administrative procedures or guides that define methods and format to be used to develop new procedures and to review existing ones?

2D.3.4.103 Do operations procedures conform to prescribed guidelines to provide uniformity among the procedures?

2D.3.4.104 Is the review and approval process for each procedure change or revision documented?

2D.3.4.105 Does the operations supervisor review and approve operating procedures?

2D.3.4.106 Are new and revised operations procedures reviewed prior to issuance and at periodic intervals to ensure that the information and instructions are technically accurate and that appropriate human-factor considerations are included?

2D.3.4.107 Are controlled copies of all operations procedures maintained in the control area for operator reference, with selected controlled copies maintained at other appropriate locations?

2D.3.4.108 Are facility operations conducted in accordance with applicable procedures that reflect the facility design basis?

2D.3.4.109 Are all facility personnel aware of the importance of controlling the posting of operator aids, (e.g., system drawings, maintenance procedures)?

2D.3.4.110 Are all operator aids approved by the operations supervisor or a higher authority?

2D.3.4.111 Are operator aids posted in a way that does not obscure instruments or controls?

2D.3.4.112 Are operator aids used only as a convenient supplement to, and not in lieu of, approved procedures?

2D.3.4.113 Is a listing maintained of all approved operator aids posted in the facility along with a copy of each aid?

2D.3.4.114 Are posted operator aids reviewed periodically to ensure they are still correct and necessary?

2D.3.4.115 Is labeling correctly applied to all of the following?

2D.3.4.116 Is the information on labels consistent with the information in facility procedures, valve lineup sheets, and piping and instrumentation diagrams?

2D.3.4.117 Are labels placed on or as near as practicable to the equipment?

2D.3.4.118 Are procedures established to ensure that misplaced or damaged labels are replaced and that labeling deficiencies are identified and corrected?

2D.3.5 Does the contractor have management processes and programs for developing safety analyses, which are used to develop and evaluate the adequacy of safety bases as specified in DOE 5480.23?

DOE 5480.23, Nuclear Safety Analysis Reports, establishes the basic requirements related to this area of the contractor's responsibilities. Each of these basic requirements is addressed by a major question, below, followed in most cases by generic assessment questions formulated to elicit objective or factual findings.

2D.3.5.1 Does the PSO designate in writing a contractor to perform a safety analysis, which is used to develop and evaluate the adequacy of the safety basis for each nuclear facility?

2D.3.5.2 Has the designated contractor performed the safety analysis in accord with DOE 5480.23, so that the safety basis analyzed includes management, design, construction, operation, and engineering characteristics necessary to protect the public, workers, and the environment from safety and health hazards posed by the nuclear facility?

2D.3.5.3 Does the contractor use written procedures to govern adherence to assumptions and commitments set forth in the facility safety analysis?

2D.3.5.4 Does the contractor prepare and submit to DOE a SAR to document safety analysis of each DOE nuclear facility under its cognizance?

2D.3.5.5 Does the contractor maintain up-to-date analyses of the safety of nuclear operations? Are analyses documented and located to facilitate a DOE audit?

2D.3.5.6 Does the contractor have well-defined procedures for keeping the PSOs and MFOs informed of the results of the nuclear facility safety analyses in accordance with DOE 5480.23?

2D.3.5.7 Does the level of detail and content of the SERs reflect the hazards involved and the risks associated with the operation or activity, (i.e., the graded approach to safety analysis)?

2D.3.5.8 Does the contractor include management and supervisory training requirements in accordance with DOE 5480.23 safety analysis provisions?

2D.3.5.9 Does the contractor request MFO approval of all temporary deviations from facility Safety Analysis Reports, Technical Safety Requirements, or Operational Safety Requirements regarding safety analysis requirements?

2D.3.5.10 Does the contractor have well-defined procedures to assess new safety issues, which arise from within the facility or from outside sources? Do the procedures include how to notify DOE?

Effective safety performance and compliance with safety requirements depend on the quantity and quality of resources, both human and capital, which are devoted to assessing and reducing risks. The determination of resources to be allocated to a facility must be based on the existing hazards, the applicable safety requirements, and the risks associated with the hazards. The business plans for a facility should clearly identify the needed resources and link them with the activities that will achieve compliance and minimize risk, as determined by the facility's missions and objectives. The timing of the resource allocations should be consistent with achieving the specific goals within the specified time frames. The DOE policy established in SEN-35-91 is applicable.

What resources are needed to meet DOE nuclear safety requirements is determined in part by assessing the safety concerns that apply at a given facility, and by studying instances where resources were not satisfactory to ensure safety in the past. Funds must be formally requested and appropriated in the budget process to meet nuclear safety requirements, and there must be a correlation between a facility's short- and long-term nuclear safety plans and the budget requests and appropriations. These requests and plans should take into account the historical difference between the requested budgets and actual appropriations in order to develop realistic projections of achievable progress toward regulatory compliance and risk minimization.

2E.1.1 Do the nuclear safety issues that arise at a facility or during an activity reflect resource deficiencies?

2E.1.2 Do budget requests reflect a detailed analysis of resources required to meet nuclear safety requirements?

2E.1.3 What are the historical differences between budget requests and allocated resources for safety improvements to meet requirements?

The quality and quantity of resources dedicated to nuclear safety at a facility or during an activity should correlate with the associated risks. Inadequate allocation of resources can lead to underachievement in safety performance and noncompliance with nuclear safety requirements. Overallocation of resources can result in inefficient performance, and even reduce the level of safety due to interference and confusion over spheres of control, objectives, missions, and means. Thus the assignment of nuclear safety resources to a particular facility or activity is to be based on the level of risk the activities pose to the public health and safety. The resources assigned are to be periodically reviewed to determine their effectiveness in achieving the stated goals and objectives, and to make any changes in allocation that are warranted.

2E.2.1 Are risk assessments used to allocate resources among facilities?

2E.2.2 Are risk assessments used to allocate resources within facilities?

2E.2.3 Is there a timely process for evaluating the effectiveness of resource allocation?

The quality and quantity of resources dedicated to nuclear safety at a facility or during an activity should correlate with the associated risks. Inadequate allocation of resources can lead to underachievement in safety performance and noncompliance with nuclear safety requirements. Over allocation of resources can result in inefficient performance, and even reduce the level of safety due to interference and confusion over spheres of control, objectives, missions, and means. Thus the assignment of nuclear safety resources to a particular facility or activity is to be based on the level of risk the activities pose to the public health and safety. The assigned resources are to be periodically reviewed to determine their effectiveness in achieving the stated goals and objectives, and to make any changes in allocation warranted. The importance of a positive safety culture is set forth as a principle in INSAG-3 and is the subject of INSAG-4. It is amplified by INPO good practices, and is stated as DOE policy in SEN-35-91.

The Secretary of Energy maintains that safety is the responsibility of line management. Oversight organizations can provide independent assessments of safety performance and technical support, but it is the line managers that must implement on a day-to-day basis the actions that enforce standards and minimize risk. Line managers must encourage development of a positive attitude toward and support of a safety culture by all employees. Managers must therefore ensure compliance with applicable safety standards, identify and promptly resolve deficiencies, audit safety performance, conduct training on facility safety standards, and demonstrate the importance of safety in the decision-making process.

2F.1.1 Do line managers document their endorsement of a nuclear safety culture as set forth in SEN-35?

2F.1.2 Do line managers establish and comply with safety standards for their organizations?

2F.1.3 Do line managers promptly resolve safety problems and deficiencies?

2F.1.4 Is there documented evidence of responsiveness to criticism and recommendations for improvement?

2F.1.5 Is there evidence of openness and mutual respect between line managers and those responsible for nuclear safety oversight?

Success in developing a safety culture depends on the knowledge and effectiveness of employees in recognizing and responding to safety deficiencies. In an organization with an acceptable safety culture, an open dialogue exists between employees and managers, which results in mutual support to achieve safety goals. Employees are aware and knowledgeable of the safety standards and policies that apply to their operations, readily accept constructive criticism from management and independent assessors that address safety performance, and are aware of how the nuclear safety principles support not only their own operations, but the accomplishment of the mission of the Department in achieving national security objectives.

2F.2.1 Do personnel respond constructively when safety problems or deficiencies are identified?

2F.2.2 Do personnel have a working knowledge of the safety standards applicable to their functional responsibilities?

2F.2.3 Do personnel know and understand safety objectives in terms broader than the scope of their assigned responsibilities?

Nuclear safety is a prime objective whose achievement must occur in tandem with the Department's other missions. Safety must be formally integrated with other program objectives so that each facility can accomplish its purposes in ways that afford adequate protection to public health and safety. Safe performance must be an established objective of each program, as demonstrated by policies, operational procedures, and audits whose importance is equal to, but does interfere with, that of other program objectives.

2F.3.1 Do program documents specifically address the need to carry out each program in a safe manner?

2F.3.2 Do program managers routinely evaluate safety performance along with performance of other program functions?

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