ML19140A331
| ML19140A331 | |
| Person / Time | |
|---|---|
| Issue date: | 07/22/2019 |
| From: | Brian Holian Office of Nuclear Security and Incident Response |
| To: | Baker B NRC/OIG/AIGA |
| Silas Kennedy | |
| References | |
| OIG-18-A-16 | |
| Download: ML19140A331 (6) | |
Text
B. Baker UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 July 22, 2019 MEMORANDUM TO: Dr. Brett M. Baker Assistant Inspector General for Audits Office of the Inspector General FROM: Brian E. Holian, Director /RA by M. Lombard for/
Office of Nuclear Security and Incident Response
SUBJECT:
STATUS OF RECOMMENDATIONS: OFFICE OF THE INSPECTOR GENERALS EVALUATION OF THE U.S.
NUCLEAR REGULATORY COMMISSIONS HEADQUARTERS OPERATIONS CENTER STAFFING (OIG-18-A-16)
This memorandum responds to your August 14, 2018, request (Agencywide Documents Access and Management System (ADAMS) accession number ML18227A009) for an update on the status of the recommendations of the Office of the Inspector General (OIG) report OIG-18-A-16, Evaluation of NRCs Headquarters Operations Center Staffing, dated June 21, 2018 (ADAMS accession number ML18172A159).
The staff has completed actions to address all three recommendations included in the report (see Enclosure). If you have any questions regarding this document, please contact the individual identified below.
Enclosure:
Status of Recommendations CONTACT: Silas R. Kennedy, NSIR/DPR (301) 287-0756
ML19140A331 OFFICE NSIR/DPR:OB NSIR/DPR QTE NSIR:D NAME S. Kennedy M. Scott C. Raynor B. Holian By
- via email M. Lombard DATE 06/21/19 06/28/19 07/10/19 07/22/19 STATUS OF RECOMMENDATIONS: OFFICE OF THE INSPECTOR GENERALS EVALUATION OF THE U.S. NUCLEAR REGULATORY COMMISSIONS HEADQUARTERS OPERATIONS CENTER STAFFING (OIG-18-A-16)
The audit report OIG-18-A-16, Evaluation of the NRCs Headquarters Operations Center Staffing, issued by the Office of the Inspector General (OIG) provided three recommendations.
Below are the OIGs recommendations followed by the NRC staffs responses and current status.
Recommendation 1:
Develop and document a HOO [Headquarters Operations Officer] workforce plan that defines the mission needs, workload, and skills and competencies of the HOO workforce to support achievement of program results.
NRC Staff Response (July 25, 2018)
The staff agrees with the recommendation.
Staff currently has existing guidance that speak to the mission needs, workload, and skills and competencies of the HOO workforce in separate documents. Staff will develop and update guidance to better define and integrate these areas to support achievement of program results.
The guidance will provide clarity regarding the work performed by HOOs and the resources required to accomplish the work.
Status The Office of Nuclear Security and Incident Response, Division of Preparedness and Response (NSIR/DPR) Procedure OB-1, Headquarters Operations Officer Staffing and Communications (Agencywide Documents Access and Management System (ADAMS) accession number ML19165A130), dated June 28, 2019, was developed and established as the HOO workforce plan. Procedure OB-1 defines the mission needs, workload, and skills and competencies of the HOO workforce to support achievement of program results.
The NSIR/DPR Operations Branch staff reviewed the NRC Incident Response Plan (Management Directive (MD) 8.2), as well as the NRCs Continuity of Operations (COOP) Plan and performed a staffing analysis and workload study with respect to the HOO/Headquarters Emergency Response Officer (HERO) job functions. Based upon these reviews and discussions with the HOOs, Operations Branch staff made several recommendations regarding changes to the position descriptions for HOO/HERO watchstanders. Updated position descriptions incorporating these recommendations were provided to the Office of the Chief Human Capital Officer (OCHCO) for review and approval on June 24, 2019. A summary of the staffing analysis and workload study, including the review of MD 8.2 and the COOP Plan, has been documented in new NSIR/DPR Procedure OB-1.
In addition, Annex B to NSIR Office Procedure TRN-700, Division of Preparedness and Response, Operations Branch, Headquarters Emergency Response Officer (HERO),
Headquarters Operations Officer (HOO) Qualification (ADAMS accession number Enclosure
ML19175A113), dated June 24, 2019, has been issued to clearly define the qualification and proficiency requirements for HOO/HERO watchstanders.
NSIR considers this action to be complete.
Point of
Contact:
Silas Kennedy, NSIR/DPR Recommendation 2:
Develop office guidance to conduct periodic assessment of the HOC [Headquarters Operations Center], to include staffing. Guidance should define
- Periodicity or triggering event for assessment.
- Stakeholders to be involved.
- Areas to be assessed.
NRC Staff Response (July 25, 2018)
The staff agrees with the recommendation.
Staff will develop a guidance document for periodic assessment of the HOO function, including staffing. The document will provide the governing process and criteria (i.e., periodicity or triggered) for when assessments are needed, and include guidance on the scope of the review and stakeholders involved. The guidance may be combined with the guidance document proposed for Recommendation 1.
Status NSIR management has recognized the importance of keeping the HOO function adequately staffed. As discussed in the status of Recommendation 3, below, specific measures are being taken to ensure adequate HOO staffing. NSIR management continuously monitors HOO staffing to ensure success in maintaining this staffing.
The Operations Branch staff will perform an evaluation each quarter of HOO full time equivalent (FTE) utilization. During our review of the OIG recommendations, staff determined that the use of excessive amounts of overtime hours is indicative of insufficient staffing. As a result, a preliminary trigger point based on total projected overtime hours logged by the HOO/HEROs has been set at 700 hours0.0081 days <br />0.194 hours <br />0.00116 weeks <br />2.6635e-4 months <br /> annually to determine when additional actions should be taken to address HOO staffing. This trigger point may be adjusted, and/or additional trigger points created through quarterly review of these evaluations. The requirement to perform a quarterly review of FTE utilization has been documented in NSIR/DPR Procedure OB-1.
A questionnaire was sent to internal NRC stakeholders on June 28, 2019, soliciting feedback on their experiences and opinions regarding HOO performance. Results of this survey will be used to inform training requirements for the HOO/HERO watchstanders or other changes to HOO operations. A survey is conducted biennially, and the stakeholders to be involved have been documented in NSIR/DPR Procedure OB-1.
NSIR considers this action to be complete.
Point of
Contact:
Silas Kennedy, NSIR/DPR
Recommendation 3:
Develop and implement a set of procedures to support human capital management and succession in the HOC, including
- Completed documentation of resource sharing with regions.
- Expedited hiring process for HOO positions.
- Backup pool of qualified HEROs and/or former HOOs.
- Formalize current communications initiatives and methods.
NRC Staff Response (July 25, 2018)
The staff agrees with the recommendation.
Staff will develop and implement guidance and procedures to support effective and timely management of HOO staffing, addressing items such as those noted in the OIG recommendation. Staff will document the process to develop, maintain, and integrate backup pools of qualified HEROs and former HOOs to support the HOO shift schedule. Staff will formalize the ongoing initiatives as part of the HOO procedures to enhance communication within and among the HOOs and Regional Operations Officers (ROOs).
Status By memorandum dated June 25, 2018 (ML18081A052), NSIR and Region IV management documented mutual expectations on resource sharing between headquarters and ROOs. The agreement, which is intended to minimize impacts on staff and to ensure a common understanding of expectations regarding regional support of the HOO function, is referenced in NSIR/DPR Procedure OB-1.
By memorandum dated February 26, 2019 (ML18323A400), NSIR and OCHCO management documented actions to be taken to implement a proactive staffing process for filling HOO/HERO vacancies. This proactive staffing strategy has subsequently been used to quickly and efficiently fill two recent HOO/HERO vacancies.
The Operations Branch staff developed a pool of backup HOO/HERO watchstanders who can be used to supplement the full-time watchstanders. Qualifications and proficiency requirements are documented into NSIR TRN-700 Annex B, Division of Preparedness and Response, Operations Branch, Headquarters Emergency Response Officer (HERO), Headquarters Operations Officer (HOO) Qualification (ML19175A113). Instructions for filling vacant shifts with backup pool personnel have been added to HOO Procedure G.4, Operations Center Scheduling Guidance (HOO procedures are maintained on the Operations Branch SharePoint site). In addition, the chief of the Operations Branch will periodically solicit (formally and/or informally) individuals to perform rotations in the Operations Branch as a HOO/HERO. Upon satisfactory completion of HOO and/or HERO qualification, the individual will be invited to volunteer to be a member of the backup pool with approval of the individuals supervisor. The requirement to maintain a backup pool of HOO/HERO watchstanders, and a target pool size, have been documented in NSIR/DPR Procedure OB-1.
Management has implemented several measures to enhance communication among the HOOs, ROOs, and management. A quarterly management forum has been developed to discuss key focus areas, such as staffing and the work environment, for the HOOs and ROOs. A Plan of the Day meeting is held daily between the HOOs, ROOs, and the Operations Branch support staff to discuss the days activities, issues occurring during the previous shifts, and general information. An expectation has been established for at least one member of NSIR management to visit Region IV every 6 months to meet with Region IV management and the ROOs. In addition, each HOO is expected to visit Region IV and observe operations of the Region IV Incident Response Center at least once every 3 years. These ongoing actions to enhance communications have been formalized and documented in NSIR/DPR Procedure OB-1.
NSIR considers this action to be complete.
Point of
Contact:
Silas Kennedy, NSIR/DPR