ML20148C651
| ML20148C651 | |
| Person / Time | |
|---|---|
| Site: | Maine Yankee |
| Issue date: | 12/31/1994 |
| From: | NRC OFFICE FOR ANALYSIS & EVALUATION OF OPERATIONAL DATA (AEOD) |
| To: | |
| Shared Package | |
| ML20148C622 | List: |
| References | |
| PROC-941231-01, PROC-941231-1, NUDOCS 9705270193 | |
| Download: ML20148C651 (61) | |
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EftCLOSURE 4 t-DIAiGNOSTIC EVALUATION TEAM l MANAGER'S HANDBOOK 1
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l DECEMBER 1994 REVISION 1 Diagnostic Evaluation and Incident Investigation Branch Incident Response Division Office for Analysis and Evaluation of Operational Data i
9705270193 970516 PDR ADOCK 05000309 y PDR
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PREFACE A Diagnostic Evaluation (DE) provides a wide range of challenges to the Senior Executive Service (SES) manager selected to lead the team. The broad, interrelated, and unique objectives, coupled with the diverse and large team composition, relatively short evaluation schedule, and high level interfaces require that the selected individual not only have a clear understanding of what is required of the team, and why, but also how and when needed implementing ctions are to be taken by whom. Several years of team evaluations, extensive experience and lessons learned have been accumulated regarding the norms and good practices for effective Diagnostic Evaluation Team (DET) management. From a team manager's perspective, application of the norms and good practices can help to optimize the success and impact of the team. At the same time, the newly selected DET manager in most cases has not had the benefit of the knowledge of those practices through prior DET manager l
experience and training. The purpose of this handbook is to supplement l
Management Directive (MD) 8.7, NRC Diagnostic Evaluation Program and provide
- additional focused direction to aid the selected DET manager in getting ,
- oriented as to his/her roles and responsibilities as well as the norms and l
! good practices for carrying out the assignment. It is not intended that this l
handbook restrict the DET manager beyond MD 8.7 or stifle creative thoughts l that could lead to future imprdvements in the process.
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TABLE OF CONTENTS EEf 1.0 PURPOSE 1
2.0 INTRODUCTION
1 3.0 GENERAL GUIDANCE 1 3.1 Goals and Objectives of the Diagnostic Evaluation Team 1 3.2 Organizational Structure and Interfaces 2 3.3 Roles and Responsibilities 2 3.3.1 Diagr.cstic Evaluation Team Manager 2 3.3.2 Office for Analysis and Evaluation of l Operational Data 4 ,
! 3.3.2.1 Directors Office for Analysis and
- Evaluation of Operational Data 4 3.3.2.2 Director, Incident Response Division 5 E
3.3.2.3 Chief, Diagnostic Evaluation and .
Incident Investigation Branch 5 3.3.3 Region 5 3.3.4 Office of Nuclear Reactor Regulation 6 3.3.5 Functional Area Leader 6 3.3.6 Diagnostic Evaluation and Incident Investigation Branqh Staff 7 3.3.7 The Diagnostic Evaluatirn Team Administrative Assistant 7 l 4.0 PLANNING AND PREPARATION 8 4.1 Objectives 8 4.2 Team Manager Responsibilities 8 4.2.1 Orientation 8 4.2.2 Plant Performance Review 9 4.2.3 Areas of Concern 9 i 4.2.4 Evaluation Plans 10 i 4.2.5 Communications 11 ,
4.3 Diagnostic Evaluation and Incident Investigation Branch Responsibilities 11 4.3.1 Scheduling 11 4.3.2 Team Composition- 12 l
4.3.3 Team Meetings 12 l
4.3.4 Proposed System for Review 12 4.4 Functional Area Leader Responsibilities 12 4.5 Administrative Assistant Responsibilities 13 4.6 Region Responsibilities 13 4 . 7. Office of NRR Responsibilities 13 4.8 Office for AE00 Responsibilities 13 ii l
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4.9 Additional References and Readings 13 4.10 Documents Prepared by the Diagnostic Evaluation Team Manager 14 5.0 ONSITE AND IN-0FFICE EVALUATION PERIODS 14 1 5.1 Objectives 14 5.2 Team Manager Responsibilities 15 5.2.1 Entrance Meeting 15 5.2.2 Implementation of the Evaluation Plan 15 5.2.3 Participation As An Evaluator 15 5.2.4 Diagnostic Evaluation Observation Forms 16 l 5.2.5 Daily Team Meetings 16 1
5.2.6 Special Topic Meetings 17 5.2.7 Interim Exit Meetings 17 l 5.2.8 Communication 18 5.2.8.1 Team 18 5.2.8.2 Licensee 19 5.2.8.3 Region 19 l
5.2.8.4 AE00 Management 19 l 5.2.9 Immediate Safety Concerns 19 l 5.2.10 In Office Review 20 l 5.2.11 Team Meeting to Summarize Findings 20 i 5.2.12 Preliminary Root Cause Analysis 20 l 5.2.13 Diagnostic Evaluation Team Member Personnel
- Issues 20 5.3 Functional Area Leader Responsibilities 21 5.4 AE00 Management Responsibilities 21 5.5 Administrative Assistant Responsibilities 21 i 5.6 Region Responsibilities 21 l 5.7 Additional References and Readings 22 i 6.0 DOCUMENTS AND COMMUNICATION OF RESULTS 22 l
6.1 Objective 22 l 6.2 Responsibilities of the Team Manager 22 6.2.1 Report Preparation 22 6.2.2 NRC Senior Managers Briefing 23 6.2.3 Licensee Exit Briefing 24 6.3 Functional Area Leaders 24 4 6.4 Region and Office of NRR 24 6.5 Office for AE00 24 6.6 Administrative Assistant 24 6.7 Sample Documents 25 Attachments: <
- l. DET Manager's (Fictional) Notes from Senior NRC Management Meetings i
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I 1A PURPOSE The purpose of this handbook is to supplement Management Directive (MD) 8.7, )
NRC Diagnostic Evaluation Program and provide additional focused direction to aid the selected DET manager in getting oriented as to his/her roles and responsibilities as well as the norms and good practices for carrying out the assignment.
2.0 INTRODUCTION
This handbook is organized into sections corresponding to-the " phases" of a diagnostic evaluation: preparation and planning; onsite evaluation; report preparation and communication of results and follow-up. The presentation in each section is provided in varying levels of detail. Each section begins with a summary of the team goals and objectives for each phase. This is followed by more general statements as to "what" is required in terms of the roles and responsibilities of the DET manager and related NRC interfaces and, is followed by more detailed discussions of the good practices of how and when actions are taken to implement these duties. It allows the DET manager to review items down to the level of detail desired. Managers with various degrees of previous team leader inspection experience will be able to review (at the level'~of detail desired) infordtion that is identified as " good practices" as well as ideas that are considered to be the " proven way of doing business" to assist them with the task of managing a DET. The discussion for each phase concludes with a section which lists supplemental relevant reference. reading material and a section with sample documents which the DET manager usually prepares. As in any program, areas for improvement exist. !
The areas that have encountered " pitfalls" during previous diagnostic l' evaluations have been evaluated during DET lessons learned meetings. The suggested practices to address the lessons learned from previous des are included in the handbook.
3.0 GENERAL GUIDANCE This section of the manual provides overall goals and objectives of the diagnostic evaluation team (DET), organizational structure and interfaces, as well as the roles and responsibilities of the DET Manager; Office for the Analysis and Evaluation of Operational Data (AE0D) Management; the region *;
functional area leaders; the Diagnostic Evaluation and Incident, Investigation Branch; and the DET Administrative Assistant.
- Note: Unless otherwise specified, " region" is defined as the region in which the Diagnostic Evaluation is conducted.
3.1 Goals and Objectives of the Diagnostic Evaluation Team The overall mal of the diagnostic evaluation is to provide an independent assessment of licensee safety performance at the selected reactor facility.
Objectives of the diagnostic evaluation are to:
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- Provide supplemental information to enable Nuclear Regulatory i Commission (NRC) Senior Management to nake more informed assessments I of current safety performance at the plant. .
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- Evaluate (in a. performance and safety-oriented framework) the j actions and effectiveness of licensee management and staff in safe I plant operations.
- Identify strengths and weaknesses in safety performance. I l
- Determine root cause(s) of safety performance problems, the I
effectiveness of related licensee safety improvement programs and the need for additional corrective actions. 1 1
3.2 Organizational Structure and Interfaces This section of the manual describes the organizational structure of the DET and the interfaces of the DET manager with respect to other organizations. An organization chart is provided in Figure 1 to orient the DET manager's position in relationship to the team, various NRC support organizations, and NRC management over ght functions. ,
3.3 Roles and Responsibilities I
This section describes the primary roles and responsibilities of the DET j manager and those of his or her NRC interfaces for each phase of the DE.
3.3.1 Diagnostic Evaluation Team Manager i
! The DET manager has responsibility for managing the team for the assigned diagnostic evaluation. Responsibilities include:
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- Meet with NRC Senior Management to determine their areas of special ,
l interest for the DE.
- Ensure adequate preparation of the site-specific diagnostic evaluation ;
plan is performed and submit it to the Director, AE00 for approval. 1
- Direct and manage the DET during the evaluation process and ensure that the objectives and schedules of the evaluation plan are met.
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- Serve as the spokesperson for DET. activities when interacting with the licensee on significant matters involving the evaluation. This includes providing regular briefings for the licensee to ensure that DET factual findings and concerns are understood and followed up by the licensee.
- Represent the DET in any Press briefings.
- Keep the Director, AE00, informed of the DET progress and findings.
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- Interact with NRC offices and other organizations as required during the course of the evaluation process.
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- Make recommendations to the Director, AE00, regarding any additional
+ resources needed (e.g., additional team members, consultants, contractor assistance) to fulfill the scope and objectives of the l
evaluation.
i a Brief the Executive Director for Operations (ED0), the Regional ,
Administrator, and the Directors for the Offices of Analysis and j Evaluation of Operational Data and Nuclear Reactor Regulation (NRR), ,
on DET findings, conclusions and root causes, and communicate team l recommendations for NRC staff follow-up actions.
- Ensure preparation of the DET report, the report transmittal letter, and the NRC staff action memorandum (to NRC program offices, AE0D and the Regional Office) and submit them to the Director, AE00 for approval. i
- Lead the two interim exit meetings following the onsite periods of
- the evaluation and prepare and participate in the final public exit meeting with licensee senior management.
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- Brief and document for the Director, AEOD, and other NRC personnel
,as appropriate, the programmatic lessons learned from the DE.
- Recommend in a memorandum to the Regional Director, Division of ,
Reactor Projects, the inspection credit which may be applied to the 2515 inspection program, as a result of the Diagnostic Evaluation.
j 3.3.2 Office for Analysis and Evaluation of Operational Data
! 3.3.2.1 Director, Office for Analysis and Evaluation of Operational Data s
The Director, AE00, is responsible for providing guidance, oversight and review for the DET during each phase of the diagnostic evaluation process.
3 Responsibilities of the Director, AE00 include: ,
- Approve and submit the site-specific Diagnostic Evaluation Plan to the
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- Keep the EDO, informed of the DET's findings.
- Coordinate the DET's recommendations with the Director, NRR, and the
! Regional Administrator.
- Act as the lead NRC representative during the exit meeting with the licensee's senior management on major findings and conclusions.
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- Review of results of the diagnostic evaluation for consistency with j programmatic requirements.
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- Approve and submit the DET report to the ED0; ensuring emphasis on the adequacy of safety performance and the discussion of root !
i cause(s) of identified problems.
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Monitor and document the status of ED0 required followup staff
- a actions on potentially generic issues identified by the DET.
3.3.2.2 Director, Incident Response Division The Director, Incident Response Division (IRD), AE00 assists the Director, l
, AE0D, in establishing and providing guidance, direction, and oversight to the 1
. diagnostic evaluation team. The specific responsibilities of the Director, IRD include:
l = Coordinate with other NRC offices in the selection of proposed DET members including the DET manager.
1 a Assist the Director, AE00, in providing guidance, direction, and i oversight of the DET throughout the diagnostic evaluation process.
Assist the Director, AE00, in the review of the diagnostic
- j evaluation results for consistency with programmatic requirements. 1 3.3.2.3 Chief, Diagnostic Evaluation and Incident Investigation Branch 5 e .h ~
.) i The Chief, Diagnostic Evaluation and Incident Investigation Branch (DEIIB)
- manages the Diagnostic Evaluation Program (DEP) and assists in the implementation and follow up for each plant-specific DE. Specific responsibilities of the Chief, DEIIB include
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= Assist the Director, IRD in the selection of proposed DET members.
- Serve as the acting DET manager during the planning and preparation phase until relieved by the selected DET manager.
- Provide an experienced core of evaluators for the DET.
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- Provide DEIIB staff for team planning and preparation and assists in J the review of DET report preparation. )
= Control implementation of any changes to the DET report, report
- transmittal letter, and staff follow-up actions after approval by the Director, AE00.
3.3.3 Region a Regional responsibilities include: '
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- Provide personnel from the DET roster to serve as DET members for j the duration of the evaluation and report preparation activities.
(Normally the region in which the selected DET plant is located will not provide personnel for the DET.)
- Provide input to the DET Manager on the perceived performance of the j licensee.
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- . Provide input on the documented site-specific evaluation plan, the DET report transmittal letter, and proposed follow-up staff actions.
- Lead the review of the licensee response to the DET report and track licensee actions taken to address significant DET findings. This will be carried out with appropriate support from AE00 and NRR.
- Review the functional area evaluation results (and plans), in coordination with the DET manager, to evaluate the credit which may i be taken per NRC Inspection Manual Chapter 2515.
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- Participate in the DET exit meeting with the licensee.
3.3.4 Office of Nuclear Reactor Regulation
{ NRR responsibilities include:
- Provide personnel from the DET roster to serve as DET members for j
the duration of the evaluation and report preparation activities.
- Provide input to the DET Manager on the perceived performance of the licensee. J - J
- Provide input on the documented site-specific evaluation plan, the DET report transmittal letter, and proposed follow-up staff actions.
- Support the review of the licensee response to the DET report and ,
the tracking of licensee actions taken to address significant DET 1 findings. j
- Participate in the DET exit meeting with the licensee.
3.3.5 Functional Area Leaders l Responsibilities of a functional area leader (FAL) ielude:
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- Ensure completion of needed planning and preparation activities of
- assigned functional area members.
- Prepare and submit a detailed functional area evaluation plan to the DET manager for review and approval.
- Provide first level guidance, _ direction, and oversight of functional area team members including contractors where applicable.
- Ensure that significant field observations of the functional area members are documented on the DET's Diagnostic Evaluation Observations (DEO) forms.
- Act as the lead spokesperson for the functional area in DET meetings and in communications with the licensee counterparts.
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- Ensure documentation of the significant findings and conclusions for
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the functional area in the DET report.
i e Assist the DET Manager in the determination of root causes.
- Review the draft report and comment and edit as necessary.
Suggest potential follow up staff actions related to the assigned functional area.
- Participate in lessons learned meetings.
3.3.6 Diagnostic Evaluation and Incident Investigation Branch Staff .
l The duties of the Diagnostic Evaluation and Incident Investigation Branch (DEIIB) staff include:
- Provide support to the DET manager for planning, scheduling, and i implementation of team preparation activities and correspondence prior to the initiation of on-site evaluation activities'.
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- Provide indoctrinatibn and training to the DET during the planning and preparation phase of the evaluation.
- Serve as a core of experienced evaluators and team leaders for each j DE.
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- Copy and distribute the final DET report, transmittal letter, and i staff actions memorandum after approval by the EDO.
- Coordinate the DET's review of the licensee response to the DET
! report and track and document the resolution of generic staff 4
actions assigned by the EDO.
- Coordinate and address lessons learned for completed des.
l 3.3.7 The Diagnostic Evaluation Team Administrative Assistant i The detailed responsibilities of the DET administrative assistant are i i documented in the DET Administrative Handbook. Responsibilities include:
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- Participation on the " bagman" trip to the site ( with the consent and approval of the DET manager) to get oriented, meet the licensee l 1 counterpart, and to arrange for badging and site access training (if l required). !
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- Establish'and manage the " library" of reference documents requested, received, and reviewed by the DET.
- Coordinate travel plans for the DET and ensure travel arrangements (hotel reservations, rental cars, etc) for AE00 personnel.
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- Arrange for office space, furniture, telecommunication equipment, office 'stpplies, and miscellaneous logistical and administrative needs c' the DET while at the licensee's facilities (plant and corporate-offices).
- Coordinate and maintain the daily schedule of DET member interviews with licensee personnel.
- Establish, maintain and distribute (as necessary) a composite file of the diagnostic evaluation team's DE0s prepared for each l functional area. l 1
- Communicate time and attendance information to,the respective time l and attendance clerk of each team member while on site.
l e Ensures that all report document files are compatible and consistent.
l 4.0 PLANNING AND PREPARATION This section of the manual' provides detailed guidance for the DET manager for the planning and preparation phase of the diagnostic evaluation. It indicates who normally is assigned as the lead group for completing these tasks and-the l manager's interfaces during these tasks.
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l 4.1 Objectives The objectives for this phase of the diagnostic evaluation are to:
- Schedule the DE and prepare all needed notification correspondence.
- Establish the team composition and membership.
- Indoctrinate the team on the methods, process, procedures and i product of a DE.
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- Assimilate performance information on the licensee and plant to I
! develop a picture of performance as perceived by others. i l
- Prepare an integrated diagnostic evaluation plan and functional' area
- j. level evaluation plans to meet the generic and plant-specific h objectives for the evaluation. .
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t 4.2 Team Manager Responsibilities 4.2.1 Orientation The DET manager should schedule a meeting (s) with the Director, AE0D, early in the assignment to receive direction and guidance on the scope and objectives of the DE and the responsibilities and authorities of the DET manager. Since many preliminary planning and preparation activities may be underway, he/she should meet with the Chief, DEIIB to determine the status of activities associated with the DE.
To obtain a good understanding of the diagnostic evaluation process, l procedures, and documentation requirements, the DET manager should review Management Directive 8.7, DET Manager's Handbook, the DET Guidelines, and read i
! one or more DET reports of which the current prototypes are the the Zion and l Palisades, Quad Cities, and South Texas DET reports. The DET manager should l also read Section 3.5.1 of the DET Guidelines, Revision 4, " Control Of The DET i Report After Approval By Director, AE0D." Section 3.5.1 of the DET Guidelines gives control of the DET report after approval by the Director, AE0D for all distribution, report revisions, and ED0-requested changes of the DET report to ,
the Diagnostic Evaluation and incident Investigation Branch, AE00. The DET manager should also become familiar with Section 3.7 of the DET Guidelines, l
" Credit For MC 2515 Inspection Procedures." Briefly, this section discusses l that the region can take credit for applicable inspection effort by the DET l after an assessment has been made by the region. l If questions arise, the DET manager should discuss the DE objectives or i
! process with the Director, IRD, the Chief, DEIIB, or the functional area leaders from the core team of the DEIIB.
l l It is expected that the office or region which furnishes the DET manager will pay for all DET related travel costs. Travel authorizations and vouchers must be. processed by the SES manager's office.
4.2.2 Plant Performance Review l I
l The DET manager (and each of the team members) should develop a picture of performance (both strengths and weaknesses), improvement initiatives, and ;
issues (as perceived by others) in the functional areas to be evaluated by the !
DET through licensee and NRC document reviews, discussions, briefings, and if l
l possible an on-site visit and plant tour as part of the advance trip to the l facility. The DEIIB staff will obtain and make available a standard set of documents for review such as Systematic Assessment of Licensee Performance l (SALP), Inspection reports, Licensee Event Report (LER) trends and pattern l studies, and senior management meeting input for review. These, plus the l documentation provided by the licensee, should be reviewed. Briefings by NRR l projects personnel and Regional staff at the initial team meetings will
! provide additional perspectives. The goal is to become knowledgeable of these performance perspectives of others without establishing a predisposition or a bias on the safety performance of the licensee.
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- 4.2.3 Areas of Concern The DE team needs to develop a clear understanding of the specific mission interests (area of focus) of the NRC senior management for the upcoming DE.
The DET manager should schedule and conduct meetings with the Regional Administrator and the Directors, NRR and AE00, to understand the basis for the
! evaluation and the areas of special concern. These meetings should be l conducted with the participation of the Chief, DEIIB, the M&O team leader, l
and, as appropriate, other team leaders of functional areas for which significant senior manager concerns are anticipated. The DET manager should also consider meeting with the NRR project manager and the resident inspector to obtain additional insights and background information. The interviews also should be used to confirm the expertise required to perform the evaluation.
Some questions the DET manager should be prepared to answer are listed below.
- What factors in your view were the basis for selecting this licensee for a diagnostic evaluation?
. What are the two or three key questions which the team must answer with respect to the plant for the effort to be successful?
. In which functional areas should the team have a heightened emphasis or focus, what aspects. and why?
l l . Are there any programmatic issues which need special emphasis?
. Are there any management or organizational concerns or questions of special importance? Are there any " safety culture" issues which need to be looked at?
. Are there any functional areas which should get less emphasis for
! some reason such as overall good performance (trends) an important area for evaluation?
The DET manager should document and discuss the basis for plant selection and the areas of concern with the team leaders / members. A sample document of the results of the DET manager's discussion with NRC Senior Managers is provided l in E tion 4.9. The DET manager should avoid over emphasis and excessive l commitment of team member time and attention to the evaluation of the identified areas of concern. The manager should be mindful that a DE should be a broad-based assessment and the areas of concern are not necessarily based l
on past and potentially outdated performance information. The manager should
- also understand that root causes are of major interest to NRC management.
Therefore the determination of probable root cause(s) is an important part of the DET mission and report. The importance of root causes should be underscored during team planning and preparation meetings.
! 4.2.4 Evaluation Plans With the support of the DEIIB, the DET manager should prepare an integrated plant-specific diagnostic evaluation plan. The plan must be submitted to the Director, AE00 for approval. DEIIB will provide a draft of the evaluation t
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i j plan to the DET manager for final revision. The DET manager shnuld take a I leading role in preparing the sections of the plan dealing with the basis for l the plant selection and Senior Management's areas of concern.
! With the support of the DEIIB staff, the DET manager should provide guidance and direction to the functional area team leaders on the preparation of i
evaluation plans including the evaluation of the areas of special concern. The l DET manager should ensure that the evaluation remains broad-based. Each functional area plan should be broad in scope as illustrated in sample plans filed with the DEllB " functional area coordinators". Plans for the evaluation of the areas of concern should also be adequately addressed in the plans. The DET manager should ensure that performance reviews, program evaluations and management and organizational assessments are addressed in each functional area plan. In cases where the FALs are experienced core team members of the l DEIIB staff, only limited guidance and direction is generally needed during the planning phase.
Once the plan and areas of concern are identified, documented, and reviewed by
- the Director, AEOD, the NRC senior managers should be briefed on the plan. The l ED0 briefing is conducted after the Directors, AE00 and NRR, and the Regional Administrator have been briefed. The ED0 will normally provide any additional 1 areas of M
- oncern or4rection at his briefing. These meetings will normally l
l be attended by the Director, AE00 and should be arranged by the DET manager.
4.2.5 Communications 1
In coordination with the DEIIB staff and the administrative assistant, the DET manager shall serve as the team liaison and senior representative in communication with the licensee's senior point of contact during the planning 1 and preparation activities. The DET manager should prepare and discuss with !
the team the schedule, outline and assignments for preparing the team report. l This is normally accomplished at the second planning meeting before the team l leaves for the site. l 4.3 Diagnostic Evaluation and Incident Investigation Branch Responsibilities 4.3.1 Scheduling i The DEIIB staff will perform many of the initial actions required for the diagnostic process. Their specific responsibilities are to schedule and provide the required notifications for the diagnostic evaluation.
I They will arrange and coordinate the advance team visit / licensee briefing with the coordination and participation of the DET manager. The DET manager should participate in the advance trip and provide the licensee with a short presentation on the purpose and process of des, establish initial face-to-face contact with licensee senior representative, obtain the name and position of his or her counterpart or point of contact for his or her daily debriefings
. with the licensee, and go on a short familiarization tour of the facility. The DET manager should answer any licensee questions and make arrangements for the i- entrance meeting (date, time and location). The DET manager may offer the 4 licensee the opportunity to make a short (approximately 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />) presentation 10
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l at the entrance meeting involving areas such as performance trends improvement l programs, organizational changes, outage plans which would help orient the l
team about recent activities and initiatives at the plant.
l The DEIIB staff drafts all sections of the diagnostic evaluation plan l
exclusive of the areas of senior NRC management concern. Other functions of the DEIIB staff are to obtain site access authorization for all team members ;
and make logistics arrangements for the onsite phase.
l The DEIIB staff provides support for the development of the detailed i
functional area evaluation plans (DET Guideline 1) and obtains contractor I support for the DE.
4.3.2 Team Composition With the concurrence of the DET manager, the DEIIB staff develops and defines the required team composition, identifies team members for selection, and i obtains agency management commitments for providing the identified personnel. l Although AE00 will take the lead in obtaining team member support for the DET, '
the DET manager may elect to participate in the process. As a minimum, the DET manager is expected to endorse the individuals proposed for ED0 approval.
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I The DET manager should be aware of the available time and money for contractor support. By procedure, changes to the level or length of contractor support must be concurred in by the AE00/DEIIB project officer. Only the Division of i Contracts, Office of Administration has the authority to modify contractor j task orders. It is the responsibility of the contractor organization to ensure that DET contractor members meet the contract security requirements for unescorted access to nuclear power plants (10 CFR Part 10 and NRC Appendix 2101, Part VI).
4.3.3 Team Meetings In coordination with the DET manager, the DEIIB staff plans, organizes and coordinates team member attendance for the team planning meetings at NRC headquarters. With the participation of the DET manager, the DEIIB staff plans and conducts team planning and training meetings. The team manager will approve tho meeting agenda and run the team meeting. Regional and headquarters staff presentations for the team meetings preparations will be arranged by.the DEIIB staff.
4.3.4 Proposed System for Review DEIIB will select one or more system (s) for a " safety system functional inspection type" review by the DET. The selected system (s) will be based on several factors such as, accessibility, safety significance, major modifications performed on the system, and problems with the system (s). The DET manager will be briefed on the proposed system (s) for concurrence.
Normally the system (s) selected for the DET will be withheld from the licensee until the advance trip to avoid providing the licensee with excessive time to initiate previously unplanned evaluations or remedial actions on the system (s)
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l in advance of the teams arrival on site. The team should be aware that such preparations will often occur in any case.
l 4.4 Functional Area Leader Responsibilities
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FAls provide oversight and direction to functional area team members to ensure required preparations of each functional area member. They develop, In coordination with functional area members, a picture of performance
) improvement initiatives, and issues (perceived by others) for the assigned functional area. The FAls prepare and submit to the DET manager detailed The DET manager approves detailed l
functional area evaluation plans.
i functional area evaluation plans. The FALs also initiate contact with the licensee counterparts.
The DET manager should coordinate plans and assign lead responsibility for determining probable root causes. The DET manager frequently delegates the lead for developing and documenting root causes to the M&O functional area leader. Plans, schedule, and responsibility for developing and documenting the root causes should be agreed upon no later than the second team meeting.
4.5 Administrative Assistant Responsibilities The administrative assistant will act as the point of contact for the team for logistical, administrative needs, and document requests. He or she sets up and administers the DET library and requests documents for and after the
" bagman" trip. The assistant develops and provides daily updates for the interview schedules and supports the DET manager in the planning and execution of all administrative activities.
4.6 Region Responsibilities The region will provide knowledgeable staff to provide briefings to the team
- regarding plant performance. The region provides input on the areas of ,
special interest for evaluation by the team. The region obtains site access l I
clearance from the licensee for team members in accordance with the requests of the DEIIB staff. The Regional Administrator reviews and provides concurrence on the diagnostic evaluation plan.
The region will identify the senior regional representative who will evaluate l the credit which can be applied to the MC 2515 program. The DET manager !
l should be aware of the potential areas for applying credit after the evaluation is completed. With the Input and assistance of the FALs, the DET l manager and regional representative will jointly concur on proposed credits i
after the evaluation is completed. The DET manager should ensure that the
! areas of potential credit (e.g., evaluation plans) are communicated to the regional representative before the onsite evaluation.
I 4.7 Office of NRR Responsibilities j
NRR will provide knowledgeable staff to provide briefings to the team
' regarding plant performance. NRR provides input on the areas of special 12
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l interest or concern for evaluation by the team. The Director, NRR reviews and provides concurrence on the diagnostic evaluation plan.
4.8 Office for AE0D Responsibilities AEOD management will discuss DET goals and objectives, responsibilities and authorities for the DET manager, and performance expectations.
l 4.9 Additional References and Readings l
l 1. Management Directive 8.7, NRC Diagnostic Evaluetion Program
! 2. Diagnostic Evaluation Team guidelines j 3. Sample diagnostic evaluation plans i
- 4. Diagnostic Evaluation Team Reports 4.10 ' Documents Prepared by the Diagnostic Evaluation Team Manager a
Sample notes from NRC senior management interviews (see Attachment 1) 1 i
- Diagnostic Evaluation Team entrance meeting talking points (see DET t
Guidelines Section 3.6) l DET exit meeting notes (see the FitzPatrick DET report appendix) l 5.0 ONSITE AND IN-0FFICE EVALUATION PERIODS
- -This section of the manual provides detailed guidance for the DET manager for i the onsite and in-office evaluation periods of the diagnostic evaluation. It indicates which group is normally assigned as the lead to complete each task l and the manager's responsibilities for that task.
5.1 Objectives The objectives for this phase of the diagnostic evaluation are to:
Implement the evaluation plan to determine:
. Licensee performance and programmatic effectiveness in each functional area Adequacy and effectiveness of licensee improvement initiatives Management involvement and resolution of problems related to safe plant operations Safety significant weaknesses in organizational environment Any noteworthy strengths and safety significant weaknesses for
, each functional area i
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- Probable root causes for identified safety significant i 7 t L performance weaknesses t
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- Significant' problems /causes not adequately addressed by licensee l corrective action. programs l
- Prepare sufficient documentation of technical, programmatic, management'and organization and root cause findings to support preparation of the DET report and briefings of NRC senior management .
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- Keep the licensee informed of the team's significant findings l l
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- Keep AE00 management informed of team findings
- Maintain liaison with the regional office on immediate safetl, j I
Concerns.
5.2 Team Manager Responsibilities 5.2.1 Entrance Meeting i The DET E nager wil?honduct the entrance meeting. At this mee' ting he or she l vill introduce team members, discuss the purpose and scope of the evaluation, i evaluation _ techniques used, evaluation objectives and schedule, establish !
communication chx..,rwis and protocol, and request assistance in obtaining resources and inforraation in specific areas (see Section 4.9, Sample Documents i Prepared By The DET Manager and Attachment 1).
5.2.2 Implementation of the Evaluation Plan The DET manager should ensure accountability for thorough implementation of the functional area evaluation plans is maintained by the FALs. The DET manager should provide guidance and direction as needed on areas that may need special evaluation or emphasis. He or she should periodically meet with the FALs to review plans and progress and assist in resolving significant l
evaluation problems. -These meetings are in addition to the daily team meeting.
The DET manager should provide direction and oversight to help ensure that the programmatic weaknesses are based on identified performance and not based
-solely on notential problems which could be caused by weaknesses in the programmatic documents.
The DET manager should en:;ure that the "SSFI-related" evaluations are allowed to selectively broaden to other systems or components as the functional' area evaluations tit.d problems within the selected system (s). This will allow the team to determine if weaknesses are 'also found on other systems (e.g.,
j' weaknesses in check valve te-sting).
l The DET manager should ensure that the evaluation is conducted consistent with
- the NRC backfit policy so as to avoid any undue regulatory burden on the i
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licensee. Specifically, communication of safety performance issues to the licensee should not result in unreviewed NRC plant-specific backfits.
5.2.3 Participation As An Evaluator
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! The DET nanager should act as an evaluator during the on site evaluation to provide cuality verification of selected team findings. The DET manager should participate in interviews of key licensee managers and if possible with other licensee personnel to obtain direct first-hand input on interview information provided by the licensee. This enables the DET manager to more effectively contribute to the evaluation and to provide a quality assurance perspective of the documented che 'cterization of significant team findings j prepared for the DET report. l
! 1 The DET manager should arrange with the licensee for the team to review the most recent Institute of Nuclear Power Operations (INP0) evaluation during the middle of the third week on site. This will allow the team to compare the findings it obtained during the three week on site period to the most recent INP0 findings.
l Issues that arise that are potentially of an immediate safety concern should i I '
be used to eva'luate how tde licensee responds to such things as operabilMy issues (and determinations) and Limiting Conditions for Operations (LCO). The j effectiveness of licensee communications and the amount of conservatism in '
operating philosophy can be judged on a first hand basis in many cases. Thus
! for some issues identified by tha DET,.it aay be i: .rmative to observe how 1 l the organiz d m and management respond to the issues before they are presented to heensee management as a concern. However, such delays cannot be applied to issbcs of immediate safety concern.
The DET manager should be cognizant of the interview scheduling process and I
resolve conflicts if necessary. Initial interviews are broad-based and informative and several people may wish to sit in on the upper level licensee management interviews. However, when detailed, issue-oriented information becomes involved later in the evaluation period, it is prudent to have no more than two interviewers per interviewee. It should also be noted that the l higher level licensee management personnel may be used to speaking to several l people at once, but the lower level workers are not and may be hesitant about
! providing information. Therefore the DET manager should monitor the interview l
schedule with respect to an excessive amount of interviewers per interviewee as well as licensee personnel being interviewed too many times.
5.2.4 Diagnostic Evaluation Observation Forms l The DET manager should remind (as needed) team leaders of the importance of l documenting findings or observations on diagnostic evaluation observation
- (DEO) forms. DE0s for findings presented at a team meeting should be handed in to the DET manager no later than 1/2 h wr before the DET manager is scheduled to debrief with his counterpart the following day. The manager must ensure quality and timely communication and documentation of findings. DE0s i should be updated to provide a "living" record of evaluation progress and to i
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I document licensee corrective actions and who identified the item (e.g., the !
licensee or the DET). Licensee corrective actions (or plans) may or may not already be underway and this should be documented. Tne FALs should ensure the DE0s are correct. DE0s are pre-decisional and may be reviewed by NRC regional personnel but the licensee shall not be provided any written material while the team is onsite. The administrative assistant is responsible for compiling, maintaining and distributing DE0s to the team on a daily basis l after each team meeting.
When findings identified and documented by one functional area (e.g., i maintenance) are more appropriately considered findings in another functional area, (e.g., engineering) the DET manager should ensure that the later functional arna includes these findings in its integrated assessment documentation.
5.2.5 Daily Team Meetings The daily team meetings are used for sharing observations, findings, and technical information. The DET manager should run the daily team meetings.
l The length of the meeting should be targeted for one hour and should very l
rarely exceed 1-1/2 hours to avoid undermining team morale. In general, team l , meetings should be held at the'end of each work day onsite, and at the same l pre-planned time. They should be conducted after the FALs have de-briefed with their counterparts. The meeting presentations for each functional area should be limited to 10 to 15 minutes maximum, and follow the same order of functional area presentations each day. Presentations must focus on what was found rather than what was done during the day. Individuals selected for making presentations should be left to the discretion of the FALs.
Corroborative or clarifying discussions by other team members is encouraged but must be secondary to the presentation of findings.
The DET manager should present his perspectives from his interviews and observations completed during the day and provide feedback to the team regarding the daily meetings with the senior licensee contact. Information of concern to only a limited number of team members should be deferred until after the team meeting. The DET manager should encourage identification of findings regardless of whether the root cause for the finding has been established. Root cause determination comes later. Significant findings and root cause determinations may evolve from team discussions of narrow issues that, when pieced together, identify a problem. Do not suppress the identification of findings if the root cause is not yet known.
The DET manager should encourage participation of all team members. However, to the extent possible, the length of daily on-site meetings should be limited j to about I hour.
- The resident inspectors should be invited to the team meetings. The team can use their expertise and experience (historical information). The Resident i Inspectors are not team members and can be expected to have a different
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perspective on the licensee and identified istues in some instances.
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Therefore, their communications with the team should be limited to dissemination of facts and their opinions should be limited.
During the onsite period, the DET manager should encourage the regional representatives to review teac plans, DE0s, and attend team meetings to fully
, understand the scope and the results of the evaluation. Such involvement will allow the regional representative to better assess the credit which may be applied to the MC 2515 program. The time and attention of the DET manager (and team members) for determining credit for the MC 2515 program should be 1 minimized until after the DET report is completed.
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- 5.2.6 Special Topic Meetings a
! The DET manager should, (if deemed beneficial) request and participate in special topical presentations by the licensee to provide the team clarification or detailed explanation of important issues. Special topical i presentations might involve the licensee's problem reporting systems (s), root cause program, specific improvement initiatives, root cause analysis results for significant equipment failures or the design modification process. DET members are to be cautioned that these meetings may slow or impede the progress of the DET and should be limited in duration and number to avoid taking excessive time from regular team evaluation activities.
5.2.7 Interim Exit Meetings The DET manager should lead interim exit meetings with the licensee. There should be an interim exit meeting at the end of the first two weeks and the third week on site. The DET manager should urge the licensee to limit the size of the licensee's participation at the interim exit meeting to key managers so as not to create the perception of a final exit meeting. The interim exit meetings should in sum be a review of the technical findings 01scussed at the counterpart meetings. The presentation is typically organized by functional area with the most safety significant findings presented first and in the most detail. The DET manager should present the status of significant technical and programmatic observations, findings, concerns, and strengths. The DET manager should not present conclusions and should continue to caution the licensee that feedback from team findings are preliminary and subject to change. Management effectiveness and preliminary root cause results generally should not be discussed during the interim exit meetings. No written materials should be provided to the licensee. The DET manager should thank the licensee for their support and briefly review the plans and schedule for future team activities. The DET manager should also solicit continued communication between team members and licensee counterparts even after leaving the site to resolve open issues. Written response to open items are also frequently requested at this meeting. Only management or organizational weaknesses of direct safety significance, (e.g., inadequate control over overtime, weak management control over control room activities) should be presented at the interim exit meeting. Broader management weakness which require significant integration of performance findings (e.g.,
complacent attitude toward the need for safety improvement) should not be presented until the final exit meeting.
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I Findings and concerns that do not meet the threshold for inclusion into the DET report may be discussed with the licensee. If possible the exit should be rehearsed to ensure presentations are well organized and coordintted.
5.2.8 Communication The DET Manager shall serve as the spokesperson for DET activities with the licensee and if necessary,. the press, on significant matters involving the evaluation. He/she should provide regular briefings to the licensee concerning DET technical findings and issues. Items shared with the licensee i
should be discussed only after a DE0 has been written, discussed and evaluated l for the issue. The manager should keep the licensee informed of technical and l programmatic issues, findings, problems and weaknesses. Conclusions related l
to management effectiveness or root causes of weaknesses should not be l
discussed with the licensee during the onsite period.
l 5.2.8.1 Team Good communication with the team must be established.
l The DET manager should provide prompt feedback when necessary. The DET l
1 manager s40uld encos$ge communication of specific findings / issues acr'oss functional areas for the pursuit of related issues by other team members, and stimulate identification of potential M&O causes for technical problems or I
programmatic problems found by technical team members for pursuit by the M&O j evaluation team.
5.2.8.2 Licensee The DET manager should periodically communicate with the licensee counterpart new findings and significant changes in the nature, stat'as (e.g., open or l resolved), of previously discussed findings. Findings discussed by the DET ,
! manager with the counterpart should have been documented on DE0s and l communicated when the available factual information indicates the weakness problem, or strength exists (subsequent information may lessen or resolve the concern,however). Written evaluation material should not be passed to the licensee. Selected strengths (if any) should also be identified from time-to-time during discussions with the licensee. It should be made clear that findings discussed during the onsite period are oreliminary. The findings do not become f.inal until the final report is approved by the EDO. Noteworthy improvements are not considered strengths.
The DET canager should offer to discuss the organizational findings (e.g.,
safety culture, climate) with tne licensee. These should generally be discussed separately with the senior managers (e.g. department heads,' plant manager, nuclear V.P., etc.) toward the end of the third week on site. These discussions provide the opportunity for the (M&O) team to feedback information of interest to the licensee even though some of it may not be sufficiently 1 significant, from a safety performance perspective, to t'e included in the high level presentation of the DET report.
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5.2.8.3 Region The DET manager normally invites the resident staff and regional management (at their option) to attend the daily team meetings. Attendance of the resident, or regional management at the meetings will facilitate regional office awareness of DET findings and observations for later follow-up.
The DET manager should arrange for a regional or site point of contact to receive any allegations received by the team as required. The resident inspector usually is the appropriate allegation coordinator.
5.2.8.4 AE0D Management The DET manager normally calls the Director, AE00 on the Friday morning at the end of the first week on site to brief him on the progress, observations and findings. This allows the Director, AE00 to brief the ED0 on the preliminary observations and findings following the Friday afternoon EDO staff meeting. A second call to the Director, AE00 is made on the Thursday cf the second week or after the Friday interim exit meeting on the results after two weeks. Other periodic calls may be made, as needed, to keep the Director, AE00 informed or request additional support.
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2 5.2.9 Immediate Safety Concerns During the DE, issues will occasionally arise that are potentially of immediate safety concern and require prompt action by the DET manager. The DET manager should always be alert to Identify these potential issues and ensure the DET response is timely and appropriate. If the issue appears to include a serious allegation, then it should be referred to regional personnel for resolution. Otherwise, the issue should be promptly evaluated and if an immediate safety concern, then both the licensee and regional personnel should be promptly notified. The DET then supports the region in the short term actions taken. Subsequent followup is the regional office's responsibility.
5.2.10 In Office Review The manager should provide direction during in-office review following the first two weeks on site. Evaluation of the information collected during the on site period should continue and mid-course changes for the third week of on site evaluations may be directed if necessary. Normally the practice is to select issues which are to be further developed during the last week on site and try to identify new issues. NRC senior management may be briefed on interim results if requested. Activities in the office should include:
requests for licensee documents, documentation of team findings, continuing root cause analysis, and team planning for the third week back, including an assessment of the team members who may not be required to return to the site.
5.2.11 Team Meeting to Summarize Findings A team meeting should be set aside near the end of the on site period for each functional area to summarize orally and in writing, their findings relative to 19
the evaluation objectives: performance problems; noteworthy strengths and safety significant weaknesses; adequacy of effectiveness of licensee improvement initiatives; significant problems not adequately addressed; or probable underlying or root causes related to the functional area. These summaries should be used as a basis for the interim exit meeting presentations. The relative balance of pluses and minuses should reflect the balance of overall results which the team wishes to convey to the licensee.
5.2.12 Preliminary Root Cause Analysis The DET manager should provide leadership and direction for the team's root cause analysis. A discussion / brainstorming of potential root causes should be scheduled for a separate team meeting sometime during the in office period or during the second week on site. The management and organization team leader may be delegated the responsibility and authority to schedule, facilitate, and document the results of the root cause meeting. The DET manager should ensure complete support is provided by the other functional areas when such delegation is exercised. Root causes must be traceable to specific examples or patterns of performance problems found by the team. Probable root causes should have " buy in" consensus of the team members. The methodology for root cause determination discussed in DET Guideline 2.7.6 should be used as appropriate. , j ..
5.2.13 Diagnostic Evaluation Team Nmber Personnel Issues The DET manager should remain sensitive to the fact that a DE is a high stress assignment for individual team members. Accordingly, the DET manager should remain alert to significant personnel problems, which he/she may help resolve.
To combat excess stress the DET manager should limit the work day to about 10 hours1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br /> with time for lunch. The team generally should work no more than 1/2 day Saturday during the two week on site evaluation period. Monitor new team members that may feel left out of after-work activities. The DET manager should ensure professional behavior of all team members during regular and off duty hours (discussed during the training sessions) and take remedial actions as necessary. Avoid micro-managing the team and provide direction through the team leaders to minimize the potential for conflicting guidance to team members.
5.3 Functi.onal Area Leader Responsibilities The FALs should provide guidance to the team members regarding evaluation activities. The FALs should discuss functional area findings from DE0s at the daily team meeting. The DE0s should be presented to the DET manager by the morning following the discussion of the DE0. The FALs must keep the DET manager informed of progress and problems and any identified immediate safety concerns should be promptly brought to the attention of the DET manager. The purpose of the DET counterpart meetings are to collect documents, make document requests, arrange schedules and inform licensee counterparts of findings and issues.
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5.4 AE00 Management Responsibilities J
AE0D management provides direction and resources as necessary to the DET manager and also serves as the communication point for DET manager to NRC senior management.
5.5 Administrative Assistant Responsibilities
- The administrative assistant maintains a library of documents and requests.
The library should be updated on a daily basis. He or she coordinates, develops, and provides daily updates for the interview schedules with licensee personnel, provides administrative support and is the point of contact with licensee administrative support. He or she ensures site access is available for all team members, arranges for site specific training, and whole body l counts. -
The administrative assistant should also ensure that copies of DE0s and interview writeups are made available to the FALs for information. Additional guidance on the duties and good practices of the DET Administrative Assistant during the onsite phase is documented in the DET Administrative Assistant Handbook.
5.6 Region Responsibilities The region will provide follow-up of allegations as necessary. The resident inspectors should provide corporate memory at daily team meetings and take l appropriate actions for items identified as safety significant. I 5.7 Additional References and Readings j
- Management Directive 8.8, " Allegations"
- NUREG 1409, "Backfitting Guidelines" 6.0 DOCUMENTATION AND COMMUNICATION OF RESULTS This section of the manual provides detailed guidance for the documentation and communication of the results from the diagnostic evaluation.
6.1 Objective The overall objectives for this phase of the diagnostic evaluation are to:
- Accurately document the results of the DET evaluation that warrant senior NRC management attention.
- Items that do not reach this elevated level may be orally communicated to the licensee.
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- Prepare the DET report in a timely manner
- Clearly characterize the extent the licensee was aware of an issue and the corrective actions (or lack thereof) planned or underway. j
- Complete the root cause analysis and document the results. I l
- Brief NRC senior management on the findings and conclusions of the l DET.
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- Conduct a final exit meeting with the lice."ee. .
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- Develop staff actions. '
6.2 Responsibilities of the Team Manager 6.2.1 Report Preparation ;
, The DET manager directs the DET report preparation. The manager should !
confirm report milestones prior to leaving the site and issue these milestones to the DET. The goal is to send the DET report to the ED0 within 6 weeks following completion of onsite activities. The manager should develop a
- schedule for team members regarding report writing and followup team meetings. I l During the report preparation, the DET manager will consolidate all functional area report outlines and create a master report outline. The draft DET report l will be distributed to all team members. A team meeting will be held to
! discuss and comment on the first draft (all team members may not be required).
l The introduction may be written before the evaluation is complete. This should be followed by the Evaluation Results (Section 2). Section 2 is then used in tne preparation of the root cause section (Section 3). Sections 2 and 3 are then used to prepare the Executive Summary, the cover letter to the l licensee, and the draft staff actions memoranda. The team leaders normally write their related areas of Section 2 of the report and provide input to the other sections. The DET manager should assign personnel to consolidate input and draft the remaining sections of the report. The final exit meeting presentation should be referred to during the report preparation to ensure l consistency.
l l The report format and report writing standards should follow the prototype report which is currently the Palisades, Quad Cities, and South Texas DE reports. The draft report when assembled, should be distributed to the Chief, DEIIB, Director, IRD, Deputy Directors AE0D and Director, AE0D for review.
The manager should review and resolve comments from AEOD management with assistance of team leaders. DEIIB is responsible for controlling EDO requested changes to the DET report, report transmittal letter, and staff l followup actions after they have been approved by the Director, AE00. DEIIB is also responsible for copying and distribution of the final report, transmittal letter, and staff actions memorandum after approval by the EDO.
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The DET manager should ensure the preparation of the report transmittal documents (i.e., the memorandum from the Director, AE00 to the EDO and from the EDO to the licensee).
6.2.2 NRC Senior Managers Briefing The DET manager should provide characterization and significance of team findings. The DET Manager should conduct debriefings on preliminary DET findings for AE00, NRR, Regional senior management and the ED0 soon after the end of the first two week on-site evaluation period and after the end of the final one week onsite period. The DET Manager should conduct a final senior management debriefing on the integrated DET results including root causes before the final public exit meeting with the licensee. Handouts should be l
, prepared for the NRC briefing and licensee exit meeting. The manager should l l obtain concurrence from team leaders, and distribute the initial draft of the l exit meeting slides and proposed staff actions to the Director, AEOD for l
comment and review. Following the resolution of comments, the planned exit l meeting slides and staff actions are sent to the region and NRR for review and l discussion. The region, NRR, and the EDO are then briefed on the proposed l exit meeting and staff actions within one week after the first draft of the report has been completed. The ED0 will be briefed following NRR and regional l senior management. The manager will provide information and clarification if l necessary to the region and NRR prior to the exit meeting. Additional l briefings may be necessary with regional personnel on selected issues to ,
l ensure effective follow up. l The NRC senior managers briefi; g should be viewed as a rehearsal for the final l exit meeting with the licensee. Each FAL should review the presentation of l their functional area to ensure consistency with the findings and conclusions,
! In their area. The presentation should address each of the objectives of the l DET: (1) safety performance in each functional area; (2) strengths and I weaknesses in safety performance; (3) actions and effectiveness of licensee
! management and staff in safe plant operations; (4) probable root causes and l (5) where safety improvement initiatives are not adequate to address the i underlying causes. The presentation should be kept at a high level with technical examples cited where needed to support the findings and conclusions.
The presentation should be fully consistent with the findings, conclusions and overall balance and emphasis contained in the DET report. The DET manager should be prepared to recommend areas for NRC followup staff actions as appropriate. The meetings should be scheduled by the DET manager consistent t
with the availability of the Director, AE00.
6.2.3 Licensee Exit Briefing The Director, AE0D, with DET manager support, will conduct the final public
- exit meeting at the licensee offices. A DET member may be requested to attend the exit meeting to note significant NRC and licensee comments. The exit meeting provides the teams significant technical, programmatic, management and organizational strengths and weaknesses, as well as the root cause analysis resul ts. It should balance strengths and weaknesses, and closely follow the final DET report.
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l The final licensee exit meeting presentation and handouts should track the l
presentation to NRC senior management with changes made, as needed, in l consideration of the comments and recommendations made at the NRC senior l
management briefings. The FALs should be cognizant of any changes made to the l presentation following the senior management briefing.
The Director, AE0D will typically start the presentations and introduce the
- DET manager. The DET manager will then present the results of the DE in each l functional area. The Director, AE0D may choose to present the root causes, l and areas not yet adequately addressed by the licensee.
! 6.3 Functional Area Leaders The FALs shall provide a functional area report outline following the onsite perio0. This is usually accomplished within 14 days after they return from the site. Team leaders will provide a final draft of evaluation results. The l FALs should then provide their recommended inputs for the root cause section, l the senior NRC management briefing slides and the NRC staff actions memo.
6.4 Region and Office of NRR
! The staff actions memo and DET report transmittal letter are sent to NRR and the region for review and concurrence. The draft DET report will be provided to the region and NRR for background information.
After the DET report is issued (or after the final exit meeting with the l licensee), the DET manager and functional area leaders should meet with the regional staff to debrief and respond to questions on the significant DE0s.
l 6.5 Office for AE0D 1 The Director, AE00 will approve the DET report and transmittal letter and j submit it to the ED0 for transmittal to the licensee. He will review and approve the staff actions memo. He will also approve the final exit slides l
and maintain control of subsequent changes to the DET report.
I 6.6 Administrative Assistant The administrative assistant should maintain the document library and maintain l the DEO file.s until the final report is issued. He/she should consolidate the l functional area draft reports into a common document.
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- 6 . 7. Sample Documents
- 1. Final Senior Managers Meeting briefing slides i 2. Final license briefing slides ,
i- 3. Staff actions memo '
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4 .- Report transmittal letter 4
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Attachment 1 DET MANAGER'S (FICTIONAL) NOTES FROM .
SENIOR NRC MANAGEMENT MEETINGS SENIOR NRC MANAGEMENT CONCERNS
, Director. NRR l
- NRC has regularly reminded this utility that the performance of their plant has been marginal. This licensee has been routinely discussed at the SMM. We need to know.why plant performance has not improved.
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- Safety culture is in question at this plant. Are there personnel relations problems?
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- The licensee appears to be aware of his problems, but apparently has not l been able to turn the performance around as of this time.. g l l l Deputy Director )
- The licensee has problems caused by an old plant with a lot on their l plate. Big ticket projects in the past (such as EQ) distracted them from l l doing other things. Thus, there is a bigger burden on management making .j compliance even harder. .
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- Performance characterized by: major outages, shaky startups, frequent ;
equipment problems, and significant escalated enforcement actions. ;
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- Once management recognizes (acknowledges) a problem, it gets fixed. They i l seem to be doing more prioritization. - l l
- Is their performance program going to better integrate activities?
Director. AE0D and Division Director l
- The licensee performance has not been stable.
- Improvement programs should be evaluated for scope and allocation of resources. We think the licensee may be holding back the dollars needed to get the programs fully implemented. You need to check if people and j dollar resources are an issue at the plant, i i !
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- Management and organization issues should avoid " cultures," seek tangible
- causes for performance and use examples. Explain time frames of l- performance (then-now-future). ,
Associate Director for Insoection and Technical Assessment (ADT)
- Ultimately need to understand the cause for inconsistent performance.
- Cause of the frequent equipment failures should be determined. ;
- Management Effectiveness: Are organization structure and communications adequate?
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- Workload: is the operating staff overwhelmed with work? How large is the backlog? .
- Decide whether an SSFI approach would be useful based on sample events analyses.
Associate Director for Pro.iects. Director of Reactor Pro.iects
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- Are equipment problems the apparent cause for poor performance? I l
- Operators are good and resourceful.
- Plant procedures are adequate, but hard to use. Human factors will be !
improved by procedure improvement program.
- The " Excellence Program" has only been implemented about a year, even though there are already 7 revisions. Still believe that it takes an
~
Inordinate amount of time to get problems fixed, j
- Too soon to assess impact of substantial management changes.
Reaional Administrator. Reaional Directors
- The licensee is capable, but site personnel make many mistakes. However, they seem to mean well.
- Strengths: The plant looks good and has some state-of-the-art features.
Good corrective action programs except they are usually not implemented in a timely manner.
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- Not clear whether commitments are well planned because they do not appear i to apply enough resources. Region believes they usually put heavy ,
- emphasis on the budget and do not apply appropriate priorities. '
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- Licensee has been refused several recent rate increase requests. Do they :
l have sufficient resources. I i
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OTHER NRC STAFF NOTES Site Visit with DEIIB Core Members
- Introduction by the licensee. Several managers were on leave or at meetings. The license asked simple questions about DET and were generally cooperative.
- The director of startup and testing described the planning efforts to l prepare for the DET: seemed not to be knowledgeable about activities in 1 other organizations and characterized present conditions as fragmented. I Senior Resident and Resident inspectors Meetina e Large amount of work that historically has not been well-planned. They really need an MTI; many of the problems resulted from poor preventive maintenance practices and lack of knowledge about the plant design because it was a turn-key project.
- Residents' concerned' bout' plant safety. While the past events have not been particularly significant, they have usually been complicated by other failures; its only a matter of time before a significant event occurs.
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- The safety review process is different. A Safety Review Manager reports directly to the licensee. Occasional trouble with design basis versus design features.
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