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DOE M 140.1-1B Interface with the DNFSB |
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ATTACHMENT 2
RESPONSE TO RECOMMENDATION GUIDELINES
This attachment provides the activities and schedule milestones of a systematic process for
responding to Board recommendations. It may be used as a checklist to ensure response
development is on target (schedule targets are from publication of the Board recommendation in
the Federal Register). The target dates and durations establish an appropriate pace to complete
the necessary activities within the required time frames.
Within 2 Days of Receipt
Following receipt of a Board recommendation, the Departmental Representative will notify the
affected Secretarial Offices and their Points of Contact and will initiate the response process
described below. The Departmental Representative's staff will distribute the Board
recommendation to Secretarial Officers, their Points of Contact, Operations/Area Offices, and
other affected Departmental elements, as appropriate. The Departmental Representative will
identify a member of his/her staff as Issue Lead to support coordination of the recommendation
response.
Days 1-14
These activities are necessary to initiate the evaluation process:
• identify the Responsible Manager;
• identify the response team;
• assign preliminary team tasks and responsibilities;
• identify significant safety issues associated with the recommendation;
• identify underlying causes and implications of these safety issues;
• develop alternatives for resolving the safety issues; and
• establish recommended courses of action.
The cognizant Secretarial Officer must identify the Responsible Manager who will manage the
response as well as manage development and implementation of the associated implementation
plan. The Departmental Representative should inform the Executive Secretariat of the cognizant
Secretarial Officer and designated Responsible Manager within 14 days of receipt of the
recommendation.
The Responsible Manager, assisted by the Issue Lead, will develop an agenda and call a meeting
with the designated representatives of the affected Departmental elements. These individuals
(the response team) must be empowered to represent their management throughout the evaluation
of the recommendation, the development of the Department's response and implementation plan,
and the actual plan implementation, if necessary.
The Responsible Manager, the Issue Lead, and the response team should ensure the following
features that the Board considers key are demonstrated in the Department's response: (1) an
understanding of what is being asked or recommended; (2) a commitment by the Department to
take action to meet the recommendation; (3) the name of the Responsible Manager; and
(4) specifications of what the Department intends to do so that the Board can determine whether
material terms of the recommendation will be met.
Throughout the evaluation process, the Issue Lead should provide guidance and support to the
Responsible Manager and the cognizant Secretarial Officer, including performance of the
following actions:
• coordinate actions agreed to by the affected parties;
• distribute key documents, comments, and agendas;
• disseminate requests pertaining to the recommendation; and
• facilitate communications between the Department and the Board staff.
Day 14
The Responsible Manager and the Issue Lead should work together to document the
Departmental strategy and identify significant issues, actions, milestones, and responsibilities
necessary to develop an acceptable response. The Issue Lead should distribute this information
to affected organizations. The Responsible Manager should also make an initial assessment of
the need for a 45 day extension request.
Days 14-25
The response team should complete a detailed evaluation of the Board recommendation, which
includes consideration of the following:
• applicability and substantive strategic input;
• schedule, cost, and funding for implementation; and
• need and availability of specialized resources for implementation.
Affected organizations should transmit their evaluations and strategic input to the Responsible
Manager within the time frame requested. Response team members and points of contact should
coordinate these inputs from within their respective organizations. To develop the best response,
affected Departmental line managers should consider contractor/laboratory comments, but should
validate this input, ensuring its applicability, and verifying cost and time estimates.
The Responsible Manager should work with the Issue Lead to ensure plans and actions are
responsive to the Board's recommendation. For clarification or guidance on the meaning or
intent of any part of the recommendation, the Issue Lead should provide the necessary liaison
with the Board staff, and the Departmental Representative should provide liaison with the Board.
Day 25
In conjunction with the Departmental Representative, the Responsible Manager should develop
an agenda and schedule a meeting with the senior management team (affected Secretarial
Officers) to present the recommended Departmental position. The agenda should include
discussion of the Responsible Manager's estimate of the associated costs and contribution to
safety.
The senior management team, chaired by the Deputy Secretary, is composed of organizations that
have direct line responsibility or significant involvement in activities encompassed by the
Department's response, and typically includes the following Senior Managers:
• Under Secretary for Nuclear Security (NA-1),
• Deputy Administrator for Defense Programs (DP-1),
• Assistant Secretary for Environment, Safety and Health (EH-1),
• Assistant Secretary for Environmental Management (EM-1),
• General Counsel (GC-1), and
• Appropriate field managers.
Some recommendations may require one or more of the following additional individuals to
participate with the senior management team:
• Chief Financial Officer (CR-1),
• Assistant Secretary for Energy Efficiency and Renewable Energy (EE-1),
• Assistant Secretary for Fossil Energy (FE-1),
• Director, Management and Administration (MA-1),
• Director, Office of Nuclear Energy, Science and Technology (NE-1),
• Deputy Administrator for Defense Nuclear Nonproliferation (NN-1),
• Assistant Secretary for Policy and International Affairs (PO-1), and
• Director, Office of Science (SC-1).
If consensus is not expected within 5 days of the senior management team meeting, the senior
management team should consider requesting from the Board up to a 45-day extension to submit
the Department's response. The Responsible Manager, supported by the Issue Lead, must
prepare and coordinate this request.
Follow-up actions for the two possible outcomes from the senior management team meeting
(i.e., consensus or not consensus) are described below.
Outcome 1: Senior Team Reaches Consensus on Agency Position
Day 28
The Responsible Manager finalizes the response and with the assistance of the Issue Lead
delivers the response to the affected Departmental elements for concurrence. Response team
members and points of contact should assist in acquiring the appropriate concurrence within their
respective organizations.
Day 32
The Responsible Manager submits the response to the cognizant Secretarial Officer for approval
and ensures that it is delivered to the Executive Secretariat for processing.
Day 39
Secretary approves the response to the Board. This completes the response actions. Follow-up
actions are described at the end of this attachment.
Outcome 2: Senior Team Does Not Reach Consensus on Agency Position
Day 26
The Deputy Secretary should provide guidance and direction to the cognizant Secretarial Officer
and Departmental Representative relative to resolution of the issues and conflicts.
Days 27-31
Affected Departmental elements will negotiate and attempt to agree on a position.
Day 32
The senior management team should meet a second time for the purpose of arriving at an agency
position.
If the Senior Team Agrees On An Agency Position
Day 35
With the assistance of the Issue Lead, the Responsible Manager prepares and delivers the
response to the affected Departmental elements for concurrence. Response team members and
points of contact should assist in acquiring the appropriate concurrence within their respective
organizations.
Day 38
The Responsible Manager will submit the response to the cognizant Secretarial Officer for
approval and ensure that it is delivered to Executive Secretariat for processing.
Day 45
Secretary approves the response to the Board. This completes the response actions. Follow-up
actions are described at the end of this attachment.
In Rare Cases When The Senior Team Still Does Not Agree On An Agency Position
Day 33
The Departmental Representative should contact the Executive Secretariat to advise of the need
to escalate the response for Departmental senior management decision. The senior management
team should brief the Deputy Secretary on the remaining material facts preventing development
of a unified Departmental position. The Deputy Secretary will then render a decision.
Day 36
In extraordinary cases requiring the Secretary's participation to achieve consensus, the Deputy
Secretary should brief the Secretary on the material facts preventing development of a unified
Departmental position. The Assistant Secretary for Environment, Safety and Health, the
cognizant Secretarial Officer, and the Departmental Representative should support this briefing,
as appropriate. The Secretary will then render a decision.
Day 39
The cognizant Secretarial Officer prepares the response and delivers the response to the
Executive Secretariat for processing.
Day 45
Secretary approves the response to the Board. This completes the response actions. Follow-up
actions are described below.
Follow-up Actions
These follow-up actions described below should be taken based on the response:
1. If the response accepts all or part of the recommendation, the Responsible Manager,
supported by the Issue Lead, should complete development of the associated
implementation plan (in accordance with Chapter III, paragraph 1 of this Manual).
2. If the response rejects all or part of the recommendation, the Board may revise or
reaffirm its recommendation. Following receipt of the Board's response, the Responsible
Manager, supported by the Issue Lead, should prepare the Department's final decision (in
accordance with Chapter II, paragraph 5 of this Manual).
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This Site Last Updated: Friday, January 16, 2009
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