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OFFICE OF HEALTH, SAFETY AND SECURITY DEPARTMENTAL REPRESENTATIVE TO THE DNFSB
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I. Overview
II. Rec. and Responses
III. Implementation Planning
IV. Safety Issues Management
V. Correspondence Management
VI. Other Communications
VII. Site Interfaces
VIII. Annual Report
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DOE M 140.1-1B Interface with the DNFSB   

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CHAPTER VII

SITE INTERFACES


1. PREPARATION FOR SITE VISITS.

a. Schedules and Visit Plans.
(1) The Departmental Representative should coordinate with the Board and its staff, to the extent possible, in long-range scheduling of planned site visits (exclusive of those pursuant to formal investigations) and should publish weekly updates of visit plans for the Department's use.

(2) The Departmental Representative should obtain input from Secretarial Officers and Operations/Area Office Managers regarding site schedules and facility conditions for use in coordination of site visit scheduling with the Board staff.

(3) The Departmental Representative's office should provide copies of the schedules and plans to Secretarial Officers and Points of Contact.

b. Board/Board Staff Requests for Site Visit.
(1) The request for a visit to a facility is normally made by the Board or its staff with the appropriate Operations/Area Office Point of Contact. The Operations/Area Office Point of Contact must inform the Departmental Representative and the appropriate Secretarial Officer Point(s) of Contact and Program Manager(s) of the request. If the Board or Board staff's request is made directly to Headquarters or others, the cognizant Departmental staff member should inform and coordinate with the appropriate Operations/Area Office Point of Contact.

(2) The Departmental Representative should ensure prompt distribution of the Board/Board staff requests for site visits. The objective is to ensure that affected Departmental elements receive as much advance notice as possible. The Departmental Representative's office or the Operations/Area Office Point of Contact should distribute additional visit information and a detailed agenda as it becomes available.

(3) The Operations/Area Office Point of Contact should work with the requesting parties to understand the topics being reviewed and to establish an appropriate site visit agenda. If the topics or areas had recently been reviewed by other Board representatives, the Operations/Area Office Point of Contact should raise this fact with the requesting parties and understand how the information to be reviewed will be new or different from that which was reviewed previously. The Operations/Area Office Point of Contact should endeavor to obtain a preliminary agenda or lines of inquiry to develop a preliminary agenda at least 3 weeks prior to the site visit. Early transfer of the preliminary agenda topics is necessary to facilitate site visit planning.

c. Responsibilities for Site Visit Preparation, Coordination and Conduct.

(1) The cognizant Operations/Area Office Point of Contact must prepare, coordinate, and conduct Departmental activities to support site visits. The cognizant Operations/Area Office Point of Contact should ensure:

(a) local facility resources including tour escorts, operational and technical expertise, and a schedule of facility activities for the duration of the site visit are provided;

(b) appropriate communication and responsiveness to requests by the Board or its staff during the visit are provided; and

(c) affected managers, Secretarial Officer points of contact, Secretarial Officer Program Manager(s) and participants are kept informed of changes in the schedule or agenda.
(2) The Secretarial Officer point of contact should work with the Operations/Area Office Point of Contact to coordinate the involvement of Headquarters and field personnel within their organizations in preparation for and conduct of the site visit.

d. Internal Notice of Site Visits.

(1) The Operations/Area Office Point of Contact should ensure a visit agenda is prepared and distributed to affected personnel. The agenda should provide:

(a) the name of the facility(ies) or site to be visited;

(b) arrival and departure dates;

(c) dates, times, and locations of briefings and presentations;

(d) names of the Board participants;

(e) purpose of visit, including buildings and programs to be reviewed;

(f) topics to be discussed; and

(g) Departmental and contractor participants.

(2) The Operations/Area Office Point of Contact and affected Departmental organizations should develop agenda information through discussions with the lead Board staff member for the visit. If the schedule or agenda requested by the Board cannot be accommodated, the Operations/Area Office Point of Contact, in coordination with affected Departmental organizations, should resolve any issues or conflicts with the lead Board staff member.

(3) If changes in the schedule or agenda topics arise, the Operations/Area Office Point of Contact should modify and redistribute the agenda. If there is insufficient advance notice of a substantive change in the schedule or agenda to reissue the notice, the Operations/Area Office Point of Contact should contact the affected participants to alert them of the changes as soon as possible.

e. Site Access Coordination. The Operations/Area Office Point of Contact must coordinate security and safety requirements for the Board visitors, including badging, safety instruction, general employee training, escorts, transportation and dosimetry. To the extent allowed by local procedures and programs, allowance should be made for training and access requirements completed at other Departmental facilities.

f. Access to Subject Matter Experts. The Operations/Area Office Manager, in coordination with the Operations/Area Office Point of Contact, must arrange for the availability of Departmental and contractor subject matter experts for potential discussions with the Board and its staff, consistent with the schedule and agenda topics.

2. SITE VISIT PROTOCOL.
a. Entrance Briefings. The Operations/Area Office Manager should request the opportunity to hold an entrance briefing with the Board representatives. The entrance briefing should introduce key personnel, review the planned activities and schedule, identify protocols and procedures that will be used, and discuss any special arrangements that have been or need to be made. If an entrance briefing is held, the point of contact should ensure that appropriate Operations/Area Office officials and management representatives from the contractor are notified to attend. As a minimum, the Operations/Area Office Point of Contact should meet with the Board representatives upon their arrival at the site.

b. Facility Tours. The Operations/Area Office Point of Contact should coordinate conduct of requested facility or area tours. To the extent any unannounced tours can be accommodated, Departmental personnel should assist the Board representatives in this matter. The Operations/Area Office Point of Contact should be notified of any such requests for unannounced tours. The Operations/ Area Office Point of Contact must ensure that appropriate access requirements, such as those related to security, safety, and radiation protection, are satisfied for the areas to be toured, whether the tour is announced or unannounced, before beginning the tour.

c. Document Reviews.

(1) The Department must provide the Board with access to information necessary for the Board to accomplish its statutory duties. The Secretary may deny access to information for only two reasons:

(a) the person requesting the information has not been granted an appropriate security clearance or access authorization by the Secretary, or

(b) the person requesting the information does not need such access in connection with the duties of such person (see Chapter I, subparagraph 2a).

(2) The Operations/Area Office Point of Contact should coordinate arrangements for the availability of such documents as may be requested by the Board or its staff for review. Departmental personnel should accommodate, to the extent possible, each request made prior to or during the site visit for documents or other information required by the Board representatives (see Chapter VI, paragraph 1b). Departmental personnel should encourage the Board representatives to use a completed Board Information Request (Attachment 5), approved by a member of the Board or its staff.

(3) The Operations/Area Office Point of Contact should determine prior to the visit whether classified materials will be reviewed by the Board staff during their visit and verify with the Board's Technical Director that the Board staff members have appropriate clearance and need to know. If the Board staff requests additional classified information beyond the pre-established scope, the Operations/Area Office Point of Contact should verify with the Board's Technical Director that this requested information is necessary for the Board to accomplish its statutory purposes. If difficulties emerge in the process of verifying the Board staff member's need to know, the Operations/Area Office Point of Contact should advise the Departmental Representative.

d. Site Visit Briefings.
(1) The Operations/Area Office Point of Contact should serve as the Departmental lead for site visit briefings. The briefings should be coordinated and conducted in the same manner as described in Chapter VI, subparagraph 2a.

(2) Notice and documentation of site visit briefings are performed as a part of the site visit process in lieu of Chapter VI, paragraphs 2b and 2d. Additional briefings requested during the site visit should be accommodated by the Operations/Area Office Point of Contact to the extent possible.

(3) The Board or its staff may also request to attend Departmental and contractor briefings. These requests generally will be accommodated, consistent with the Department's responsibilities for full cooperation and ready access. The Board or Board staff may be involved in the Department's decision-making process as observers, not as participants, to the extent that their involvement is necessary for the performance of their duties and is in the interest of the Department for facilitating efficient Board oversight.
e. Personnel Interviews.
(1) Departmental personnel contacted by the Board or its staff must cooperate with the Board and provide requested information. Departmental personnel should be courteous, open, honest, and responsive. Departmental personnel should be mindful of their organizational authority and not agree to take actions outside their immediate level of authority. Subsequent to the interaction, the Departmental personnel should report the substance of the interaction to the Operations/Area Office Point of Contact.

(2) Departmental and contractor personnel, such as control room operators, who are directly performing safety-related functions must request Board representatives to schedule interviews at mutually convenient times when safety-related duties cannot be compromised.

f. Potential or Actual Unsafe Conditions.
(1) If Board representatives identify any potential or actual unsafe condition, Departmental and/or contractor personnel must immediately evaluate the condition and implement the applicable approved facility procedures, if necessary.

(2) The Operations/Area Office Point of Contact should inform the cognizant Secretarial Officer and the Departmental Representative of the concern as soon as practical.

(3) The Operations/Area Office Point of Contact should coordinate a response to the Board representative who originally identified the issue within an appropriate amount of time. The Operations/Area Office Point of Contact should take the initiative to inform the appropriate Board representative of significant occurrences, particularly those related to topical areas the Board or its staff has been or is investigating. The Operations/Area Office Points of Contact are encouraged to perform as a continuing source of information on site activities for the Board staff lead and site representative for that facility.

g. Exit Briefings. The Operations/Area Office should request the opportunity to hold an exit briefing with the Board representatives. The exit briefing should include a discussion of significant conditions, observations, and issues identified during the visit and reach consensus on follow-up Departmental information transmittals and action items. When exit briefings are held, appropriate Operations/Area Office officials and management representatives from the contractor should be present.

h. Visit Summaries.

(1) The Operations/Area Office Point of Contact should prepare a visit summary, which includes the following information:

(a) the names and titles of individuals involved,

(b) significant conditions, observations, or issues identified during the visit,

(c) a description of Departmental action items, and

(d) the responsible organization and due date for each action item.

(2) Departmental action items require approval by an authorized Departmental official. Approval authority for action items is established either by the actions being within the normal realm of responsibility for that position or by specific delegation of that responsibility from the cognizant Departmental manager. These action items need to be satisfied to maintain an effective working relationship with the Board and its staff; they should be tracked and managed at the Departmental level where the action items are undertaken.

(3) The Operations/Area Office Point of Contact should transmit the visit summary to the affected Secretarial Officer Points of Contact and the Departmental Representative whenever the site visit has implications beyond the specific site that was visited. The Departmental Representative's office should make additional distribution within the Department to ensure appropriate parties are apprized of the results.

(4) The Departmental Representative's staff should periodically interact with the Board staff after site visits to verify follow-up actions are fully identified and to receive significant comments and observations. The Departmental Representative's staff should also share this information with the affected parties. The Departmental Representative's staff should facilitate communications and interaction among the various Operations/ Area Office Points of Contact to ensure all are cognizant of emerging Board issues and priorities.

i. Extended Site Visits. The point of contact should arrange for periodic progress briefings between Department's site management and the Board representative during extended site visits lasting more than 5 days. Daily de-briefs during extended site visits have proven to be an effective means to ensure that the Department promptly addresses Board concerns and requests for information during the course of a site visit. Summaries of significant issues discussed in the progress briefings should be documented and promptly distributed to affected Departmental elements.
3. INTERFACE AT FACILITIES WITH BOARD SITE REPRESENTATIVES.

a. The Operations/Area Office Point of Contact must facilitate the on-site interface activities of the dedicated on-site Board representatives (also known as site representatives). This facilitating role includes the following responsibilities:

(1) scheduling interviews and other review activities with affected facility personnel,

(2) providing access to facilities and personnel,

(3) identifying and resolving any difficulties getting information or cooperation,

(4) notifying the Board site representative of significant site activities and occurrences, and

(5) providing for distribution of routine information, such as facility operational status, to the Board site representative.
b. The Operations/Area Office Manager should establish the policy regarding use of Board Information Requests (Attachment 5) for requests by the local Board site representatives. Recommended policy is that documents and information requested and used by the Board site representatives on site does not require use of the Board Information Requests. However, transmittal of documents and information to other Board representatives or off-site should be accompanied by documentation on a Board Information Request.

c. To ensure full cooperation, the Operations/Area Office Point of Contact should frequently interact with the on-site Board representative to discuss the status of Board-related issues.

d. The Operations/Area Office Manager should periodically review Board-related issues with the Board site representative, along with the point of contact. If applicable to other sites, the Operations/Area Office Point of Contact should prepare and transmit a summary of such periodic reviews to the Secretarial Officer and the Departmental Representative.

 

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