FocalPoint Recommendations and Staff Planned Actions 

 Section Lead Recommendation Implementation

Schedule 

Status/Plan or Justification

1 1 – CTS NRR/ 

DIRS 

Train regional staff as subject-matter experts for safety culture assessment 

Long Term (under evaluation) 

The staff is currently evaluating the tsafety culture assessments as noted 0054, “Reactor Oversight Process SCalendar Year 2008.” 

2 1 – CTS NRR/ 

DRA 

Conduct a lessons learned study to assess the history of and causes for the fire protection issues 

Long Term (scheduled implementation is 2Q2010) 

This effort is being tracked by SECYfor Stabilizing Fire Protection RegulaInfrastructure,” dated November 5, 2

3 1 – CTS NSIR/

DPR 

Enhance exercise evaluations through improved standardization; incorporate a post exercise survey of respondents and input from participating government agencies 

Complete IR standardized the exercise critique 

sheets to provide consistency among Participant solicitation for comment iparticipating licensees and agenciesinclude other licensees and agenciesare included in post-exercise critique Corrective actions are captured and tracking to closure. 

4 1 – CTS NRR/ 

DIRS 

Continue to focus on assessing the reasons for lack of variation in PIs in order to ensure that this does not continue to undermine their utility as indicators of potential problems 

Ongoing. No additional action planned. 

As noted in the annual ROP self-ass09-0054), “The staff will continue to message that a green PI represents does not require additional NRC oveprovide useful trending information, only a contributor to the identification outliers. In addition, the staff will conexisting PIs and explore options for iPIs to ensure that the PI program proinsights and contributes to the identideclining performance.” 

5 1 – CTS NRR/ 

DIRS 

Adopt performance metric to reflect safety deficiency correction rate 

No specific additional action planned. 

The staff believes that the existing Gis appropriate. The staff does not pladditional resources on developing operformance measures until OMB coguidance regarding future expectatioreviews. 

6 1 – CTS NRR/ 

DIRS 

Adopt metric to track program efficiencies (Program Cost per MWh) 

No specific additional action planned. 

Budget efficiencies are currently idenbudget process and are documented Book. The staff does not plan to expresources on developing other specimeasures until OMB comes out with 
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regarding future expectations for pro

7 1 – CTS NRR/ 

DRA 

Implement a database to track the status of fire protection exemptions, compensatory measures, and manual actions in place at plants in order to facilitate the assessment of compliance trends 

Long Term (scheduled implementation is 1Q2010) 

This effort is being tracked by SECYfor Stabilizing Fire Protection RegulaInfrastructure,” dated November 5, 2plans to develop and implement a firexemptions database which is being The staff plans to track compensatorpart of task 5, but will not be preparincompensatory measures. Similarly, completions are being tracked as pa

8 2 – BPI OCFO 

NRR/ PMDA 

Establish published crosswalk of the Program’s budget to demonstrate alignment of costs to Program outputs and annual and long-term outcomes 

Short Term (by end of CY 2009) 

The new agency budget structure bebeginning with FY 2011 addresses trecommendation. 

9 2 – BPI OCFO 

NRR/ PMDA 

Develop logic model or performance framework that clarifies linkage between outputs and outcomes 

Long Term (by end of CY 2010 for Strategic Plan aspect). 

The new budget structure, in combinrequired periodic update of the agenand continued improvements in the aPerformance Management program opportunity to examine and address 

10 2 – BPI OCFO 

NRR/ PMDA 

Develop marginal cost model to conduct sensitivity analyses 

Long Term (scheduled implementation is October 2010) 

The agency is in the midst of establisaccounting system, Financial AccouIntegrated Management System (FAaddress this issue. 

11 2 – BPI OCFO 

NRR/ PMDA 

Assess the full costing methodology to ensure accurate representation of full program costs 

Long Term  (scheduled implementation is October 2010) 

The upgrade of the Budget Formulatand the implementation of FAIMIS aissue. 

12 2 – BPI OCFO 

NRR/ PMDA 

Improve performance reporting to provide integrated and comprehensive monitoring of financial and operating results against plan in a timely manner 

Long Term  (scheduled implementation is October 2010) 

The agency is in the midst of establisaccounting system, Financial AccouIntegrated Management System (FAcontinuing improvements in the agenManagement program that will addre

13 3 – IEI NSIR/

DPR 

Identify and document objectives from implementation actions in terms of outcome improvements, timeliness, process and/or cost efficiencies 

Complete NSIR DPR has added performance 

review, document and track key actioincluding process effectiveness and 

14 3 – IEI NSIR/ Complete the process of updating and Short Term NSIR DPR has implemented the IR W
 3

DPR maintaining current key program 

documentation (expected 

completion is December 2009) 

process for updating and maintaining documentation. DPR has also reproresources in FY09 for contract suppoupdate IR procedures, including prog

15 4 – PC NRR/ 

DIRS OEDO 

Improve logistics of public meetings Short Term 

(by end of CY 2009) 

These suggestions will be includerevision to the “Public Meeting Bes

page. 

16 4 – PC NRR/ 

DIRS NSIR/DPR 

Evaluate external survey program and include incident response activities in the survey 

No changes planned beyond current practice 

IR programs are subject to continual stakeholders, and recommendations from external sources are consideremeetings, stakeholder focused meetsessions provide the opportunity for activities are outside the scope of the survey which focuses on implementaof the ROP. 

17 4 – PC NSIR/

DPR 

Increase publicly available Web-based information on incident response function and security cornerstone 

No changes planned beyond current practice 

Licensee incident response informatavailable (as part of ROP). Agency readiness performance is publically aGreen Book for the Agency Budget. performance information is generally Agency policy due to sensitivity. 

18 5 – OA NSIR/

DPR 

Clarify procedures for coordination and handoff after the emergency/plume phase of an incident 

Long Term NSIR DPR will request budget to sup

phase exercise support and additionbased training for responders. A critprogram instructions and practices wdetermine corrective actions. The refor FY12, with corrective actions follo

19 6 – FM OCFO Improve program performance on 

corporate measures related to financial management, specifically carryover target 

Short Term (by end of CY 2009) 

OCFO is aware of the concerns regaobligation of funds, which contributes carryover, and is working to address 

20 7 – E/A NRR/ 

DRA OE 

Address issues and uncertainties regarding compliance with the fire safety requirements 

Long Term (scheduled implementation is 2Q2010) 

This effort is being tracked by SECYfor Stabilizing Fire Protection RegulaInfrastructure,” dated November 5, 2#5). In addition, EGM 09-002, “EnfoDiscretion for Fire Induced Circuit Fain May 2009 and additional enforcemprogress to clarify fire protection comuncertainties. 

21 7 – E/A OE Add additional level of review in nonescalated enforcement actions to Short Term (by the end of CY This effort is being tracked by the sta

recommendations related to the OIG 
 4

review outcomes and procedures to help ensure that standardized procedures are used 

2009) 

NRC’S Enforcement Program (O

most recent update dated June 3, 20(recommendation #1). The recommstaff corrective actions are focused o

cases; NRR has programs and pplace that adequately address reenforcement cases.

22 7 – E/A OE Standardize procedures for tracking of 

enforcement cases 

Short Term (by the end of CY 2009) 

This effort is being tracked by the starecommendations related to the OIG NRC’S Enforcement Program (O

most recent update dated June 3, 20(recommendations #2-3). The recomstaff corrective actions are focused o

cases; NRR has programs and pplace that adequately address reenforcement cases.

23 8 – SD NRR/ 

DIRS OEDO 

Analyze root causes of increased inspection turnover and take actions to address this issue 

Complete SECY-09-0050, “Actions to Enhance 

Retention for Employees,” dated Maprovided the staff’s evaluation and aaddress this issue. 

24 8 – SD HR Conduct follow-up surveys three 

months after training 

Long Term (plan to develop surveys and conduct pilot by 4Q2009) 

This effort is being tracked by SRM MJune 17, 2008 which requested the smethod for measuring the effectivenThe Training Effectiveness Working proposing conducting follow-up survtraining to evaluate training effective

Area applies to the 8 distinct areas of the report: 

CTS – Contribution to Safety BPI – Budget Performance Integration IEI – Internal Evaluation and Improvement PC – Public Communications OA – Interaction with Other Agencies FM – Financial Management E/A – Enforcement and Allegations SD – Staff Development 

Short Term - Recommendation to be implemented by end of CY 2009 Long Term - Recommendation to be implemented in CY 2010 or beyond 
 5

Recommendation Details 

 Section Recommendation Details of Recommendation 1 1 – CTS Train regional staff as subject-matter 

experts for safety culture assessment 

The evaluation of safety culture is an important part of the assessmbased on input from interviewees and internal stakeholders, we beuniqueness and subjectivity of safety culture assessments are chaconsuming for inspection staff. The Program should recruit and traindividuals to have more knowledge in the area of safety culture. Twould be a resource for inspectors making SCCI assessments and knowledge sharing and consistency in assessment of safety culturcould provide guidance and standards, as needed, for the indepenassessments performed by licensees in column 4 of the ROP Actiostaff to develop specialized knowledge in the area safety culture wincluding more high quality safety culture assessments and increaswould lead to higher credibility with constituents and stakeholders. 

2 1 – CTS Conduct a lessons learned study to 

assess the history of and causes for the fire protection issues 

Given that the fire protection rules were established in 1980 and thsignificant reliance among licensees on interim measures and enfoand there is non-compliance among some licensees, the Program lessons learned study in calendar year 2009. We concur with this pthat lessons learned be applied where appropriate to other aspects regulations to help to identify ways to avoid similar problems in the 

3 1 – CTS Enhance exercise evaluations through 

improved standardization; incorporate a post exercise survey of respondents and input from participating government agencies 

To ensure that post-exercise evaluations are consistently performeopportunity for and documented evidence of participant feedback ainclude non-NRC response stakeholders (e.g. State, local, Federainvolved in the drill/exercise/event, and ensure that clear documenprocess is evident, the post-exercise/event evaluation process shodescribed in IR procedures. These procedures should include: • Preparatory actions for coordination with offsite response organizregarding their participation or observance; • Post-exercise/event critique review forms used in soliciting and dparticipant comments; • Format and timeliness schedules for post-action reports; and • Instruction and retention guidance for evaluation materials. 

4 1 – CTS Continue to focus on assessing the 

reasons for lack of variation in PIs in order to ensure that this does not continue to undermine their utility as indicators of potential problems 

The performance indicators provide limited visibility to variations in As such, it is more difficult to confirm their utility as indicators of poThe Program should continue to assess the reasons for lack of varperformance indicators. To the extent that the lack of greater-than-does not reflect good performance on the part of the licensee, the consider options such as: reviewing and modifying thresholds for WRed indicators; reviewing inspection procedures for validating licencollecting and reporting data for the performance indicators to ensuassessment of performance; and identifying options for modifying i
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regular basis in order to reduce fatigue of the indicators. 

5 1 – CTS Adopt performance metric to reflect 

safety deficiency correction rate 

To track the extent to which issues identified in inspections or throucorrected, the Program should consider adopting a metric that traccorrection rate, such as: The percentage of findings that do not recof the original finding. This metric could replace the existing metricoperating reactors whose integrated performance entered the InspChapter 0350 process, the multiple/repetitive degraded cornerstonunacceptable performance column of the ROP Action Matrix. OMB existing metric as not being ambitious enough and lacking in the aWe believe the proposed metric provides an opportunity to set a maggressive target, e.g., over 99%. The value would increase as the findings increases, and the number of findings are resolved and do addition, since there are a large number of findings, tracking of this provide visibility to trends. 

6 1 – CTS Adopt metric to track program 

efficiencies (Program Cost per MWh) 

In order to monitor the program costs, the Program should adopt eprogram cost per aggregate power output of licensed facilities. Program Cost per MWh = Direct program costs/ Aggregate power facilities This measure reflects increased benefits to the public as a result oregulation, underlying research, and other activities supporting powextent that the scope of security-related assessment has increased may want to limit this metric to safety-related assessment and incidto facilitate comparison over time. 

7 1 – CTS Implement a database to track the 

status of fire protection exemptions, compensatory measures, and manual actions in place at plants in order to facilitate the assessment of compliance trends 

Given the reliance among licensees on interim measures, the Progimplement a central database of interim compensatory measures bof permanent fire protection features. Such a database could help trends of compliance to the fire protection rules. Such information cmake informed decisions as it works to resolve this long-standing i

8 2 – BPI Establish published crosswalk of the 

Program’s budget to demonstrate alignment of costs to Program outputs and annual and long-term outcomes 

The program budget request lacks transparency in that it does not relationship between resources and annual and long-term performto demonstrate that performance informs budget formulation and redecisions reflect desired performance levels, the Program should cOCFO, who leads the PBPM process and development of the annuBudget and Performance and Accountability Report, to present the program budget in a more transparent manner. This may include abudget with the agency’s strategic goals, safety and security, and lProgram’s strategic outcomes, performance measures, and output 

9 2 – BPI Develop logic model or performance 

framework that clarifies linkage 

The relationship between resources and annual and long-term pernot clearly defined. The Program is complex for the uninitiated read
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between outputs and outcomes model or redesign framework might facilitate understanding of the 

outputs and outcomes (e.g., oversight activity and safety). The Prodeveloping a logic model or revising the ROP performance framewlinkage between the oversight activities and program outcomes for not indoctrinated in the NRC mission. The logic model developmenopportunity to add/retain a limited number of measures that are apmeaningful, and reflective of desired program outcomes, and proviand quality measurement. This will also present an opportunity to emeasures that do not meet the criteria. 

10 2 – BPI Develop marginal cost model to 

conduct sensitivity analyses 

The Program needs improvement in demonstrating the impact of fuand longterm outcomes. The Program may consider developing a the impact of reducing and increasing funding by a given percentaglong-term outcomes. With the Program’s goal of zero nuclear accidpublic’s intolerance for a nuclear incident, developing a programmamarginal cost model represents a challenge to the Program. The Pconsider developing a marginal cost analysis to demonstrate the imoutput performance and extrapolating these results to provide a quof the impact on annual and long-term outcomes. 

11 2 – BPI Assess the full costing methodology to 

ensure accurate representation of full program costs 

Our analysis of direct vs. indirect costs for the Program found a relindirect cost percentage for the RO program than the other programNuclear Reactor Safety Program. There may be a reasonable progexplanation for the higher indirect costs, but due to our inability to oexplanation of the full costing methodology and how it was applied we recommend the Program assess the full costing allocation meththe infrastructure and support costs that are allocated to the Prograand representative of its full program costs. 

12 2 – BPI Improve performance reporting to 

provide integrated and comprehensive monitoring of financial and operating results against plan in a timely manner 

The Program needs improvement in relating budget, workforce, acperformance information. Improved performance reporting that proand timely account of program resources budgeted vs. expended woutputs/outcomes targeted vs. achieved enables management to mperformance and to ensure program targets are achieved. The annreport can be used to develop the Performance Budget and the PeAccountability Report as well as reporting to OMB’s expectmore.goImplementation of this recommendation requires system enhancemefficient and timely data collection, analysis, and reporting. In additshould also be assigned for financial and performance monitoring aprogram level. Our assessment does not include a separate recomsystems improvements since the Agency already has a number of underway. Currently, NRC is implementing a new core financial mathat combines the functionality of the core accounting, license fee baccounting, allotment/allowance financial plan, and the capitalized Some key benefits sought from this new system include improved 
 8

efficiency, and overall quality in financial and performance reportintime and labor system is also undergoing a major upgrade which is improve the Program’s capability to collect information for fee billinaccounting and provide a wider range of management reports. 

13 3 – IEI Identify and document objectives from 

implementation actions in terms of outcome improvements, timeliness, process and/or cost efficiencies 

While improvements are tied to specific recommendations, clear obimpacts are not always developed. The Program should identify obaction plan as it is developed and approved and then confirm the imimprovement actions. The objectives should identify the problems addressed, expected benefits, and criteria for success. 

14 3 – IEI Complete the process of updating and 

maintaining current key program documentation 

In some areas, the procedure documentation was out of date. The for IRMC 0410 Drill and Exercise Standards, 0420 Drill and DeveloCoordination, and 0810 Outreach Programs are not available from published Web site although Appendix A of each was available. In regions and headquarters have different documented procedures fcoordination. The published NUREG 0728, Rev. 4 is stamped as “mode” since its April 15, 2005 issue date and is pending Rev. 5 in would benefit from greater specificity of procedures. Going forwardshould focus on more consistent document maintenance, increasebetween regions and headquarters organizations, and increased leensure consistent response actions. 

15 4 – PC Improve logistics of public meetings Interviewees and respondents from the biennial external survey me

shortfalls in the logistics of public meetings. The Program has madincluding providing more detailed agendas in reactor oversight meeannouncements and modifying Category 2 meeting processes to pcomments at the end of each topic. Several participants at Working also noted some logistical problems. The Program should ensure paccess through security up until the time of the meeting, sufficient are provided, and a microphone for speakers is available. 

16 4 – PC Evaluate external survey program and 

include incident response activities in the survey 

One issue is the declining level of the reactor oversight survey partthere were only 7 responses (similar to 2006 levels). Another issue stakeholders who do not respond are skeptical that their input will band acted upon by the Program. The Program should consider optresponsiveness and encourage greater participation in the externaProgram should also evaluate reasons for the decrease in responsoutreach to previous responders. Given findings, options to increasshould be evaluated including modifying the survey instrument, incworking with an organization like INPO, or other outreach campaigProgram should solicit stakeholder input on incident response activ

17 4 – PC Increase publicly available Web-based 

information on incident response function and security cornerstone 

The Program should provide more information on the progress of iefforts. As discussed above, the Program is assessing its approach dissemination of non-sensitive and unclassified security informatiocontinue to do so to enhance confidence with regard to activities a
 9

security cornerstone. While the current Emergency Preparedness Web site includes information on incident response objectives, roleinformation should be expanded to increase stakeholder understanconfidence in the incident response function. For example, informaresponse public meetings should include a post-meeting summary comments and feedback/actions taken. Also a periodic update on aimprovement actions related to incident response would demonstra

18 5 – OA Clarify procedures for coordination and 

handoff after the emergency/plume phase of an incident 

The incidence response documents are clear and fairly detailed wiand responsibilities during the emergency and plume phase of an they are less specific about what happens during the intermediate phase. Additional detail and clarity would improve preparedness foThe Program should raise this topic through working group meetinupdate documentation, and test and evaluate these procedures thrdiscussions or drills. 

19 6 – FM Improve program performance on 

corporate measures related to financial management, specifically carryover target 

Over the past year, the Agency has made significant efforts to impstandardize the corporate performance measures, which include mfinancial management. The OEDO tracks office performance on thmeasures on a quarterly basis. Some of the program support officeare not meeting the Green targets for the measures related to finanProgram support offices need to improve their performance for the out of standard, especially the carryover measure, which has a targ6 months starting in FY 2009 and beyond. Other out-of-standard mTime and Labor (T&L) certification timeliness, T&L correction rate,’ order/purchase card invoice certification timeliness, contract fundintimeliness, and contract invoice timeliness. For any corporate perfothat does not have an appropriate target for Red/Yellow/Green stasupport office should coordinate with the OCFO and/or OEDO to rethat they are meaningful and representative of the desired performdiscussed above under the financial management systems criteriadoes not include a separate recommendation for systems improveAgency already has a number of initiatives underway. 

20 7 – E/A Address issues and uncertainties 

regarding compliance with the fire safety requirements 

There has been uncertainty among some stakeholders regarding senforcement of fire safety rules. The NRC has made recent clarificshould address at least some of the questions. The Program shoullicensee requirements to help establish a transparent regulatory coenforcement of fire protection rules, where it is clear when licenseecompliance, thus making it easier to enforce. 

21 7 – E/A Add additional level of review in nonescalated enforcement actions to 

review outcomes and procedures to help ensure that standardized procedures are used 

The IG found that the enforcement program lacks clear and comprneeded to ensure consistent program implementation. As a result, inconsistencies in the way enforcement was carried out among the Office of Enforcement is considering calling for adding an additionae.g., review by a Branch Chief before enforcement actions are sub
 10

with this approach. In addition, we recommend clarifying the guidaexamples and adding additional training for Branch Chiefs on standin enforcement decisions. We also recommend that a Community oestablished in the Agency’s Knowledge Management System for senforcement to make use of this system as a way of sharing practi

22 7 – E/A Standardize procedures for tracking of 

enforcement cases 

The IG report states that enforcement decisions may not be based reliable data. This study was agency-wide and therefore was broadthe reactor oversight and incident response program. The finding rincomplete and unreliable data was in part due to lack of a standartracking system. However, since the RPS is used to support enforcreactors in the Regions, this finding may apply less to reactor overenforcement. We recommend that guidance be updated with additclarify requirements and data quality standards for information to benforcement cases. 

23 8 – SD Analyze root causes of increased 

inspection turnover and take actions to address this issue 

High turnover is making it difficult to meet site staffing objectives. Tanalyze the root cause of the increased turnover by conducting exleaving, conducting a market study on salaries and benefits, and cemployee satisfaction survey. While some of the turnover is structuwith the overall challenges the Agency is having with turnover, the analysis should be applied to make the work context changes avaiProgram. 

24 8 – SD Conduct follow-up surveys three 

months after training 

Currently post-class surveys are conducted immediately after the cnot conducted systematically after a period of time when the emploassess the impact on his or her job performance. The Program shofollow-up surveys three months after the course is taken. Other agsuch follow-up surveys in similar contexts and have had good resuthe FAA also sends surveys to inspectors and their supervisors 90 course completion to obtain their perspectives on whether the courthe extent to which the inspector is applying new skills and knowle