January 26, 2017 To: Angela Chambers, Program Manager, US DOE Nuclear Criticality Safety Program (N CSP) From: D. G. Erickson, Chair, US DOE NCSP Criticality Safety Support Group (CSSG) Subject: CSSG Tasking 2017?04 Response In tasking 2017-04 a subgroup of the CSSG was requested to perform an advisory review of the LANL Criticality Safety Program (CSP) to evaluate the CSP with regards to the following goals.and objectives: 0 Evaluate the current staf?ng situation against workload for adequacy and recommend any compensatory measures/ef?ciency measures to better balance workload; 0 Evaluate the staf?ng analysis, goals, and trends in relation to needed improvements training, quali?cation, tools, and retention) and recommend additional actions to improve; 0 Evaluate core program implementation and advise on necessary next steps in the rebuilding process; 0 Evaluate the program improvement plan for its ability to generate an effective program and recommend any long/ short term improvements; 0 Evaluate management engagement in monitoring the overall health of the NCS program including use of the NCS committee, NCS metrics, management assessments, and brie?ngs to senior management; 0 Evaluate changes for effectiveness in resolving CSSG 2012 and 2013 identi?ed issues and recommend any additional changes needed; 0 Evaluate corrective actions taken to address CSSG identi?ed issues ?'om the 2012 and 2013 assessments for effectiveness and note any gaps/additional actions needed. The CSSG subgroup was comprised of the following members: 0 Kevin Kimball (Team Leader) 0 David Erickson The attached CSSG Response presents the results of the advisory review. Review was provided by the entire CS 86 and included a factual accuracy review by LANL. All comments have been incorporated into the ?nal version of the Response that is attached to this memo. Cc: CSSG Members CSSG Emeritus and Ex-of?cio Members D. Bowen L. Scott Attachment 1: Response to CSSG Tasking 2017?04 CSSG TASKING 2017-04, CSSG Review of LANL CSP January 25, 2018 Prepared by: Kevin D. Kimball, Team Lead, CSSG David G. Erickson, CSSG Chair Table of Contents Section Page 1 Executive Summary ............................................................................................................................ 1 2 Background and Scope of Assessment................................................................................................ 3 3 Assessment Team ................................................................................................................................ 4 4 Management of the NCS Program ...................................................................................................... 4 4.1 Review of CSSG 2012 and 2013 Corrective Actions (Objective 1) ................................................... 4 4.2 Management of the Nuclear Criticality Safety Division (Objectives 2, 3, 4) ..................................... 4 4.3 Challenges for Operations Management ............................................................................................. 7 5 Staffing Observations (Objectives 5, 6) .............................................................................................. 7 6 Process Observations .......................................................................................................................... 9 7 Conclusion .......................................................................................................................................... 9 8 Attachments ...................................................................................................................................... 10 8.1 Attachment 1 – CSSG Tasking 2017-04 ........................................................................................... 10 8.2 Attachment 2 – List of References Reviewed ................................................................................... 13 8.3 Attachment 3 – Los Alamos National Security, LLC and Los Alamos Field Office Titles of Personnel Interviewed ....................................................................................................................... 15 8.4 Attachment 4 – Assessment Out Brief Slides ................................................................................... 16 CSSG TASKING 2017-04, CSSG Review of LANL CSP 1 Executive Summary In 2012 and 2013 the Department of Energy (DOE) Criticality Safety Support Group (CSSG) performed assessments of the Los Alamos National Laboratory (LANL) Nuclear Criticality Safety (NCS) Program. An opportunity for improvement from the 2012 assessment addressed a pending severe attrition potential within the criticality safety group. Shortly thereafter, there was a departure of the majority of the experienced NCS staff. This led to significant support issues for ongoing operations at LANL and in combination with Conduct of Operations issues, ultimately resulted in a pause of operations at Technical Area (TA) Plutonium Facility (PF)-4. Since that time there has been much effort put forth, including documenting the various plans to return the LANL NCS Program health to the appropriate level. This Tasking Report provides a summary of the observations and recommendations regarding the current management of the LANL Nuclear Criticality Safety Program. Since this review is an advisory review and not a compliance assessment, there are no findings. The assessment was largely conducted through plant interviews and document reviews. No facility walk downs were performed. The report is divided into three sections. The key observations and recommendations for each section are summarized below. NCS Program Management • The 2012 and 2013 CSSG assessment recommendations have been appropriately implemented with one exception regarding the CSO program. The CSO program is not nearly as mature as the CSSG expected it would be given the amount of time that has passed since the last CSSG visit. LANL Operations recently began filling full-time CSO positions with experienced leaders. • The management of the Nuclear Criticality Safety Division (NCSD) appears to be on the right track for recovery of the program. The program, though improving, is still in a very fragile state where progress could be disrupted by many factors. One such factor requiring close management attention is the upcoming contract change. • LANL management has elevated the NCS Manager position from a Group Leader level to a Division Leader level. The hired Division Leader is a former Lawrence Livermore National Laboratory employee experienced in NCS; though that individual is inexperienced as a manager. The review team is concerned that the Division Leader has too many “tactical” and technical responsibilities, which create an inherent choke point in productivity and could adversely impact improvement efforts. The team did note that there were plans to hire either a Deputy or two additional line managers. Implementing that plan would support succession planning and help to mitigate management risks. • The use of facility/operation centric Work Teams with identified NCS Points of Contact provides a good framework to maintain enhanced communications between NCSD and Operations. • The Nuclear Criticality Safety Program Improvement Plan, NCS-PLAN-16-001, and the Nuclear Criticality Safety Division Staffing Plan, NCS-PLAN-16-002 are both good working documents. These should be reviewed by senior management regularly, and revised as appropriate to ensure Task 2017-04 Report January 25, 2018 that progress on NCSD improvement efforts is meeting expectations. Some improvement strategies may need to be changed as progress is measured. • Management needs to be planning to ensure that the non-analysis tasks (e.g., engineer floor time or professional development opportunities) are not adversely affected by a change to normal funding levels (i.e., when NA-50 supplemental funding ceases). • The metric report appears to be much improved since the last review by the CSSG; however, some key information seems to be lacking. A graphical display of trends and the identification of corrective actions for adverse trends would be useful for senior management to quickly grasp the health of the program. • Two generic limit sets are widely applied within the facilities. These limits are more conservative than what was implemented for previous operations. Operators will naturally assume that the new limits are overly conservative if they have been working to much higher values. This can lead to a false sense of security or a belief that the limits are so conservative that strict adherence is not necessary. Operations management should ensure that the operations staff understand the basis for these limits. • Transitioning to a new “normal” way of doing business requires extra diligence by managers and supervisors. Years of operating in a prior culture are not easily changed; in fact they are easily reverted to. Increased infractions should be expected during this time because of heightened reporting. Careful management approaches are needed to ensure that reporting of infractions are continued (and not suppressed) and that process improvements are directed toward helping operators be consistent and reliable in performing the operation. NCS Program Staffing • An NCS Division Staffing Plan (NCS-PLAN-16-002) has been developed and is being followed/managed. This plan is presented in an earlier section of the report. While progress is being made in the total number of staff, the CSP is still significantly understaffed with qualified analysts. • The staff is made up of engineers with all levels of experience, and the qualification process is being managed. The limited number of experienced LANL staff are serving as mentors for the inexperienced staff. It was noted from discussions that most of the subcontractors are only providing part time support to LANL, and some of that support appears to be happening remotely. The remote location of Senior Criticality Safety subcontractors does not provide a means for the senior staff to provide the mentoring that most of the unqualified/inexperienced staff require. • The time and priority afforded to the inexperienced NCS staff to pursue qualification appears appropriate as compared to programs at other sites. The Technical Seminars that are provided to the CSAs appear to be well worth the effort. LANL Management may want to consider implementing a similar seminar program for the operators to cover the bases behind controls. • LANL is in a unique position in the complex because of the breadth of activities they support. There are opportunities to provide criticality safety analysts with a variety of career enhancing skills not available elsewhere, which would help retention for the mid-level analyst position. • The NCS staff interviewed were all aware of their goals for in-facility time to observe operations and it appeared that management was affording them the opportunity to meet these goals. Having 2 Task 2017-04 Report January 25, 2018 facility walk downs with participation from senior analysts, CSOs, ORSs, NNSA, etc. is noted as a positive. This provides the less experienced staff with different perspectives. LANL is encouraged to continue this practice. NCS Process Observations • A cursory review of the Criticality Safety Program Description Document required by DOE O 420.1C concluded that it was compliant with the requirements. Some elements of the document refer to DOE standards that have been recently revised. The new revisions would help in reducing the complexity of some elements of the NCS evaluations. SD-130 should be reviewed for these significant changes in requirements, which should help with the NCS evaluation process. • Collaboration with other sites will help LANL from re-inventing a process already in use. Two good forums for networking with other NCS organizations are the American Nuclear Society meetings and the Energy Facility Contractors Group (EFCOG) NCS subgroup meetings. 2 Background and Scope of Assessment In 2012 and 2013 the DOE CSSG performed assessments of the Los Alamos National Laboratory (LANL) Nuclear Criticality Safety (NCS) Program. An opportunity for improvement from the 2012 assessment addressed a pending severe attrition potential within the criticality safety group. Shortly thereafter, there was a departure of the majority of the experienced NCS staff. This led to significant support issues for ongoing operations at LANL and in combination with Conduct of Operations issues, ultimately resulted in a pause of operations at Technical Area (TA) Plutonium Facility (PF)-4. Since that time there has been much effort put forth, including documenting the plans to return the LANL NCS Program health to the appropriate level. The CSSG was recently requested to perform an advisory review with the objectives listed below. The objectives are referenced in the major report sections. Objective 1: Evaluate changes for effectiveness in resolving CSSG 2012 and 2013 identified issues and recommend any needed additional changes. Objective 2: Evaluate core program implementation and advise on necessary next steps in the rebuilding process; Objective 3: Evaluate the program improvement plan for its ability to generate an effective program and recommend any long/short term improvements; Objective 4: Evaluate management engagement in monitoring the overall health of the NCS program including use of the NCS committee, NCS metrics, management assessments, and briefings to senior management. Objective 5: Evaluate the current staffing situation against workload for adequacy and recommend any compensatory measures/efficiency measures to better balance the workload; Objective 6: Evaluate the staffing analysis, goals, and trends in relation to needed improvements (e.g., training, qualification, tools, and retention) and recommend additional actions for continued improvement; 3 Task 2017-04 Report January 25, 2018 This Tasking Report provides a summary of the observations and recommendations regarding the current management of the LANL Nuclear Criticality Safety Program. Since this review is an advisory review and not a compliance assessment, there are no findings. The assessment was largely conducted through plant interviews and document reviews. No facility walk downs were performed. A list of interviewee titles is provided in Attachment 3. The body of the report is divided into three sections: • Management of the NCS Program • NCS Program Staffing • NCS Process Observations A summary conclusion is provided at the end of the report. 3 Assessment Team The members of the assessment team were: Kevin D. Kimball, Team Lead, CSSG David G. Erickson, CSSG Chair These individuals have significant experience in managing criticality safety programs across the DOE complex and have been involved in recovery efforts at other sites. Biographies on the above team members may be located on the internet at the following address: https://ncsp.llnl.gov. 4 Management of the NCS Program 4.1 Review of CSSG 2012 and 2013 Corrective Actions (Objective 1) A review of the CSSG 2012 and 2013 assessments was performed in order to identify any progress and improvements that have occurred in the LANL NCS program following those assessments. Both the 2012 and 2013 assessments identified corrective recommendations. The current program documents were reviewed and interviews were conducted to determine if the previous CSSG recommendations were appropriately considered and implemented. This approach is consistent with the conduct of an advisory review. Based on a review by the team it appears that the recommendations have been appropriately implemented with one exception. That exception is a recommendation regarding the CSO program. The CSO program is still significantly understaffed and thus underutilized. More information is provided in Section 4.3 below. 4.2 Management of the Nuclear Criticality Safety Division (Objectives 2, 3, 4) The management of the Nuclear Criticality Safety Division (NCSD) appears to be on the right track for recovery of the program. Progress is ongoing and management recognizes that recovery to full capabilities will take a significant amount of time. Interviews indicate that senior management (i.e., above the Division Leader level) is engaged in the recovery efforts. Several observations were made in the area of management, which are presented below. • Workload of the NCS Division Leader. Since the NCS workforce attrition in 2012 and 2013, LANL management has elevated the NCS Manager position from a Group Leader level to a Division Leader level. The hired Division Leader previously worked at Lawrence Livermore 4 Task 2017-04 Report January 25, 2018 National Laboratory and is experienced in NCS; though that individual is inexperienced as a manager. Interviews show that he is respected among the individual members of the division, and they attribute much of the current success in the NCSD to the Division Leader. However, there are many indications that the Division Leader is overwhelmed with responsibilities. The review team is concerned that the Division Leader is performing too many “tactical” and technical tasks, which create an inherent choke point in productivity and could adversely impact improvement efforts. Some of this is certainly understandable given the low experience level of much of the staff. The assignment of establishing work priorities and schedules has been delegated to an Executive Advisor that supports the Division Leader. This delegation is a good example of what needs to be done to divest some tasks from the Division Leader, allowing the position to focus on more pressing management/leadership issues. The Division Leader position needs to maintain focus on strategic improvements and not day-to-day routine issues to ensure that improvements continue at the needed pace. Aligned with this concern is the fact that the review team did not see evidence of succession planning for the Division Leader position. It is acknowledged that there may not currently be a LANL NCS individual capable at this time to succeed to the position. The team did note that there were plans to hire either a Deputy or two additional line managers. Implementing that plan would support succession planning and help to mitigate management risks. • Use of Work Teams. The use of facility/operation centric Work Teams with identified NCS Points of Contact provides a good framework to maintain enhanced communications between NCSD and Operations. In addition, the organizational framework enables consistent resources to be applied to each operational area, which will help to rebuild operation-specific experience within the NCSD and helps to build trust between the operators and the assigned NCS engineers. Limited interviews with operations staff appear to confirm a good working relationship between the operations point of contact and the associated NCS engineers. • Staffing Plan and Program Improvement Plan. The Nuclear Criticality Safety Program Improvement Plan, NCS-PLAN-16-001, and the Nuclear Criticality Safety Division Staffing Plan, NCS-PLAN-16-002 are both good working documents. These should be reviewed by senior management regularly, and revised as appropriate to ensure that progress on NCSD improvement efforts is meeting expectations. In addition, some improvement strategies may need to be changed as progress is measured. One particular example was noted in the Staffing Plan. There are fixed retention bonuses established in the plan to hire and keep qualified individuals in the division. The bonuses are payable for a period of five years. This period was extended from three years because it was foreseen that attrition could occur at the point in time where the experienced individual was very much needed. Experience at Consolidated Nuclear Security, LLC and backed by industry experience, is that a fixed bonus is a temporary fix that will lead to future problems. The bonuses are of a size that removing them at any point in time will cause discord in the division. An alternate approach is to perform a base salary review and upgrade the salaries as appropriate. Then, a performance-based bonus program could be implemented that would reward the high performers and provide some incentive to the lower performers. Changing the compensation plan is not meant as a CSSG recommendation, but this example is one where the staffing strategy needs to be reviewed periodically against metrics to see if retention is improving. As noted in the 2013 CSSG review, compensation is not the primary reason for attrition. Compensation needs to be competitive, but focus also needs to be on the non-compensation areas that cause a person to leave. 5 Task 2017-04 Report January 25, 2018 • NCSD Budget. It was noted during the review that the NCSD is well funded with NA-50 support. This allows much flexibility for the NCS staff to spend time in training, time on the floor, continuing professional development, and upgrading criticality safety evaluations. However, it is unlikely that this funding will continue indefinitely. Management needs to be planning to ensure that the non-analysis tasks (e.g., engineer floor time or professional development opportunities) are not adversely affected by a change to normal funding levels (i.e., when NA-50 supplemental funding ceases). • Metrics. The metric report appears to be much improved since the last review by the CSSG; however, some key information seems to be lacking. The metrics cover many areas where improvement needs to be measured and provides a quick look at the health of the NCS program. Topics covered by the metrics include training, program implementation, assessments, criticality safety evaluations, process deviations, and program improvements. Some information is buried in the metrics report or requires a briefing to obtain. For example, the metric regarding employee turnover ratio displays month-by-month data regarding staffing. The turnover ratio is based on a 12-month average and shows relatively little change due to the averaging period. If only a surface look is taken, the metric indicates a negative trend in retention. An explanation of the metric, with corrective actions is not provided in the report. A graphical display of trends and the identification of corrective actions for adverse trends would be useful for senior management to quickly grasp the health of the program. Metrics need to be diagnostic in nature, with measurements to show the impact of intended positive actions. • Senior Management Engagement. During the interview process many senior managers who were interviewed indicated that they were very engaged in NCS. However, during the interviews with the Operations or NCS staff, it was apparent that they didn’t have the same opinion. The reason for the different opinions is most likely due to differing expectations by each group. This is a different concept than the assigned responsibilities in SD-130. Managers tend to consider themselves engaged if they are briefed on status reports or occasionally attend review meetings. Their perspective is that they manage the overall effectiveness of a given program and as long as they are cognizant of the issues, they are “engaged”. Individual staff members, however, consider Senior Managers as engaged when they see them in their work environment having oneon-one communications to go over accomplishments, issues of the day, or effectiveness of established work processes. It is recognized that Senior Managers’ time is valuable and limited. Nevertheless, their engagement is not only needed and appreciated, but is required by ANSI/ANS-8-19, Administrative Practices for Nuclear Criticality Safety. There are some methods for maximizing effectiveness of the limited, available Senior Managers’ time. At Y-12, a monthly scheduled management plant walkthrough is scheduled. The walkthrough is normally attended by a senior manager, a direct line manager, the NCS representative from the site office, one or two operators, and one or two NCS engineers responsible for a given system or process. The walkthroughs typically take a couple of hours, and in that time the NCS engineer has an opportunity to explain what changes are occurring for a particular system and the work they are performing to support those changes. In some cases the walkthrough is a review of a recent criticality safety infraction. The dialog is mission focused and often very informative to the Senior Manager. Such engagement conveys the importance of what the engineer is working on and support for the difficult decisions the engineer is called to make. Senior Management engaging with the staff even for just a few hours in a month, especially when it is expressed that the management is really supporting them, can go a long way in addressing some of the trust issues that have been noted in prior assessments/reviews. 6 Task 2017-04 Report January 25, 2018 4.3 Challenges for Operations Management • Reduced Operating Limits. Some years ago a Potentially Inadequate Safety Analysis (PISA) was declared by LANL regarding water flooding of gloveboxes due to a fire and activation of the fire suppression system. The PISA was followed by an Evaluation of the Safety of the Situation (ESS), which allowed two generic limit sets to be widely applied within the facility (a 4.5 kg dry material limit and 520 g limit for small sample / liquid operations). With the broad brush used to implement the reduced limits some operations are operating at limits well below past practices. Operators will naturally assume that the reduced limits are overly conservative if they have been working to much higher values. Without training on the background (the why), this can lead to a false sense of security or a belief that the limits are so conservative that strict adherence is not necessary. Accordingly, operations management should ensure that the operations staff understand the basis for these limits and provide confidence that management is aware of the limitations on their operation and are working to a planned schedule to address the restrictions. • Transition to a New “Normal” Operation. LANL operations, especially those in PF-4 have experienced numerous Readiness Assessments (RAs) to restart operations. The RAs tend to bring the highest level of formality in the conduct of the demonstrated operation. Once an operation is approved for restart, the high degree of formality (e.g., reader-worker method) of the RA will naturally tend to settle on a new normal operating practice. In many cases, a rigorous level of formality may not be warranted, though proper conduct of operations must always be followed. Experience from Y-12 showed that transitioning to a new “normal” way of doing business required extra diligence by managers and supervisors. Years of operating in a prior culture are not easily changed; in fact they are easily reverted to. Increased infractions should be expected during this time because of heightened reporting. Careful management approaches are needed to ensure that reporting of infractions are continued (and not suppressed) and that process improvements are directed toward helping operators be consistent and reliable in performing the operation. • CSO Program. The CSO program is not nearly as mature as the CSSG expected it would be given the amount of time that has passed since the last CSSG visit. The position appears to still remain for the most part a collateral or part time position. It is apparent that the related recommendations of the CSSG have not been implemented as was intended. The CSO program, if properly implemented and used, can be a vital leadership position to ensure proper implementation and conduct of operations. Just recently LANL Operations began filling full-time CSO positions with experienced leaders. The recent additions are experienced CSOs from other sites. LANL needs to give weight to their recommendations to improve the CSO program. Additional information from other sites through benchmarking trips would be beneficial if Operations management is a participant in the trips. Care should also be taken to ensure that the CSOs are not under undue operations pressure to “allow work to continue”. They play an important role in supporting operational implementation but if not supported by management can quickly be perceived as simply a hindrance to operations. 5 Staffing Observations (Objectives 5, 6) • Staffing Level and Experience. The LANL CSP Management has been working hard to improve the overall CSP staffing levels. An NCS Division Staffing Plan (NCS-PLAN-16-002) has been developed and is being followed/managed. This plan is presented in an earlier section of the report. While progress is being made in the total number of staff, the CSP is still 7 Task 2017-04 Report January 25, 2018 significantly understaffed with qualified analysts. The workload appears to be more than the currently staffed organization can handle. Management should proceed with caution in pushing the inexperienced staff too far out in front of their experience level. The staff is made up of engineers with all levels of experience, and the qualification process is being managed. The limited number of experienced LANL staff are serving as mentors for the inexperienced staff. While the time to achieve qualifications appears appropriate, it is noted that many staff are still going through the qualification process. Even after these engineers are qualified, more time will be needed to gain the experience necessary to provide efficient support. The NCSD Organization Chart that was provided notes that a significant number of the Senior Criticality Safety Analysts are subcontractor staff. It was noted from discussions that most of the subcontractors are only providing part time support to LANL, and some of that support appears to be happening remotely. This use of resources may be sufficient for supporting the development of the CSEDs, however, that was not evaluated as part of this assessment. The remote location of Senior Criticality Safety Analysts does not provide a means for the senior staff to provide the mentoring that most of the unqualified/inexperienced staff require. Such an arrangement will likely cause delays in qualifying existing staff and will certainly hamper qualification of staff yet to be hired. • Training. The time and priority afforded to the inexperienced NCS staff to pursue qualification appears appropriate as compared to programs at other sites. The Technical Seminars that are provided to the CSAs appear to be well worth the effort. LANL Management may want to consider implementing a similar seminar program for the operators to cover the bases behind controls. This could lead to more ownership of on-the-floor criticality safety, and improved conduct of operations related to criticality safety. LANL needs to ensure there are opportunities for other types of professional development to support improved retention of the CS staff. LANL is in a unique position in the complex because of the breadth of activities they support. There are opportunities to provide criticality safety analysts with a variety of career enhancing skills. Some may be interested in the critical experiments side, and could spend six to twelve months supporting the activities being performed at NCERC. Some may be interested in the Monte Carlo codes being utilized and could spend a similar amount of time supporting the code developers. While it is possible that some may choose to leave the NCSD they may remain employed at LANL and be open to future opportunities. • Time in Facility. The NCS staff interviewed were all aware of their goals for in-facility time to observe operations and it appeared that management was affording them the opportunity to meet these goals. What wasn’t clear was how the NCS staff determined when to be in the facility. The communications between the NCS staff and operations is important, particularly to note when specific operations are being performed that would be of most value for NCS observation. Operations should initiate the lead to bring the associated NCS analyst to ongoing fissile operations or major maintenance evolutions where equipment is being taken apart. This is especially important for fissile operations that are infrequent. Having facility walk downs with participation from senior analysts, CSOs, ORSs, NNSA, etc. is noted as a positive. This provides the less experienced staff with different perspectives. LANL is encouraged to continue this practice. 8 Task 2017-04 Report January 25, 2018 6 Process Observations Some observations were made regarding the NCS program processes that arose during interviews. None of the following areas are surprises to LANL, but are mentioned because process issues often have been solved or addressed at other sites. Therefore, routine communications with other NCS organizations may help solve such issues in a timely manner. • NCS Program Description (SD-130). A cursory review of the Criticality Safety Program Description Document required by DOE O 420.1C concluded that it was compliant with the requirements. Some elements of the document refer to DOE standards that have been recently revised. The new revisions would help in reducing the complexity of some elements of the NCS evaluations. For example, the requirements for addressing natural phenomena hazards was revised significantly in DOE-STD-1020-2016. Similarly, DOE-STD-3009-2014 revised guidance on elevation of NCS controls to the DSA. Additional guidance is available in a newly released major revision to DOE-STD-3007. SD-130 should be reviewed for these significant changes in requirements, which should help with the NCS evaluation process. • Resumption of Operations from Process Deviations. The following observations were noted about resumption of operations following a process deviation or upset condition. In one instance, that was discussed, the review team understood that an immediate action was taken to suspend the ability of the fissile workers to perform fissile operations until the issue was reviewed and resolved. Some actions that may seem appropriate to management, may be seen as ‘punishment’ by operations staff, thereby having the unintentional impact of stopping self-reporting. There are clear cases where suspension of “qualifications” is appropriate, but care must be taken to avoid setting up a negative environment that will drive a poor nuclear safety culture. Another issue that the team observed, was associated with the length of time needed to resume operations from minor process upsets. It was noted that Y-12 had a procedure on how to identify very minor deviations that could be field correctable and a process to develop a temporary deviation from evaluations to allow operations to continue. (As a side note, it is our understanding that Y-12 has sent their procedures to LANL.) Such procedural allowances may require a more mature NCS organization, so the ability to implement similar processes needs to be evaluated accordingly. Collaboration with other sites will help LANL from re-inventing a process already in use. Two good forums for networking with other NCS organizations are the American Nuclear Society meetings and the Energy Facility Contractors Group (EFCOG) NCS subgroup meetings. 7 Conclusion This review endeavored to take a high-level look at the LANL Criticality Safety Program, and based on the experiences of the review team to identify areas where things may be going well, but also to identify issues that if not properly addressed could lead to a degradation of the program. The team’s limited review indicated that management is engaged in the improvement efforts, and that plans are adequate to achieve the goal of a sufficient nuclear criticality safety program. However, high level attention must be maintained on the improvement progress. The program, though improving, is still in a very fragile state where progress could be disrupted by many factors. One such factor requiring close attention is the upcoming contract change. The very concept of a contract change will impact retention and management focus, and transition could adversely impact improvement efforts for a significant amount of time. Other factors are predictable (e.g., organizational or positional changes) and they need to be planned for well in advance as a risk mitigating action. 9 Task 2017-04 Report January 25, 2018 8 Attachments 8.1 Attachment 1 – CSSG Tasking 2017-04 CSSG Tasking 2017-04 Date Issued: October 3, 2017 10 Task 2017-04 Report January 25, 2018 CSSG TASKING 2017-04 Date Issued: October 3, 2017 Task Title: CSSG Review of LANL CSP Task Statement: In 2012, as documented in CSSG Tasking Response 2011-06, the CSSG identified a concern that a large fraction of the LANL CS staff had sought or was seeking alternative employment due to disputes with LANL management. In 2013 the concern came to fruition, resulting in the departure of nearly all CS staff members. Since that time there has been much effort put forth, including documenting the plan(s) to return the LANL CS Program health to the appropriate level. The CSSG is being requested to perform an advisory review with the objectives listed below: • Evaluate the current staffing situation against workload for adequacy and recommend any compensatory measures/efficiency measures to better balance workload; • Evaluate the staffing analysis, goals, and trends in relation to needed improvements (e.g., training, qualification, tools, and retention) and recommend additional actions to improve; • Evaluate core program implementation and advise on necessary next steps in the rebuilding process; • Evaluate the program improvement plan for its ability to generate an effective program and recommend any long/short term improvements; • Evaluate management engagement in monitoring the overall health of the NCS program including use of the NCS committee, NCS metrics, management assessments, and briefings to senior management. • Evaluate changes for effectiveness in resolving CSSG 2012 and 2013 identified issues and recommend any additional changes needed; • Evaluate corrective actions taken to address CSSG identified issues from the 2012 and 2013 assessments for effectiveness and note any gaps/additional actions needed. Resources: CSSG Task 2017-04 Team Members: • Kevin Kimball (Team Lead) • David Erickson Task Deliverables: 1. CSSG Subgroup to receive all necessary documentation prior to: October 6, 2017 2. Subgroup will meet at LANL: Week of October 23, 2017 11 Task 2017-04 Report January 25, 2018 3. CSSG Subgroup to provide draft document to full CSSG for review: November 15, 2017 4. Full CSSG to provide review comments to Task Team Leader: November 27, 2017 5. CSSG Subgroup to address comments and provide document to LANL for factual accuracy review: December 5, 2017 6. LANL provide comments by: December 12, 2017 7. CSSG team address comments, issue final report to NCSP Manager: December 20, 2017 Task Completion Date: December 22, 2017 Signed: _____________________________ Angela Chambers, Manager US DOE NCSP Office of the Chief of Defense Nuclear Safety, NA-511 12 Task 2017-04 Report January 25, 2018 8.2 Attachment 2 List of References Reviewed 13 1-H Task 2017-04 Report January 25, 2018 Documents Reviewed Approval of SD 130, Nuclear Criticality Safety Program, Revision 4, Kimberly Davis Lebak, NNSA Manager dated April 12, 2017. CSA Qualification Status, dated October 11, 2017 Current Organization Charts (Laboratory Director, Associate Directorate of Nuclear & High Hazard Operations, Nuclear Criticality Safety Division, Plutonium Science and Manufacturing). DIR-15-063, Revised Charter and Membership of the Institutional Nuclear Criticality Safety Committee, Charles F. McMillan, Laboratory Director dated May 28, 2015. LA-CP-16-20538, Annual Report on Status and Quality of LANL Nuclear Criticality Safety Program 2015-2016, October 4, 2016. NCS-MEMO-17-037, Nuclear Criticality Safety Program Performance Metrics through September FY17, dated October 10, 2017. NCS-PLAN-16-001, Nuclear Criticality Safety Program Improvement Plan, February 24, 2017, Revision 1. NCS-PLAN-16-002, Nuclear Criticality Safety Division Staffing Plan, October 25, 2016, Revision 0. SD 130, LANL System Description, Nuclear Criticality Safety Program, dated September 30, 2009. 14 Task 2017-04 Report January 25, 2018 8.3 Attachment 3 – Los Alamos National Security, LLC and Los Alamos Field Office Titles of Personnel Interviewed NNSA-Los Alamos Criticality Safety Engineer Nuclear Criticality Safety Division Leader Principal Associate Director Operations and Business Principal Associate Director Weapons Program Associate Director Nuclear & High Hazard Operations Deputy Associate Director Nuclear & High Hazard Operations (2) Associate Director Plutonium Science & Manufacturing Nuclear Criticality Safety Executive Advisor Nuclear Criticality Safety Engineers (5) Operations Responsible Manager (1) Operations Responsible Supervisor (2) Criticality Safety Officer Strategic Science & Engineering Division Office? TA-55 Facility Operations Director Nuclear Criticality Safety Committee Chair Nuclear Criticality Safety Board Chair 15 Task 2017-04 Report January 25, 2018 8.4 Attachment 4 Assessment Out Brief Slides 16 1-H 12/20/2017 CSSG Review of LANL CSP Out Brief Kevin Kimball, Team Lead David Erickson, CSSG Chair October 26, 2017 Los Alamos, NM OUTLINE • Introduction • Overall – CSSG – NCS – OPS • Specific Observations – Management – Staff – Process 2 1 12/20/2017 Overall • CSSG (2013 Assessment) – All LANL recommendations appear to have been addressed with  one exception • CSO Program   • Overall NCS program on right track, but fragile • NCSD – Inexperienced Staff – High Workload – Leadership vs Management • Operations – Restrictive Limits – Readiness Assessments vs Usual Operation 3 Management Observations • NCSD Leadership and staffing on right track – Work Teams with Points of Contact good  framework – Assignment of work priorities and schedules to  Executive Advisor a good management practice – Concern about bandwith of NCSD manager • Need to move forward with either deputy or  Management leads • Other Sites examples on technical management • Succession Planning 4 2 12/20/2017 Management Observations • Staffing Plan and Program Improvement Plan  good working documents • Budget for NCS well funded with NA‐50 support • Metrics – Metric report improved from last review – Report leaves open questions • Actions to correct • Display of trends • When to elevate declining or stagnant trends 5 Management Observations • Senior Management presence “on the floor” • CSO Program – Recommendation of CSSG not implemented as  intended – Can be a vital leadership position to help  operations transition to new “normal” – New full‐time Positions filled with experienced  leaders – give weight to their recommendations – Other sites examples; possible benchmark trips 6 3 12/20/2017 Staff Observations • Sr. CSA – Some not onsite (misleading?) – Mentors (availability?) • Training – Time/priority seems appropriate – Technical Seminars for CSAs; consider for operators – Opportunities for other professional development • Time in Facility – Two‐way communications important • Invite from Operations to observe FMO? – Facility Walkdowns • CSAs, CSOs, ORS, NNSA (variety is positive) 7 Process Observations • SD‐130 approved and compliant • Noted areas of struggle: – Design Basis events • NPH – look at DOE‐STD‐1020‐2016 • Fire – requires close interaction with Fire Protection – Resumption of Operations from Process  Deviations • Avoid driving negative behavior • Other Site examples 8 4 12/20/2017 Questions?