INDEX
CHAPTER VI
SURVEY RATINGS AND FOLLOW-UP ACTIONS
1. RATING SYSTEM. Permissible composite nuclear materials or security
survey ratings are SATISFACTORY, MARGINALLY SATISFACTORY, and
UNSATISFACTORY. The following composite survey ratings shall reflect a
balance of performance and compliance results as determined by the
surveying organization.
a. Satisfactory. The safeguards and security element being evaluated
meets identified protection needs or provides plausible assurance
that those protection needs will be met should they arise.
b. Marginally Satisfactory. The safeguards and security element
being evaluated only partially meets identified protection needs
or provides questionable assurance that those protection needs
will be met should they arise.
c. Unsatisfactory. The safeguards and security element being
evaluated does not meet identified protection needs or does not
provide adequate assurance that those protection needs will be met
should they arise.
2. IDENTIFIED PROTECTION NEEDS. Identified protection needs are those
defined by DOE Orders as modified by approved MSSAs, facility
safeguards and security plans, approved safeguards and security
upgrades, and documented and approved exceptions to DOE requirements.
These modifiers specify site-specific considerations and tailor the
safeguards and security program to the local mission and operating
environment. They shall be comprehensive and supportable relative to
threat and safeguards and security interests (i.e., targets).
3. USE OF THE "MARGINALLY SATISFACTORY" RATING. A facility shall not be
assigned a survey rating of Marginally Satisfactory for consecutive
survey periods unless the following conditions apply:
a. The previous survey which resulted in a composite survey rating of
Marginally Satisfactory identified different deficiencies and
reasons for the rating.
b. The deficiencies and reasons which were the basis for the previous
Marginally Satisfactory composite survey rating were related to
the completion of a major line-item construction project. In that
case, acceptable interim measures must have been implemented and
physically verified pending completion of the construction. These
interim measures shall be documented in the survey report.
4. USE OF UNSATISFACTORY RATING. If either of the conditions cited in
paragraphs 3a or b, above, are not met, an Unsatisfactory rating shall
be assigned.
5. CORRECTIVE ACTIONS AND SURVEY RATINGS. A composite nuclear materials
and/or security survey rating which must be based on conditions
existing when the rating was assigned. Shall be stated in the survey
report, ratings shall not be based upon future corrective actions. If
corrective actions have been taken in the interval between the
performance of the onsite survey and the assignment of the composite
survey rating, the final rating should reflect these actions.
6. DEFICIENCIES IN DOCUMENTATION. A facility's failure to comply with
procedural documentation requirements, of and by itself, shall not
normally be the basis for a reduction in a composite rating. Ratings
of less than Satisfactory in any area shall be based on verified
weaknesses in the safeguards and security system or deficiencies in
performance in an operational area.
7. COMPLIANCE. The compliance segment rating of a facility reflects the
judgments of the surveying organization as to the assurance with which
the facility's safeguards and security system protects the DOE
interests located at that facility as measured against related DOE
directives (see page V-4, paragraph 5).
8. PERFORMANCE. The rating for the set of exercises, system studies, and
technical evaluations, constituting the performance segment of the
survey, shall be based on an evaluation of the degree to which the
elements of the safeguards or security system meet protection
objectives.
9. SURVEY FOLLOW-UP AND CORRECTIVE ACTIONS.
a. When a nuclear materials and/or security survey report contains
findings, the surveyed organization shall submit a response
identifying corrective action(s) for each finding to the
responsible and surveying organizations not later than 30 days
after receiving the survey report.
b. When a survey report indicates a composite rating of Satisfactory
and contains findings requiring corrective action, the responsible
organization shall provide to SA-10, the appropriate Secretarial
Officers, and the surveying organization (if appropriate), a
quarterly status report of corrective actions. Notification shall
be by memorandum and shall include the identification of the
facility, a description of the deficiency, and a description of
corrective actions taken to date or planned (with associated
milestone dates).
c. When a survey report has a composite rating of Marginally
Satisfactory, the responsible organization shall notify the
Director, SA-10, the surveying organization (if appropriate), and
the applicable DOE Field Office and Secretarial Officer(s) within
15 working days after completion of the survey of interim
corrective actions taken, or to be taken, to correct identified
risks or vulnerabilities. If interim corrective actions are
instituted, the surveying organization shall physically verify
them for adequacy. If the surveying organization differs from the
responsible organization, the surveying organization shall
promptly notify the responsible organization of the rating. The
responsible organization shall then take appropriate corrective
and notification actions outlined above or authorize the surveying
organization to take those actions. If the surveying organization
is unable to contact the responsible organization and a serious
threat exists or is imminent, the surveying organization shall
take action to protect the safeguards and security interest(s)
until the responsible organization is notified. Subsequent action
shall be taken on the basis of agreement between the two
organizations.
d. When a survey report has a composite rating of Unsatisfactory, and
the rating is indicative of a significant vulnerability, such as
unacceptable risk in the area of SNM theft, radiological or
industrial sabotage or espionage, the DOE Field Office Manager
shall immediately, in coordination with the cognizant Program
Secretarial Officer or as soon as possible, but not later than
within 24 hours: (1) take action to shut down/suspend operation
of the facility or activity, pending remedial action; or (2)
provide the rationale for continuing this critical operation to
the cognizant Secretarial Officer and SA-10 and identify those
immediate interim corrective actions being undertaken to mitigate
identified risks or vulnerabilities. For all other Unsatisfactory
ratings, the DOE Field Office Manager of the responsible
organization shall notify the cognizant Secretarial Officer and
SA-10 within 15 working days of interim corrective actions taken,
or to be taken, to correct identified risks or vulnerabilities.
e. When either a Marginally Satisfactory or Unsatisfactory composite
rating is assigned, the responsible office shall provide to SA-10
and the applicable DOE Field Office and Secretarial Officer(s)
quarterly status reports on completed or planned corrective
actions (with associated milestone dates) until all have been
completed. When the responsible organization determines that the
composite survey rating should be upgraded to Satisfactory, the
surveying organization shall physically verify the completion and
adequacy of corrective actions for those deficiencies which
contributed to the Marginally Satisfactory or Unsatisfactory
composite rating. The responsible organization shall then notify
the Director, SA-10, and the cognizant Secretarial Officer(s) that
the rating should be upgraded.
f. A finding associated with a significant vulnerability shall not be
considered closed until associated corrective action has been
completed and SA-10 and the Secretarial Officer(s) are notified.
A commitment by the facility to institute corrective action does
not constitute completion of that corrective action.