NA-1 SD M 226.1A, NNSA Line Oversight and Contractor Assurance System Supplemental Directive
The Line Oversight and Contractor Assurance System (LOCAS) is the National Nuclear Security Administration (NSSA) management system that drives mission performance and operational excellence. It requires the implementation of effective contractor self-assurance systems. coupled with focused Federal oversight. It allows efficient use of personnel and budgets. This Supplemental Directive, in conjunction with the requirements of Department of Energy (DOE) P 226.1A, DOE Oversight Policy, and DOE O 226.1A: Implementation of DOE Oversight Policy, establishes the broad framework for executing NNSA's overall oversight system. This
Supplemental Directive provides requirements and guidance for the NNSA line oversight and contractor assurance systems and additional requirements and expectations for specific functional areas.
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Section 1
MANUAL
Approved: 10-1 7-08
NNSA Line Oversight and Contractor
Assurance System Supplemental Directive
U.S. DEPARTMENT OF ENERGY
National Nuclear Security Administration
AVAILABLE ONLINE AT:
Iink to NNSA Policicsisupplementa1 directives
This page is intentionally blank.
NNSA LINE OVERSIGHT AND CONTRACTOR ASSUWNCE SYSTEM
SUPPLEMENTAL DIRECTIVE
1. PURPOSE. 'The Line Oversight and Contractor Assurance System (1,OCAS) is the
National Nuclear Security Administration (NSSA) management system that drives
mission performance and operational excellence. It requires the implementation of
effective contractor self-assurance systems. coupled with focused Federal oversight. It
allows efficient use of personnel and budgets. This Supplemental Directive, in
conjunction with the requirements of Department of Energy (DOE) P 226.1A, DOE
Oversight Policy, and 001; O 226.1A: Itnplementurion qf'll)OE Oversight Policy.
establishes the broad framework for executing NNSA's overall oversight system. This
Supplemental Directive provides requirements and guidance for the NNSA line oversight
and contractor assurance systems and additional requirements and expectations for
specific functional areas.
'I -. CAKCH,LATIO. None.
9
3. AI'PLICABILITY.
a. Departmental Elements. Except for the exclusions in paragraph 3.cl this
Supplemental Directive applies to all KNSA Departmental elements.
b. NNSA Contractors. Except for the exclusions in paragraph 3.c, Attachment 1 of
the Contractor Requirements Document (CRD) sets forth the requirements of this
Supplemental Directive that apply to contractors. This Supplemental Directive
applies only to Management and Operating contracts, prime security contractors.
and other prime contractors as identified by the Site Office Manager or
Contracting Officer.
Once notified, the Contracting Officer 1s respons~ble for incorporating the
applicable requirements ofthe CRI) into the laws, regulations, and DOE
Directives clause of each contract fbr contractors that perform work at or for any
KNSA facility affected by this Supplemental Directne.
Regardless of tile performer of the work, the prime contractor is responsible for
compliance with the requirements ofthe CRD that are incorporated in its contract.
The prime contractor is responsible for flowing down the requirements of the
CRD to subcontractors at any tier to the extent necessary to ensure the
subcontractor's compliance with the requirements and the safe performance of
work at or for any NNSA facility.
c. Exclusions. This Supplemental Directive applies to all KNSA elements except
for the Office of Naval Reactors (NA-30) unless the NNSA element or contractor
has an exemption granted in writing from the NXSA Administrator.
Requirements of this Supplenlental Directive do not apply to oversight of
contractors in functional areas where the contractor is externally regulated by
NA-I SD 226.1A
10-1 7-08
agencies such as the Kuclcar Regulatory Commission or the Occupational Safety
and IIealth Administration.
1. REQUIREMENTS.
Line oversight and contractor assurance system activities confirm adequate performance,
identify areas of needed improvement, and address previously identified issues.
Oversight processes must balance efforts among these objectives. The following
requiremellts and the requirements in the applicable attachments to this Supplemental
Directive (CRD Attachment 1 and Attachments 2 through 7. which impose additional
requirements for nuclear safety. environment, sarety, and health (ES&H), safeguards and
security, cyher security, emergency management, and business management,
respectively) supplement, or provide further definition to- DOE O 226.1A. In the event
of a conflict between this Supplemental Directive and a DOE Order or blanual, the DOE
Order or Manual takes precedence.
Section 2
a. Contractor Assurance System.
(1) In addition to the requirements and expectations set forth in DOE O
226.1A or successor directives and applicable contract requirements, the
Contractor Assurance System (CAS) must meet the requirements in
Attachment 1 to the CRD.
b. NNSA Site Office Line Oversight.
This section provides specific direction supplelnental to DOE O 226.1.4 for Site
Office line oversight activities. Each Site Office oversight program must include
the threc elements discussed below.
( I ) Evaluation of the Contractor's Assurance System: The Site Office must
assess the effectiveness of the CAS using a variety of methods. These
methods may include shadowing contractor assessments. comparing
contractor assessment results and performance metrics with the results of
similar assessments conducted by NNSA or credible outside evaluators,
and evaluating contractor performance in resolving previously identified
issues. Information regarding CAS effectiveness may he used to support
contract management and to tailor Site Office oversight of contractor
overall performance, as discussed in section 4.b(2) below.
(2) Evaluation of Overall Contractor Performance: Each Site Office must
develop and document an oversight program and annual implementation
plan and schedule for evaluating overall contractor performance. The
oversight program must include the use and the evaluation of CAS. The
Site Office inust reference its oversight processes or procedures in its
Contract Management Plan (CMP) as required by h e DOE Acquisition
Guide. or in an equivalent document. 'The CMP is an overarching
document that incorporates or references documents that describe how tlie
Site Office manages its contracts and evaluates contractor performance.
The Site Office oversight program. as described in the CMP, must
establish requirements for a contractor oversight process that complies
with DOE O 226.1A. This program must also establish requirements for
the frequency, approach, and level of effort of' Site Office assessments
based on criteria that are defined in the oversight program. These criteria
should reflect a tailored approach that considers such factors as the
significance ofthe requirement. the uniqueness and complexity of
contractor operations, and the potential consequences of failing to meet
contract requirements. Line oversight activities should focus on the areas
of weakness in the contractor's program as evidenced by a tailored, risk-
informed evaluation. Site Offices should use this tailored approach to
conserve Federal resources in areas where there is documented evidence
that the CAS is performing well or where the consequences oS
performance deficiencies are minimal. This allows Federal resources to
be focused on those areas where consequences of failure are high or where
more rigorous assessments to drive contractor perSormance improvement
provide the most value.
I . The effectiveness of the CAS is a factor in tailoring Site Office
oversight. Site Office oversight of contractor perfornlance should
rely on the CAS only to the extent justified by documented Site
Office evaluations of the CAS.
. .
n. The Site Office oversight program may take into consideration
information provided by external sources, including information
from contractor self-assessments, internal audits. and other
assurance systems, as well as from independent sources.
...
111. Site Office assessment activities that satisfy the assessment
Section 3
requirements in Attachments 2 through 7 include the following:
(a) Formal I>Ok or NNSA line management assessments
conducted according to documented review plans;
(b) Routine oversight by Headquarters or Site Office personnel
where the documented results of the overs~ght clearly
~dentify the scope of the oversight. the requirements against
which the contractor was evaluated. and the rcsults of the
oversight activitj; and
(c) Contractor assessment activities where Site Office
personnel participated in or observed the assessment and
NA-I SD 226.1 A
10-17-08
documented the results of their participation, including an
evaluation of the efkctiveness of the contractor assessment.
(3) Each Site Ofiice must develop and implement a procedure that defines its
approach to self-assessment that complies with the self-assessment
requirements in DOE O 226.1A. Site Offices must develop annual
schedules for executing their self-assessment procedures. Attachments 2
through 7 to this Supplemental Directive contain requirements specific to
individual functional areas.
s- . NNSA Ileadquarters.
NNSA Headquarters must develop an oversight program for evaluating Site
Office performance. NNSA Headquarters Functional Management Plans (FMPs)
are developed to define the NNSA oversight program for each functional area
covered by this Supplemeiltal Directive. For each functional area, the FMP
describes the implementation of DOE O 226.1A and this Supplemental Directive
in that area. The FbIP may reference other procedures to document specific
oversight processes. Each FMP, along with an associated assessment or review
schedule, must be submitted to the NNSA Principal Deputy Administrator for
approval on an annual basis. Prior to its being submitted for approval, each FMP
should be coordinated with all NNSA organizations assigned oversight and
assessment responsibilities and with the Site Office Manager. I h e responsible
functional area managers and the scope of each functional area are defined below:
(1 ) Nuclear Safetj - The NNSA functional leader for nuclear safety is the
Chief of Defense Nuclear Safety. This functional area encompasses those
requirements and policies defined in DOE O 410.1, Central Technical
Authority Responsibilities Regarding Nuclear Safety Requirements.
(2) Environment, Safety, and lIealth -The NNSA functional leader for ES&H
is the Senior ES&H Advisor. This functional area includes all ES&H
requirements except nuclear safety requirements. as defined in D O 1 3
410.1.
(3) Safeguards and Security - The functional leader for safeguards and
security is the Chief of Defense Nueleax Security. This functional area
includes all physical security program elements.
(4) Cyber Security - She functional leader for cyber security is the m l S A
Chief Information Officer. This functional area includes all cyber security
program elements.
( 5 ) Emergency Management - The functional leader for emergency
management is the Associate Administrator for Emergency Operations
This functional area includes all emergency management program
requirements, as defined in DOE O 15 1.1 C, C'onzprehensive Eme~gency
Mu??ugemenl Sy.stenz.
(6) Business Management - The functional leader for business management is
the Associate Administrator for Management and .4dministration. This
functional area includes the business areas of procurement. finance,
personal property, small business. contractor human resources. and
contract administration.
Section 4
In each functional area, the FMP must define an VKS.4 Headquarters oversight
program consisting of three elements: evaluation of Site Office performance
(which may include limited assessment of contractor operations, primarily for
nuclear safety, safeguards and security, cqber security, and other high-hazard
activities), operational amareness of program and facility operations, and NNSA
Headquarters self-assessment. These elements are discussed further below.
(1) Evaluation of Site Office Performance: Each FMP must contain an
approach for conducting and evaluating the effectiveness ofthe NNSA
Site Office oversight programs in that functional area. Unless otherwise
required in I)OE 0 226.1A or this Supplemental Directive, the lead for
each functioilal area may rely on a review of Site Office self-assessment
results in evaluating Site Office oversight, considering such factors as past
performance. the significance of the requirement, the uniqueness and
complexity of operations, and the potential consequences of failing to
meet rccjuirements.
(2) Operational Awareness: Each FMP must describe the operational
awareness approach within that functional area. Specilic requirements for
NNSrt Headquarters limited oversight of contractor high-hazard
operations are addressed in Attachments 2 through 7 of this Supplemental
Directive. Unless otherwise required in DOT: 0 226.1 A or this
Supplemental Directive, the lead for each functional area may choose to
rely on Site OStice oversight of the management and operating contractor
to obtain operational awareness information on contractor performance.
(3) Self-Assessnient: Each KNSA Headquarters organization must conduct a
biennial self-assessment of its oversight and line management roles and
responsibilities. The self-assessments must be consistent with the
requirements in DOE O 226.1.4. Each organization must develop a
procedure for its self-assessment program that is approved by the
appropriate Deputy or Associate Administrator. For organizations within
the immediate Office ofthe Administrator, these self-assessment
procedures must be approved by the Principal Deputy Administrator.
a. Principal Deputy Administrator.
(1) Develops and maintains this Supplemental Directive
(2) Approves the NNSA Ifeadquarters functional area FMPs and annual
assessment and review schedules.
(3) Approves the self-assessment procedure for NNSA IIeadyuarters
organizations within the immediate Office of the Administrator.
b. Deputy and Associate Administrators
(1) Ensure that the requirements in this Supplemental Directive are
implemented for facilities, activities. or programs under their cogni~ance.
(2) Appro~es the self-assessment procedures for NNSA Headquarters
organi~ations within their purvieu .
(3) Comply with the FLIPS for NNSA Headquarters oversight for the
programs, facilities. and operations within their purview.
c. Functional Leaders
(1) Develop NNSA Headquarters functional area FMPs for their assigned
functional areas.
(2) Develop assessment and review schedules for their assigned functional
areas.
d. Heads of Field Elements
(1) Fnsure that the facilities, activities. and programs uiihin their purview
comply w ~ t h the requirements of this Supplemental Directive and the
CRD.
(2) Coordinate with Contracting Officers to revise contracts to comply with
the requirements of this Supplemental Directike and to require contractors
to appropriately flow down requirements to subcontractors.
Section 5
(3) I;,nsure that procurement requcsts include applicable CRD requirements to
be applied to awards or subauards.
(4) Review and approve (through the Contracting Office as necessary) the
detailed program descriptions for the contractor's CAS and subsequent
updates reflecting significant changes.
( 5 ) Approve the CMP, 1,inc Opersight Plans, and annual execution schedules.
6. REFERENCES.
b DOE P 226.1A, Del~urtnzent of E n e r a Overright Polley
c. DOE Acquisition Guide
d. Guide to Creating a Contract Management Plan," March 2002
7. DEFINITIONS.
a. Assessment: This definition, taken from the Nuclear Safety PMP. describes the
Site Office activities that constitute assessments: formal Site Office assessments
conducted according to documented review plans; routine facility representative
coverage where the results of the facility representative observations clearly
document the activities ohsenred, the requirements being evaluated, and the
results of the observations; routine oversight by safety system oversight personnel
where the documented results of the oversight clearly identify the scope of the
oversight, the requirements against which the contractor was being evaluated. and
the results of the oversight activity; and contractor assessment activities where
Site Office personnel participated in or observed the assessment and documented
the results of their participation, including an evaluation of thc effectiveness of
the contractor assessment.
b. Contract Management Plan: A plan that summarizes how contract oversight
responsibilities will be conducted. It does not identify ever] action that the Site
Office or contractor must complete or perform, but rather sets forth the higher-
level contract requirements, deliverables. and performance activities.
c. Finding: 4 violation of an identified requirement
d. Functional Management Plan: A plan that summarizes the meihodolog> of
uslng individual or integrated functional oversight plans to meet Headquarters
requirements for line overs~ght of Site Offices.
e. High-Risk Activity: Activities that involve nuclear safety. nuclear material
safeguards and security, or cyber security. Other activities are evaluated on a
case-by-case basis to determine risk. An activity that may be considered high-risk
is a Biosafety Levei 3 operation.
f. Preventive Action: A change implemented to address a weakness in a
management system that has not yet resulted in a finding.
g. System-Based Oversight: Oversight activities that assess contractor
performance through evaluating the contractor's processes and management
systems and the &data normally generated by these systems.
h. Transactional-Based Oversight: Oversight activities that assess contractor
performance through evaluating contractor activities at the work, task, or facility
level: direct interaction with personnel at any level within the contractor
organization; and direct independent Federal staff evaluation of activities.
physical conditions, and contractor documentation.
1. Weakness: A situation that. while not a direct violation of an identified
requirement, may, if not resolved. lead to degradation in performance.
Management attention is recommended to evaluate the situation and take action as
deemed appropriate.
8. CONTACT.
Questions concerning this Supplemental Directive should be should be addressed to
James McConnell at (202) 586-4379.
. ~ o M A ' s P. I) 'AGOSTI~O
Administrator
ix (and xf
CONTENTS
Section 6
Contractor Assurance System CRD ............................................................................. Attachment 1
Nuclear Safety ............................................................................................................. T4ttacl~mcnt 2
Environment. Safety. and Health ................................................................................. Attachment 3
Safeguards and Security .............................................................................................. Attachment 4
Cyber Security ............................................................................................................. Attachment 5
Emergency hlanage~nent ............................................................................................. Attachment 6
Business Management ................................................................................................. Attachment 7
This page is intentionally blank.
Attachment 1
CONTRACTOR ASSCRAKCE SYSTEM
CONTRACTOR REQUIREMENTS DOCUMENT
Attachment 1
Page 1 (and 2)
The contractor must submit a detailed contractor assurance system (CAS) program description to
the Site Oftice Manager for review and approval that addresses, at a minimum, the following
aspects of operations: (I) nuclear safety; (2) environment, safety, and health. (3) safeguards and
security; (3) emergency management; (5) cyber security; and (6) business management. The
contractor must submit any updates to the detailed CAS program description to the Site Office
Manager for revieu and approval whenever significant changes occur.
rhe contractor shall facilitate effective sharing of all CAS information with NNSA. including
electronic access.
, I . his page is intentionally blank
NA-I SI) 226.1 X
10-1 7-08
Attachment 2
Page 1
Attachment 2
NUCLEAR SAFETY
1. PURPOSE. This Attachment establishes the specific rcquirements and guidance for
NNSA nuclear safety line oversight.
2. CANCELLA TION. None
a. Departmental Elements. Except for the exclusion in paragraph 3.b. this Chapter
applies to all NNSA Departmental elements that are responsible for. or manage,
nuclear facilities as defined in 10 CFR 830, h'ucleur Sufity Munugernent.
b. Exclusion. This Attachment applies to all NWSA elements except for the Office
of Naval Reactors, KA-30.
a. NKSA Sitc Oftice Line Oversight Systems.
(I) Nuclear safety oversight must be conducted with the frequency, level of
comprehensiveness, and rigor appropriate to ensure safety of the workers,
the public, and the environment. One of the primary goals of nuclear
safety obersight is to preclude, not just minimize the potential for,
catastrophic nuclear accidents
( 2 ) NNSA Site Office oversight of nuclear safety should take advantage of the
information provided by external sources. but the Site Office's nuclear
safety oversight program must be sufficiently comprehensi~e to allow the
Site Office Manager to accurately exaluate and communicate contractor
performance against all nuclear safety requirements, identify nuclear
safety performance issues in a timelq manner, and effectively resolve
nuclear safety issues without relying on external oversight.
b. Site Oftjce oversight of nuclear safety can be tailored to account for the contractor
assurance sqstem (CAS) to the extent that the Site Office has ~erified and
documented the adequacy of the CAS.
Section 7
c. For nuclear safety. the Site Office oversight program must assess the adequac) of
contractor programs and procedure? and the implementation of those programs
and procedures. Assessing the implementation of contractor programs and
procedures must involve direct obsenrat~on of contractor performance or a revle*
of specific work products resulting from the contractor programs and procedures.
Attachment 2
Page 2
d. At a minimum, the Site Office program ibr oversight of nuclear safety must
include the following elements (in addition to the specific requirements in DOE 0
226.111):
(1) Assessments that validate the continuing, effective implementation of
technical safety requirements (TSRs) for Hazard Category 2 and 3 nuclear
facilities. The number of assessments should bc sufficient to draw a
meaningful conclusion regarding the status of fSR implementation on an
annual basis.
(2) Assessments of equipment configuration, material condition. and
maintenance of safety-class and safety-significant systems. structurcs, and
components (SSCs). An assessment of each safety-class SSC should
occur at least once every three years. An assessment of each safety-
significant SSC should occur at least once every five years. Assessments
of a representative sample of similar systems arc acceptable provided that
the systems are of similar age. design. and classificat~on.
(3) Assessments of the safety management programs defined in documented
safety analyses for Hazard Category 2 and 3 nuclear facilities. An
assessment of each safety management program should occur at least once
every five years. Where a site-wide safety management program covers a
number of facilities, it is sufticient to sample the implementation in a
subset ofthe facilities, provided that at least one safety management
program in each Huard Category 2 and 3 nuclear facility is assessed over
a given five-year period.
[4) Assessments that, over a period not to exceed five years, ensure the
effective implementation of nuclear safety requirements in the directives
listed in Attachment 1 to DOE O 41 0.1, C:enlrul Technical Authoriry
Re.spon.sibilities Regurding l\~uclear Sufi@ Requi~.ements, that are not
covered by the assessments described above.
(1) For nuclear safety, direct assessment of contractors by SNSA
Headquarters organizations consists of the following:
1. Biennial review of Site Office nuclear safety performance -
although these are primarily reviews of Site Off7ce performance;
they contain an element of direct contractor assessment to validate
the results of Site Office oversight and assessment activities.
Attachment 2
Page 3 (and 4)
. .
n. For-cause reviews - from time to time. NNSA Headquarters
organizations may conduct for-cause reviews, accident or incident
investigations, or direct assessments responding to inquiries from
external stakeholders. 'These reviews must have the approval of
the appropriate NNSA line mdnager (Assistant Deputy
Administrator for Nuclear Safety and Operations or Site Office
Manager) or of the Chief of Defense Nuclear Safety. Each review
should be coordinated with the appropriate Site Office Manager.
. . '
in. Reviews requested by the Site Office Manager
iv. Support of Site Office assessments - NNSA Headquarters
organizations may provide support for Site Office assessments of
contractor nuclear safety programs.
Section 8
(2) The primary mechanism for oversight of Site Office performance in the
area of nuclear safety is the NKSA biennial review process. Biennial
reviews are conducted according to a protocol approved by the NNSA
Administrator or Principal Deputy Administrator. From time to time, the
Administrator. Principal Deputy Administrator, or Deputy Administrator
for Defense Programs may direct specific for-cause reviews of Site Office
performance issues in thc area of nuclear safety. Such reviews are outside
the planned scope of the Functional Management Plan (FMP) for nuclear
safety.
(3) The nuclear safety FMP will describe the routine operational awareness
programs for the Deputy Administrator for Defense Programs and tile
Chief of Defense Nuclear Safety Collectively, these operational
awareness programs should meet the requirements in DOI: O 226.1A.
Specific operational awareness activities must include oversight of
corrective actions. including metrics, periodic status reporting, and rollups
of NNSA correctibe action tracking
Attachment 3
Page I
Attachment 3
ENVIRONMENT, SAFETY, AND HEALTH
1. PURPOSE. rhis Attachment establishes the specific requirements and guidance for line
NNSA line oversight concerning environment, safety, and health (ES&II).
2. CAr\lCEI,I.ATION. hone
a. Departmental Elements. Except for the exclusion in paragraph 3.b. rhis Chapter
applies to all NNSA Llepartmental elements.
b. Exclusion. This Attachment is applicable to all NNSA elements except for the
Office of Naval Reactors. NA-30.
a. NXSA Site Office Line Oversight Systems.
1) ES&II oversight must be conducted with the frequency. level of
comprehensiveness, and rigor appropriate to ensure safety of the workers,
the public, and the environment.
2 ) NNSA Site Office ES&H oversight should take advantage ofthe
information provided by external sources, but the Site Office's ES&H
oversight program must be sufficiently comprehensive to allow the Site
Office Manager to accurately evaluate contractor performance against all
ES&II requirements and communicate resulrs; identi@ ES&H
performance issues in a timely manner; and effectively resolve ES&H
issues without relying on external oversight.
a) Site Office ES&H oversight can be tailored based on assessment
results of the contractor assurance system (CAS) only to the extent
that the Site Office has herified and documented its adequacy.
b) Site Office ES&l1 oversight should primarily be accomplished
through rnonitor~ng and evaluatmg the contractor's CAS. The
level and nature of Site Off& I:S&IJ oversight. l.e., transactional
vs. systemic. should be based on the significance of the ha/ard and
performance by the contractor. including performartce of the CAS
c) Once the CAS has been deemed fully operational, the Site Office
Manager may continue to perform transactional oversight of
specific non-nuclear operations mvolving high risks to the
environment or to worker and public safet] and health (e.g..
Attachment 3
Page 2
Biosafcty Level 3 operations). The designation of non-nuclear
operations as high-hazard and the associated oversight plan must
be included in the annual Site Office schedule of planned
assessments and focus areas for operational awareness.
Transactional oversight may also be a necessary component of any
for-cause evaluation.
d) At a minimum, the Site Office ES&H oversight program must
include assessments of aspects of the following program elements
(in addition to the specific requirements in DOE O 226. I A,):
Section 9
1. -1 he contractor's 10 CI'R Part 85 1 -compliant Worker
. .
Safety and Health Program.
11. The contractor's t:nv~ronmental Management System
. . .
111. The contractor's Work Planning and Control System.
3 ) Site Offices should develop a self-assessment plan to ensure that major
aspects of all ES&EI programs are evaluated at least every three years.
Site Office ES&II self-assessments should include an evaluation of its
Federal Employee Occupational Safety and Health (FEOSH) Program.
4) NNSA is responsible for maintaining operational awareness of contractor
ES&II activities. In addition to scheduled oversight, Site Offices maintam
daily interactions. conduct meetings regularly with contractor personnel to
monitor the status of issues and initiatives, and routinely observe
contractor activities.
I ) NNSA Headquarters ES&H oversight shall include:
a) Quadrennial assessments of Site Office FEOSH Programs
b) Quadrennial reviews of Sitc Office ES&H performance - Although
these are primarily reviews of Site Office performance. they may
contain an element of direct contractor assessment to validate the
results of Site Office oversight and assessment activities.
2) For-Cause Reviews: When conditions warrant, NNSA Headquarters
organizations may conduct for-cause reviews. accident or incident
investigations, or direct assessments responding to inquiries from external
stakeholders. These reviews must have the approval of the appropriate
NNSA line manager (i.e., the Assistant Deputy Administrator or above).
Each review should be coordinated with the appropriate NNSA Site Office
Manager.
Attachment 4
Page 1
Attachment 1
SAFEGUARDS AND SECURITY
1. PURPOSE. This Attachment establishes the specific requirements and guidance for
NNSA line oversight concerning safeguards and security.
2. CANCEL,I,ATION. None.
a. Departmental Elements. Except for the exclusion in paragraph 3.b, this
Attachment applies to all NNSA Departmental elements.
b. E.uclusion. rhis Attachment is applicable to all NNSA elements except the
Office of Naval Reactors. NA-30.
4. REOLIREMENTS.
a. General.
1) The Implementation Plan (IP) describes NNSA requirements expectations
and the methodology by which compliance is verified. Corrective action
planning is also incorporated in the IP. All expectations are graded with
respect to risk importance.
2) The contractor's trend analyses of security incidents arc used to detem~ine
and implement preventive measures that contribute to improved NNSA
policies.
3) All security specialists conducting oversight must participate in the
'Technical Qualification Program (TQP). All Federal security staff
members should complete the training recommended in DOE-STD-I 171 -
2003. .Yuft;guuril.s undSecurity Fzmctionul ilreu Stundurd and DOE-STD-
1 146-2007, Generul Echnicul Bu.se Quwl~ficu~ion, per the TQP.
b. XNSA Site Office Oversight
I ) The NNSA Site Officedefines its expectations for the roles of system-
based and transactional-based oversight of the management and operating
contractor or. if applicable. protective forces security contractor.
2) Thc Site Office is responsible for conducting direct line management
okersight. such as inspect~ons. reLiews, surveillances, surveys. operational
awareness, and ualkthroughs that evaluate programs and management
systems.
'4ttachment 4
Page 2
3) Security Surveys
Section 10
a) The Site Office is required to complete an annual comprehensive
evaluation report of the contractor security program that assigns
overall and topical area performance ratings. Site Offices should
develop a survey activity schedule for evaluations occurring
throughout the year. with consideration being given to other
evaluation activities such as the contractor's self-assessment. Self-
assessment deficiencies and weaknesses are documented in the
Pegasus issues management system (or comparative system) and
subject to corrective action processes. The evaluations are based
on compliance with requirements (e.g., laws, regulations, and DOE
directives) and on contractual objectives performance.
b) The Site Office security survey focuses on contractor performa~ice.
I'llis includes contractor effectiveness in conducting self-
assessments and completing corrective actions.
c) The Site Office is responsible for approving and validating closure
of contractor corrective action plans. Corrective action planning
involves performing causal analyses and identifying security risks.
Findings and corrective action plan milestones are reported in the
DOE Safeguards and Security Lnformation hlailagement System
(SSIMS).
d) Site Office responsibility for the security program includes
evaluating findings based on the huard and risk associated with
the underlying activities. Findings and the status of corrective
action planning are reported to the Associate Deputy Administrator
for Defense Nuclear Security (NA-70) as part of the contractor
assurance system.
4. NNSA is responsible for maintaining operational awareness of contractor
security program activities. In addition to scheduled survey activities, Site
Oftices maintain on-going interactions. conduct regular meetings with
contractor security managers to monitor the status of issues and initiatives,
and routinely observe contractor activities.
Attachment 4
Page 3 (and 4)
'She Chief of Defense Nuclear Security (C!DNS) is the NNSA Cognizant Security
Authority, with responsibility for security Sine management oversight of the Site
Offices. C/I)US implements overarching security actions for line oversight
processes and management systems that provide infomation concerning security
programs and transaction-based oversight for Federal assessments (e.g.,
inspections and observations).
Attachment 5
CYBER SECURlTY
Attachment 5
Page 1
1. PIJRPOSE. This Attachment establishes the specific requirements and guidance for
NNSA line oversight concerning cyber security.
2. CANCE1,LATION. None
a. Departmental Elements. Except for the exclusion in paragraph 3.b., this
Attachment applies to all NNSA Departmental elements.
h. Exclusion. This Attachment is applicable to all Nh'SA elenlents except for the
Office of Naval Reactors, NA-30.
4. REQUIREMENTS.
a. NNSA Site Office Line Oversight Systems.
1) Site Office oversight of cyber security can be tailored to account for site-
specific requirements and results of the contractor assurance system
(CAS) to the extcnt that the Site Office has verified and documented its
adequacy.
2) The Site Office cyber security oversight program must assess the
adequacy of contractor programs and procedures as well as the
implementation of those programs and procedures. i\ssessments of the
implementation of contractor programs and procedures must involve direct
observation of contractor performance or a review of specific work
products resulting from the contractor programs and procedures.
Section 11
a) At a mininlum. the Site Office program for oversight of cyber
securit) must include the following elements (in addition to the
specific requirements in DOE O 205 1 A, Depuriment ojEner'y
(>her Securrty ~ ~ n u g e n z e n t ) :
i Assessments that validate the continuing, effective
implementation of technical, managcment. and
administrative cyber security controls. The nuinber of
assessments should be sufficient to draw a meaningful
conclusion regarding the status of implementation of these
controls on an annual basis;
ii Assessments of the configuration management process; and
Attach~iient 5
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...
111 Annual assessments of the cyber security management
program as defined in NNSA Cyber Security Policy 14.lC
and the Cyber Security Strategic Plan. Where a site-wide
security management program covers a number of
programs, it is sufficient to sample the implementation in a
subset of the cyber secunty program.
b. NNSA Headauarters.
1) For cyber security. direct assessment of NNSA contractors by NASA
Ifeadquarters organizations consists of the following:
a) Annual revieus of Site Office cyber security programs. Although
these are primanlq reviews of S ~ t e Office performance, they
contain an element of direct contractor assessment to validate the
results of Site Office oversight and assessment activities:
b) For-cause reviews. From time to time, the NNSA Office of the
Chief Information Officer (OCIO) may conduct for-cause reviews,
cyber incident reviews, or direct assessments in response to
inquiries from external stakeholders. These reviews must have the
approval of the appropriate NNSA line manager (Site Office
Manager). Chief Information Officer (CIO), or the Chief of
Defense Nuclear Security (CiDNS). Each review will be
coordinated with the appropriate NNSA Site Office h4anager:
c) Reviews requested by the Site Office Manager; and
d) l'he NNSA OCIO may provide support for Site Office assessments
of contractor cyber security programs.
2) The primary mechanism for oversight of Site Office performance in the
area of cyber security is the NNSA OCIO annual cyber security site
assessment visit (SAV), which is conducted according to a protocol
approved by the NNSA C1O. l'hc Administrator, Principal Deputy
Administrator, or C/I>NS may also direct specific reviews of Site Office
performance issues in the area of cyber security. Such reviews are outside
the planned scope of the SAV for cyber security.
3) The NXSA Cyber Security Program Cyber Security Plan (PCSP)
describes the routine operational awareness programs for the CIO and the
C/DNS with regard to cyber security. Collectively, these operational
awareness programs meet the requirenients in I>OE O 205.1A. Specific
operational awareness activities must include oversight of corrective
actions, including metrics, periodic status reporting, and rollups of NNSA
corrective action tracking.
NA- 1 SD 226.1 A
10- 17-08
Attachment 6
Page 1
Attachment 6
EMERGENCY MANAGEMENT
1. I'URPOSE. This Attachment establishes the specific requirements and guidance for
NNSA line oversight concerning emergency management.
2. CANCELLATION. None.
a. NNSA Elements. Except for the e.tclusions in paragraph 3.b. this Chapter
applies to all NNSA elements that are responsible for emergency management
under DOE O l j l . l C , C'onzprel?etzclve Et7~er,oency Wunugement Sy\yrtenz. and other
applicable standards and plans.
b. Exclusion. This Attachment is applicable to all NNSA elements except for the
Service Center and the Office of Naval Reactors, NrZ-30.
Section 12
a. Site Office Line Oversight Svstems.
1 ) At a minimuin, the NNSA Site Office oversight program must include the
elements of DOE 0 151.1C.
2) Non-mandatory assessment tools or guides to NKSA Site Offices to assist
in the planning and conduct of emergency management self-assessments
and contractor assessments.
b. NKSA IIeadquarters.
1 ) The Office of NNSA Emergency Management Implementat~on (NA-43) is
the IIeadquarters organ~zation responsible for coordinating and
implementing line oversight in the area of emergcncy management for
NNSA sltes, facilities. and operations.
2) NA-43 develops and Issues assessment and review schedules for
emergency management okersight of NNSA field elements and prepares a
Functional Management Plan (1-MI') to document the approach for
implementing emergency management line oversight functions and
conducting IIeadquaners seli'assessments and Site Office assessments. -
The FMP describes line oversight acti%ities for emergency management
and protocols for issues management and communicating results.
3) NA-43 uses a systematic approach for conducting 1-Ieadquarters line
oversight of Site Offices through its fktdyuarters ilssessment Guide.fi)r
Attachment 6
Page 2
Site Ofices ' Emergency ~Zil~mugemenr Progrums and accompanying
checklists. This Guide uses goals and criteria froin the Emergency
Munugemerzt Guide (DOE 61 5 I . 1 - 1) and DOE O 15 I . 1 C. Included as
part of the toolkit is an Oversight SclzeduIe qfAnnuuI E~nergency
~tlcmugemenr Acriviries. 'I'his schedule lists critical functional areas and
the associated oversight responsibilities and can be used to organize and
schedule oversight activities for the entire year. Due dates and specific
review and update requirements are also provided.
4) 'I'he FMP for emergency management describes the use of the following
programs. processes, and operational awareness activities to monitor and
evaluate compliance and performance:
I Support the Chief of Defense Nuclear Safety (CDNS) in
implementing its review process to ensure safet) and emergency
preparedness at nuclear sites and facilities. These reviews are
conducted according to a protocol approved by the NNSA
Administrator.
. .
11 Coordinate with, and assist. the Site Offices in evaluating
contractor performance through the Corporate Performance
Evaluation Plan (CPEP) process for management and operating
contractors.
iii Support Site Offices in conducting assessments. performance
reviews, and exercise evaluations.
iv Assist field elements in validating and verifying corrective actions.
v IJse site-specific Emergency Readiness Assurance Plans (ER4Ps)
to prepare the Annual Report on the Status of Emergency
blanagement Programs at YNSA Sites, Facilities. and Operat~ons.
Attachment 7
Page 1
Attachment 7
BUSINESS MANAGEMENT
I . PLJRPOSE: 1 his Attachment establishes the specific requirements and guidance for line
overs~ght with~n the buslness management function.
2. CANCELLATION: None
a. Departmental Elements. Except for the exclusion in paragraph 3.c, this
i\ttachment applies to all NKSA Departmental elements that are responsible for
performing business management functions as defined in paragraph 4 below.
b. NSSA Contractors. Except for the exclusion in paragraph 3.c, the Contractor
Reauirements Document (CRD) sets forth the requirements that apply to contracts
that include the CRD.
c. Exclusion. This Attachment is applicable to all NKSA elements except for the
Office of Naval Reactors, NA-30.
Section 13
4. REOUIREMEK I S.
a. NiXSt-\ Site Office 1-ine Oversight.
1) Site Offices use a Contract Management Plan (CMP) combined with
internal oversight plans, procedures, and processes to administer contracts
and to conduct contractor oversight.
b. SKSA Headquarters.
I ) The NNSA Office of .4cquisition and Supply Management (KA-63)
provides oversight of the business management functions at the Site
Offices and the Service Center. The functional oversight responsibilities
are to monitor, evaluate. and report on the efficiency and effectiveness of
the Site Office and Service Center in properly performing their Federal
oversight responsibilities to ensure that contractors meet their contractual
requirements. NA-63 fulfills these responsibilities through the review and
analysis of selected internal perfornmance indicators and results of
assessment activities, and through direct observation of Site Office
performance.
2) 'fhe NUSA Business Management Functional Oversight Plan describes the
procedures for conducting oversight and surveillance activities. The Plan
details the processes and methodologies to be used to verify effective Site
Attachment 7
Page 2
Office operations in Procurement, Finance, Property, Small Business.
Contractor Human Resources, and Contract Administration.
c. XNSA Service Center
'The NXSA Service Center provides technical assistance and support to NNSA
Headquarters and the Site Offices in overseeing hf&O contractor business
management systems. The Service Center is continuously involved in operational
awareness of hl&0 contractor business management systems, validating reported
performance. recommending process changes as required, and providing feedback
to the contractor on an agreed-upon basis. 'The Service Center is responsible for
maintaining all documentation associated with systems reviews, operational
awareness, recommended corrective actions, and recommendations to the Site
Contracting Officer for systems or conditional approval or disapproval.