SD 251.1 Admin Chg 1, Policy Letters: NNSA Policies, Supplemental Directives, and Business Operating Procedures
This Supplemental Directive defines the formal system to set, communicate, and institutionalize policies, requirements, responsibilities, and procedures through NNSA Policy Letters in the form of NNSA Policies (NAPs), Supplemental Directives (SDs), and Business Operating Procedures (BOPs). This system of Policy Letters institutionalizes how NNSA will establish policy and provide direction and guidance to all its elements. This SD supplements Department of Energy (DOE) Order 251.1D, Departmental Directives Program.
Associated DOE Directive:
Related To:
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Text extracted from the attached file. Refer to the original document for the authoritative version.
Section 1
NA SD 251.1 Admin Chg 1 1
10-7-13
ADMINISTRATIVE CHANGE TO
SD 251.1, Policy Letters: NNSA Policies, Supplemental Directives, and Business Operating
Procedures
Locations of Changes:
Page Paragraph Changed To
Cover Footer Office of Management and Budget Office of Business Operations
1, 2,
A1-1
multiple
locations the Administration NNSA
2 6.a.(1) (1) Concurred in by the NNSA
Management Council Deleted
3 7.b.
Once a NAP, SD, or BOP has been
reviewed and comments addressed by
the originating organization, it must be
submitted to the Management Council
for approval prior to obtaining the
Administrator’s (or designee’s)
signature
Deleted
3, 4,
A1-1
multiple
locations NA-MB-30 NA-MB-50
3 7.c. site Deleted
4 8.a. NNSA Deleted
4 8.c.
c. Management Council.
(1) Concurs on all NAPs, SDs, and
BOPs, as well as the
cancellation thereof.
(2) Resolves impasse issues prior
to publication of a NAP, SD, or
BOP.
c. Management Council.
Resolves impasse issues prior to
publication of a NAP, SD, or
BOP.
4,
A1-3
multiple
locations Site Field
4 8.d.(2)
After concurrence by the Management
Council, approve BOPs for those
elements for which they are
responsible.
Approve BOPs for those
elements for which they are
responsible.
5 Signature Thomas P. D’Agostino
Administrator
Bruce Held
Acting Administrator
A1-2 10 NNSA Deleted
2 NA SD 251.1 Admin Chg 1
10-7-13
Page Paragraph Changed To
A1-3 12
12. Step 12: NA-MB-20 Certifies
Review Process is Complete and
Prepares Recommendation. NA-
MB-20 certifies review process and
prepares final package for approval
of the Management Council. Final
package will include:
a. Summary memo to the
Management Council
identifying commentors,
summary of comments received
and their resolution, and NA-
MB-20 recommendation;
b. Comment resolution matrix;
and,
c. Final NAP, SD, or BOP.
12. Step 12: NA-MB-20 Certifies
Review Process is Complete
and Prepares
Recommendation. NA-MB-
20 certifies review process
and prepares final package.
Final package will include:
a. Summary memo
identifying commentors,
summary of comments
received and their
resolution, and NA-MB-
20 recommendation;
b. Comment resolution
matrix; and,
c. Final NAP, SD, or BOP.
A1-3 13
Step 13: Management Council
Reviews and Approves (IF
MANAGEMENT COUNCIL
DISAPPROVES, PROCEED TO
STEP 16). The Management Council
provides each member with five
working days to review and approve
the package.
Deleted
A1-3 17
Step 17: NA-MB-20 Works with
Originating Organization to Resolve
Deficiencies. If additional reviews are
requested, go to Step 4. If the
Management Council requests
additional action, NA-MB-20 will
determine the path forward to resolve
issues and return the revised NAP, SD,
or BOP package to the Management
Council. If the deficiencies cannot be
resolved to the satisfaction of the
Management Council, NA-MB-20 will
provide the non-concurrence to the
NAPs, SDs, or BOPs originator. The
originator may then decide to appeal
the Management Council’s decision to
the Administrator. The Management
Council’s non-concurrence must be
part of the forwarding package and
should be submitted through the
originator’s management chain.
Deleted
SUPPLEMENTAL DIRECTIVE
Approved: 7-5-11
Admin Change 1: 10-7-13
Policy Letters: NNSA Policies,
Supplemental Directives, and Business
Operating Procedures
NATIONAL NUCLEAR SECURITY ADMINISTRATION
Office of Management and Budget
NA SD 251.1
AVAILABLE ONLINE AT: INITIATED BY:
https://www.nnsa.energy.gov Office of Business Operations
Section 2
https://www.nnsa.energy.gov/
THIS PAGE INTENTIONALLY LEFT BLANK
NA SD 251.1 1
7-5-11
Policy Letters: NNSA Policies, Supplemental Directives, and Business Operating
Procedures
1. PURPOSE. This Supplemental Directive defines the formal system to set, communicate,
and institutionalize policies, requirements, responsibilities, and procedures through
NNSA Policy Letters in the form of NNSA Policies (NAPs), Supplemental Directives
(SDs), and Business Operating Procedures (BOPs). This system of Policy Letters
institutionalizes how NNSA will establish policy and provide direction and guidance to
all its elements. This SD supplements Department of Energy (DOE) Order 251.1C,
Departmental Directives Program.
2. CANCELLATION.
a. NAP-1, Establishment of a Policy Letter System for Managing Policy, Directives,
and Business Practices within the National Nuclear Security Administration, dated
May 21, 2002.
b. NAP-18, Implementation of NNSA Pilot Program on Determination of Fiscal and
Other Impacts of New or Revised Directives, dated July 13, 2006.
3. APPLICABILITY.
a. This Supplemental Directive applies to all NNSA entities, Federal or contractor,
and to non-NNSA elements funding activities at sites where NNSA is the
landlord.
b. The requirements and processes in the Supplemental Directive apply to NNSA
NAPs, SDs, and BOPs that apply to more than one NNSA Headquarters or field
element. NNSA Headquarters and field elements are authorized to publish SDs
and BOPs for use by those organizations and their contractors, provided they do
not contradict, delete, or duplicate provisions in any applicable Policy, regulation,
Order, Notice, or NNSA Policy Letter. Prior to issuance, NNSA Headquarters
and field elements must have an approved and current process outlining the
methodology for promulgating unique requirements.
4. BACKGROUND. The NNSA’s Policy Letter system is established under the authority of
Section 3212(d) of Public Law 106-65, the National Defense Authorization Act for Fiscal
Year 2000, as amended. This law gives the NNSA Administrator authority to establish
Administration-specific policies, unless disapproved by the Secretary. DOE Order
251.1C, Departmental Directives Program, authorizes Headquarters elements to publish
supplemental directives for use by those organizations and their contractors, provided the
supplemental directives do not contradict, delete, or duplicate provisions in any
applicable Policy, regulation, Order, or Notice.
2 NA SD 251.1
7-5-11
5. POLICY.
a. DOE Directives are the primary means to establish, communicate, and
institutionalize policies, requirements, responsibilities, and procedures for
multiple Departmental elements, including NNSA, and as such provide the
building blocks for NNSA operations. The Department’s Directives are
applicable to NNSA unless an NNSA Policy Letter is provided.
b. NNSA will use NAPs, SDs, and BOPs as its primary means to establish,
communicate, and institutionalize policies, requirements, responsibilities, and
procedures specific to NNSA elements and contractors. In NAPs, SDs, and
BOPs, the NNSA Administrator may establish Administration-specific policies
unless disapproved by the Secretary.
Section 3
c. When determined necessary by the Office of Business Operations (NA-MB-20),
NAPs, SDs, or BOPs must have a written initial assessment of the costs and
benefits (including fiscal, personnel, and other impacts) and, if necessary, a
secondary, more in-depth quantitative and qualitative written analysis. These
Initial Assessments and Further Evaluation Documentation will provide senior
NNSA management with the necessary information to enable them to make
informed decisions regarding NAPs, SDs, or BOPs that may be accompanied by
onerous or unfunded burdens that exceed their assessed benefits.
6. POLICY LETTERS (NAPs, SDs, and BOPs).
a. Must be:
(1) Maintained by the Director, Office of Business Operations (NA-MB-20);
and,
(2) Rescinded only by the person authorized to issue the NAP, SD, or BOP
unless directed otherwise by the Administrator or his/her designee.
b. NAPs, SDs, or BOPs that contain sensitive or classified information are subject to
the review procedures in this policy. They must not be circulated by unsecure
email, unsecure facsimile, or other unsecure means.
c. NAPs can apply to both Federal and contractor elements to:
(1) Impart policy and/or requirements unique to NNSA; or
(2) Provide short-term notices until more formal direction can be provided.
d. SDs can apply to both Federal and contractor elements and are utilized, in
conjunction with the Department’s Directives System, to:
(1) Indicate how NNSA will implement a Departmental directive; and
NA SD 251.1 3
7-5-11
(2) Implement Departmental directives in a cost efficient manner.
e. BOPs provide procedures applicable only to NNSA Federal employees. BOPs
provide a process for issuing sound business and operating procedures that are
essential to efficient Federal operations.
f. When a NAP, SD, or BOP addresses a topic covered by a Departmental directive,
it will be numbered to correspond to the Departmental directive.
g. Unless specified otherwise in an NNSA Policy Letter, Exemptions are granted by
the Administrator or designee, in consultation with the originating office, and
documented in a memorandum. For those directives requiring CTA concurrence,
concurrence is also required prior to the granting of Exemptions.
7. REQUIREMENTS.
a. Preparation and review of NAPs, SDs, and BOPs must follow the process outlined
in the Attachment to this SD.
b. When determined necessary by the Office of Business Operations (NA-MB-20),
the Office of Planning, Programming, Budgeting and Evaluation (NA-MB-50)
shall conduct a written initial assessment of the costs and benefits (including
fiscal, personnel, and other impacts) and, if necessary, a secondary, more in-depth
quantitative and qualitative written analysis of proposed NAPs, SDs, or BOPs.
c. NNSA Federal staff shall perform the required cost/benefit analysis. NNSA
management and operating contractors and other prime contractors shall provide
assistance as required to complete the analysis as determined by NNSA
Headquarters and or field management.
d. When changes are required to a NAP, SD, or BOP, the Office of Business
Operations (NA-MB-20), in conjunction with the originating organization, shall
determine whether the change is administrative or non-administrative.
(1) Administrative changes are those that do not significantly alter
requirements or responsibilities, and thus do not require a review and
comment process.
(2) Non-administrative changes are those that significantly alter requirements
or responsibilities, and thus do require a formal review and comment
process.
Section 4
e. NAPs, SDs, and BOPs will be reviewed every two years by the Office of Business
Operations and the originating organization to verify continuing relevance and
whether any action (i.e., revision or cancellation) is necessary. The Office of
Business Operations will initiate the review process.
4 NA SD 251.1
7-5-11
8. RESPONSIBILITIES.
a. Administrator.
(1) Approves and signs NAPs and SDs.
(2) Approves the cancellation of NAPs and SDs.
These responsibilities can be delegated in writing by the Administrator.
b. Principal Deputy Administrator. Determines whether costs and/or other impacts
of each subject NAP or SD exceed the assessed benefits and, if so, recommends a
course of action to the Administrator.
c. Management Council. Resolves impasse issues prior to publication of a NAP,
SD, or BOP.
d. Deputy Administrators, Associate Administrators, Heads of NNSA Mission
Support Offices, and Field Office Managers.
(1) Propose NAPs, SDs, and BOPs for their organizations.
(2) Approve BOPs for those elements for which they are responsible.
(3) Reviews and comments on NAPs, SDs, or BOPs prepared by other NNSA
elements.
e. Associate Administrator for Management and Budget.
(1) Manages the NNSA Policy Letter System.
(2) Manages the review of all NAPs, SDs, and BOPs.
(3) Maintains the records management system for all NAPs, SDs, and BOPs.
(4) Serves as the NNSA DPC required by DOE Order 251.1C.
(5) Performs the following functions through the Office of Planning,
Programming, Budget and Execution (NA-MB-50):
(a) When determined necessary by NA-MB-20, performs an initial
estimate (the “Initial Assessment”) on the impact of each proposed
NAP, SD, or BOP. It will be a rough cost/benefit estimate used to
determine if further analysis is required.
(b) For NAPs, SDs, or BOPs identified as having the potential for
significant impact; and, when requested by Office of Business
Operations (NA-MB-20), provides a more precise cost/benefit
NA SD 251.1
7-5-11
analysis (the "Further Evaluation Documentation") of the fiscal
and/or other impacts, both quantitative and qualitative.
(c) Develops and maintains documented methodologies for both the
Initial Assessment and Further Evaluation Documentation.
9. CONT ACT. Office of Management and Budget, Office of Bi1siness Operations, at 202-
586-3857.
BY ORDER OF THE ADMINISTRATOR:
Attachment: Policy Letter Process
Edward Bruce Held
Acting Administrator
5
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NA SD 251.1 Attachment
7-5-11 A1-1
Attachment to “NNSA Policy Letter Review Process”
Detailed Instructions for
NNSA Policy Letter Process
1. Step 1: Submit draft NAP, SD, or BOP to the Office of Business Operations (NA-MB-20).
To initiate a review, the document should be sent electronically (e-mail) to the “NNSA
Policy Letters” mailbox. The transmission should include the following:
a. A cover memo requesting Headquarters and Field review of a NAP, SD, or BOP
that:
i. Briefly outlines the background of the action; identifies what problem this
action solves (address statutory or other drivers, the benefits the action will
bring to NNSA, and the consequences of disapproval);
ii. Identifies any known significant costs associated with the action;
iii. Discusses how NNSA compares with other Federal agencies in this area;
and,
iv. Lists the organizations and individuals that have been involved in its
development and clearance.
b. The draft NAP, SD, or BOP should be in final form, including appropriate
Section 5
attachments, appendices, etc. Every NAP, SD, or BOP that specifies a procedure
or process should include a flow chart of that process and identify the resource
requirements (financial and manpower).
c. Approval by the Deputy/Associate Administrator.
2. Step 2: NA-MB-20 Reviews for Completeness. Upon receipt, NA-MB-20 shall ensure that
all the items delineated in Step 1 (above) are included with the request and assign a
tracking number to the NAP, SD, or BOP. The number will be sequential and have an
annotation if there is an associated DOE Directive. If any information is missing, NA-
MB-20 will return the package to the originator.
3. Step 3: NA-MB-20 Places Draft NAP, SD, or BOP in Program and Field Review. NA-
MB-20 will electronically circulate for review, the NAP, SD, or BOP and any necessary
explanatory information, to designated Points-of-Contact (POC) for each organizational
element within NNSA Headquarters and the Field. Distribution will include NA-MB-50
for Initial Assessment and possible Further Documentation Evaluation. A due date for
responses will be set by NA-MB-20.
4. Step 4: Program and Field Elements Review and Provide NA-MB-20 with Comments.
Comments will be accepted electronically (email to the “NNSA Policy Letters” mailbox)
from the designated Headquarters and Field POCs to NA-MB-20. NA-MB-20 will
provide an information copy of the comments electronically to the originator as they are
received.
5. Step 5: NA-MB-20 Consolidates Comments on a Review Form and Sends to Originator.
Within 24 hours of the conclusion of the comment period, NA-MB-20 will consolidate
Attachment NA SD 251.1
A1-2 7-5-11
the review comments and officially forward (electronically) to the originating office for
response. (If no comments are received during the review, proceed to Step 12.)
6. Step 6: Originator Prepares Responses to Comments and Revises the NAP or BOP.
Originator should prepare responses to comments and make associated changes to the
NAP, SD, or BOP. Every effort should be made to resolve comments during the
comment resolution phase (generally two weeks). If additional time is required, NA-MB-
20 must be notified and a new due date may be established. The final package must be
electronically transmitted to NA-MB-20 and include:
a. Comment resolution matrix ( include all comments received and proposed
resolution for each comment);
b. Final revised NAP, SD, or BOP;
c. Redline/strikeout of the revised NAP, SD, or BOP showing changes made as a
result of the review process; and,
d. Approval by the Deputy/Associate Administrator.
7. Step 7: Comment Responses are Provided to NA-MB-20. NA-MB-20 will ensure all
items in Step 6 are included in the response. If any information is missing and/or
comments are not addressed, NA-MB-20 will return the package to the originator.
8. Step 8: NA-MB-20 Provides Responses to Reviewers; Obtains Concurrence or
Identification of Issues. NA-MB-20 will electronically transmit the package to the
designated POCs for each organizational element within NNSA. This transmission will
include the comment resolution matrix, redline/strikeout and clean copies of the NAP,
SD, or BOP, and any other information or changes deemed necessary by NA-MB-20 as a
result of its review of the package.
Section 6
9. Step 9: Responses Accepted by Reviewers PROCEED TO STEP 11; IF RESPONSES
ARE NOT ACCEPTED, GO TO STEP 10. The designated POC for each organizational
element within NNSA will ensure that the resolutions are reviewed and accepted by said
organizational element and that the resolution is acceptable to the organization’s
management. Acceptance will be sent (electronically) to the “NNSA Policy Letters”
mailbox.
10. Step 10: (a) NA-MB-20 Brokers a Resolution OR (b) If resolution is not reached, NA-MB-
20 prepares impasse paper for Management Council. NA-MB-20 will work with the
document originator and POC for the commenter to broker a resolution. If resolution is
not possible, NA-MB-20 (in consultation with the originator and POC commentor) will
prepare an impasse paper for the Management Council. The impasse paper will be signed
by the appropriate management (Deputy Administrator, Associate Administrator, or Head
of Staff Office) prior to elevation to the Management Council.
NA SD 251.1 Attachment
7-5-11 A1-3
11. Step 11: NA-MB-20 Prepares Final Package. NA-MB-20 will confirm to the originator
the acceptance of the resolution of all comments. Originator will prepare the final
package and electronically transmit it to NA-MB-20. It shall include:
a. Comment resolution matrix (revised to include the name of person accepting
resolution).
b. Final revised NAP, SD, or BOP.
c. Redline/strikeout of the revised NAP, SD, or BOP showing changes made as a
result of the review process.
12. Step 12: NA-MB-20 Certifies Review Process is Complete and Prepares
Recommendation. NA-MB-20 certifies review process and prepares final package. Final
package will include:
a. Summary memo identifying commentors, summary of comments received and
their resolution, and NA-MB-20 recommendation;
b. Comment resolution matrix; and,
c. Final NAP, SD, or BOP.
13. Step 14: Administrator (or other NNSA Official) Signs. Administrator (or other
designated NNSA Official) signs NAP or SD and returns to NA-MB-20 for further
processing. Deputy Administrators, Associate Administrators, Heads of NNSA Mission
Support Offices, and Field Office Managers, signs BOP and returns to NA-MB-20 for
further processing.
14. Step 15: NA-MB-20 notifies originator of approval and distributes to all NNSA
Elements. Upon approval, NAPs, SDs, and BOPs will be distributed to all NNSA
Headquarters and Field organizational elements. Original copies will be sent to NA-MB-
20 for entry into the NNSA policy retention system. NA-MB-20 will forward
(electronically) to DOE’s Office of Information Resources (MA-90) for inclusion in the
DOE Directives System.
15. Step 16: Return to NA-MB-20 for Correction of Deficiencies. If document is
unacceptable to the Management Council, package with comments will be returned to
NA-MB-20 for comment resolution.
16.