SD 450.4-1, Integrated Safety Management System Description

NA-1 SD 450.4-1 Approved: 10-23-07 National Nuclear Security Administration Headquarters Integrated Safety Management System Description This NNSA Headquarters Integrated Safety Management System Description describes the NNSA Headquarters role in establishing expectations and accomplishing work in a safe and environmentally sound manner to successfully execute the NNSA mission and strategic goals. NNSA senior managers strongly support and are personally committed to implementation of the policy and principles of Integrated Safety Management. Approved: &? .> ,& o&k Thomas P. D7Ago, tino Administrator h Table of Contents EXECUTIVE SUMMARY............................................................................................................. v ACRONYMS ................................................................................................................................. vi INTRODUCTION........................................................................................................................... 1 1.0 Purpose and Objectives ...................................................................................................... 2 2.0 Integrated Safety Management System Overview ............................................................. 2 2.1 Objective of Integrated Safety Management...................................................................... 3 2.2 Guiding Principles and Safety Culture Elements ............................................................... 3 2.3 Core Functions ................................................................................................................... 5 2.4 Responsibilities .................................................................................................................. 5 2.5 Implementation of Integrated Safety Management ............................................................ 5 3.0 NNSA Management Expectations...................................................................................... 5 4.0 Safety Performance Measures, Objectives and Commitments........................................... 7 5.0 Roles and Responsibilities.................................................................................................. 9 6.0 Implementation of ISM in NNSA HQ Work Activities ................................................... 11 6.1 Implementing ISM Guiding Principles and Safety Culture Elements.............................. 12 6.1.1 Guiding Principle 1: Line Management Responsibility for Safety.........................12 6.1.2 Guiding Principle 2: Clear Roles and Responsibilities...........................................13 6.1.3 Guiding Principle 3: Competence Commensurate with Responsibilities...............13 6.1.4 Guiding Principle 4: Balanced Priorities ................................................................14 6.1.5 Guiding Principle 5: Identification of Safety Standards and Requirements...........15 6.1.6 Guiding Principle 6: Hazard Controls Tailored to Work Being Performed ...........15 6.1.7 Guiding Principle 7: Operations Authorization......................................................16 6.1.8 Safety Culture Element 8: Individual Attitude and Responsibilities for Safety .....17 6.1.9 Safety Culture Element 9: Operational Excellence ................................................17 6.1.10 Safety Culture Element 10: Oversight for Performance Assurance .......................18 6.1.11 Safety Culture Element 11: Organizational Learning for Performance

Improvement...........................................................................................................19 6.2 Implementing ISM Core Functions .................................................................................. 19 6.2.1 Core Function 1: Define Scope of Work ................................................................20 6.2.2 Core Function 2: Identify and Analyze Hazards ...................................................20 6.2.3 Core Function 3: Develop and Implement Hazard Controls ..................................21 6.2.4 Core Function 4: Perform Work Within Controls ..................................................21 6.2.5 Core Function 5: Provide Feedback and Continuous Improvement.......................22 6.3 Integration with Quality Assurance, Environmental Management Systems, and Integrated Safeguards and Security Systems.................................................................... 29 6.3.1 Integration of Quality Assurance with ISM ...........................................................29 6.3.2 Integration of Environmental Management Systems with ISM .............................29 6.3.3 Integration of Integrated Safeguards and Security Management with ISM ...........30 7.0 Other Safety-Related Initiatives ....................................................................................... 31 8.0 Annual ISM System Description Maintenance and Improvement ................................... 32 - iii - Appendices Appendix A. Reporting of NNSA Safety Management Performance Measures......................... A-1 Appendix B. Initial NNSA HQ Actions to Imporve Implementation of ISM............................. B-1 List of Figures Figure 1. Safety Management System Hierarchy of Components ................................................ 2 Figure 2. ISMS Guiding Principles and Core Functions ................................................................ 4 Figure 3. NNSA Organization for Safety Management Responsibilities....................................... 9 List of Tables Table 1. Implementing Mechanisms, Processes, and Methods for ISM Guiding Principles 1, 2, and 3 ................................................................................................... 23 Table 2. Implementing Mechanisms, Processes, and Methods for ISM Guiding Principle 4.................................................................................................................... 25 Table 3. Implementing Mechanisms, Processes, and Methods for ISM Guiding Principles 5 and 6 ........................................................................................................ 26 Table 4. Implementing Mechanisms, Processes, and Methods for ISM Guiding Principle 7.................................................................................................................... 27 - iv - EXECUTIVE SUMMARY The Department developed DOE M 450.4-1, Integrated Safety Management System Manual, to help improve the effectiveness of and institutionalize expectations associated with Integrated Safety Management (ISM). A main emphasis of DOE M 450.4-1 is the development and implementation of DOE Federal ISM system descriptions. Department personnel play a vital role in the Department-wide ISM system. The Department role is at various times characterized as owner, customer, or regulator, which is markedly different from the contractor role, but very important for assuring safety.

DOE M 450.4-1 requires development of this NNSA Headquarters (HQ) ISM System Description. This NNSA HQ ISM System Description accomplishes the following: • Emphasizes the strong support and personal commitment of NNSA senior managers to implementation of the policy and principles of Integrated Safety Management • Describes the NNSA HQ role in establishing expectations for accomplishing work in a safe and environmentally sound manner to successfully execute the NNSA mission and goals • Defines the NNSA HQ work activities related to achieving the ISM objective of safe mission accomplishment • Describes the specific mechanisms, processes, and methods by which NNSA management ensures that ISM core functions and guiding principles are effectively implemented • Describes how ISM, which includes Environmental Management Systems per DOE Policy 450.4, is integrated with other management systems, such as Line Oversight and Contractor Assurance Systems, Quality Assurance Programs, and Integrated Safeguards and Security Management Systems. In a separate but related action, NNSA has commenced efforts to eventually consolidate additional management systems into one integrated management system. • Describes the set of Performance Objectives, Measures and Commitments that NNSA HQ currently uses to gauge the effectiveness of its ISM System. The NNSA Senior Advisor for Environment, Safety and Health (NA-3.6) maintains this document and coordinates completion of actions required in DOE M 450.4-1, which are to: • Perform an annual review of the effectiveness of implementation of the NNSA HQ ISM System • Update this document as necessary to reflect new mechanisms, processes, methods, or improvements to remedy any identified gaps that NNSA Headquarters uses to implement Integrated Safety Management • Update the set of Performance Objectives, Measures and Commitments as necessary. Each NNSA Site Office is required under DOE M 450.4-1 to develop an ISM System Description within six months of approval of this document. The NNSA Office of Naval Reactors (NA-30) is not within the scope of this document. The NNSA Office of Secure Transportation (NA-15) is a government-owned, government-operated organization located outside the NNSA HQ region and will develop its ISM System Description in accordance with the timetable for NNSA Site Offices. - v - ACRONYMS BOP Business Operating Policy CAIRS Computerized Accident Incident Reporting System CAS Contractor Assurance System CATS Corrective Action Tracking System CDNS Chief of Defense Nuclear Safety CFR Code of Federal Regulations CTA Central Technical Authority DART Days Away, Restricted or on Job Transfer DEAR U.S. Department of Energy Acquisition Regulation DNFSB Defense Nuclear Facilities Safety Board DNS Defense Nuclear Security DOE U.S. Department of Energy DSA Documented Safety Analysis DPO Differing Professonal Opinion EMS Environmental Management System ES&H Environment, Safety and Health ESAAB Energy Systems Acquisition Advisory Board FEOSH Federal Employee Occupational Safety and Health FRAM Safety Management Functions, Responsibilities, and Authorities Manual FTCP Federal Technical Capability Program GAO Government Accountability Office HQ Headquarters HR Human Resources HSS Office of Health, Safety and Security IDP Individual Development Plan IG Inspector General ISM Integrated Safety Management ISMS Integrated Safety Management System ISSM Integrated Safeguards and Security Management LL Lessons Learned LOCAS Line Oversight Contractor Assurance System NA National Nuclear Security Administration NAP NNSA Policy Letter NESS Nuclear Explosive Safety Study NEPA National Environmental Policy Act NNSA National Nuclear Security Administration NTS Noncompliance Tracking System ORPS Occurrence Reporting and Processing System OST Office of Secure Transportation PAAA Price-Anderson Amendments Act PPBE Planning, Programming, Budgeting and Evaluation PSO Program Secretarial Office QAP Quality Assurance Program RFP Request for Proposal SRSO Savannah River Site Office TRC Total Recordable Cases TSR Technical Safety Requirement

- vi - INTRODUCTION In 2000, the National Nuclear Security Administration (NNSA) was established as a new element within the Department of Energy (DOE) in response to a Congressional mandate to reinvigorate the security posture throughout the nuclear weapons program and to reaffirm the Nation’s commitment to maintaining the nuclear deterrence capabilities of the United States. NNSA was chartered to focus management attention on enhanced security, proactive management practices, and mission within the Department’s national defense and nonproliferation programs. The Department performs its national security mission involving nuclear weapons and nuclear materials and technology through the NNSA. The Department of Energy 2006 Strategic Plan includes the following strategic goals for NNSA: Goal 1 – Nuclear Deterrent Transform the Nation’s nuclear weapons stockpile and supporting infrastructure to be more responsive to the threats of the 21st Century. Goal 2 – Weapons of Mass Destruction Prevent the acquisition of nuclear and radiological materials for use in weapons of mass destruction and in other acts of terrorism. Goal 3 – Nuclear Propulsion Plants Provide safe, militarily effective nuclear propulsion plants to the U.S. Navy. [Note: this strategic goal is achieved through the Office of Naval Reactors (NA-30). This NNSA organization is excluded from the scope of this Integrated Safety Management System Description per DOE M 450.4-1, Integrated Safety Management System Manual] This NNSA HQ Integrated Safety Management System Description describes the mechanisms through which NNSA HQ implements Integrated Safety Management to work safely to achieve the strategic goals. - 1 - 1.0 Purpose and Objectives The NNSA Headquarters Integrated Safety Management (ISM) System Description describes the NNSA Headquarters (HQ) role in establishing expectations and accomplishing work in a safe and environmentally sound manner to execute the NNSA mission and strategic goals. This NNSA HQ ISM System Description accomplishes the following: • Emphasizes the strong support and personal commitment of NNSA senior managers to implementation of the policy and principles of Integrated Safety Management • Describes the NNSA HQ role in establishing expectations for accomplishing work in a safe and environmentally sound manner to successfully execute the NNSA mission and goals • Defines the NNSA HQ work activities related to achieving the ISM objective of safe mission accomplishment • Describes the specific mechanisms, processes, and methods by which NNSA management ensures that ISM core functions and guiding principles are effectively implemented • Describes how ISM, which includes Environmental Management Systems per DOE Policy 450.4, is integrated with other management systems, such as Line Oversight and Contractor Assurance Systems, Quality Assurance Programs, and Integrated Safeguards and Security Management Systems. In a separate but related action, NNSA has commenced efforts to eventually consolidate additional management systems into one integrated management system. • Describes the set of Performance Objectives, Measures and Commitments that NNSA HQ currently uses to gauge the effectiveness of its ISM System. 2.0 Integrated Safety Management System Overview

Integrated Safety Management involves the integration of safety awareness and practices into all aspects of work performance. ISM provides a formal process where people plan, perform, assess and improve the safe conduct of work. Safety is integral to the planning and accomplishment of each job. NNSA conducts work in a manner that protects the worker, the public and the environment. The safety management system establishes a hierarchy of six components to facilitate consistent implementation throughout the complex. Safety Management System Hierarchy of Components Objective In cr ea si ng L ev el o f D et ai l Guiding Principles Core Functions Mechanisms Responsibilities Implementation DOE established the approach to integrating safety into all aspects of work at its facilities in DOE P 450.4. This Policy describes the safety management system consisting of six components: 1) Objective, 2) Guiding Principles, 3) Core Functions, 4) Mechanisms, 5) Responsibilities, and 6) Implementation. See Figure 1. The Objective, Guiding Principles, and Core Functions of safety management are used consistently in implementing safety management throughout the DOE complex and are Figure 1. Safety Management System Hierarchy of Components - 2 - described in the following sections. The mechanisms, responsibilities, and implementation components are unique to the organization that owns the System, and are established according to the type of work and hazards associated with that work. NNSA HQ ISM mechanisms, responsibilities, and implementation components are more fully described later in Sections 5 and 6. 2.1 Objective of Integrated Safety Management DOE P 450.4, Safety Management System Policy, describes the objective of ISM, which is: The Department and Contractors must systematically integrate safety into management and work practices at all levels so that missions are accomplished while protecting the public, the worker, and the environment. This is to be accomplished through effective integration of safety management into all facets of work planning and execution. In other words, the overall management of safety functions and activities becomes an integral part of mission accomplishment. 2.2 Guiding Principles and Safety Culture Elements The following Guiding Principles are fundamental policies that guide NNSA HQ actions, from development of plans and procedures to conduct of work: (1) Line Management Responsibility for Safety: Line Management is responsible and accountable for protection of the public, workers, and the environment (2) Clear Roles and Responsibilities: Clear and unambiguous lines of authority and responsibility for ensuring safety is documented, communicated, and maintained (3) Competence Commensurate with Responsibilities: Personnel possess the experience, knowledge, skills, and abilities necessary to discharge their responsibilities (4) Balanced Priorities: Resources are effectively allocated to address safety and programmatic and operational considerations. Protecting the public, workers, and the environment is an overriding priority (5) Identification of Safety Standards and Requirements: Before work is performed, the associated hazards shall be evaluated, and an agreed-upon set of safety standards and requirements are established, which provide adequate assurance that the public, workers, and the environment are protected from adverse consequences

(6) Hazard Controls Tailored to Work Being Performed: Administrative and engineering controls to prevent and mitigate hazards are tailored to the work and associated hazards (7) Operations Authorization: The conditions and requirements for operations to be initiated and conducted are agreed upon and clearly established. In addition to these Guiding Principles, with issuance of DOE M 450.4-1, the Department established the following four Safety Culture Elements to be used in concert with ISM Guiding Principles to enhance the effective implementation of ISM. The Safety Culture Elements are: - 3 - (8) Individual Attitude and Responsibility for Safety: individual accepts nsibility for safe on performance. duals demonstrate a oning attitude by nging assumptions, stigating anomalies, and ering potential adverse sequences of planned s. All employees are ndful of work conditions ay impact safety, and ther in nting unsafe acts or viors. (9) tional Excellence Every respo missi Indivi questi challe inve consid con action mi that m assist each o preve beha Opera : nizations achieve ined, high levels of tional performance, passing all DOE and tractor activities to meet n, safety, productivity, y, environmental, and lity (10) Oversight for Performance Assurance Orga susta opera encom con missio qualit other objectives. High-reliability is achieved through a focus on operations, qua decision-making, open-communications, deference to expertise, and systematic approaches to eliminate or mitigate error-likely situations. F i : Competent, robust, periodic and independent nd er oversight is an essential source of feedback that verifies expectations are being met a identifies opportunities for improvement. Performance assurance activities verify wheth standards and requirements are being met. Performance assurance through conscious, directed, independent reviews at all levels brings fresh insights and observations to be considered for safety and performance improvement. (11) Organizational Learning for Performance Improvement: The organization demonstrat excellence in performance monitoring, problem analysis, solution planning, and solution implementation. The organization encourages openness and trust, and cultivates a continual learning environment. e 2 depicts the ISM Guiding Principles and Core Functions. es Figur - 4 - 2.3 The five ISM Core Functions, established in DOE P 450.4, describe the structure necessary for w onment. The Core Functions are applied as a continual cycle, with the degree of rigor appropriate to control the work hazards. The five Core Functions are: of Work Core Functions ork activities that pose a hazard to the public, workers, or the envir (1) Define the Scope : Missions are translated into work, expectations are set, tasks are identified and prioritized, and resources are allocated (2) Analyze the Hazards: Hazards associated with the work are identified, analyzed, categorized (3) and olsDevelop and Implement Hazard Contr : Applicable standards and requirements are identified and agreed upon, controls to prevent/mitigate hazards are identified, the safety envelope is established, and controls are implemented (4) Perform Work within Controls: Readiness is confirmed and work is performed safely (5) Provide Feedback and Continuous Improvement: Feedback information on the adequacy of controls is gathered, opportunities for improving the definition and planning of work are identified and implemented, line and independent oversight is conducted and, if necessary, regulatory enforcement actions occur.

2.4 The Revisio accoun y directiv nctions, Responsibilities and uthorities Manual (DOE FRAM) and assignments and delegations made by the Administrator. , a afety responsibilities for NNSA HQ Federal workers are included in the ction .0 NNSA Management Expectations Act with a sense of urgency o re Responsibilities NNSA Safety Management Functions, Responsibilities and Authorities Manual (FRAM) n 1, dated February 28, 2005, defines NNSA expectations regarding organizational tability for safety management. These expectations are based on Department of Energ es listed in DOE M 411.1C, Safety Management Fu A Also dditional general s NAP-6, Federal Employee Occupational Safety and Health Program for National Nuclear Security Administration Headquarters Employees. Section 5 contains a summary of safety management responsibilities. 2.5 Implementation of Integrated Safety Management Implementation of safety management including the processes and methods by which NNSA HQ managers ensure safety management is effectively implemented are described in detail in Se 6. 3 NNSA management fully supports the Operating Principles described in the DOE 2006 Strategic Plan which are: • Ensure safe, secure, and environmentally responsible operations • • W rk together • T at people with dignity and respect - 5 - • Make the tough choices tion Strategic Plan, dated November 2004, describes afety is embedded in the NNSA core values and is necessary for e NNSA mission. In addition to adopting these core values, tinuing to take steps to improve safety in NN t Inv • NNSA management must actively y of views, accept outside criticism, and avoid over-simplification of technical informa • NNSA management must actively and continually review its ope he organization does not fall into the trap of being conditioned by past successes. n of Ma hief of Defense Nuclear Safety • Keep our commitments • Embrace innovation • Always tell the truth • Do the right thing. The National Nuclear Security Administra the core values for NNSA. S successful achievement of th NNSA CORE VALUES Excellence We strive for excellence in performing our critical national security missions: scientific exploration and technology development; laboratory and industrial operations; information and materials security; environment, safety, and health activities; and, Integrity project and program management. We demand the highest standards of ethical behavior, for each of us is personally entrusted with and accountable for protecting and defending our national security. We meet our commitments. Respect We treat our colleagues with dignity, val reward achievement. ue diversity, provide fair opportunity, and Teamwork orking cooperatively andWe accomplish our mission by w respecting the roles of leaders and team embers. m - From NNSA Strategic Plan, November 2004 NNSA is con SA. These steps resulted from the detailed review of the Space Shuttle Columbia Acciden estigation Board Report and the lessons relevant to NNSA, including the following: encourag a diversite tion. rations and ensure that t Also, NNSA implemented the Central Technical Authority (CTA), responsible for reviewing nuclear safety requirements and maintaining operational awareness of the implementatio nuclear safety requirements and guidance, consistent with the principles of Integrated Safety nagement across the NNSA complex. The position of C - 6 -

(CDNS) was created to serve as a senior technical advisor to the Administrator and CTA. The NS and staff supports the NNSA CTA, including maintaining awareness of comCD plex, high- azard nuclear operations conducted in the NNSA nuclear complex, through such activities as d h monitoring of applicable reports and performance metrics, reviewing various site-specific and complex-wide documents, discussing and providing guidance on technical issues, and conducting onsite visits. The NNSA management commitment to its workforce follows: • Senior managers will “lead by example” to achieve a safety conscious work environment an an accident free workplace. • Work is planned, hazards are identified, and actions are taken to mitigate hazards before work begins. ISM principles and functions drive work planning and execution. • NNSA is self-critical and invites external evaluations to achieve continual improvement. NNSA defines clear roles, responsibilities and authorities for each employee. technical capabilities are in • the DOE-wide corporate operating experience program so that • ow- d • work planning and • tted to implementing an effective safety culture. the d decision-making process. NN ore open to alternate views and n supports a safety conscious work environment where healthy professional discourse is rm tim e goals to ess erformance objectives are described in DOE M 450.4-1 as long-term management system goals ctives and measures are eveloped through the LOCAS process which continues to be refined. • • NNSA continues to train its workers to ensure demonstrated place to fulfill safety responsibilities at all levels of the organization. NNSA actively participates in we continually “learn from experience.” NNSA applies the functions and principles of ISM to prevent the occurrence of l probability, high-consequence events at nuclear facilities. • NNSA monitors actual performance against annual safety performance goals an commitments and shares the results with its employees. NNSA assesses contractor operations to determine the effectiveness of work control processes. NNSA selects contractors who are commi • Environmental management considerations (understanding the impact of an action to environment) are an integral part of the NNSA planning an SA has taken important steps to make its safety culture m mi ority opinions, challenging technical positions in the interest of technical integrity. NNSA encouraged. NNSA recently developed a Differing Professional Opinion (DPO) process to fo alize roles, responsibilities and requirements to ensure that these DPOs are resolved in a ely, consistent, and fair manner. 4.0 Safety Performance Objectives, Measures and Commitments NNSA HQ personnel evaluate safety performance results against identified performanc determine the success of our safety culture. NNSA uses indicators to measure the effectiven of its management systems and the overall safety performance of its organization. P driven by strategic planning or safety processes. NNSA performance obje d - 7 - Performance measures are used to track progress and monitor achievement of the performance objectives. Some performance measures indicate how well the NNSA ISM system is being maintained. They include: • Quarterly Safety Briefings consistently provided to the Administrator and senior NNSA ersight plan NNSA FRAM is updated as needed (Note: updating the NNSA FRAM is an action listed in

rsonnel in the Technical Qualification Program fully qualified in • lification Program overdue in their Oth e measures indicate in a general sense how well the ISM system is achieving a • ate as, misses Correction of past ISM performance deficiencies and resolution of issues identified in annual the periodicity of reporting the information to providing this information to 8.0 e initial set and are reviewed updated annually as p Site Offices will annually prepare and submit their info A- bjectives, measures and commitments. The initial set of commitments appears in ppendix B. managers to provide safety data discussed above • Planned CDNS reviews conducted • Planned NA-10 oversight activities conducted in accordance with ov • Appendix B) • NNSA HQ ISM effectiveness reviews occur • Percentage of NNSA pe their assigned functional area (NNSA Goal: at least 80%). Number of NNSA personnel in the Technical Qua qualifications (NNSA Goal: 0). • Delegations of authority are reviewed, as necessary er performanc safe work environment. They include: • Worker Total Recordable Cases (TRC) Rate Worker Days Away, Restricted or on Job Transfer (DART) R • Occurrence Reporting and Processing System (ORPS) occurrences in certain focus are such as electrical safety and near • Type A & B Accident Investigations • effectiveness reviews or declarations. Appendix A lists these performance measures and the NNSA CTA or appropriate PSO. The manner and periodicity of NNSA management is reviewed as part of the annual effectiveness review described in Section . These performance measures represent th ap ropriate. Per DOE M 450.4-1, NNSA safety performance objectives, measures and commitments, and provide these to NNSA HQ for rmation. Performance commitments include specific actions that will be taken to achieve objectives. In the area of mission accomplishment, NNSA develops commitments and measures progress as part of the NNSA programming, planning, budgeting and evaluation processes. Currently, in the area of safety, NNSA line management develops annual site specific measures as part of the Contractor Performance Evaluation Plans. For ISM, line management in consultation with N 3.6 sets schedules and develops expectations for Site Office annual review of ISM safety performance o A - 8 - 5.0 Roles and Responsibilities To accomplish the mission and strategic goals, the NNSA FRAM describes in detail the specific safety managem ent functions, responsibilities and authorities for the Administrator, Principal nd Deputy Administrators, Central Technical Authority, Chief of Defense Nuclear Safety, enior Advisor for ES&H, Associate Administrators, Site Office Managers, and Service enter Director. re anization for execution of safety management sponsibilities in support of authorized work. Though all offices and employees within NNSA ese described in each contractor organization’s ISM System Description. a S C Figu 3 below shows the NNSA org re have some responsibility for implementing safety, those organizations in green shaded boxes have Federal line management responsibilities for safety within NNSA (within the scope of DOE M 450.4-1). Offices with an asterisk (*) provide safety support as a primary function. Site contractors have important line management responsibilities in the safe execution of work. Th responsibilities are NA-10 Defense Programs NA-20 Defense Nuclear Nonproliferation NA-30 Naval Reactors NA-40 Emergency Operations

NA-50 Infrastructure & Environment NA-60 Management & Administration NA-70 Defense Nuclear Security NA-1 Administrator and Under Secretary for Nuclear Security Staff Offices NA-2.1 Defense Nuclear Safety* NA-3.6 Senior Advisor for ES&H* Others NA-2 Principal Deputy Los Alamos Site Office Livermore Site Office Kansas City Site Office Nevada Site Office Pantex Site Office Y-12 Site Office NNSA Service Center NA-17Asst. Deputy Administrator for Facilities and Quality* NA-26 Asst. Deputy Administrator for Fissile Materials Disposition* Sandia Site Office Savannah River Site Office Site Contractors Site Contractors Site Contractors Site Contractors Site Contractors Site Contractors Site Contractors Site Contractors Figure 3. NNSA Organization for Safety Management Responsibilities - 9 - The NNSA Administrator (NA-1) is the senior line manager responsible for the safety of NNSA operations. NA-1 monitors delegated authorities and the overall performance of safety management implementation within NNSA. The Administrator is the Senior Procurement Executive for NNSA. The NNSA Principal Deputy Administrator (NA-2) (currently the Central Technical Authority (CTA)) is the second most senior line manager within NNSA, and supports the Administrator by providing a single, authoritative source for NNSA guidance and expectations regarding implementation of nuclear safety requirements by NNSA personnel and contractors. The CTA is responsible for ensuring that NNSA HQ maintains operational awareness of nuclear safety issues and the implementation of nuclear safety requirements and guidance throughout the NNSA complex. The CTA is responsible for ensuring that NNSA maintains adequate numbers of trained federal employees to fulfill NNSA safety responsibilities. The Chief of Defense Nuclear Safety (CDNS or NA-2.1) supports the Administrator and the CTA in executing their responsibilities. With primary focus on nuclear safety, the CDNS executes numerous activities in order to establish operational awareness, including conduct of biennial reviews of each field element, review of concurrence requests, and managing the Differing Professional Opinion process for NNSA. The CDNS also supports field element managers, who are line managers with direct responsibility for safety. The NNSA Senior Advisor for ES&H (NA-3.6) provides expert advice to the Administrator, the Principal Deputy Administrator, the CTA and other senior NNSA officials on ES&H policy and issues (e.g., worker safety, environmental protection, quality assurance, fire protection, radiological control, and DOE corporate operating experience) which affect safety in nuclear facilities. The Senior Advisor for ES&H is currently designated the ISM Champion for NNSA HQ, although this role is expected to rotate through other NNSA HQ organizations. NA-3.6 maintains the NNSA HQ ISM System Description for the CTA. The Deputy Administrator for Defense Programs (NA-10) has authority for the programmatic and Enviro ent. The eputy Administrator for Defense Programs (NA-10) has authority for all nuclear safety, nuclear xplosive safety (NES) and ES&H matters and is the Lead Program Secretarial Officer as for or 26 and 6 he nment, Safety and Health (ES&H) line oversight aspects of safety managem D e defined in the DOE FRAM and in a Memorandum of June 25, 2003 from the Administrator all eight NNSA sites.

The Deputy Administrator for Defense Nuclear Nonproliferation (NA-20) has authority f nuclear safety and ES&H matters relative to its programmatic responsibilities and exercises that authority in coordination with NA-10. The “Memorandum of Agreement between Deputy Assistant Deputy Administrator for Fissile Materials (NA-26) and the Savannah River Site Office (SRSO) Manager” specifies the respective roles and responsibilities between NA- the SRSO Manager in relation to NA-26 activities performed at the Savannah River Site. NA-2 has also executed an “Agreement on Safety Management at the Savannah River Site” with t Savannah River Operations Office in which NA-26 subscribes to the Operations Office ISM System Description. - 10 - The Associate Administrator for Emergency Operations (NA-40) is responsible for all aspects of emergency management and response including allocation of resources as relate DOE Emergency Management Systems. The Associate Administrator for Infrastructure and Environment (NA-50) is responsible for corporate integration, development, oversight and execution of NNSA facilities, project, and environmental management policies and programs. The Associate Administrator for Man d to agement and Administration (NA-60) has the authority r resource allocation processes, including personnel and funding, with concurrence from the S provides engineering, technical, operational, budget and administrative irection to NNSA programs and field elements to assure effective security operations at NNSA nter Director provides safety management support to other NNSA rganizations and is responsible for all aspects of safety management for the NNSA Service HQ Work Activities rk • Establishing the NNSA mission and ensuring it is performed safely • Developing and fulfilling safety management roles, responsibilities and requirements s relate more to establishing the desired environment and the desired safety culture, more attention to implementing the ISM fo appropriate Deputy Administrator(s), as related to safety management. The Associate Administrator for Defense Nuclear Security (DNS or NA-70) is the Cognizant Security Authority for NNSA. DNS is fully responsible for the overall direction and management of security programs at NNSA facilities, to include line management oversight of security programs. DN d facilities, including the physical, personnel, materials control and accounting, classified and sensitive information protection and technical security programs. NNSA Site Office Managers have the authority for day-to-day execution of the safety management program at their site, including: direct assignments extracted from the DOE FRAM documented in the NNSA FRAM, delegated authorities from NNSA HQ, and alignment of their Site Office FRAM with the NNSA FRAM, and annual ISM reviews and declarations. The NNSA Service Ce o Center facility in Albuquerque. 6.0 Implementation of ISM in NNSA The NNSA HQ role in assuring safe mission accomplishment differs from contractor and NNSA site offices safety roles, but is nonetheless important. The NNSA HQ role is defined by its wo activities, which include the following: • Acquiring resources • Developing annual budgets and priorities • Performing program and project management • Performing Federal oversight and self-assessments • Setting overall safety performance expectations and objectives • Monitoring and sustaining an effective safety culture.

This NNSA HQ ISM System Description is focused at the NNSA enterprise level, encompassing activities of two Secretarial Offices (NA-10 and NA-20) and the Administrator, along with supporting NNSA HQ organizations. As the ISM Guiding Principle - 11 - Guiding Principles is expected at higher levels of the organization (such as the enterprise and site o he following sections describe the specific ISM implementing mechanisms, processes, and to create an effective nvironment for ISM implementation. Implementing mechanisms, processes and methods are s and methods that v rinciples. These tables lay out how NNSA currently implements ISM t e. As ISM matures in NNSA HQ, these tables may ffectiveness reviews. d NNSA-level mechanisms, processes, ility for Safety), 2 (Clear urate with Responsibilities). These uiding Principles are grouped together because they help ensure the management structure has able 3 on page 26 lists the applicable DOE-level and NNSA-level mechanisms, processes, and ethods for Guiding Principles 5 (Identification of Safety Standards and Requirements) and 6 azard Controls Tailored to Work Being Performed). These Guiding Principles are grouped the ty standards nd applying them to tailor hazard controls to the work. es, and sh and tor identify and implement safety controls before starting to ork. Once the work begins, it is performed in accordance with these safety controls. level). Therefore, the specific mechanisms, processes, and methods used by NNSA HQ t implement ISM will focus on the ISM Guiding Principles. Implementation of Safety Culture Elements and Core Functions will be described in relation to the Guiding Principles. 6.1 Implementing ISM Guiding Principles and Safety Culture Elements T methods by which NNSA implements the ISM Guiding Principles e developed at various levels within the DOE and NNSA organizations to ensure consistent expectations and approaches. Tables 1-4 (pp. 23-27) list related implementation mechanisms, processe co er all seven Guiding P wi hin the DOE and NNSA directives structur change as a result of gap analyses or annual ISM e Table 1 on page 23-24 lists the applicable DOE-level an and methods for Guiding Principles 1 (Line Management Responsib Roles and Responsibilities), and 3 (Competence Commens G personnel who focus on safe accomplishment of mission, understand their assignments, and can carry out the core safety management functions correctly and efficiently. Table 2 on page 25 lists the applicable DOE-level and NNSA-level mechanisms, processes, and methods for Guiding Principle 4 (Balanced Priorities). DOE and the contractor identify and prioritize work and allocate resources. DOE provides performance expectations by strategic plans, goals, and objectives, and through program execution guidance. T m (H toge r because they are similar in that they deal with identifying applicable safe a Table 4 on page 27 lists the applicable DOE-level and NNSA-level mechanisms, process methods for Guiding Principle 7 (Operations Authorization). DOE and contractors must establi and agree upon the conditions and requirements to be satisfied for operations to be initiated conducted. DOE and the contrac w 6.1.1 Guiding Principle 1: Line Management Responsibility for Safety - 12 - Line management is directly responsible for the protection of the public, the workers, and the summarized in ection 5.0 of this document. An identified gap is that the NNSA FRAM needs to be updated to

.1.2 Guiding Principle 2: Clear Roles and Responsibilities he NNSA Safety Management Functions, Responsibilities and Authorities Manual (NNSA o s and sponsibilities. For example, within the CDNS, roles and responsibilities are established in its t work at Savannah River Site. NA-70 is developing a FRAM for its security sponsibilities. are necessary to ischarge their responsibilities. To ensure NNSA HQ personnel possess the experience, knowledge, skill, and abilities necessary e DOE Technical Qualification rogram. The Senior Advisor for ES&H manages implementation of the program within NNSA. ical Safety ing approximately 42 persons at NNSA HQ. Also, some members of NNSA HQ aff have professional certifications or licenses. NNSA HQ provides resources for staff development, both within HQ and in the field. environment. NNSA line management responsibilities for safety are described in DOE M 411.1-1C, Safety Management Functions, Responsibilities and Authorities Manual, as modified by Secretary Bodman letter of April 26, 2005, the NNSA Safety Management Functions, Responsibilities and Authorities Manual (FRAM) Revision 1, dated February 28, 2005, and are S reflect current roles and responsibilities. This gap is listed in Appendix B. Specific mechanisms, processes, and methods are described in Table 1. 6 Clear and unambiguous lines of authority and responsibility for ensuring safety shall be established and maintained at all organizational levels within the Department and its contractors. T FRAM), Revision 1, dated February 28, 2005, defines NNSA expectations regarding organizational accountability for safety management. These expectations have been derived from appropriate DOE directives listed in DOE M 411.1C, Safety Management Functions, Responsibilities and Authorities Manual and assignments and delegations made by the Administrator. Some rganizations within NNSA HQ have further defined their specific role re CDNS M 411.1-1, CDNS Management System Description. NA-20 is developing a FRAM for nuclear projec re Specific mechanisms, processes, and methods are described in Table 1. 6.1.3 Guiding Principle 3: Competence Commensurate with Responsibilities Personnel shall possess the experience, knowledge, skills, and abilities that d to discharge their responsibilities, NNSA HQ has implemented th P Approximately 70 members of NNSA HQ staff are enrolled in the Technical Qualification Program in various functional areas. The single largest functional area is Senior Techn Manager, hav st - 13 - The Deputy Secretary’s memorandum dated December 27, 2005, describes the require delegating nuclear safety responsibilities from HQ Cognizant Secretarial Officers to field managers. NNSA HQ is implementing this memorandum and using the criteria describ The CDNS developed procedures by which CTA must concur for delegation of certain n safety approval ments for ed therein. uclear authorities below the level of Site Office Manager or Deputy Site Office anager. In addition, the NNSA procedures require CTA concurrence for those delegations that sts and sponsibilities, NNSA HQ has implemented effective human resource anagement systems which identify needed skills, evaluate the employees’ skills, identify skill ges professional ertification and obtaining advanced educational degrees. pecific mechanisms, processes, and methods are described in Table 1. lanced Priorities NNSA or safety management and safety support, in

igure 3 are represented in the budget process and provide input for the final resource allocation gates uous and ns. NSA ith the he 5- s and specific program direction and itiatives for the planning period, and tasks specific analyses with programmatic implications. hip Plan, provide formation about accomplishments, challenges, goals and milestones for their respective M have compensatory measures. The CDNS supports the review of concurrence reque recommends disposition to the CTA. To ensure personnel possess the experience, knowledge, skill, and abilities necessary to discharge their re m gaps, and arranges for training to eliminate the gaps. NNSA HQ encoura c S 6.1.4 Guiding Principle 4: Ba Resources shall be effectively allocated to address safety, programmatic, and operational considerations. Protecting the public, the workers, and the environment shall be a priority whenever activities are planned and performed. NNSA HQ sets priorities for all of NNSA and leads the annual budget preparation to acquire and allocate the necessary resources to ensure safe mission accomplishment. NA-60 is lead for coordinating NNSA HQ processes associated with budgeting and resource allocation. All HQ organizations, including those responsible f F decisions by NA-1. NNSA HQ adheres to DOE directives and NNSA policy letters described in Table 2 for the overall process. For specific guidance to be used each year, NA-60 promul NNSA Program and Fiscal Guidance. The NNSA Planning, Programming, Budgeting and Evaluation (PPBE) process is a contin cycle for establishing goals, and developing, prioritizing, funding and executing programs, and evaluating performance results to provide feedback for future planning. At NNSA, planning programming are primarily HQ functio Planning and programming are HQ-driven processes to develop, prioritize and integrate N programs. The processes begin with and flow from the NNSA Strategic Plan, coupled w DOE Strategic Plan, which together provide the overall NNSA mission and set broad goals and themes. The NNSA Strategic Planning Guidance establishes the Administrator’s view of t 15 year future planning environment, provides his prioritie in Periodic updates of several documents, including the Stockpile Stewards in - 14 - programs. NNSA HQ annually reviews budgets against these plans and adjusts to the anagement concerns and safety priorities affecting NNSA mission work. NNSA requires A-10, NA-20 and the CDNS, through their oversight processes, identify needed improvements rk pecific mechanisms, processes, and methods are described in Table 2. azards shall be evaluated and an agreed-upon set of fety standards and requirements shall be established which, if properly implemented, will w and aluation on of ract Q reviews and recommends approval or disapproval for contractor-submitted ariance requests under 10 CFR 851. After considering the recommendation from HSS, the S, along with other NNSA HQ personnel, review implementation of safety standards nd requirements through the biennial review process, including authorization agreements, y ons and exceptions to nuclear safety quirements and provides advice and concurrence prior to their approval. pecific mechanisms, processes, and methods are described in Table 3. .1.6 Guiding Principle 6: Hazard Controls Tailored to Work Being Performed m appropriate allocation of resources to address safety, programmatic, and operational considerations.

N in nuclear safety for use in achieving appropriate balance with competing requirements and drivers. Project management systems in DOE O 413.3 are in place to guide, monitor, and evaluate wo scope performance on new projects and major modifications. The NNSA ESAAB equivalent process provides the framework by which significant safety concerns and issues are brought to the attention of NNSA HQ management for resolution. S 6.1.5 Guiding Principle 5: Identification of Safety Standards and Requirements Before work is performed, the associated h sa provide adequate assurance that the public, the workers, and the environment are protected from adverse consequences. DOE has directives and standards that are carefully applied in planning work. NNSA identifies applicable DOE directives. NNSA HQ provides leadership in the directives process, working with the Office of Health, Safety and Security in originating, issuing and revising directives and standards that protect employee health and safety, as well as that of contractors, the general public, and the environment. All of NNSA HQ organizations participate in the DOE Revie Comment process to ensure that NNSA mission needs are addressed. NNSA Source Ev Boards review requests for proposals (RFP) prior to issuance to ensure adequate identificati hazards on List B and applicable safety standards and requirements and provides cont reviews. NNSA H v Administrator decides whether to grant a variance to 10 CFR 851 requirements. The CDN a conduct of operations requirements, and development and implementation of safety bases for nuclear facilities under 10 CFR 830. CDNS reviews the implementation of DOE nuclear safet requirements in contracts in support of the CTA concurrence role on those requirements. The CTA, with CDNS support, reviews requests for exempti re S 6 - 15 - Administrative and engineering controls to prevent and mitigate hazards shall be tailored to the work being performed and associated hazards. NNSA HQ managers typically delegate approval of hazard controls to the field according to ecific criteria and procedures. Where not delegated, NNSA HQ personnel participate in the views pecific mechanisms, processes, and methods are described in Table 3. ment and plementation nuclear and other hazard controls at a facility, project, or activity level prior to the contractor establish nd agree upon the conditions and requirements to be satisfied for operations to be initiated and fore inding upon the contractor. The formality and rigor of the review process and the extent of ocess should ensure programs addressing all pplicable functional areas are adequately implemented to support safe performance of the work. lear ome site offices, NNSA HQ tains these authorities. irements. The area of readiness is a topical area specifically xamined in the CDNS biennial review process. The NNSA Service Center also provides sp review and approval of DSAs and make recommendations to NNSA HQ managers. NNSA HQ personnel review operating experience data to identify problems in the field. NNSA HQ personnel also perform oversight to evaluate implementation of hazard controls in the field and confirm that work is performed within the scope of the project. The CDNS reviews the implementation of safety basis controls as part of its biennial reviews. On an as-needed basis, the CDNS analyzes the adequacy of these controls. The CDNS, through its review and recommendation of concurrence/non-concurrence on exemption requests, re the adequacy of proposed compensatory measures and controls, and provides recommendations on any additional controls needed.

S 6.1.7 Guiding Principle 7: Operations Authorization The conditions and requirements to be satisfied for operations to be initiated and conducted shall be clearly established and agreed upon. ISM provides a process to confirm adequate preparation, including develop im authorizing operations. DEAR 970.5223-1(b) (7) requires that DOE and a conducted. These conditions and requirements are included in the contract and are there b documentation and level of authority for agreement should be based on the hazard and complexity of the work being performed. The pr a For nuclear facilities/activities, NNSA HQ may delegate authority to site office personnel to approve safety basis documents, including documented safety analyses and technical safety requirements. NNSA HQ also may delegate authority for startup and restart of certain nuc activities. However, these delegations are only made after a thorough review of site office capabilities and processes by NNSA HQ line management. For s re The CDNS reviews and comments on the adequacy of readiness review startup notification reports, plans of action, implementation plans, and readiness review reports. The CDNS provides operational support to readiness review teams by participating as team members or team leaders in support of line requ e - 16 - significant support in the readiness review process. This will be described in the NNSA Service fety aff member understands his/her role in performing NNSA work safely. Every NNSA employee e and ure timely resolution. Using this process, NNSA demonstrates its ommitment to safety. NNSA HQ personnel participate in the DOE Federal Employee ted in rther guidance for inclusion of similar safety elements in erformance plans for non-supervisory NNSA personnel. pecific mechanisms, processes, and methods are described in Table 1. E and ate or or-likely situations. Center ISM System Description. Specific mechanisms, processes, and methods are described in Table 4. 6.1.8 Safety Culture Element 8: Individual Attitude and Responsibilities for Sa Every NNSA employee accepts responsibility for safe mission performance. Individuals demonstrate questioning attitude by challenging assumptions, investigating anomalies, and considering potential adverse consequences of planned actions. All employees are mindful of work conditions that may impact safety, and assist each other in preventing unsafe acts or behaviors. NNSA management communicates its goals and expectations regularly to all NNSA staff so each st is afforded the opportunity and encouraged to raise concerns about any aspect of achieving th NNSA strategic goals safely. NNSA strongly supports a safety conscious work environment developed a Differing Professional Opinion process so that concerns receive adequate review and timely resolution. Any immediate threat to health or safety is dealt with expeditiously. Several systems exist for employees to report concerns about work-related hazards, and NNSA tracks these reports to ens c Occupational Safety and Health (FEOSH) Program that includes workplace inspections and safety communications and training for Federal workers (See DOE O 442.1 and NAP-6 ci Table 1). NNSA supervisors and managers were tasked to update their performance plans to include specific safety elements to foster increased awareness and responsibility for safety. DOE and NNSA personnel are developing fu p S 6.1.9 Safety Culture Element 9: Operational Excellence

NNSA achieves sustained, high levels of operational performance, encompassing all DO contractor activities to meet mission, safety, productivity, quality, environmental, and other objectives. High-reliability is achieved through a focus on operations, conservative decision making, open communications, deference to expertise, and systematic approaches to elimin mitigate err NNSA processes foster a culture of safety excellence. Performance is measured and tracked to maintain safe operations and progress. - 17 - NNSA Federal staff performance is evaluated with defined measures in performance plans. NNSA awards its staff for exceptional performance. The NNSA Federal Safety Professiona the Year Award recognizes employees who make significant contributions to accomplishing the NNSA strategic goals safely. NNSA also participates in DOE-wide awards such as the DOE Facility Representative of the Year. NA-60 administers the overall award process as describ the NA-1 memorandum dated January 9, 2006, Honor Awards. NNSA HQ l of ed in personnel from line organizations and supporting safety organizations (see Figure 3) articipate in the evaluation of site contractor performance by reviewing submitted Performance age and red NNSA group led by NA-10 ersonnel to support NNSA line management and NNSA contractors in developing, using and throughout NNSA. The OCAS Council is described in more detail in Section 7.0. NSA also encourages participation in the DOE Voluntary Protection Program to recognize surance dentifies opportunities for improvement. Performance ssurance activities verify whether standards and requirements are being met. Performance s 6.1 ss. Pilot oversight projects at the ansas City Plant and Los Alamos National Laboratory meet the intent of the order with respect to on s. This gap is listed in Appendix B. 3), mance assurance oversight through several mechanisms, including readiness reviews, project reviews, NESS, assessments, DSA reviews, and QA reviews. NNSA HQ fully p Evaluation Plans. NNSA provides incentives for operational excellence in the contract langu it prepares and in the oversight of contractor performance. A major initiative in operational excellence is the development of effective contractor assurance systems. The Line Oversight Contractor Assurance System (LOCAS) Council is a charte p sustaining vital, mature line oversight and contractor assurance systems L N safety excellence. Specific mechanisms, processes, and methods are described in Table 1. 6.1.10 Safety Culture Element 10: Oversight for Performance As Competent, robust, periodic and independent oversight is an essential source of feedback that verifies expectations are being met and i a assurance through conscious, directed, independent reviews at all levels brings fresh insight and observations to be considered for safety and performance improvement. NNSA fully supports and implements safety oversight responsibilities described in DOE O 22 to ensure that contractor assurance systems and DOE oversight programs are comprehensive and integrated for all aspects of operations essential to mission succe K to safety oversight responsibilities. NNSA HQ supports independent oversight of its activities by DOE HSS and the DOE IG and outside agencies such as the DNFSB and GAO. NNSA HQ has points of contact designated interact with these organizations to coordinate various reviews and ensure management attention is focused on the results of the reviews. Senior NNSA HQ managers are periodically briefed results of these oversight group activities to gain insight into organizational performance and to direct needed corrective actions. An identified gap is the formality with which NNSA HQ reviews and concurs on proposed PAAA enforcement action

NNSA HQ line management organizations with support from safety organizations (see Figure also conduct perfor - 18 - supports and expects all employees and contractors to use the ORPS, CAIRS, and NTS reporting ure that appropriate ction is taken. eriodic reports detail progress and any problems in project performance. NNSA performance 4. d A-40 provides notifications to NNSA personnel of operational situations at NNSA sites that s NNSA Technical Bulletins quarterly to share important information and ssons learned. The NNSA Service Center issues monthly continuing training information with are applied as a continuous cycle with the degree of rigor ppropriate to address the type of work activity and the hazards involved. systems to provide timely reporting of occurrences and track these to ens a P and trends are reported to the PSOs, CTA and Administrator who set priorities for action and funding. NNSA staff provides expertise to field activities to assist in resolving technical issues and to measure progress. Specific mechanisms, processes, and methods are described in Tables 2, 3 and 6.1.11 Safety Culture Element 11: Organizational Learning for Performance Improvement NNSA demonstrates excellence in performance monitoring, problem analysis, solution planning, and solution implementation. The organization encourages openness and trust, and cultivates a continuous learning environment. Performance monitoring is a cornerstone of performance improvement. Information reported to NNSA and gathered by NNSA is analyzed to discover both trends in performance excellence an emerging problems. NNSA partners closely with the Office of Health, Safety and Security to collect and analyze data such as CAIRS, NTS, ORPS, TRC rate, and other safety information. Analyses and summaries are shared throughout NNSA via safety briefings, bulletins, emails, conference calls and newsletters. N required HQ Emergency Operations Center involvement. NA-40 is responsible for coordinating NNSA emergency management and response capabilities with other federal government agencies, and provides information and training regarding emergency situations that have occurred. The CDNS issue le lessons learned and other pertinent safety topics. NA-10 personnel participate in periodic technical seminars on a wide range of topics related to accomplishing the mission. NNSA encourages open communication and provides numerous opportunities for employees to share information and concerns. Specific mechanisms, processes, and methods are described in Table 4. 6.2 Implementing ISM Core Functions DOE P 450.4, DOE Safety Management System Policy, lists the five Core Functions that provide the necessary structure for any work activity that could potentially affect the public, the workers, and the environment. The functions a - 19 - In addition to these Guiding Principles, the Department included in DOE M 450.4-1 four Safe Culture Elements to enhance implementation of ISM. Tables 1, 2, 3 and 4 depict the close relationship among the core functions, guiding principles and safety culture elements and the specific implementing mechanisms ty in NNSA. , and e allocated. rk to erform work within the scope of their contract using the set of quirements specified in List A and List B of the contract. The NNSA CTA, NA-10, and NA-20 is adequately covered. he CDNS assists in this role for the CTA and also evaluates requests from NNSA employees or

orms of relief from nuclear safety requirements to pport decision-making by the CTA. 0 resources to address uclear safety and ES&H requirements with elements for long-term planning, landlord activities, roduction Manual. pecific mechanisms, processes, and methods are described in Tables 1, 2, and 3. .2.2 Core Function 2: Identify and Analyze Hazards work are identified, analyzed, and categorized. hazard to en uclear facilities, NNSA site contractors develop DSAs and TSRs in ccordance with 10 CFR 830. These DSAs describe facility hazards and associated controls. If 6.2.1 Core Function 1: Define Scope of Work Missions are translated into work, expectations are set, tasks are identified and prioritized resources ar NNSA defines its work through planning documents developed in accordance with the implementing mechanisms, processes or methods described in Tables 1, 2 and 3. The work planning documents, together with finalized budgets, determine the amount and type of wo be accomplished. Contractors at NNSA sites p re evaluate directives and guidance in NNSA contracts to ensure that safety T contractors for waivers, exemptions, or other f su NA-10 provides mission assignments and program guidance to Site Office Managers and OST. NA-20 provides mission assignments and program guidance to its programs. NA-10 and NA-2 prepare proposed budgets for the program offices ensuring the adequacy of n and NNSA-wide facility safety. These efforts are coordinated with the Associate Administrator for Management and Administration (NA-60). The weapon quality management system requirements are described in the Weapons Quality Policy (QC-1), the Quality Assurance Procedure Manual, and the Development and P S 6 Hazards associated with The objective of hazards analysis is to develop an understanding of the potential for the affect the health and safety of workers, the public, or the environment. Hazard controls are th established based on this understanding and other factors related to the work. For work in Hazard Category 2 and 3 n a a contractor proposes a methodology not described in 10 CFR 830, NA-10 or NA-20 must approve with CTA concurrence the methodology for the DSA. NA-10 or NA-20 approves contractor DSAs, unless the approval authority has been delegated. For work in other facilities - 20 - that do not meet Hazard Category 2 or 3 criteria, NNSA Site Office Managers determine the approval mechanisms based on the potential hazards involved. The DOE General Counsel ruling 1995-1 is an official interpretation of 10 CFR Parts 830 and 835, and it states in part that nuclear r non-nuclear safety deficiencies that affect the safety of nuclear facilities are subject to Price fety and with concurrence from e CTA. NA-10 ensures that the Site Office Managers maintain the status of safety basis and in Tables 1 and 3. ndards lth Goals provides xpectations for the Department to foster and maintain a work environment that encourages free eprisal or iscrimination for reporting such concerns. NNSA fully supports this goal and encourages every ey are convinced a tuation may exist that could place them, their coworker(s), or the environment in danger. o Anderson enforcement. 10 CFR Part 850, Chronic Beryllium Disease Prevention, and Part 851 contain requirements for the identification and assessment of hazards that affect worker safety in all facilities. Earlier Section 6.1.5 describes the review and approval process for variances requested from worker safety requirements in 10 CFR 851.

NA-10 and NA-20 approve requests for exemptions from requirements of DOE nuclear sa regulations listed in DOE M 411.1-1C, Safety Management Functions, Responsibilities and Authorities Manual, as authorized by the provisions of 10 CFR 820 th related documents for Hazard Category 2 and 3 nuclear facilities. Specific mechanisms, processes, and methods are described 6.2.3 Core Function 3: Develop and Implement Hazard Controls Applicable standards and requirements are identified and agreed on, controls to prevent or mitigate hazards are identified, the safety envelope is established, and controls are implemented. This Core Function is closely related to Guiding Principle 5: Identification of Safety Sta and Requirements and Guiding Principle 6: Hazard Controls Tailored to Work Being Performed. The same description in sections 6.1.5 and 6.1.6 apply for Core Function 3. Specific mechanisms, processes, and methods are described in Tables 1 and 3. 6.2.4 Core Function 4: Perform Work Within Controls Readiness is confirmed and work is performed safely. NNSA HQ provides overall leadership, direction, and oversight to ensure site programs, operations, and resources are managed in an open, safe, environmentally sound, and cost- effective manner. NNSA HQ personnel perform assessments of site offices and contractors performance to ascertain facility and program status, determine whether implementation of requirements is effective, and evaluate the effectiveness of the contractor’s self-assessment program. DOE P 450.7, Department of Energy Environment, Safety and Hea e and open expression of ES&H concerns, and where employees have no fear of r d NNSA employee to raise concerns, without the fear of reprisal, when th si - 21 - Specific mechanisms, processes, and methods are described in Tables 1, 3, and 4. 6.2.5 Core Function 5: Provide Feedback and Continuous Improvement ependent oversight conducted, and, if necessary, regulatory and enforcement actions occur. ffective and timely feedback is critical to identification of improvement opportunities. NNSA romote continuous improvement in M implementation. Some of these mechanisms are: ers Contractor Performance Evaluations NA-1 with Laboratory Directors Periodic calls with site offices by Deputy NA-10 for Site Operations en Monthly calls between NA-3.6, NA-17 and NNSA Facility Representative Steering Annual NNSA HQ FEOSH workplace inspection ent reviews to sk team participation as feedback sources. Key performance feedback is provided by NNSA ncouraged to self entify and report problems and may reduce fines and penalties in certain areas if they do so (for ed earlier, NNSA HQ participates in the dinated by HSS to sort and screen of NNSA facilities, as well as other sites in the DOE cribed in Table 4. Feedback information on the adequacy of controls is gathered, opportunities for improving the definition and planning of work are identified and implemented, line and ind is E HQ employs various mechanisms to collect feedback and to p IS • Quarterly Safety Briefings to NNSA Senior Manag • • CDNS biennial review reports • NA Technical Bulletins developed by CDNS • Weekly call by • • Weekly calls by CDNS with site offices • Monthly calls between site offices and NA-17 on commitments to the DNFSB and on op CATS items • Committee members • Monthly calls between NA-3.6, NA-17 and NNSA Site Office Points of Contact for 10 CFR

851 implementation • NNSA SC Continuing Training information • Daily ORPS reports provided by HSS • Lessons Learned / Operating Experience Program communications • • DPO Process. NNSA HQ monitors other site activities, ranging from surveillances and docum ta site offices as part of the formal contractor award fee and performance evaluation process. The amount of award fee earned by the contractor at the end of a rating period is determined after due consideration of performance and feedback for the period. Contractors are e id example, Price-Anderson Amendments Act activities). In addition to the NNSA feedback mechanisms discuss DOE Lessons Learned/Operating Experience program coor lessons learned pertaining to the operation complex. Specific mechanisms, processes, and methods are des - 22 - - 23 - TABLE 1. Implementing Mechanisms, Processes, and Methods for ISM Guiding Principles 1, 2, and 3 ISM Guiding Principles Closely Related ISM Core Functions DOE-Level Implementing Mechanisms, Processes, and Methods NNSA-Level Implementing Mechanisms, Processes and Methods 1. Line Management Responsibility 2. Clear Roles and Responsibilities 3. Competence Commensurate with Responsibilities Related ISM Safety Culture Elements 8. Individual Attitude and Responsibility 9. Operational Excellence 10. Oversight for Performance Assurance 1. Define Scope of Work 2. Identify and Analyze Hazards 3. Develop and Implement Hazard Controls 4. Perform Work Within Controls 5. Feedback and Continuous Improvement • 2006 DOE Strategic Plan • DOE O 226.1, Implementation of Department of Energy Oversight Policy • DOE O 331.1B Chg 1, Employee Performance Management System • DOE O 360.1B, Federal Employee Training • DOE M 360.1-1B, Federal Employee Training Manual • DOE O 361.1A, Acquisition Career Development Program • DOE M 411.1-1C, Safety Management Functions, Responsibilities and Authorities Manual, as modified by Secretary Bodman letter of April 26, 2005 • DOE O 412.1A, Work Authorization System • DOE O 413.3A, Program and Project Management for the Acquisition of Capital Assets • DOE O 414.1C, Quality Assurance • DOE M 426.1-1A, Federal Technical Capability Manual • DOE O 442.1A, Department of Energy Employee Concerns Program • DOE M 442.1-1, Differing Professional Opinions Manual for Technical Issues • DOE M 450.4-1, Integrated Safety Management System Manual • U.S. DOE Federal Technical Capability Program Corrective Action Plan, Revision 1, January 17, 2007 • NNSA 2004 Strategic Plan • NNSA Safety Management Functions, Responsibilities and Authorities Manual (FRAM) Revision 1, dated February 28, 2005 • NNSA HQ QAP, July 2006 • NA-1 M 411.1-1 Headquarters Biennial Review of Site Office Nuclear Safety Performance • NA-1 SD 442.1-1, NNSA Differing Professional Opinions Manual for Technical Issues Involving Environment, Safety, & Health • NAP-4A, Corporate Performance Evaluation Process for Management and Operating Contractors • NAP-6, Federal Employee Occupational Safety and Health Program for National Nuclear Security Administration Headquarters Employees • BOP-002.02a, NNSA Student Loan Repayment Program • BOP-002.03a, NNSA Recruitment, Relocation and Retention Incentives Program: Interim Policy Pending Issuance by US Office of Personnel Management of Final Regulations • BOP 002.04a, NNSA Competitive Service Merit Promotion Plan • BOP-003.0401A, NNSA Acquisition Career Development

• BOP-006.002 NNSA Employee Concerns Program • CDNS 251.1-3, Concurrence with Rules & Directives that Affect Nuclear Safety • CDNS M 360.1N, Nuclear Safety Continuing Education • CDNS M 411.1-1, CDNS Management System Description • CDNS M 442.1-1, CDNS Differing Professional Opinion Process • NA-70 FRAM (under development) - 24 - TABLE 1. Implementing Mechanisms, Processes, and Methods for ISM Guiding Principles 1, 2, and 3 Closely Related ISM Guiding DOE-Level Implementing Mechanisms, NNSA-Level Implementing Mechanisms, Processes and Methods ISM Core Principles Processes, and Methods Functions • NNSA Activity Level Work Planning and Control Processes: Attributes, Best Practices and Guidance for Effective Incorporation of ISM and QA, January 2006 (Sent to Site Office Managers by NA-10 memo, January 23, 2006) • DP Program Management Manual • Initial Headquarters Line Management Oversight Plan for ES&H and Emergency Operations (NA-10) • NNSA Technical Qualification Program Plan, dated June 24, 2004 • NNSA Technical Bulletins • Monthly NNSA Service Center continuing training notifications • NNSA Program and Fiscal Guidance, March 2007 • NNSA PPBE Programming Instructions, March 2007 • DP Program and Resource Guidance • NEPA/EIS Guidance from HS • Annual Planning & Production Document • Annual Stockpile Stewardship Plan (“Green Book”) • NNSA Development & Production Manual, 56XB, Revision 2 • NNSA Quality Assurance Procedures Manual • NNSA Safety Software Quality Assurance Handbook, Rev. A, October 2006 • QC-1, Rev. 10, Weapons Quality Policy • Quality Assurance Procedures Manual, February 2005 • Memorandum dated 1/9/2006 from NA-1, Subject: Honor Awards • Memorandum dated 11/30/2006 signed by NNSA Associate Administrator for Management and Administration and the DOE Deputy Human Capital Officer • NNSA HQ review of site contractor Performance Evaluation Plans - 25 - TABLE 2. Implementing Mechanisms, Processes, and Methods for ISM Guiding Principle 4 ISM Guiding Principle Closely Related ISM Core Function DOE-Level Implementing Mechanisms, Processes, and Methods NNSA-Level Implementing Mechanisms, Processes, and Methods 4. Balanced Priorities Related ISM Safety Culture Elements 10. Oversight for Performance Assurance 1. Define Scope of Work • DOE O 130.1, Budget Formulation • DOE O 135.1A, Budget Execution Funds Distribution and Control • DOE M 135.1-1A, Department of Energy Budget Execution Funds Distribution And Control Manual • DOE O 226.1, Implementation of Department of Energy Oversight Policy • DOE M 411.1-1C, Safety Management Functions, Responsibilities and Authorities Manual, as modified by Secretary Bodman letter of April 26, 2005 • DOE O 412.1A, Work Authorization System • DOE O 413.3A, Program and Project Management for the Acquisition of Capital Assets • DOE O 414.1C, Quality Assurance • DOE M 426.1-1A, Federal Technical Capability Manual • DOE O 452.3, Management of the Department of Energy Nuclear Weapons Complex • DOE Performance and Accountability Report • NNSA 2004 Strategic Plan • BOP-001 series on NNSA Programming, Planning, Budgeting and Evaluation processes • NNSA Strategic Planning Guidance • Annual Program & Fiscal Guidance (March 7, 2007) • Annual Programming, Planning, Budgeting and Evaluation (PPBE) Programming Process Instructions (March 21, 2007) • Annual Stockpile Stewardship Plan (“Green Book”) • NNSA Safety Management Functions,

Responsibilities and Authorities Manual (FRAM) Revision 1, dated February 28, 2005 • NA-1 M 411.1-1 Headquarters Biennial Review of Site Office Nuclear Safety Performance • NAP-4A, Corporate Performance Evaluation Process for Management and Operating Contractors • BOP-50-003, Establishment of a National Nuclear Security Administration (NNSA) Independent Project Review (IPR) Policy • CDNS M 411.1-1, CDNS Management System Description • DP Program Management Manual • Initial Headquarters Line Management Oversight Plan for ES&H and Emergency Operations (NA-10) • NNSA Technical Qualification Program Plan, dated June 24, 2004 • DP Program and Resource Guidance • NEPA/EIS Guidance from HS • Annual Planning & Production Document • NNSA Development & Production Manual, 56XB, Revision 2 • NNSA HQ review of site contractor Performance Evaluation Plans • Charter for LOCAS Council - 26 - TABLE 3. Implementing Mechanisms, Processes, and Methods for ISM Guiding Principles 5 and 6 ISM Guiding Principles Closely Related ISM Core Functions DOE-Level Implementing Mechanisms, Processes, and Methods NNSA-Level Implementing Mechanisms, Processes, and Methods 5. Identification of Safety Standards 6. Tailor Hazard Controls to Work Related ISM Safety Culture Element 10. Oversight for Performance Assurance 1. Define Scope of Work 2. Identify and Analyze Hazards 3. Develop and Implement Hazard Controls 4. Perform Work Within Controls • 10 CFR 820, Procedural Rules for DOE Nuclear Activities • 10 CFR 830, Nuclear Safety Management • 10 CFR 835, Occupational Radiation Protection • 10 CFR 850, Chronic Beryllium Disease Prevention Program • 10 CFR 851, Worker Safety and Health • DOE O 210.2, DOE Corporate Operating Experience Program • DOE O 226.1, Implementation of Department of Energy Oversight Policy • DOE M 411.1-1C, Safety Management Functions, Responsibilities and Authorities Manual, as modified by Secretary Bodman letter of April 26, 2005 • DOE O 413.3, Change 1, Program and Project Management for the Acquisition of Capital Assets • DOE O 414.1C, Quality Assurance • DOE O 420.1, Facility Safety • DOE O 425.1C, Startup and Restart of Nuclear Facilities • DOE O 440.1B, Worker Protection Management for Federal Employees • DOE HQ O 442.1, Headquarters Occupational Safety and Health Program • DOE O 450.1, Environmental Protection Program • DOE M 450.3-1, DOE Closure Process for Necessary and Sufficient Sets of Standards • DOE O 452.2C, Nuclear Explosive Safety • DOE M 452.2-1, Nuclear Explosive Safety • DOE O 452.3, Management of the DOE Nuclear Weapons Complex • NNSA Safety Management Functions, Responsibilities and Authorities Manual (FRAM) Revision 1, dated February 28, 2005 • NA-1 SD 251.1-1 CTA Management of Nuclear Safety Requirements • NA-1 SD 251.1-2 Index of Baseline Nuclear Safety Requirements • NA-1 M 411.1-1 Headquarters Biennial Review of Site Office Nuclear Safety Performance • NAP-5, Standards Management • NAP-6, Federal Employee Occupational Safety and Health Program for NNSA Headquarters Employees • BOP-50.001, NNSA ESAAB Equivalent Process • BOP-50-003, Establishment of a National Nuclear Security Administration (NNSA) Independent Project Review (IPR) Policy • Nuclear Weapons Production and Planning Directive • CDNS M 251.1-1, Evaluating Exemptions • CDNS M 251.1-3, Concurrence with Rules and Directives that Affect Nuclear Safety • CDNS M 411.1-1, CDNS Management System Description • CDNS M 411.1-2, Evaluating Requirements in

Contracts • CDNS M 411.1-3, Evaluating Delegations of Nuclear Safety Authority • CDNS M 413.3A, ESAAB Equivalent Process - 27 - TABLE 4. Implementing Mechanisms, Processes, and Methods for ISM Guiding Principle 7 - 28 - ISM Guiding Principles Closely Related ISM Core Function DOE-Level Implementing Mechanisms, Processes, and Methods NNSA-Level Implementing Mechanisms, Processes, and Methods 7. Operations Authorization Related ISM Safety Culture Element 10. Oversight for Performance Assurance 11. Organizational Learning for Performance Improvement 4. Perform Work Within Controls 5. Feedback and Continuous Improvement • 10 CFR 850, Chronic Beryllium Disease Prevention Program • 10 CFR 851, Worker Safety and Health • DOE O 210.2, DOE Corporate Operating Experience Program • DOE O 226.1, Implementation of Department of Energy Oversight Policy • DOE M 411.1-1C, Safety Management Functions, Responsibilities and Authorities Manual, as modified by Secretary Bodman letter of April 26, 2005 • DOE O 420.1, Facility Safety • DOE O 413.3A, Program and Project Management for the Acquisition of Capital Assets • DOE O 414.1C, Quality Assurance • DOE O 425.1C, Startup and Restart of Nuclear Facilities • DOE O 452.2C, Nuclear Explosive Safety • DOE M 452.2-1, Nuclear Explosive Safety • DOE O 452.3, Management of the Department of Energy Nuclear Weapons Complex • NNSA Safety Management Functions, Responsibilities and Authorities Manual (FRAM) Revision 1, dated February 28, 2005 • NA-1 M 411.1-1 Headquarters Biennial Review of Site Office Nuclear Safety Performance • NNSA HQ QAP, July 2006 • NAP-6, Federal Employee Occupational Safety and Health Program for National Nuclear Security Administration Headquarters Employees • BOP-50.001, NNSA ESAAB Equivalent Process • BOP-50-003, Establishment of a National Nuclear Security Administration (NNSA) Independent Project Review (IPR) Policy • Nuclear Weapons Production and Planning Directive • CDNS M 251.1-1, Evaluating Exemptions • CDNS M 411.1-1, CDNS Management System Description • CDNS M 411.1-3, Evaluating Delegations of Nuclear Safety Authority • CDNS M 413.3A, ESAAB Equivalent Process • Initial Headquarters Line Management Oversight Plan for ES&H and Emergency Operations (NA-10) • NNSA Activity Level Work Planning and Control Processes: Attributes, Best Practices and Guidance for Effective Incorporation of ISM and QA, January 2006 (Sent to Site Office Managers by NA-10 memo, January 23, 2006) • NNSA Program and Fiscal Guidance, March 2007 • NNSA PPBE Programming Instructions, March 2007 • DP Program and Resource Guidance • NEPA/EIS Guidance from HS • Annual Planning & Production Document • NNSA Development & Production Manual, 56XB, Revision 2 • NNSA Quality Assurance Procedures Manual • NNSA Safety Software Quality Assurance Handbook, Rev. A, October 2006 • QC-1, Rev. 10, Weapons Quality Policy • Quality Assurance Procedures Manual, February 2005 • NA-10 Technical Seminars • NNSA NA-40 Notifications of EOC Actions 6.3 Integration with Quality Assurance, Environmental Management Systems, and Integrated Safeguards and Security Systems In general, the development and implementation of the NNSA HQ ISM System requires NNSA HQ to integrate safety into all aspects of work planning and execution, using the Guiding Principles, Safety Culture Elements, and Core Functions set forth in the DOE M 450.4-1. Integration means that all management systems and programs are designed to fit together to enable safe and efficient performance of work. Safety is to be incorporated as a value into all business and operations systems. NNSA has commenced efforts to eventually consolidate critical management systems into one system.

The ways in which other management systems such as the Quality Assurance Program, Environmental Management System, and Integrated Safeguards and Security Management are integrated with ISM are described below. 6.3.1 Integration of Quality Assurance with ISM NNSA is committed to quality of all mission processes and the elimination of errors. Each NNSA HQ organization has a Quality Assurance Program (QAP). The QAP describes the method by which quality assurance is implemented with ISM and the overall work processes. To institutionalize programmatic aspects of integrating QAP with ISM within NNSA, the QA Roadmap effort was developed and continues to be refined. This effort coordinates QA and ISM activities between site offices, contractors, NNSA HQ, and other DOE organizations to ensure that closely linked efforts are coordinated. To further the effective integration of QA with ISM at the work activity level, NNSA developed a guidance document, “NNSA Activity Level Work Planning and Control Processes: Attributes, Best Practices and Guidance for Effective Incorporation of ISM and QA, January 2006.” This was sent to NNSA Site Office Managers by NA-10 memorandum dated January 23, 2006. The document provides attributes and best practices/guidance for effectively incorporating ISM core functions and guiding principles, and QA criteria, into activity level work planning and control processes. The attributes were drafted by NNSA Headquarters, Site Office, and contractor personnel involved in work planning and control for the various types of NNSA non-office environment work activities (e.g., construction and modification work, operations activities, research and development, maintenance). The attributes described in the document are intended to be applicable to all types of work and the workers (e.g., scientists, operators, crafts, engineers) who perform the work. Improvements in activity-level work planning and control have resulted from this effort. It is expected that further improvements to ISM systems will result as the activity-level processes are matured and integrated with improved site- and facility-level level ISM processes resulting from implementation of DOE M 450.4-1. 6.3.2 Integration of Environmental Management Systems within ISM To implement sound stewardship practices which protect the air, water, and land, NNSA HQ adheres to the responsibilities and requirements of DOE O 450.1, Environmental Protection - 29 - Program, for itself and its contractors. The Environmental Management System (EMS) is implemented to ensure environmental protection actions and measures are integrated into all work planning and performance. In fact, DOE Policy 450.4 incorporates EMS into ISM. NA-50 coordinates with the Office of Environmental Management to execute environmental legacy remediation activities to minimize the potential for human and environmental exposure to hazardous contaminants resulting from nuclear weapons research, production and lifecycle stewardship activities. NNSA HQ expects site office management to review and evaluate contractor implementation of EMS as part of reviewing the ISM program. NNSA HQ works closely with HSS to gather and analyze data regarding EMS implementation at the NNSA sites. NNSA periodically reports ES&H performance and operating experience information to NNSA senior management. NNSA HQ personnel determine the appropriate actions to assist site offices in correcting any identified weaknesses.

In response to Executive Order 13423, Strengthening Environmental, Energy, and Transportation Management, the Secretary expects DOE to exceed the goals in several areas including reduced energy intensity and greenhouse gas emissions, building efficiency, clean energy production and use, and fleet management, and to lead all major Federal agencies in overall environmental, energy, and transportation management. These initiatives are integral to implementation of EMS and ISM throughout NNSA. 6.3.3 Integration of Integrated Safeguards and Security Management with ISM Just as NNSA directs mission-related work with due consideration for safety, it also fundamentally considers security in accomplishing its work. Safety roles, responsibilities, and authorities of the Office of Defense Nuclear Security, NA-70, are described in the NNSA FRAM. The necessary elements of Integrated Safeguards and Security Management (ISSM) for NNSA HQ are described in the draft DNS FRAM, dated May 2007. Many of the core values and principles of ISM are related to those of ISSM and are reflected in both FRAM documents. NA-70 personnel are qualified using some elements of the DOE Technical Qualification Program. These elements contain many safety-related competencies. NNSA Defense Nuclear Security (NA-70) and the NNSA site offices have adopted the DOE Training Qualification Program (TQP) (or a site specific modified version of the TQP) as the standard for departmental training to ensure all technical employees involved with providing management direction or oversight that could affect the safe and secure operation of Defense Nuclear Security programs are trained and qualified. The TQP consists of General Technical Base Qualification Standard and Functional Area Base Qualification Standard. The Technical Qualification Program is divided into three levels of technical competence and qualification (familiarity, working, and expert levels). The General Technical Base Qualification Standard establishes the base technical competence required of all Department of Energy Defense Nuclear Security facility technical personnel. The Functional Areas Qualification Standards build on the requirements of the General Technical Base Qualification Standard and establish Department-wide functional competency requirements in each of the identified security functional areas. Office/facility- - 30 - specific qualification standards establish unique operational requirements at the Headquarters or Field element, site, or facility level. 7.0 Other Safety-Related Initiatives Line Oversight and Contractor Assurance System (LOCAS) Integration Council – The Council is a chartered group chaired by the Deputy for Site Operations in NA-10 to support NNSA line management. The LOCAS effort has four teams looking at different elements of improving LOCAS: • Team 1: Peer Review/CAS Implementation Plan – The team will pull together the collective wisdom on what constitutes a “good” CAS. • Team 2: Performance Measures Action Plan – The team will analyze key performance measures being used or developed in conjunction with LOCAS implementation. • Team 3: Portal Design and Implementation Action Plan – The team will examine the potential mechanisms for posting LOCAS information, develop a proposal for implementation, obtain authorization including funding, and oversee the implementation of an electronic, portal-like website or websites.

• Team 4: Policy Integration Implementation Plan – The team will ensure that Line Oversight and CAS policy and requirements are clear. NNSA Authorization Basis Senior Advisor / Continuous Learning Chair –The NNSA Administrator started this effort in 2006 to achieve confidence in the preparation, review, approval, verification, and maintenance of 10 CFR 830 nuclear facility safety bases. This function will further the NNSA Administrator’s vision by establishing centralized and dedicated leadership to promote corporate excellence and consistency across the NNSA complex, both Federal and contractor elements, in the following safety basis areas: • Personnel training, qualification, re-qualification, continuous learning, and career progression • Policy • Procedures • Implementation practices • Organizational behavior. Electrical Safety Improvement – NNSA HQ and sites have focused attention on the types and causes of occurrences involving electrical safety. A video teleconference on September 26, 2006 with all the NNSA sites and NA-1, NA-10 and others raised awareness of the unacceptably high number of electrical incidents in NNSA and shared lessons learned on local initiatives at each site that can be potentially transferred to other sites. This focused attention continues in Quarterly Safety Briefings to NNSA HQ senior managers as electrical safety occurrences and trends are reported and trends are analyzed. A DOE workshop in July 2007 furthered this focus even though an improving trend at most sites was evident. Biosurety – NNSA participates in the DOE efforts to improve biosurety. NA-3.6 chairs the DOE Biosurety Executive Team chartered by the Secretary of Energy to develop safety and security policy for DOE facilities engaged in hazardous biological research activities. - 31 - Communications from NA-1 to all of NNSA – Frequent, periodic emails are sent from the NNSA Administrator to all NNSA employees on a variety of topics, including safety. These messages communicate expectations and priorities directly to each NNSA employee and are also kept on the NNSA intranet web site. 8.0 Annual ISM System Description Maintenance and Improvement Annual NNSA HQ and Site Office ISM Effectiveness Review and Declaration – NNSA HQ and each site office performs an annual ISM effectiveness review to develop its annual ISM declaration. NA-3.6 coordinates this annual review. Guidelines for performing annual ISM effectiveness reviews are provided in DOE M 450.4-1, Integrated Safety Management System Manual. In addition, the manner and frequency with which performance is measured and reported to the NNSA CTA is part of this review. NNSA HQ annually issues a declaration report of the status of implementation of ISM, including applicable site and contractor operations. NNSA HQ must evaluate applicable NNSA HQ and Site Office activities, and applicable contractor activities; and the Site Offices must evaluate applicable Site Office activities and applicable contractor activities. NNSA HQ line management (NA-17) issues line management expectations and sets the schedule for Site Office annual ISM reviews and declarations. Annual Review of ISM System Description – The NNSA HQ ISM System Description is reviewed approximately annually and NA-3.6 communicates the results of this review to the Administrator and CTA. This review is part of the Annual ISM Effectiveness Review and Declaration. If no changes are needed to maintain ISM system description complete, accurate, and up-to-date, then no annual update is necessary. Any changes based on any identified gaps from management or self-assessments in NNSA HQ are approved by the NNSA Central Technical Authority and submitted for final approval by the Administrator. NA-3.6 coordinates this annual review.

Annual Performance Expectations and Performance Objectives – NNSA HQ provides safety performance measures and information to the NNSA CTA. This is expected to be done in accordance with Appendix A, which meets the intent of DOE M 450.4-1 to provide this type of information annually. The initial safety objectives, measures, and commitments are described in Section 4. Line Oversight of ISM Implementation – NNSA HQ performs line oversight of ISM implementation at the next lower tier, consistent with the requirements and guidance of DOE O 226.1, Implementation of Department of Energy Oversight Policy. NNSA HQ oversees implementation at the Site Office, with sampling at the contractor level, as needed based on available performance information, to evaluate the effectiveness of the Site Office. - 32 - Appendix A Reporting of NNSA Safety Management Performance Measures Performance Measure Periodicity Reported to NNSA CTA Reporting Mechanism Quarterly Safety Briefings consistently provided to the Administrator and senior NNSA managers to provide safety data Quarterly Briefing Planned CDNS reviews conducted According to CDNS schedule Written Report Planned NA-10 oversight activities conducted in accordance with oversight plan Approximately 6 months Updated oversight plan NNSA FRAM is updated as needed As Needed Updated FRAM NNSA HQ ISM effectiveness reviews occur Annually Written Report Percentage of NNSA personnel in the Technical Qualification Program fully qualified in their assigned functional area. [NNSA Goal: at least 80%] Quarterly Written Report Number of NNSA personnel in the Technical Qualification Program overdue in their qualifications. [NNSA Goal: 0] Quarterly Written Report Delegations of authority are reviewed, as necessary As Needed Written Report TRC Rate Quarterly Briefing DART Rate Quarterly Briefing ORPS Occurrences in certain focus areas, such as electrical safety and near misses Quarterly Briefing Type A & B Accident Investigations Quarterly Briefing A-1 Appendix B Initial NNSA HQ Actions to Improve Implementation of ISM Action Responsible Office Expected Completion Date Develop NNSA HQ Differing Professional Opinion Procedure for NA-3.6 and NA-2.1 NA-3.6 / NA-2.1 June 2007 - Completed Update NNSA FRAM NA-3.6 / NA-2.1 December 2007 Set schedules and expectations for Site Office annual review of ISM safety performance objectives, measures and commitments NA-17 / NA-3.6 June 2008 Review NNSA HQ ISM System Description for any needed updates NA-3.6 August 2008 Review implementation of ISM System at NNSA HQ NA-3.6 August 2008 Perform a NA-10 Gap Analysis for NNSA HQ ISM implementation NA-17 January 2008 Develop and implement mechanisms to remedy NA-10 NNSA HQ ISM Gap Analysis results NA-17 March 2008 Develop line management expectations and schedule for Site Office ISM review and declaration NA-17 June 2008 Develop PAAA Procedure NA-3.6 December 2007 Continue to improve NNSA Safety Culture based on results of oversight, management and self assessments, and annual effectiveness review NA-3.6 Ongoing B-1 2.2 Guiding Principles and Safety Culture Elements 2.3 Core Functions