SD 452.2, Nuclear Explosive Safety Evaluation Processes
This Supplemental Directive (SD) provides supplemental details to support the nuclear explosive safety (NES) evaluation requirement of Department of Energy (DOE) Order (O) 452.2D Admin Chg 1, Nuclear Explosive Safety, dated 07-10-13. This
SD is now the governing directive for NES evaluations and NES change control. It incorporates and modifies the provisions and guidance formerly promulgated in DOE M 452.2-2.
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Document text
Text extracted from the attached file. Refer to the original document for the authoritative version.
Section 1
SUPPLEMENTAL DIRECTIVE
NNSA SD 452.2
Approved: 11-17-14
Nuclear Explosive Safety
Evaluation Processes
NATIONAL NUCLEAR SECURITY ADMINISTRATION
Office of Safety and Health
CONTROLLED DOCUMENT OFFICE OF PRIMARY INTEREST (OPI):
AVAILABLE ONLINE AT: Office of Safety and Health
http://nnsa.energy.gov
printed copies are uncontrolled
http://nnsa.energy.gov/
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NNSA SD 452.2 i
11-17-14
Nuclear Explosive Safety Evaluation Processes
1. PURPOSE. This Supplemental Directive (SD) provides supplemental details to support
the nuclear explosive safety (NES) evaluation requirement of Department of Energy
(DOE) Order (O) 452.2D Admin Chg 1, Nuclear Explosive Safety, dated 07-10-13. This
SD is now the governing directive for NES evaluations and NES change control. It
incorporates and modifies the provisions and guidance formerly promulgated in DOE M
452.2-2.
2. CANCELLATION. DOE M 452.2-2 Admin Chg 1, Nuclear Explosive Safety Evaluation
Processes, dated 07-10-13, once the Department cancels DOE M 452.2-2.
3. APPLICABILITY.
a. NNSA Applicability. This Supplemental Directive applies to all Federal NNSA
entities, and to non-NNSA Federal elements that are involved on behalf of NNSA
in performing, managing, overseeing, or directly supporting nuclear explosive
operations or associated activities, including those created after the Supplemental
Directive is issued.
b. Contractors. The contractor requirements document (CRD) in Attachment 1 will
apply to the extent set forth in the contract. The CRD is intended to be applicable
to contractors with responsibilities for operation and/or management of sites or
facilities and whose responsibilities include performing, managing, overseeing, or
directly supporting nuclear explosive operations (NEOs) or associated activities.
4. SUMMARY. To ensure adequate nuclear explosive safety for nuclear explosive
operations (NEOs) conducted by the NNSA and its contractors, this Supplemental
Directive presents eight chapters detailing administrative and procedural requirements
supplementary to DOE O 452.2D, as follows:
a. Chapter I provides an introduction and establishes management responsibilities
including administration of this Supplemental Directive.
b. Chapter II provides an overview of the different forms of formal NES evaluations.
c. Chapter III sets forth requirements for the personnel performing NES evaluations.
d. Chapters IV-VI presents detailed guidance and requirements for each type of
nuclear explosive safety evaluation.
e. Chapter VII addresses how NES evaluation findings are characterized, responded
to, and formally closed.
f. Chapter VIII establishes the process for requesting and granting exemptions to the
requirements of this Supplemental Directive.
g. Attachment 1 is the Contractor Requirements Document (CRD).
11
(1)
(2)
NNSA SD 452.2
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Attaclunent 1, Appendix A specifies requirements for education,
experience, teclmical competencies, and certification of NNSA Contractor
NBS-certified personnel (NESSG members and NES representatives).
Attaclunent 1, Appendix B identifies topical areas that must be included in
NES Study input documentation.
h. Attachment 2 provides guidance and criteria to characterize issues identified in
NES evaluations and to help document the rationale for NES evaluation
conclusions.
1. Attachment 3 defines the acronyms used in this Supplemental Directive.
Section 2
5. CONTACT. The Associate Administrator for Safety and Health is responsible for
updating and maintaining this Supplemental Directive. Questions concerning this
Supplemental Directive or its implementation should be addressed to 202-586-3885.
BY ORDER OF THE ADMINISTRATOR:
J~JJ.~
Frank G. Klotz
Administrator
NNSA SD 452.2 iii
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CONTENTS
CHAPTER I ................................................................................................................................ I-1
INTRODUCTION AND RESPONSIBILITIES ...................................................................... I-1
1. INTRODUCTION ............................................................................................................. I-1
2. RESPONSIBILITIES ........................................................................................................ I-1
a. Assistant Deputy Administrator for Stockpile Management ......................................... I-1
b. Associate Administrator for Safety and Health.............................................................. I-1
c. Director, Office of Nuclear Weapon Surety and Quality ............................................... I-2
d. Director, Nuclear Explosive Safety Division ................................................................. I-2
e. Nuclear Explosive Safety Study Group Chairs .............................................................. I-3
f. NESSG Member ............................................................................................................. I-4
g. NNSA Field Element Managers Responsible for NEOs ................................................ I-4
h. Assistant Deputy Administrator for Secure Transportation. .......................................... I-5
i. NNSA Production Agencies........................................................................................... I-5
j. NNSA Design Agencies ................................................................................................. I-6
k. NNSA Project Team Leads. ........................................................................................... I-6
l. Senior Technical Advisors. ............................................................................................ I-7
CHAPTER II ............................................................................................................................. II-1
NUCLEAR EXPLOSIVE SAFETY EVALUATION OVERVIEW .................................... II-1
1. NES EVALUATION TYPES AND TIMING ..................................................................II-1
a. Nuclear Explosive Safety Studies .................................................................................II-3
b. Operational Safety Reviews ..........................................................................................II-4
c. Contractor NES Change Evaluations ............................................................................II-5
d. Office of Secure Transportation NES Screens ..............................................................II-5
e. NES Change Evaluations ..............................................................................................II-5
Section 3
2. SECURITY OPERATIONS .............................................................................................II-6
3. URGENT NES CONCERNS ............................................................................................II-6
4. NES EVALUATION SCHEDULES ................................................................................II-6
5. PROCESS DEVIATIONS ................................................................................................II-6
6. RECORDS ........................................................................................................................II-7
CHAPTER III ..........................................................................................................................III-1
NUCLEAR EXPLOSIVE SAFETY EVALUATION PERSONNEL .................................III-1
1. INTRODUCTION .......................................................................................................... III-1
2. NESSG QUALIFICATIONS .......................................................................................... III-1
a. Personal Characteristics .............................................................................................. III-1
b. Training ....................................................................................................................... III-2
c. Independence ............................................................................................................... III-2
d. Certification ................................................................................................................. III-3
3. NESSG FORMATION ................................................................................................... III-4
4. NESSG COMPOSITION ................................................................................................ III-4
5. TECHNICAL ADVISORS (TAS). .................................................................................. III-4
6. NNSA CONTRACTOR NES REPRESENTATIVES .................................................... III-4
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CHAPTER IV........................................................................................................................... IV-1
NUCLEAR EXPLOSIVE SAFETY STUDY PROCESS ..................................................... IV-1
1. INTRODUCTION .......................................................................................................... IV-1
2. NESS PLANNING MEETINGS ..................................................................................... IV-1
3. NESS INPUT DOCUMENTATION .............................................................................. IV-1
4. USE OF SAFETY BASIS DOCUMENTATION ........................................................... IV-2
5. NESSG PREPARATION ................................................................................................ IV-2
a. Study-specific NESSG Training ................................................................................. IV-2
b. Input Documentation Delivery .................................................................................... IV-3
c. Orientation Meeting .................................................................................................... IV-3
d. NESSG Final Preparation............................................................................................ IV-3
Section 4
6. NESS PREREQUISITES ................................................................................................ IV-4
7. NESS CONDUCT ........................................................................................................... IV-4
a. Briefings ...................................................................................................................... IV-5
b. Demonstrations............................................................................................................ IV-5
c. Deliberations ............................................................................................................... IV-5
d. Report Generation and Concurrence ........................................................................... IV-7
8. STA COMMENTS.......................................................................................................... IV-9
9. FEEDBACK ................................................................................................................... IV-9
10. NESS VALIDATION ................................................................................................... IV-10
11. NESS POST-EVALUATION PROCESS ..................................................................... IV-10
CHAPTER V ............................................................................................................................. V-1
OPERATIONAL SAFETY REVIEW PROCESS ................................................................. V-1
1. INTRODUCTION ........................................................................................................... V-1
2. OSR PLANNING ............................................................................................................. V-1
3. OSR SUPPORTING DOCUMENTATION .................................................................... V-2
4. OSR PREPARATION ..................................................................................................... V-3
5. OSR CONDUCT .............................................................................................................. V-3
a. Briefings ....................................................................................................................... V-4
b. Observations ................................................................................................................. V-4
c. Issue Resolution ........................................................................................................... V-4
d. Deliberations ................................................................................................................ V-4
e. Report Generation and Concurrence ............................................................................ V-4
6. STA COMMENTS........................................................................................................... V-5
7. FEEDBACK .................................................................................................................... V-6
8. OSR POST-EVALUATION PROCESS .......................................................................... V-6
CHAPTER VI........................................................................................................................... VI-1
NUCLEAR EXPLOSIVE SAFETY CHANGE CONTROL PROCESSES ....................... VI-1
1. INTRODUCTION .......................................................................................................... VI-1
2. ORGANIZATIONAL CHANGE CONTROL ASSESSMENTS ................................... VI-1
Section 5
a. Focus ........................................................................................................................... VI-2
b. Documentation ............................................................................................................ VI-2
c. Determination Processes ............................................................................................. VI-2
NNSA SD 452.2 v
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d. Determination Outcomes............................................................................................. VI-4
3. EMERGING INFORMATION EVALUATION REQUESTS ....................................... VI-5
4. NESSG CHANGE EVALUATIONS ............................................................................. VI-5
CHAPTER VII ....................................................................................................................... VII-1
NUCLEAR EXPLOSIVE SAFETY EVALUATION FINDINGS .................................... VII-1
1. FINDINGS AND DELIBERATION TOPICS ............................................................... VII-1
2. RESPONSE TO FINDINGS. ......................................................................................... VII-2
3. DISTRIBUTION OF FINDING DISPOSITION CORRESPONDENCE ..................... VII-6
4. FINDING CLOSURE PROCESS .................................................................................. VII-6
5. STATUS REPORTS ...................................................................................................... VII-6
6. CLOSURE APPROVAL ............................................................................................... VII-7
CHAPTER VIII .................................................................................................................... VIII-1
EXEMPTIONS ...................................................................................................................... VIII-1
ATTACHEMNT 1 -CONTRACTOR REQUIREMENTS DOCUMENT............................ 1-1
APPENDIX A - NNSA CONTRACTOR NESSG MEMBER AND NES
REPRESENTATIVE QUALIFICATION REQUIREMENTS ............................................ A-1
APPENDIX B - NESS INPUT DOCUMENTATION ............................................................B-1
ATTACHMENT 2 - CRITERIA FOR CATEGORIZING ISSUES FROM NUCLEAR
EXPLOSIVE SAFETY EVALUATIONS ............................................................................... 2-1
ATTACHMENT 3 - ACRONYMS AND ORGANIZATIONAL DESIGNATIONS .......... 3-1
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NNSA SD 452.2 I-1
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CHAPTER I
INTRODUCTION AND RESPONSIBILITIES
1. INTRODUCTION. The evaluations described in this Supplemental Directive comprise a
formalized approach to ensuring the nuclear explosive safety (NES) of all nuclear
explosive operations (NEOs) performed by the National Nuclear Security Administration
(NNSA) and its contractors. This approach requires that all new, approved, current, and
proposed changes to NEOs and associated supporting infrastructure receive a
commensurate level of review and analysis.
2. RESPONSIBILITIES.
a. Assistant Deputy Administrator for Stockpile Management.
(1) Ensures the process for addressing NES findings defined in Chapter VII of
this Supplemental Directive is followed.
(2) Approves/disapproves extensions to the requirement for ten-year NESS
reevaluations of ongoing operations in coordination with the Associate
Administrator for Safety and Health. This authority may not be delegated
below the Assistant Deputy Administrator or Acting Assistant Deputy
Administrator level.
Section 6
(3) Approves exemptions to this Supplemental Directive, with concurrence
from the Central Technical Authority (CTA).
(4) As appropriate, tasks action agencies to take corrective action for NESSG
findings.
Note: Action agencies are the organization (NNSA or contractor) designated by
NNSA management as the proper organization to appropriately take action
on an issue raised by the NESSG or Senior Technical Advisors.
(5) Provides NNSA management of Project Teams assembled to plan,
prepare, and present input documentation, briefings, and demonstrations
for production agency NES evaluations.
(6) Considers the criteria in Attachment 2 when developing the Office’s
position on findings and minority opinions from NES evaluation reports.
(7) Provides funding for the Senior Technical Advisors (STAs).
b. Associate Administrator for Safety and Health.
(1) Coordinates with the Assistant Deputy Administrator for Stockpile
Management on extensions to the requirement for ten-year NESS
reevaluations of ongoing NEOs.
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(2) Selects, ensures the hiring/contracting of, releases funds, and certifies an
appropriate number of Nuclear Explosive Safety Study Group (NESSG)
STAs.
(3) Provides for a periodic (approximately annual) review of the STA
comments and any follow-up actions.
(4) Updates and maintains this Supplemental Directive.
c. Director, Office of Nuclear Weapon Surety and Quality. Approves/disapproves
deviations from NES evaluation process requirements as assigned in this
Supplemental Directive.
d. Director, Nuclear Explosive Safety Division.
(1) Ensures any applicable NES Division internal operating procedures are
consistent with this supplemental directive.
(2) Recruits NESSG STAs and recommends selections to the Associate
Administrator for Safety and Health.
(3) Receives, reviews, and accepts or rejects the certifications for NESSG
members.
(4) Ensures that NES training courses are identified and developed as needed.
(5) Ensures the training and certification currency of an appropriate number of
NESSG chairs to meet workload and schedule demands.
(6) Ensures that NESSG STAs receive the NES training required for
certification.
(7) Provides periodic NES evaluation schedule updates to organizations
providing NESSG personnel.
(8) Selects a NESSG chair for each NES evaluation.
(9) Provides NES oversight of the closure process for NES evaluation
findings through periodic audit (sampling) of closure packages approved
by the closure authority.
(10) Tracks the scheduling of NES evaluations for ongoing NEOs to ensure
NESSs and OSRs are performed in the timeframes specified in Chapter II.
(11) Maintains an accounting of the topics covered by each NESS and OSR,
and works with NNSA and contractor line management to schedule OSRs.
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(12) Monitors NEO restart activities to determine the form of NES evaluation
needed to support the restart authorization.
(13) Maintains a file copy of the Single Integrated Input Document until the
NESS is superseded or otherwise no longer relevant.
e. Nuclear Explosive Safety Study Group Chairs.
(1) Satisfy responsibilities of NESSG members in paragraph 2f below.
(2) Review nominations and approve NESSG personnel for NES evaluations.
(3) Verify that NESSG personnel certifications will be current at the start of a
NES evaluation and ensure that NESSG personnel certifications remain
current during the course of an evaluation.
Section 7
(4) Conduct OSR planning meetings and coordinate OSR schedule with the
Project Team as applicable.
(5) Determine the need for and ensure the conduct of NES Change Evaluation
(NCE) planning meetings, as appropriate.
(6) Recruit technical advisors (TAs) to participate in NES evaluations, as
needed.
(7) Coordinate with the Project Team and/or NNSA line management as
appropriate to plan and schedule NES evaluations.
(8) Organize, convene, and lead NES evaluations.
(9) Suspend a NES evaluation if unable to fulfill the requirements of this
Supplemental Directive.
(10) Ensure NESSGs use the guidance and criteria in Attachment 2 to
characterize NES evaluation findings and to document rationale.
(11) Coordinate substantive changes to NESS and OSR reports and NCE
memoranda with participating NESSG personnel and retain associated
documentation.
(12) Forward final copies of NESS and OSR reports, NCE memoranda, and
associated correspondence to participating NESSG personnel and
appropriate organizations as described in this Supplemental Directive.
I-4 NNSA SD 452.2
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f. NESSG Member.
(1) Prepares for the NES evaluation by reading the input documentation,
attending training and orientation meetings, developing lines of inquiry,
and researching issues as needed.
(2) Attends briefings and demonstrations (or NEO observations), and
critically evaluates the information presented or observed to ensure that
evaluated NEOs (including proposed changes or responses to emerging
information affecting an approved NEO) meet the NES Standards and
other NES criteria.
(3) Participates in NESSG deliberations, including, examining all sides of
NES issues, resolving lines of inquiry, and developing findings and
deliberation topics, as appropriate.
(4) Uses the criteria in Attachment 2 when deliberating, categorizing, and
documenting issues in NES evaluations.
(5) Contributes to the report writing and signs the report indicating approval
of report content (except as noted in any minority opinions).
g. NNSA Field Element Managers Responsible for NEOs.
(1) Ensure that all NEOs under their purview are covered by a current NES
evaluation.
(2) Participate in NES evaluation planning meetings as applicable.
(3) Provide a formal request to the Director, Nuclear Explosive Safety
Division to proceed with NES evaluations.
(4) Ensure that NESSGs have adequate administrative and logistical
resources.
(5) Follow the process defined in Chapter VII of the Supplemental Directive
for responding to NES findings.
(6) Consider the criteria in Attachment 2 when developing a position on
findings and minority opinions from NES evaluations.
(7) Task action agencies under their cognizance to take corrective action for
NESSG findings.
(8) Ensure a process is established for tracking and closing NES evaluation
findings.
(9) Approve/disapprove closure of NES evaluation findings.
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(10) Ensure the training of and certify NNSA Field Element NESSG members.
h. Assistant Deputy Administrator for Secure Transportation.
(1) Ensures that all NEOs under Office of Secure Transportation (OST)
purview are covered by a current NES evaluation and requests NES
evaluations as needed.
(2) Provides NNSA management of Project Teams assembled to plan,
prepare, and present input documentation, briefings, and demonstrations
for NES evaluations of OST operations.
(3) Provides input, briefings, and demonstrations as required and certifies the
completeness and accuracy of the information.
Section 8
(4) Ensures that NESSGs have adequate administrative and logistical
resources.
(5) Provides a formal request to the Director, Nuclear Explosive Safety
Division to proceed with NES evaluations.
(6) Considers the criteria in Attachment 2 when developing a position on
findings and minority opinions from NES evaluation reports.
(7) Establishes a process for tracking and closure of NES evaluation findings.
(8) Approves/disapproves closure of NES evaluation findings.
(9) Establishes a process for approving and implementing Assistant Deputy
Administrator for Secure Transportation allowable changes.
(10) Establishes and maintains auditable records of OST NES screens, NCE
determinations, and approval of Assistant Deputy Administrator for
Secure Transportation allowable changes.
(11) Provides NNSA management of Project Teams assembled to plan,
prepare, and present input documentation, briefings, and demonstrations
for operation-specific NES evaluations.
i. NNSA Production Agencies. (This information is provided here for reference
only – actual contractor responsibilities are found in Attachment 1)
(1) Ensure the training of and certify contractor NESSG members.
(2) Nominate and provide TAs to support NES evaluations, as needed.
(3) Provide input, briefings, and demonstrations as required and certify the
completeness and accuracy of the information.
I-6 NNSA SD 452.2
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(4) Lead the development of safety supporting documentation for NES
evaluations and ensure the completeness of the information.
(5) Identify, train, and certify independent NES representatives to perform
Contractor NES Change Evaluations (CNCE).
(6) Prepare change packages and initiate the NEO change control process for
proposed changes to authorized NEOs.
(7) Conduct CNCEs.
(8) Establish and maintain auditable records of CNCE determinations and
approval of contractor-allowable changes.
(9) Establish a process for approving and implementing contractor-allowable
changes.
(10) Take appropriate action on NES evaluation findings.
j. NNSA Design Agencies. (This information is provided here for reference only –
actual contractor responsibilities are found in Attachment 1)
(1) Ensure the training of and certify design agency NESSG members.
(2) Nominate and provide TAs as requested by NESSG chair to support NES
evaluations.
(3) Provide input, briefings, and demonstrations as required and certify the
completeness and accuracy of the information.
(4) Take appropriate action on NES evaluation findings.
(5) Inform NNSA and NNSA Production Agency contractor via the
Information Engineering Release (IER) process of actionable information
that has the potential to adversely impact NES for approved NEOs.
k. NNSA Project Team Leads.
(1) Implement the necessary tooling, processes, and procedures to ensure that
the proposed NEO (including proposed changes or responses to emerging
information affecting an approved NEO) meets the NES Standards and
other NES criteria.
(2) Conduct NESS planning meetings and document and distribute planning
meeting results.
(3) Ensure explicit certification of the technical accuracy and completeness of
NES evaluation input documentation.
NNSA SD 452.2 I-7
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(4) Submit to the NNSA Field Element or OST, as applicable, a formal
declaration of readiness to proceed with a NES evaluation based in part on
their judgment that the operation presented for NES evaluation meets the
NES Standards and other NES criteria.
Section 9
(5) Manage study preparation, including input documentation, briefings, and
demonstrations for topics brought to a formal NES evaluation.
(6) Ensure the presentation of all relevant information from all available
sources relating to the proposed change or response to emerging
information. In cases where there is a conflict in the technical opinion,
present all sides of the issue for the NESSG to deliberate.
(7) Maintain involvement in all programmatic NES evaluations (NESSs,
OSRs, and NCEs) to ensure the NESSG is provided timely accurate and
complete information to ensure effective NESSG deliberations.
l. Senior Technical Advisors.
(1) Support the independent oversight function of the Associate Administrator
for Safety and Health.
(2) Stimulate a more basic and complete consideration of NES for proposed
operations by the Project Teams.
(3) Suggest to senior NNSA management opportunities for improvement in
the NES evaluation process.
(4) Prepares for the NES evaluation by reading the input documentation,
attending training and orientation meetings, developing lines of inquiry,
and researching issues as needed.
(5) Attends briefings and demonstrations (or NEO observations), and
critically evaluates the information presented or observed.
(6) Participates in NESSG deliberations, including, examining all sides of
NES issues, resolving lines of inquiry, and developing findings and
deliberation topics, as appropriate.
(7) Uses the criteria in Attachment 2 when deliberating, categorizing, and
documenting issues in NES evaluations.
(8) Contributes to the report writing.
(9) Documents any STA comments to be included in the report.
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NNSA SD 452.2 II-1
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CHAPTER II
NUCLEAR EXPLOSIVE SAFETY EVALUATION OVERVIEW
1. NES EVALUATION TYPES AND TIMING. NES evaluations qualitatively assess the
adequacy of positive measures in meeting the DOE NES Standards and other NES
criteria specified in the DOE 452-series orders. The focus of a NES evaluation is the
NEO and supporting procedures, facilities, equipment, people, and management systems.
NES evaluations must be conducted a) before an NEO is authorized; b) periodically for
ongoing NEOs; and c) when proposed changes or emerging information—for example,
discovery of anomalous conditions—could potentially affect an approved NEO. NES
evaluations are initiated on request from the responsible NNSA line management and rely
on descriptive documentation and analyses performed by others, as well as direct
observations of simulated or actual NEOs and associated facilities, equipment, tooling,
and management programs.
The five kinds of formal NES evaluation are NESSs, OSRs, and NCEs, which are
performed by a NESSG; CNCEs conducted by qualified NNSA management and
operating (M&O) contractor NES representatives; and OST NES screens performed by
OST staff.
Section 10
Proposed new or significantly modified operations, support facilities, and processes must
be evaluated by a NESS. Approved NEOs are subject to periodic reevaluation in the
form of either a NESS or OSRs. Ongoing operations must be reevaluated using the
NESS process at intervals as described below. OSRs are required evaluations that must
occur at approximately the midpoint between NES evaluations. OSRs are targeted for the
period between three and seven years after the associated NESS and may be divided into
segments (e.g. assembly and disassembly) to facilitate the evaluation. The OSR(s) may
start as early as the second anniversary of the NESS report and must be completed by the
seventh anniversary of the NESS report. See Figures 1 and 2 below. The Director of the
Nuclear Explosive Safety Division and the NESSG chair determine OSR scope, duration,
and schedule based upon information provided by the Project Team. The Director of the
Nuclear Explosive Safety Division is responsible to ensure OSRs are scheduled
appropriately. However, if the OSR process has not been completed by the seven-year
anniversary of the NESS report, an OSR must be performed for that portion of the
operation at the next occurrence of the affected operations unless the operation is deemed
to be lapsed. If the operation has been deemed as lapsed, the NESS for the portion of the
operation deemed as lapsed is no longer valid and a NESS must be completed before the
operation can be re-started. The OSR process is outlined in Chapter V.
The NES Master Study (as described below) must be conducted every five years with the
same time constraints as for a NESS (i.e. Master Study must start no later than 120 days
before the five-year anniversary date and must be completed no later than one year after
the anniversary date).
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Figure 1 Timeline for NESS/OSR Process
Figure 2 Timeline for NES Master Study Process
The next NESS for an ongoing operation must begin within ten calendar years of the date
the report for the previous NESS was signed by the NESSG Chair, unless an extension to
the ten-year requirement is approved by the Assistant Deputy Administrator for Stockpile
Management. The study must be completed no later than eleven years following the
NESS report date. For purposes of establishing the timeline for periodic reevaluation of
ongoing operations, a NESS is considered to begin at the first meeting of the entire
NESSG (study-specific NESSG training or orientation meeting as described in Chapter
IV paragraph 5). A NESS is considered complete when the NESSG Chair signs
(approves) the final report. The ten-year period means ten calendar years.
If a NEO is not operating at the end of the ten years, the NESS may be, but does not have
to be, performed at that time. However, a NESS must be completed and findings where a
NES Standard is not met must be closed before the NEO may restart.
For ongoing operations, if a NESS has not begun by 120 days before the ten year
anniversary of the date the NESSG Chair signed the previous NESS report, the
responsible NNSA Field Element Manager or Assistant Deputy Administrator for Secure
Transportation, as applicable, must notify the Assistant Deputy Administrator for
Stockpile Management and the Associate Administrator for Safety and Health in writing,
with a copy to the Director, Office of Nuclear Weapon Stockpile; Director, Office of
Nuclear Weapon Surety and Quality; and Director, Nuclear Explosive Safety Division,
no later than 90 days before the ten year anniversary and either request an extension or
indicate the date by which the NESS will begin. If an extension is not requested, the date
for beginning the NESS must be before the ten-year anniversary of the date the NESSG
Chair signed the previous NESS report.
Section 11
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Extension requests must include:
• Reference to the NESS for which the extension is requested.
• Summary of associated OSR/NCE history and results.
• A compelling reason for the extension.
• The rescheduled date for conducting the NESS.
• Other pertinent data or information used as a basis for the extension request.
• Identification of any additional risks that will be incurred if the extension is
granted.
• Relevant information from the open findings status reports, as detailed in Chapter
VII, paragraph 4.
To grant a NESS extension, the Assistant Deputy Administrator for Stockpile
Management must establish that it is warranted under the circumstances specified and
would not present an undue risk. The Assistant Deputy Administrator for Stockpile
Management must document the reason for approving, including as appropriate
conditions of approval, or denying the extension in correspondence that includes
• The requester.
• Associate Administrator for Safety and Health.
• Director, Office of Nuclear Weapon Stockpile.
• Director, Office of Nuclear Weapon Surety and Quality.
• Director, Nuclear Explosive Safety Division.
For ongoing operations, if a NESS is not begun by the ten year anniversary of the date
when the NESSG Chair signed the previous NESS, or within the period granted by
extension(s), or completed by the eleventh year (plus extensions), affected NEOs must be
suspended until an extension is approved or the NESS is completed.
Proposed changes to approved NEOs and emerging information with the potential to
impact NES are the impetus for CNCEs, OST NES screens and, in turn, sometimes to an
NCE or NESS as detailed in Chapter VI of this Supplemental Directive.
The following is an overview of each kind of NES evaluation. Detailed guidance is
provided in Chapters IV-VI of this Supplemental Directive.
a. Nuclear Explosive Safety Studies. All NEOs must be supported by a
preoperational NESS, or set of relevant NESSs, approved before operations can
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begin. A NESS may also be used to evaluate proposed changes, emerging
information or for periodic reevaluation in lieu of OSRs in accordance with the
provisions of Chapter V, paragraph 2.
(1) There are two kinds of NESSs.
(a) Operation-specific studies evaluate proposed NEOs and interfaces
with applicable Master Studies and other programs, procedures,
and processes relevant to NES not addressed in a Master Study, to
determine if there are gaps or weaknesses in the positive measures
needed to meet the NES Standards and other NES criteria.
(b) Master Studies (MS) evaluate facilities, equipment, processes, and
management programs that may be common to multiple NEOs to
determine if they are adequately characterized and controlled to
support future evaluation of their use in operation-specific NEOs.
Because a Master Study is not NEO-specific, definitive statements
regarding satisfaction of the NES Standards may not be possible.
(2) An operation-specific study or Master Study, as appropriate, must be
performed—
(a) for the startup of a NEO facility;
(b) for all proposed NEOs;
(c) when jointly determined to be necessary by the NNSA Field
Element Manager or Assistant Deputy Administrator for Secure
Transportation, as applicable, and the Director, Nuclear Explosive
Safety Division;
(d) when the NNSA Field Element Manager or Assistant Deputy
Administrator for Secure Transportation, as applicable, and the
Director, Nuclear Explosive Safety Division do not agree whether
an NCE or a NESS is appropriate for a proposed process change;
and
Section 12
(e) in accordance with the NESS-OSR evaluation cycle detailed
above.
Detailed requirements for planning and performing a NESS are presented in
Chapter IV.
b. Operational Safety Reviews. OSRs are a form of periodic NES evaluation for
ongoing NEOs with a current NESS. The NESSG applies current criteria,
documentation, and other information to previously NESSG evaluated and
approved NEOs, facilities, and programs. OSRs differ from NESSs in that they
NNSA SD 452.2 II-5
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rely on observations of actual NEOs rather than simulations, and on approved
current documentation that describes the NEO and its safety case.
OSRs evaluate authorized, ongoing NEOs to determine if there are gaps or
weaknesses in the positive measures needed to meet the NES Standards and other
NES criteria. NES Master Studies are not eligible for an OSR evaluation.
Detailed requirements for planning and performing an OSR are presented in
Chapter V.
c. Contractor NES Change Evaluations. CNCEs are performed by the production
agency to assess proposed changes to approved NEOs. The scope is generally
limited to aspects of the operations, activities, or programs affected by the
proposed change or emerging information that has the potential to impact NES.
Qualified NNSA M&O contractor NES representatives evaluate proposed
changes and emerging information with the potential to impact NES against the
criteria detailed in Chapter VI, paragraph 2c(1). Contractor NES representatives
determine if the NES implications of the circumstances allow for contractor
approval or if the issue must be elevated to an NCE or appropriately-scoped
NESS.
The CNCE process is detailed in Chapter VI.
d. Office of Secure Transportation NES Screens. OST NES Screens are conducted
by OST personnel to evaluate proposed changes or emerging information for the
potential to impact NES. In the absence of NES personnel certified in accordance
with the requirements detailed in Chapter III, designated OST staff utilize
screening criteria set forth in OST 46XA, Offsite Transportation Safety Manual,
Chapter 2.2, Appendix G to determine if the circumstances allow for Assistant
Deputy Administrator for Secure Transportation approval or if the issue must be
elevated to an NCE or appropriately-scoped NESS.
The OST NES screen process is detailed in Chapter VI.
e. NES Change Evaluations. NCEs are performed to determine if approved NEOs
will continue to meet the DOE NES Standards and other NES criteria after
implementation of a proposed change or response to emerging information.
Emerging information may include, but is not limited to, new information that
may affect the basis for prior NES evaluation conclusions, as-found conditions
that have impact beyond the scope of an ongoing evaluation, and discovery
conditions that are not bound by a currently approved NES evaluation (e.g.,
anomalous condition).
The scope of an NCE is generally limited to aspects of operations, activities, or
programs affected by the proposed change or emerging information that has the
potential to impact NES. A NESSG is convened to perform an NCE when:
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(1) The change control process determines that the circumstances do not
satisfy the criteria detailed in Chapter VI, paragraph 2c for a contractor-
allowable change, or OST 46XA, Offsite Transportation Safety Manual,
Chapter 2.2, Appendix G for an OST-allowable change, or
Section 13
(2) Requested by the Director, Nuclear Explosive Safety Division in
conjunction with the responsible NNSA Field Element Manager or
Assistant Deputy Administrator for Secure Transportation, as applicable.
and
(3) The proposed change or emerging information does not require a NESS.
The decision to perform a NESS or NCE is made by the Director, Nuclear
Explosive Safety Division in conjunction with the responsible NNSA
Field Element Manager or Assistant Deputy Administrator for Secure
Transportation, as applicable. If an agreement cannot be reached, then a
NESS must be performed.
For significant changes to a large portion of the process, such as the introduction
of a significant number of new specialized tooling throughout the process or the
introduction of new Category 1 electrical equipment, which has never before been
authorized for any nuclear explosive operation, a NESS, rather than a NCE,
should be performed.
Detailed requirements for planning and performing an NCE are presented in
Chapter VI.
2. SECURITY OPERATIONS. NES evaluations must, as appropriate, include
consideration of security operations and the potential adverse impact on NES. The
NESSG does not evaluate the overall adequacy of security measures for preventing
unauthorized access to nuclear explosives.
3. URGENT NES CONCERNS. If a NESSG considers any NES concern to require urgent
attention, the NESSG chair must promptly inform NNSA line management.
4. NES EVALUATION SCHEDULES. The Director, Nuclear Explosive Safety Division
must provide periodic schedule updates to NESSG member organizations.
5. PROCESS DEVIATIONS. Unless otherwise specified in this Supplemental Directive,
the Director, Office of Nuclear Weapon Surety and Quality is the approval authority for
administrative and procedural deviations to Chapters III – VI, the NES evaluation
process. Deviation requests must be submitted to Director, Office of Nuclear Weapon
Surety and Quality for approval as far as possible in advance of the need for the deviation
with a copy to the Associate Administrator for Safety and Health and any organization
affected by the decision. Deviations to Chapter III must be concurred with by the
Associate Administrator for Safety and Health.
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Deviation requests must include:
a. Reference to the requirement for which the deviation is requested.
b. A compelling reason for the deviation.
c. Benefits to be realized through the deviation.
d. A statement indicating whether the deviation sought is permanent or, if
temporary, when compliance will be achieved.
e. Other pertinent data or information used as a basis for requesting a deviation.
f. A description of alternative or mitigating action that has been or will be taken.
To grant a deviation, the Director, Office of Nuclear Weapon Surety and Quality must
establish that it does not present an undue risk and is warranted under the circumstances
specified. The Director, Office of Nuclear Weapon Surety and Quality must document
the reason for approving, including as appropriate conditions of approval, or denying the
process deviation in correspondence that includes the requester; the Director, Nuclear
Explosive Safety Division; the Associate Administrator for Safety and Health; and any
organization affected by the decision.
6. RECORDS. Maintain records according to National Archives and Records
Administration (NARA)-approved DOE Records Schedules.
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Section 14
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CHAPTER III
NUCLEAR EXPLOSIVE SAFETY EVALUATION PERSONNEL
1. INTRODUCTION. NESSGs include the NESSG chair, other voting NESSG members,
technical advisors, and Senior Technical Advisors (STAs), as appropriate.
NESSG chairs must be NNSA federal employees who meet the requirements of this
Chapter and DOE-STD-1185, Nuclear Explosive Safety Study Functional Area
Qualification Standard. Other NESSG members must be (a) NNSA federal employees
who meet the requirements of this Chapter and DOE-STD-1185; or (b) NNSA
management and operating (M&O) contractor employees who meet the requirements of
this Chapter and Attachment 1, Appendix A, and who are advising on matters related to
their contracts with NNSA.
Senior Technical Advisors (STAs) are persons who are acting as individual consultants.
STAs are preferred to be recruited from outside the NES community (i.e. former NESSG
members) to reinforce the independence and diversity of NESSGs. Recognized, senior-
level, science, engineering, and management experts are preferred. Experience in, for
example, safety evaluations, panels assessing high-consequence operations, and peer
reviews is considered valuable. STAs support the independent oversight function of the
Associate Administrator for Safety and Health, and are expected to stimulate a more
basic and complete consideration of NES for proposed operations by the Project Teams,
and to suggest to senior NNSA management opportunities for improvement in the NES
evaluation process.
2. NESSG QUALIFICATIONS.
a. Personal Characteristics. NESSG personnel must—
(1) bring reasoned judgment to NES evaluations;
(2) have the ability and willingness to question and challenge NNSA line
management safety statements and rationale for issues with the potential to
impact NES;
(3) be able and willing to actively participate as part of a team and to take
unpopular stands when warranted;
(4) have the ability to—
(a) develop appropriate NES evaluation approaches; contribute to
effective planning meeting decisions;
(b) critically assess input documentation, briefings, and
demonstrations;
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(c) develop and pursue relevant lines of inquiry; articulate NES
concerns;
(d) develop appropriate feedback; and
(5) have oral communication skills to participate effectively in deliberations
and written communication skills to clearly document conclusions.
b. Training. The Director, Nuclear Explosive Safety Division must ensure that NES
training courses are identified and developed to enable NESSG personnel and
personnel-in-training to meet and maintain the requirements for NESSG
personnel certification.
(1) NESSG Chairs. The Director, Nuclear Explosive Safety Division must
establish a training program ensuring that NESSG chairs achieve and
maintain the proficiencies needed to meet the requirements of DOE-STD-
1185. The Director, Nuclear Explosive Safety Division must also ensure
that a process exists for experienced NESSG chairs to convey useful
knowledge to less experienced NESSG chairs.
(2) Other Members.
(a) NNSA Federal Employees. NNSA Federal organizations
providing NESSG members must ensure their members receive the
training required to achieve and maintain the proficiencies needed
to meet the requirements of this Supplemental Directive and DOE-
STD-1185.
(b) NNSA M&O Contractors. NNSA M&O Contractors providing
employees to serve as NESSG members ensure their members
receive the training required to achieve and maintain the
proficiencies needed to meet the requirements in Attachment 1,
Appendix A.
Section 15
(3) STAs. The Director, Nuclear Explosive Safety Division, using the
national laboratories and other providers, as appropriate, must ensure
STAs receive general orientation training on nuclear explosive operations,
NES, the NES evaluation process, U.S. nuclear explosives, and other
topics as needed for certification before assignment to a NESSG.
c. Independence. The NESSG must make objective, independent judgments
regarding the NES adequacy of systems, operations, and processes. NESSG
personnel must not be subject to management influence in performing their NES
obligations, and must not—
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(1) have current responsibility for the design, development, production, or
testing of the specific nuclear explosive, NEO, facility, or management
system under evaluation;
(2) have responsibility for advocacy of special interests of any organization,
or for defending a specific nuclear explosive, NEO, facility, or
management system under evaluation; or
(3) participate in the preparation of NESS input technical documentation,
OSR supporting documentation, NCE input, or the preparation or
presentation of briefings or demonstrations.
d. Certification. Certification authorities differ for each type of NESSG participant.
(1) NESSG chairs. The Director, Nuclear Explosive Safety Division certifies
NESSG chairs based on satisfaction of the requirements for personal
characteristics, training, and independence (paragraphs 2a -2c, above) and
the requirements for education, experience, technical competencies, and
proficiency activities established in DOE-STD-1185. Certification is
documented by a certification letter retained by the Director, Nuclear
Explosive Safety Division and is valid for two years.
(2) Other Members. The Assistant Deputy Administrator for Stockpile
Management, NNSA Field Element Manager, Laboratory Directors, and
NNSA M&O contractor managers, as appropriate, designate certification
authorities who can objectively judge whether their NESSG members
meet the requirements established in this Supplemental Directive.
Certification is documented by a certification letter to the Director,
Nuclear Explosive Safety Division and is valid for two years.
(a) NNSA Federal Employees. NNSA Federal organization
certification authorities must certify each of their NESSG members
based on satisfaction of the requirements for personal
characteristics, training, and independence (paragraphs 2a - 2c,
above) and the requirements for education, experience, technical
competencies, and proficiency activities established in DOE-STD-
1185.
(b) NNSA M&O Contractors. NNSA M&O Contractors providing
employees to serve as NESSG members certify each of their
NESSG members based on satisfaction of the requirements for
personal characteristics, training, and independence (paragraphs 2a
-2c, above) and the requirements for education, experience,
technical competencies, and proficiency activities in Attachment 1,
Appendix A.
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(3) STAs. The Associate Administrator for Safety and Health certifies STAs
based on satisfactory completion of the required NES training and
requirements set forth in this Chapter. Certification is documented in a
certification letter to the Director, Nuclear Explosive Safety Division.
STA certifications have no expiration date. Prior certifications made by
other than the Associate Administrator for Safety and Health remain valid.
Section 16
3. NESSG FORMATION. The NESSG chair for each NES evaluation is assigned by the
Director, Nuclear Explosive Safety Division. Organizations providing NESSG members
nominate personnel for each NES evaluation as requested by the NESSG chair. The
NESSG chair selects NESSG personnel for each NES evaluation and verifies that
NESSG personnel certifications will be current at the start of the evaluation. NESSG
personnel should not be changed for the duration of a specific NES evaluation.
4. NESSG COMPOSITION. NESSG composition must meet the minimum staffing
requirements specified in Table 1. The NESSG chair may recruit additional members or
participants, including TAs or Field Element personnel, as deemed appropriate.
TABLE 1. NESSG COMPOSITION FOR NNSA NES EVALUATIONS
Providing Organization NESS OSR NCE
Nuclear Explosive Safety Division 1 NESSG chair 1 NESSG chair 1 NESSG chair
Office of Safety and Health 2 STAs 1 STA -
Los Alamos National Laboratory 1 1
1 Lawrence Livermore National
Laboratory 1 1
Sandia National Laboratories 1 1
Pantex Plant M&O 1 (Pantex
evaluations)
1 (Pantex
evaluations)
1 (Pantex
evaluations)
Nevada National Security Site
(NNSS) M&O
1 (NNSS
evaluations)
1 (NNSS
evaluations)
1 (NNSS
evaluations)
5. TECHNICAL ADVISORS (TAs). NESSG chairs must consider the use of TAs to
contribute specific expertise to NES evaluations. Based on the scope and complexity of
the NES evaluation being performed, the NESSG chair may recruit one or more TAs with
relevant training, experience, and recognized expertise. TA independence requirements
are the same as for the NESSG detailed in paragraph 2c above.
6. NNSA CONTRACTOR NES REPRESENTATIVES. NNSA Contractor NES
representatives are specifically trained and certified to perform CNCEs. Qualifications
for Contractor NES representatives include the following. (This information is provided
here for reference only –contractor requirements are found in Attachment 1)
a. Personal characteristics are as stated for NESSG members in paragraphs 2a (1) to
2a (3) above.
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b. Independence as stated for NESSG members in paragraph 2c above.
c. Training as specified in Attachment 1, Appendix A.
d. Certification as stated for NESSG members in paragraph 2d above based on :
(1) Satisfaction of the requirements for personal characteristics and
independence.
(2) Satisfaction of the training, education, experience, technical competencies,
and proficiency activities in Attachment 1, Appendix A.
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NNSA SD 452.2 IV-1
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CHAPTER IV
NUCLEAR EXPLOSIVE SAFETY STUDY PROCESS
1. INTRODUCTION. Except as detailed below, the process for the two kinds of NESSs—
operation-specific studies and Master Studies—is the same. Operation-specific studies
have an OSR performed between NESSs, which occur approximately every ten years as
described in Chapter II.
2. NESS PLANNING MEETINGS. The Project Team is responsible for conducting
planning meetings with the Nuclear Explosive Safety Division, other NESSG personnel,
and representatives from responsible NNSA line management organizations, design
agencies, and the production agency, as appropriate. To ensure a successful NESS and
promote a common understanding of the approach being taken, planning meeting
participants:
a. Define the study scope and objectives. The scope should describe boundaries
with any associated NESSs (such as NES Master Studies) to ensure no gaps exist.
Section 17
b. Identify topics to be addressed in input documentation, briefings, and
demonstrations.
c. Identify organizational points of contact and assign responsibilities for compiling
input documentation.
d. Develop schedules and, as appropriate, agendas for preparatory activities detailed
in this Chapter.
e. Plan briefings, demonstrations, and resources required to support the NESS.
The Project Team is responsible for documenting and distributing planning meeting
agreements, assumptions, issues, and decisions to participants and appropriate
organizations.
3. NESS INPUT DOCUMENTATION. A NESS relies on detailed written information and
analyses to describe and substantiate the subject activities. Compromises to the
completeness or currency of the required information should be avoided to promote the
timely and effective conduct of the study.
Input documentation is compiled in the form of a comprehensively-indexed single
integrated input document (SIID). The Project Team is responsible for compiling the
SIID and obtaining explicit certification of the technical content completeness and
accuracy from the organization providing the inputs.
Explicit certification must be provided formally in a letter, memorandum, or engineering
authorization. Completeness is determined by the inclusion of the appropriate documents
listed in Attachment 1 Appendix B. Accuracy means that information will be verified to
be correct and current. The requirement for current information does not preclude
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historical documents, which may be pertinent to NES from being included in the SIID.
The Project Team will identify any historical documents included in the SIID to the
NESSG.
In addition to informing the NESSG, the SIID also provides a means to document
rationale for a Project Team assertion that the operation presented for NES evaluation
meets the NES Standards and other NES criteria.
The SIID must be delivered or presented to the NESSG for their use at the orientation
meeting, and available to members for comprehensive review and evaluation during the
NESSG preparation period prior to the NESS.
Attachment 1 Appendix B specifies topics that, if applicable, should be included in a
SIID and tailored as appropriate for each NESS.
4. USE OF SAFETY BASIS DOCUMENTATION. NES evaluations assess operations,
facilities, and management programs to determine if they are adequately controlled to
meet the NES Standards and other NES criteria. While it is not a NESSG function to
evaluate the accuracy and completeness of safety basis documentation, those documents
are valuable resources for the NESSG. A comprehensive safety basis is useful to answer
questions related to hazards considered by the process designers, the basis for the controls
established, and whether controls important to NES are adequately protected. The
NESSG may consider the broad range of applicable positive measures, including but not
limited to those controls identified in safety basis documentation. However, NES
evaluations generally converge on factors that more directly control or influence NEOs,
such as the written procedures used by personnel performing hands on work and
attributes of equipment, facilities, or management systems. If the NESSG finds that
adequate positive measures are effectively incorporated at the working level, the safety
basis documentation might help determine if those positive measures are likely to endure
as safety basis controls. If the NESSG finds that adequate positive measures are not
incorporated at the working level, the safety basis documentation might help determine if
a credible postulated scenario has been missed, ineffectively dealt with, or effectively
dealt with in some other manner.
Section 18
5. NESSG PREPARATION. To efficiently and effectively prepare the NESSG to conduct
the NESS, the following NESS preparatory activities should be conducted in sequence
(paragraphs 5a-5d, following):
a. Study-specific NESSG Training.
(1) For operation-specific studies, study-specific NESSG training is typically
held at the design agency one month or less before the orientation
meeting. Although specific content is defined at the planning meeting,
study-specific training must address the input topics related to nuclear
explosive design as well as the features and attributes important to NES at
relevant levels of assembly. Particular focus must be directed to
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characteristics important to the design of the proposed NEOs, and
susceptibilities to possible environments in which the NEOs will be
performed.
(2) For MSs, the need for study-specific training will be determined at NESS
planning meetings. If study-specific training is deemed useful, the
NESSG chair and Project Team will define the approach, content,
provider, and venue as appropriate to each study.
b. Input Documentation Delivery. SIID completion and availability must coincide
with or shortly precede the start of the orientation meeting.
c. Orientation Meeting. The primary objectives of the orientation meeting are to
introduce the NESS subject and SIID content and organization, and to attain
NESSG agreement on the planned NESS approach, agenda, and schedule.
Commitments to support the agreed-upon schedule must be secured from all
participants.
NESSG familiarization must focus on proposed NEOs for operation-specific
studies, and on proposed facilities, equipment, processes, and management
programs for MSs. SIID content, organization, and hardware/software
requirements must be addressed. The level of detail in briefings and
demonstrations should reflect the NESSG-familiarization objective of the
orientation meeting.
The detailed NESS agenda developed at the orientation meeting must define the
required content and initial schedule for NESS briefings, demonstrations, and
other activities, as well as the final NESS preparation elements detailed in the
following paragraph. NESS start dates and schedules are tentative until the
NESSG determines that the SIID is adequate and the NESSG and Project Team
define a suitable preparation period.
d. NESSG Final Preparation. Consistent with prior NESSG agreements, the NESSG
must:
(1) Evaluate the SIID to determine if it is adequate to proceed with the NESS.
(2) Perform individual study and research as needed.
(3) Begin developing lines of inquiry (LOIs) as needed.
(4) Participate in periodic teleconferences with members, advisors, and the
Project Team to assess progress, discuss LOIs, and modify the NESS plan
as required.
Lines of inquiry are a communication tool that the NESSG uses to pursue
potential NES issues. A line of inquiry is an informal document that the NESSG
may use to track issues, focus the oral debate during deliberations, and use as an
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interim tool to produce a written finding, deliberation topic, or narrative for the
final NESSG report. The LOI is used to state the known facts relevant to an issue,
submit written questions to the Project Team, document the answers to those
questions, and summarize any conclusions based upon the information provided.
The use of LOIs is not required for the NESSG to pursue any particular issue, but
its use is encouraged as the LOI is particularly useful during the deliberation and
report writing phases of the NES evaluation.
Section 19
Sufficient resources and time to accomplish these tasks—nominally three to five
weeks after the input documentation is available to the NESSG members—must
be allocated.
6. NESS PREREQUISITES. A NESS must not begin until preparatory work on the
facilities and operations are completed and the safety basis is in formal change control
and submitted to the approval authority. To ensure the most timely and effective conduct
of the NESS, the Project Team must provide a declaration of readiness and the
appropriate federal line management (Field Element Manager or Assistant Deputy
Administrator for Secure Transportation) must make a formal request to initiate the
NESS.
If a NESS concludes before the safety basis is approved, the NESSG Chair must review
the conditions of the safety basis approval and determine if these conditions will result in
changes that may affect the NESS conclusions before issuing the final NESS report. If
necessary, the NESSG may be reconvened to consider the effect on their earlier
conclusions. If the NESS concludes before the safety basis is approved, and the NESSG
is not reconvened once it is approved, then the NESSG Chair will include a statement in
the NESSG report stating that the safety basis approval was reviewed.
7. NESS CONDUCT. For the timeframe of the operation-specific study or MS, the primary
responsibility of the NESSG is preparing for and conducting the NESS. Conflicting
assignments must be resolved in favor of NESS duties from the date the input
documentation is made available until conclusion of the NESS. Assigning NESSG
members to overlapping NESSG evaluations should be avoided. The timely availability
of Project Team, laboratory, and contractor personnel supporting the NESS should be
ensured. TA support should be scheduled to ensure the most efficient and effective
utilization of their technical expertise in support of the NESS.
The NESSG chair has authority to suspend the NESS if unable to fulfill the requirements
of this Supplemental Directive. If an evaluation is suspended, the NESSG chair will
notify the Authorizing Official of the reason for suspension. If the suspension is for a
period of time greater than one month or if the suspension is for a reason other than
administrative, the NESSG chair must document the reason for suspension and forward it
to the Director of the Nuclear Explosive Safety Division with copies to the Director,
Nuclear Weapon Surety and Quality, the Assistant Deputy Administrator for Stockpile
Management, the Associate Administrator for Safety and Health, and the appropriate
Authorizing Official. Administrative delays include delays due to NESSG member
availability, project team factual accuracy reviews of draft reports, etc.
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The NESS content and activity sequence are defined or modified based on NESS scope,
planning meeting agreements, and in-progress decisions. The central NESS elements are:
a. Briefings. Briefings by subject matter experts cover key elements of the input
documentation and present the NES foundation for the proposed NEO, facility, or
program under evaluation to ensure a common understanding and allow NESSG
interaction with subject matter experts. The NESSG must critically consider the
briefings, identify potential issues, and, as appropriate, question or challenge
points made or omitted in the briefings.
Section 20
b. Demonstrations. NESS demonstrations simulate proposed NEOs using trainer
units or other mock-ups. NESS demonstrations for NES MSs involve facility or
site walkdowns and tours of systems/items of NESSG interest.
(1) Demonstration details, including simulation fidelity, are defined during
planning meetings, but may be modified as needed during a NESS.
Demonstrations allow an examination of interfaces between and among
the nuclear explosive and tooling, testers, other equipment, support
systems, procedures, personnel, and the facility. The NESSG critically
evaluates the process to identify potential NES deficiencies and
opportunities to strengthen positive measures to meet the NES Standards
or other NES criteria.
(2) Demonstrations must:
(a) Provide the most realistic simulation practicable.
(b) Be conducted by trained and qualified technicians or operators.
(c) Use actual or representative tooling, testers, other equipment, and
systems.
(d) Use written procedures that are under change control and
sufficiently developed to be used in the NEO upon approval.
(e) Be conducted in actual bays or cells, or in facilities representative
of key conditions in which the NEO is to be performed. For
example, a training area replicating the actual facility in size,
layout, and workflow may be deemed by the NESSG an acceptable
representative facility.
The NESSG is the final arbiter of the suitability of demonstration
conditions.
c. Deliberations. NESS deliberations are collaborative efforts among the NESSG,
TAs, STAs, Project Team, and subject matter experts to consider all sides of
issues identified during NESS preparation, training, briefings, and
demonstrations. The focus of deliberations is potential NES deficiencies and
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other NES-related issues that might warrant documentation in the NESS report.
The NESSG must sort, characterize, and document these issues using the
guidance in Attachment 2.
As draft findings and deliberation topics mature, the NESSG should share those
drafts with the Project Team and allow Project Team feedback regarding the
factual basis of the issues or other input the Project Team considers relevant.
When deliberating an issue that appears to be similar to an existing open finding,
the NESSG should attempt to determine the extent of the linkage. If the current
issue is fully covered by an existing open finding, the NESSG should say so in a
deliberation topic. If the current issue adds new or not previously considered
information, the NESSG should focus on that new information. In that case, they
might write a new finding that references the existing finding, but focused only on
the new information. Alternatively, they might write a new all-encompassing
finding that subsumes the existing finding, along with a statement recommending
that the previous finding be closed. They might also conclude that significant
portions of the previous finding have been effectively corrected and write a
narrower proposed replacement finding that focuses on the deficiencies
remaining. The Authorizing Official remains the closure authority for all findings
including those that the NESSG recommends be closed or replaced.
If the NESSG identifies an issue that was the subject of a previously closed
finding, the NESSG should critically and thoroughly review the closure package.
If the NESSG believes that the deficiency still exists, they should document why
the previous corrective actions are considered insufficient.
Section 21
Although the NESSG strives for unanimity, individual NESSG members may
submit or endorse a minority opinion when their judgment differs from that of the
majority. A minority opinion is a position taken by the minority of the NESSG
and represents the minority’s disagreement with some aspect of the NESSG
report. Examples include the disagreement with the categorization of a NES issue
and the lack of inclusion of a NES issue in the report. A minority opinion must be
included in the NESS report in its entirety, and NESSG majority personnel must
prepare a written response to the minority opinion. If applicable, the minority
opinion should include a statement that describes the negative impact on NES if
NNSA management accepts majority’s position. The NESSG should only use the
minority opinion process after all reasonable means to come to consensus have
been attempted.
While the NESSG normally conducts deliberations in open meetings and is
receptive to relevant input from knowledgeable, informed sources, all NESS
report content, including characterization and categorization of issues, must be
determined exclusively by the report signatories. At the discretion of the NESSG
chair, the NESSG may also hold closed executive sessions in which only the
NESSG participates.
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If the number of voting members on a NESSG is even, the potential for a tie vote
exists. If a tie vote occurs, it is expected that the NESSG will attempt to come to
consensus on the issue. The NESSG may choose to present the issue to the
Project Team for additional input. If the tie has occurred due to differences in
interpretation of NES requirements, the NESSG may contact the Nuclear
Explosive Safety Division, the Office of Nuclear Weapon Surety and Quality, or
the Office of Safety and Health for guidance. The NESSG chair may choose to
temporarily adjourn the NESS until the additional information or guidance is
provided.
Should a tie vote remain after reasonable attempts for the NESSG to come to
consensus, the majority position will be the position taken arguing for a higher
categorization of the issue (i.e. If the vote is split between categorizing an issue as
a finding or a deliberation topic, the issue will be documented as a finding.). The
fact that the vote was tied will be documented in the report. A minority opinion
which documents the position of the remainder of the NESSG will be included in
the report.
d. Report Generation and Concurrence. NESS report development begins while the
NESS is in progress and continues throughout the study. The NESS report must
include the following:
(1) Abstract.
(2) Table of contents.
(3) NESSG signature page.
(4) Study purpose and background, including identification of other relevant
NESS reports.
(5) Scope of the study.
(6) Evaluation criteria such as the NES Standards.
(7) Applicable specific Nuclear Explosive Safety Rules (NESRs).
(8) NESSG statement on the adequacy and implementation of the specific-
NESRs.
(9) NESSG evaluation activities, dates, and locations.
(10) Summary descriptions of the management programs, facilities, tooling and
other equipment, processes, nuclear explosive and/or NEOs under
evaluation.
(11) Evaluation results and supporting rationale, including:
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(a) Overall conclusion, including a statement on whether the
conclusion is contingent on completion of corrective action for any
NESSG finding.
Section 22
1 For an operation-specific study: NESSG judgment on the
adequacy of positive measures to meet the NES Standards
and other NES criteria.
2 For a MS: NESSG judgment on whether the studied
facilities, equipment, processes, and management systems
are adequately characterized and controlled to support
future evaluation of their application in operation-specific
NEOs.
(b) Findings identifying NES deficiencies, if any. For each finding,
provide NESSG judgment on whether affected NEOs meet the
NES Standards, and identify any associated NES requirement that
is not met. (See elaboration in Chapter VII paragraph 1 and
Attachment 2.)
(c) Deliberation Topics summarizing substantive discussions that did
not result in findings. (See additional elaboration in Chapter VII,
paragraph 1 and Attachment 2.)
(d) NESSG minority opinions, if any, and associated NESSG majority
response.
(e) A statement on the adequacy of resources and activities such as
documentation, briefings, demonstrations, observations, time, and
administrative support for the evaluation.
(f) Lessons learned, as appropriate, from the NESS activities.
(g) Issues that may be outside the scope of the current evaluation but
should be considered by the appropriate NESSG for other
evaluations.
(12) References, including specific written procedures for the subject studied
(by date, issue number, revision number) and other input documentation.
(13) Appendices:
(a) NESS agenda.
(b) Participants.
(14) The NESSG chair and voting members sign the NESS report and are
responsible for its content. Signatures represent concurrence with the
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report findings and conclusions, except as noted in minority opinions. No
agreement by a signatory's organization is implied.
With signatory consent, signatures may be obtained based on final
working copies of the individual findings, deliberation topics, and other
major sections of the report. Subsequently, the Chair compiles, formats,
and assembles a report suitable for publication. The NESSG report is
dated when the chair signs indicating that all member final concurrences
have been obtained.
8. STA COMMENTS. These comments developed from NESSG activities convey the
impressions of a NESSG STA and are intended as constructive input to NNSA managers.
They may not be strictly limited to the specified NESS scope or NESSG charter, and do
not require follow-up actions unless a responsible NNSA manager specifies otherwise.
When a responsible manager specifies follow-up action, it must be entered into the action
agency’s issue tracking system. Additionally, the manager providing such direction must
inform the Associate Administrator for Safety and Health and Assistant Deputy
Administrator for Stockpile Management of that decision.
STAs do not vote in NESSG determinations; otherwise, the STAs are full participants in
NESSG activities, including observing operations, questioning input data, deliberating
issues, and writing the report. Any NES issues raised by an STA must be deliberated by
the group in the same manner as issues raised by a voting member, and may thereby be
documented in the NESSG report as a NESSG position. If voting members are not
persuaded by an STA’s argument on a NES issue, the STA may submit a written
comment for inclusion in the NESSG report. Such STA comments on a NES issue will
be treated in the same manner as a minority opinion from a voting member. Any STA
comment documented in a NESSG report must state the factual basis derived from NES
evaluation activities, the reason the author considers it a NES deficiency or other NES-
related issue, and whether any action by NNSA or its contractors is recommended.
Section 23
STAs may also write comments on issues that are outside the purview of the NESSG.
These non-NES comments need not be deliberated by the NESSG voting members. The
STAs also may write differing professional opinions under DOE O 442.2 Differing
Professional Opinions for Technical Issues involving Environment, Safety, and Health.
The Associate Administrator for Safety and Health may assign a lead member of the STA
group to summarize the STA comments on an annual basis and a tracking system must be
maintained for STA comments for which a responsible NNSA manager has directed
action. The Associate Administrator for Safety and Health must provide for a periodic
(approximately annual) review of the STA comments and any follow-up actions. STAs
are encouraged to keep abreast of on-going NES evaluations and comment as they feel
appropriate at the periodic review.
9. FEEDBACK. Feedback is important for promoting improvement in the NESS process.
NESSG personnel are encouraged to document lessons learned throughout all NESS
activities, including preparation and planning.
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10. NESS VALIDATION. In NESS validations, the NESSG personnel observe actual NEOs
to confirm they are consistent with key aspects of operations demonstrated during a
NESS. Validations are expected to be the norm for operation-specific studies of startup
activities, but can also apply to other NES evaluations. The NESSG must consist of an
NNSA chair and one or more certified NESSG members (preferably NESSG members
who participated in the associated study).
The NESSG recommends in the NESS report whether a NESS validation should be
performed after operations have begun and which operations should be observed based
on consideration of such factors as the:
a. Fidelity and completeness of the demonstrations.
b. Extent to which NESS briefings and input documentation included operations-
ready information.
c. Anticipated interval between the NESS and start of operations.
d. Projected changes associated with corrective actions originating from the NESS
or readiness review.
e. Relative risk of operations (e.g. bare CHE operations).
f. Past NES or operational issues.
g. Operations where the expected number of units to be processed is high, such as a
Life Extension Program.
The NESSG documents (in the NESS report) the factors that should be considered in
developing the schedule and scope of the validation. The NESSG Chair and responsible
operations personnel must jointly plan and schedule validations based on the NESSG
recommendations and the operations schedule.
The NESSG Chair must document NESS Validation activities and results in
correspondence that includes the responsible NNSA Field Element Manager or Assistant
Deputy Administrator for Secure Transportation, as applicable; Assistant Deputy
Administrator for Stockpile Management; and Associate Administrator for Safety and
Health.
11. NESS POST-EVALUATION PROCESS.
a. Post-Evaluation Briefings and Conferences. At the conclusion of the study, the
NESSG chair summarizes the NESS activities, minority opinion(s), STA
comment(s), and results in briefing(s) to the––
(1) Responsible NNSA Field Element Manager or Assistant Deputy
Administrator for Secure Transportation, as applicable.
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(2) Assistant Deputy Administrator for Stockpile Management.
(3) Associate Administrator for Safety and Health.
b. Report Distribution. The NESSG chair distributes the final report to:
Section 24
(1) Assistant Deputy Administrator for Stockpile Management.
(2) Responsible NNSA Field Element Manager or Assistant Deputy
Administrator for Secure Transportation, as applicable.
(3) Associate Administrator for Safety and Health.
(4) Director, Office of Nuclear Weapon Stockpile.
(5) Director, Office of Nuclear Weapon Surety and Quality.
(6) Director, Nuclear Explosive Safety Division.
(7) Participating NESSG members and other NESSG member organizations.
c. Responsible Manager Actions. The responsible Authorizing Official (NPO, FO,
or ADAST) must resolve any minority opinions and direct response to NESSG
findings, in accordance with Chapter VII, section 2 of this supplemental directive.
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CHAPTER V
OPERATIONAL SAFETY REVIEW PROCESS
1. INTRODUCTION. OSRs focus on ongoing operations and approved current
documentation to determine if there are gaps or weaknesses in the positive measures
needed to meet the NES Standards and other NES criteria. OSRs are not appropriate for
operations that have lapsed or which utilize documentation not maintained through NES
change control. An operation is considered lapsed if declared so by a responsible NNSA
line manager or judged so in a NESSG report. Factors to consider in making this
judgment include length of time between last performance and next performance (i.e. > 3
years), significant changes since the NESS, results of other relevant NES evaluations,
degree of similarity or difference from active operations, and relevant changes in
knowledge or expectations since the NESS. Before a lapsed operation can restart, a
NESS must be completed for the affected activities.
2. OSR PLANNING. OSR Planning is a continuing process. The OSR schedule and scope
are dependent on the timing of relevant operations. OSRs are targeted for the period
between three and seven years after the associated NESS. At the discretion of the
NESSG chair and/or the Director of the Nuclear Explosive Safety Division, the OSR may
be divided into two or more separate portions to limit the length of time the NESSG must
be continuously convened, and to be compatible with scheduled operations. For
example, a program-specific OSR may be performed in two separate evaluations: one
evaluation focused on assembly operations, the other focused on disassembly operations.
The objective is to cover all elements of the NESS scope during the period from three to
seven years after the NESSG Chair signed the previous NESS report. The process for
addressing OSR observation gaps is addressed in Paragraph 5 below.
The Director, Nuclear Explosive Safety Division must maintain an accounting of the
topics covered by each NESS and work with NNSA and contractor line management to
schedule OSRs to meet the above objective. The NESSG convened for each OSR must
review the relevant OSR history, preview operational plans out to the next NESS, and
recommend a plan to achieve the desired OSR coverage. The Director, Nuclear
Explosive Safety Division must meet with the M&O Contractor periodically
(approximately annually) to review OSR scheduling to ensure planned review periods
coincide with planned operational activities and to identify potentially lapsed NEOs well
in advance. The Director, Nuclear Explosive Safety Division, must provide the updated
OSR schedule to:
a. Assistant Deputy Administrator for Stockpile Management.
Section 25
b. Responsible NNSA Field Element Manager or Assistant Deputy
Administrator for Secure Transportation, as applicable.
c. Associate Administrator for Safety and Health.
d. NESSG-member organizations.
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The reason for using both NESSs and OSRs for periodic reevaluation of operation-
specific studies is to capitalize on the different strengths of each and reduce the effects of
their different disadvantages.
The NESSG Chair is responsible for conducting planning meetings with appropriate
NNSA and contractor line management organizations, and for documenting and
distributing planning meeting decisions, agreements, assumptions, and issues to OSR
participants and appropriate organizations. The Project Team should be involved
throughout the OSR process to ensure that the NESSG is provided the proper assistance
to completing observations and to ensure that LOIs are being answered in a timely
manner to facilitate completion of the review.
To ensure a common understanding of the approach being taken for an OSR, planning
meeting participants:
a. Define the OSR scope and objectives.
b. Review operational schedules and identify opportunities for OSR
observations. Make preliminary judgments on the effect of any
anticipated observation gaps (activities covered by the NESS but not
available for OSR observation).
c. Review past operational activities to determine if an operation proposed
for any upcoming OSR increment may have lapsed since the last NESS.
d. Identify required OSR supporting documentation.
e. Identify organizational points of contact and assign responsibilities for
providing supporting documentation and briefings, and for responding to
NESSG lines of inquiry.
f. Develop a schedule and, as appropriate, agendas for the OSR preparatory
activities detailed in this Chapter.
3. OSR SUPPORTING DOCUMENTATION. To ensure an adequate evaluation of NES,
an OSR relies on up-to-date existing information and analyses. Compromises to the
completeness or currency of the required information should be avoided to promote the
timely and effective conduct of an OSR. NNSA line management is responsible for
making available complete and current OSR supporting documentation to OSR
participants (as requested by the NESSG).
As applicable to the scope of each OSR, supporting documentation must include:
a. Current safety basis documents, including identification of changes that required
DOE/NNSA approval since the NESS.
b. Descriptions of changes to the configuration of the nuclear explosive or the WSS
since the NESS.
NNSA SD 452.2 V-3
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c. Approved written procedures.
d. Summary of associated OSR/NCE history and results.
e. Relevant information from quarterly status reports of implemented and pending
corrective actions for approved findings, occurrence reports, and SFIs.
f. Identification of any activities covered by the NESS that are not expected to be
available for OSR observation. State when last performed and when expected to
be performed in the future. For those that management desires continued
authorization until the next NESS, compare and contrast with activities that will
be observed.
g. Relevant NES evaluation reports.
4. OSR PREPARATION. NESSG personnel and TAs must review the baseline NESS and
supporting documentation, perform individual study and research as needed, and begin
developing LOIs prior to the start of an OSR increment. Sufficient resources and time to
accomplish these tasks—nominally three to five weeks before NEO observations are
expected to begin—must be allocated.
Section 26
During the preparation period, the NESSG chair conducts a final planning meeting with
all OSR participants and responsible NNSA line management organizations to:
a. Finalize the OSR scope and objectives.
b. Review operational schedules and identify NEO observation opportunities.
Refine earlier judgments regarding the impact of any known observation gaps.
c. Review the status of current safety basis documents and changes since the
baseline NESS.
d. Identify required briefing topics.
e. Plan briefings, observations, and resources as required supporting the OSR.
f. Develop an OSR schedule and agenda that are sufficiently detailed to enable
effective ongoing management of the OSR.
The NESSG chair documents and distributes meeting results, including statements
regarding the OSR scope, objectives, and schedule, to the meeting participants and
affected organizations.
5. OSR CONDUCT. For the timeframe of the evaluation, the primary responsibility of the
NESSG is preparing for, conducting, and documenting the OSR. Conflicting
assignments must be resolved in favor of OSR duties from the date the supporting
documentation is made available until conclusion of the OSR. Assigning NESSG
members to overlapping NESSG evaluations should be avoided. The timely availability
V-4 NNSA SD 452.2
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of Project Team, laboratory, and contractor personnel supporting the OSR should be
ensured.
The NESSG chair has authority to suspend the OSR if unable to fulfill the requirements
of this Supplemental Directive. If an evaluation is suspended, the NESSG chair will
notify the Authorizing Official of the reason for suspension.
The OSR content and activity sequence are defined or modified based on the relevant
NESS scope, and planning meeting and in-progress decisions. The central OSR elements
are:
a. Briefings. OSR briefings are intended to ensure a common understanding and
facilitate productive observations. OSR briefings should be descriptive and
focused on the NEOs to be observed. The NESSG may request briefings at
planning meetings or during the OSR.
Briefings should also identify any activities covered by the NESS that are not
expected to be available for OSR observation. State when last performed and
when expected to be performed in the future. For those that management desires
continued authorization until the next NESS, compare and contrast with activities
that will be observed.
b. Observations. By observing actual NEOs, the NESSG critically evaluates
ongoing processes for NES deficiencies and opportunities to strengthen positives
measures to meet the NES Standards and other NES criteria.
While actual operational schedules and events might limit available activities, the
NESSG should strive to cover as much of the associated NESS scope as possible
(relevant to the OSR increment). Any OSR observation gaps must be addressed
in the OSR report.
c. Issue Resolution. While a NESS typically pursues every NES issue to a
conclusion, OSRs may take a different approach. If questions or concerns are not
quickly resolvable from existing documentation available to the production
agency (i.e., with enough information to support a valid conclusion), the OSR
NESSG may document it as a question that could not be answered in the limited
time allotted. Managers must then task an appropriate action agency to develop a
response for NESSG review with an appropriate deadline.
Section 27
d. Deliberations. OSR deliberations follow the same collaboration and issue
categorization efforts as specified for a NESS in Chapter IV paragraph 7c.
e. Report Generation and Concurrence. The NESSG may document OSRs either in
a living document (updated and given a new Issue Number with each incremental
OSR) or as a series of OSR reports. OSR report development begins while the
OSR is in progress and continues throughout the evaluation. The OSR report
NNSA SD 452.2 V-5
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contents include the information specified for NESS reports in Chapter IV,
paragraph 7d.
In addition, the NESSG must account for any OSR observation gaps relative to
the NESS scope. Each incremental OSR report must include a matrix listing all
increments needed to cover the baseline NESS and their status. This matrix must
be updated with each OSR increment to show which increments remain to be
covered before the next NESS.
The NESSG should assess the significance of any observation gaps in reaching its
overall conclusions about the currently authorized operations. All activities
covered by the NESS should be addressed in the OSR Report. Options include:
(1) Observed in OSR; no concerns.
(2) Observed in OSR resulting in finding or deliberation topic.
(3) Not observed in OSR, but no concerns based on inference from what was
observed.
(4) Not observed in an OSR increment to date, but expected to be observed in
a future OSR increment.
(5) Not observed in OSR and OSR observations did not provide an adequate
basis to judge if positive measures remain adequate to meet the NES
Standards and other NES criteria. In this case, the NESSG must judge if
the affected activity is considered lapsed and therefore requires another
form of NES evaluation (i.e., using a demonstration with a trainer unit) or
if it is appropriate for evaluation in an OSR increment when next
performed. Document the rationale for this judgment in the OSR report.
(6) Not observed in OSR and evaluation not attempted because there are no
plans to perform that activity (at least before the next NESS). The NESSG
should consider documenting that activity as lapsed.
NESSG personnel sign the OSR report and are responsible for its content.
Signatures represent concurrence with the report findings and conclusions, except
as noted in minority opinions. No agreement by a signatory's organization is
implied.
With signatory consent, signatures may be obtained based on final working copies
of the individual findings, deliberation topics, and other major sections of the
report. Subsequently, the Chair compiles, formats, and assembles a report
suitable for publication. The NESSG report is dated when the chair signs
indicating that all member final concurrences have been obtained.
6. STA COMMENTS. Guidance for STA comment derived from OSR activities is the
same as specified for a NESS in Chapter IV paragraph 8.
V-6 NNSA SD 452.2
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7. FEEDBACK. Feedback is important for promoting improvement in the OSR process.
NESSG personnel are encouraged to document lessons learned throughout all OSR
activities, including preparation and planning, and included in the report
8. OSR POST-EVALUATION PROCESS.
Section 28
a. Post-Evaluation Briefings and Conferences. At the conclusion of the evaluation,
the NESSG chair summarizes the OSR activities, minority opinion(s), and results
in briefing(s) to the responsible NNSA Field Element manager or Assistant
Deputy Administrator for Secure Transportation, as applicable. If the OSR results
include a finding where a NES Standard is not met or a minority opinion
associated with a potential finding where a NES Standard is not met, then the
NESSG chair must also brief the Assistant Deputy Administrator for Stockpile
Management and the Associate Administrator for Safety and Health.
b. Report Distribution. The NESSG chair distributes the OSR report to:
(1) Responsible NNSA Field Element Manager or Assistant Deputy
Administrator for Secure Transportation, as applicable.
(2) Assistant Deputy Administrator for Stockpile Management.
(3) Associate Administrator for Safety and Health.
(4) Director, Office of Nuclear Weapon Stockpile.
(5) Director, Office of Nuclear Weapon Surety and Quality.
(6) Director, Nuclear Explosive Safety Division.
(7) Participating NESSG personnel and other NESSG member organizations.
c. Responsible Manager Actions. The responsible Authorizing Official (NPO, FO,
or ADAST) must resolve any minority opinions and direct response to NESSG
findings, in accordance with Chapter VII, section 2 of this supplemental directive.
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CHAPTER VI
NUCLEAR EXPLOSIVE SAFETY CHANGE CONTROL PROCESSES
1. INTRODUCTION. NES evaluation of proposed changes or emerging information
begins with a CNCE for production agency NEOs, or an OST NES Screen for offsite
transportation operations. One of three subsequent approval pathways—contractor or
Assistant Deputy Administrator for Secure Transportation (as applicable), NCE, or
NESS—must be chosen to ensure an appropriate level of rigor for each evaluation and
the most efficient use of resources. An NCE or NESS for emerging information may also
be initiated at the request of the Director, Nuclear Explosive Safety Division in
conjunction with the responsible NNSA Field Element Manager or Assistant Deputy
Administrator for Secure Transportation, as applicable. NCEs are conducted by the
production agency (or OST for OST activities). The level of involvement of the NNSA
and design agency Project Team members during the NCE is determined by the scope of
the evaluation. The Project Team is responsible for ensuring that the NESSG obtains
timely responses to lines of inquiry and requests for information.
The NES change control process is separate and independent from the unreviewed safety
question (USQ) process required by Title 10 CFR 830.203, Unreviewed Safety Question
Process, and supported by DOE G 424.1-1A, Implementation Guide for Use in
Addressing Unreviewed Safety Question Requirements.
The NNSA M&O contractor evaluates the safety implications of a proposed change to a
NEO in two ways: (1) a USQ screen by personnel trained to provide the authorization
basis (AB) perspective, and (2) a NES review by a NES-certified representative. The
USQ screen and the NES review are separate and independent processes performed by
different individuals possessing specific qualifications and must be independent of NNSA
line management influence. The result of the USQ screen [or USQ Determination
(USQD), if applicable] and the NES review must be known prior to approval and
implementation of the proposed change. If the NES review indicates that a NESSG
review is required, the NNSA must approve the proposed change prior to
implementation, regardless of the outcomes of the USQ screen or USQD.
Section 29
Whatever level of review is chosen for a proposed change, implementation of a
requirement to prevent or mitigate one hazard must be assessed to ensure that there would
be no unacceptable effect on the likelihood of a significant safety incident involving
another hazard.
2. ORGANIZATIONAL CHANGE CONTROL ASSESSMENTS. CNCEs and OST NES
Screens are used to determine whether the NNSA contractor or Assistant Deputy
Administrator for Secure Transportation, as applicable, is the responsible approval
authority, or whether the change proposal or emerging information must be presented to a
NESSG for NES evaluation.
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In the absence of NES personnel certified in accordance with the requirements of Chapter
III, OST staff has less discretion than contractor NES representatives in determining the
approval authority for proposed changes or emerging information. As a result, CNCEs
and OST NES Screens have unique elements, as follows:
a. Focus. CNCEs and OST NES screens consider the NES implications of:
(1) proposed changes to procedures, materials, tooling, testers, other
equipment, facilities, facility interfaces, or management programs
associated with approved NEOs and
(2) emerging information that has the potential to impact NES of an approved
NEO.
b. Documentation. The NNSA contractor or OST, as appropriate, takes the lead in
developing the safety support documentation and compiling inputs that may be
needed from the design agencies and NNSA. The NNSA contractor or OST, as
appropriate, ensures the technical accuracy, currency, and completeness of the
documentation.
Sufficient information must be provided to establish that proposed changes are
not a threat to NES including, as applicable:
(1) A complete description of the proposal or issue with process flow
representations and detailed written procedures, as appropriate.
(2) Rationale for the proposed change, with concurrence from responsible
management personnel and design agency representatives, as appropriate.
(3) Relevant safety basis information as needed to support a determination.
c. Determination Processes. The determination process and decision basis differ for
CNCEs and OST NES Screens.
(1) CNCE. With a particular emphasis on potentially adverse impacts on
NES, a NNSA contractor NES representative reviews the submitted
documentation and presented information, and answers the following
questions to determine if the proposal must be elevated to NNSA for NES
evaluation in an NCE or NESS.
(a) Does the proposed change add, delete, or modify a nuclear
explosive safety rule (NESR), immediate-action procedure (IAP),
or other positive measure identified as important to NES in a
previous NES evaluation report?
(b) Does the proposed change involve new Category 1 electrical
equipment or the addition of an electrical test of a nuclear
explosive?
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(c) Does a proposed change to Category 1 electrical equipment
involve more than minor modifications that clearly do not affect
the functionality, quality, safety analysis, or security controls for
the equipment?
(d) Does the proposed change to a NEO involve a procedure, tooling,
tester, other equipment, transportation activity, facility interface or
other process or feature that is not bound by activities examined in
a previous NES evaluation?
Section 30
(e) Does the proposed change involve the potential application of
additional electrical, mechanical, thermal, chemical, or
electromagnetic energy to a nuclear explosive (NE), or the
application of the above energy types to other circuitry or
components of a NE in a manner or in an amount that is not bound
by activities examined in a previous NES evaluation?
(f) Could the proposed change affect one-point safety?
(g) Does the proposed change affect lifting, rotating, or other NE
movement operations not bound by activities examined in a
previous NES evaluation?
(h) Does the proposed change require an implementation of the Two-
Person Concept that does not meet the requirements set forth in
DOE M 452.2-1A (or its successor directive)?
(i) Does the proposed change involve a NEO relocation that would
adversely impact NES?
(j) Does the proposed change involve an implementation of
permanent markings or NELA verifications that does not meet the
requirements set forth in DOE M 452.2-1A (or its successor
directive)?
(k) Does the proposed change involve a management program or
process, including any form of work instructions or operating
standards that could adversely affect NES?
(l) Has information been presented that could alter previous NES
evaluation conclusions in a manner that could adversely affect
NES?
An NNSA NES evaluation must be performed if the answer to one or
more of the preceding questions is "yes" or "unknown.” If the answer to
each of the preceding questions is "no," an NNSA NES evaluation is not
required.
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Responsible line management must ensure that the NNSA contractor
documents the basis for, and maintains an auditable record of, all CNCE
determinations. These auditable records are subject to NNSA oversight.
(2) OST NES Screen. Designated OST staff review the submitted
documentation and presented information. The screening criteria
detailed in OST 46XA, Offsite Transportation Safety Manual, Chapter
2.2, Appendix G, provide the basis for determining if qualified NES
personnel must be engaged in deciding if the proposed change or
emerging information must be elevated to a NESSG for NES evaluation.
If qualified NES personnel are required, OST must refer the issue to the
Nuclear Explosive Safety Division to determine if the proposed change or
emerging information allows for Assistant Deputy Administrator for
Secure Transportation approval, or if the issue must be elevated to an NCE
or appropriately-scoped NESS. Proposed changes to the screening criteria
must also be referred to Nuclear Explosive Safety Division for
concurrence.
OST must document the basis for, and maintain an auditable record of, all
determinations. These auditable records are subject to NNSA NES
oversight.
d. Determination Outcomes.
(1) NESSG Evaluation Required. Once an NNSA contractor NES
representative or OST, as appropriate, has determined that evaluation by a
NESSG is required, NNSA line management can decide whether or not to
pursue the proposed changes or response to emerging information. For
proposed changes or response to emerging information that NNSA line
management decides to pursue, the NNSA Field Element Manager or
Assistant Deputy Administrator for Secure Transportation, as applicable:
(a) Works with the Director, Nuclear Explosive Safety Division to
jointly determine whether a NESS or NCE is the appropriate NES
evaluation.
(b) Submits a request to the Director, Nuclear Explosive Safety
Division to schedule the appropriate NES evaluation.
Section 31
(2) NESSG Evaluation Not Required. When it is determined that evaluation
by a NESSG is not required, the NNSA contractor or Assistant Deputy
Administrator for Secure Transportation, as applicable, is the approval
authority. Responsible line management must establish a process for
approving and implementing changes and responses to emerging
information that do not require NESSG evaluation. Responsible line
management must maintain auditable records subject to NNSA NES
NNSA SD 452.2 VI-5
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oversight clearly establishing that NES is not adversely impacted by
changes for which they have cognizance.
3. EMERGING INFORMATION EVALUATION REQUESTS. A request to evaluate
emerging information that has not entered into the contractor change control system may
be made to the Director, Nuclear Explosive Safety Division. For emerging information
evaluation requests brought to the Director, Nuclear Explosive Safety Division, the
Director––
a. Works with the responsible NNSA Field Element Manager or Assistant Deputy
Administrator for Secure Transportation, as applicable, to determine
(1) The credibility of the emerging information.
(2) Whether the emerging information has the potential to impact NES of an
approved NEO.
(3) The appropriate NES evaluation mechanism (NCE, appropriately-scoped
NESS, inclusion into an upcoming evaluation, etc.), as necessary.
b. The Director, Nuclear Explosive Safety Division submits a request to the NNSA
Field Element Manager to schedule the NES evaluation, if warranted.
4. NESSG CHANGE EVALUATIONS.
a. NCE. A NCE is performed to determine if approved NEOs will continue to meet
the DOE NES Standards and other NES criteria after implementation of a
proposed change or response to emerging information.
(1) Planning. The NESSG Chair conducts planning meetings as needed to
ensure a common understanding of the approach being taken for an NCE.
The need for a formal NCE planning meeting is determined through
discussions between the Director, Nuclear Explosive Safety Division and
the organizations proposing a change or providing emerging information
affecting an approved NEO. Planning meeting participants:
(a) Define the NCE scope and objectives.
(b) Identify required briefing topics and demonstrations.
(c) Plan briefings, demonstrations, and resources required to support
the NCE.
(d) Develop an NCE schedule and agenda that are sufficiently detailed
to enable effective ongoing management of the NCE.
The NESSG chair is responsible for documenting and distributing
planning meeting outcomes, including NCE scope, objectives, and
VI-6 NNSA SD 452.2
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schedule, to NCE participants and appropriate organizations. The Project
Team is responsible for ensuring the planned briefings, demonstrations,
and resources required to support the NCE are available.
(2) Input Documentation. Change proposal or emerging information
originators are responsible for preparing and distributing the NCE input.
Input requirements for NCEs must be tailored to the subject, and include:
(a) A complete description of the proposal or issue with, as
appropriate, process flow representations and/or detailed written
procedures, including dates and issue designations.
(b) The rationale for the proposed change or response to emerging
information, with concurrence from responsible management
personnel and design agency representatives, as appropriate.
(c) The inputs to and outputs from the CNCE or OST NES Screen, as
appropriate.
Section 32
(d) Relevant information from NES evaluation reports, occurrence
reports, and SFIs.
(e) An assessment of the hazards associated with the proposed change
or emerging information, and identification of any required new
controls or changes to existing controls.
The required level of input documentation detail varies with the scope and
complexity of the proposed changes or emerging information with the
potential to impact NES. Information and analyses must be sufficient to
show that affected NEOs continue to meet the DOE NES Standards and
other NES criteria after the proposed change or response to emerging
information is implemented.
(3) Preparation. The NESSG and other participants must be given sufficient
time and resources to evaluate the documentation of proposed changes to
authorized NEOs or emerging information. The needed preparation period
varies with the scope and complexity of issues to be addressed, and could
range from a few hours to multiple weeks after the documentation is
available. Requests for TA support should be tailored to ensure efficient
and effective utilization of their technical expertise in support of the NCE.
(4) Conduct. For the timeframe of the evaluation, the primary responsibility
of the NESSG participants is preparing for and conducting the NCE.
Conflicting assignments must be resolved in favor of NCE duties from the
date the input documentation is available until conclusion of the NCE.
The timely availability of Project Team, laboratory, and contractor
personnel supporting the NCE should be ensured.
NNSA SD 452.2 VI-7
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The NESSG chair may notify the change proposal or emerging
information originator during an NCE that additional information is
needed and, as appropriate, may suspend the NCE until the information is
provided. The NESSG chair also has authority to suspend the NCE if
unable to fulfill other requirements of this Supplemental Directive. If an
evaluation is suspended, the NESSG chair will notify the Authorizing
Official of the reason for suspension.
The sequence and content of NCE elements are defined or modified based
on the NCE scope and planning meeting decisions. The central NCE
elements are:
(a) Briefings. The need for NCE briefings is determined during
planning but may also be requested by the NESSG during the
NCE. These briefings cover key elements of the input
documentation and present the NES foundation for the change or
emerging information under evaluation to ensure a common
understanding and allow NESSG interaction with subject matter
experts. The NESSG must critically consider the briefings,
identify potential issues and, as appropriate, question or challenge
points made or omitted in the briefings.
(b) Demonstrations. The need for NCE demonstrations is determined
during planning, but may also be requested by the NESSG during
the NCE. NCE demonstrations are simulations that may use
trainer units or other mock-ups. Demonstration details, including
simulation fidelity, are established during the planning, but may be
modified as needed during an NCE.
Demonstrations allow an examination of interfaces between and
among the nuclear explosive and tooling, testers, other equipment,
support systems, procedures, personnel, and the facility. The
NESSG critically evaluates the process to identify potential NES
deficiencies and opportunities to strengthen positive measures to
meet the NES Standards and other NES criteria.
Demonstrations must:
Section 33
1 Provide the most realistic simulation practicable.
2 Be conducted by trained and qualified technicians or
operators.
3 Use actual or representative tooling, testers, other
equipment, and systems.
VI-8 NNSA SD 452.2
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4 Use written procedures that are under change control and
sufficiently developed to be used in the NEO upon
approval.
5 Be conducted in an actual bay, cell, or other representative
facility. A training facility set-up to replicate the actual
facility in size and layout may be deemed by the NESSG an
acceptable representative facility. For some NCE subjects
the NESSG may decide that an actual or representative
facility is not needed to achieve an effective demonstration.
The NESSG is the final arbiter of the suitability of demonstration
conditions.
(c) Deliberations. NCE deliberations follow the same collaboration
and issue categorization efforts as specified for a NESS in Chapter
IV paragraph 7c.
(d) NCE Memoranda. NCE memoranda must include:
1 The signature of the NESSG chair and identification of
other NESSG personnel.
2 A summary description of the NEO, facility, management
system, or emerging information evaluated, as appropriate.
3 Evaluation results, including:
a Conclusions with supporting rationale.
b Findings, if any.
c NESSG minority opinions, if any, and associated
majority response.
d A statement on the adequacy of resources and
activities such as documentation, briefings,
demonstrations, observations, time, NESSG
composition, and administrative support for the
evaluation.
4 NCE input (attached or referenced).
5 NCE participants.
The NESSG is responsible for the content of the NCE
memorandum.
NNSA SD 452.2 VI-9
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(e) Feedback. Feedback is important for promoting improvement in
the NCE process. NESSG personnel are encouraged to document
lessons learned throughout all NCE activities, including
preparation and planning.
(5) NCE Post-evaluation Process.
(a) Post-Evaluation Briefings and Conferences. At the conclusion of
the evaluation, the NESSG chair summarizes the NCE activities,
minority opinion(s), and results in briefing(s) to the responsible
NNSA Field Element Manager or Assistant Deputy Administrator
for Secure Transportation, as applicable. If the NCE results
include a finding where a NES Standard is not met or a minority
opinion associated with a potential finding where a NES Standard
is not met, then the NESSG chair must also brief the Assistant
Deputy Administrator for Stockpile Management and the
Associate Administrator for Safety and Health.
(b) Report Distribution. The NESSG chair distributes the NCE memo
to:
1 Responsible NNSA Field Element Manager or Assistant
Deputy Administrator for Secure Transportation, as
applicable.
2 Assistant Deputy Administrator for Stockpile Management.
3 Associate Administrator for Safety and Health.
4 Director, Office of Nuclear Weapon Stockpile.
5 Director, Office of Nuclear Weapon Surety and Quality.
6 Director, Nuclear Explosive Safety Division.
7 Participating NESSG personnel and other NESSG member
organizations.
(c) Responsible Manager Actions. The responsible Authorizing
Official (NPO, FO, or ADAST) must resolve any minority
opinions and direct response to NESSG findings, in accordance
with Chapter VII, section 2 of this supplemental directive.
(6) NESS. Change proposals or emerging information determined to not be a
candidate for one of the alternate forms of NES evaluation must be
evaluated using the NESS process detailed in Chapter IV, tailored as
appropriate to suit the subject.
Section 34
VI-10 NNSA SD 452.2
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The scope of a NESS performed for change control should be limited to aspects of
the NEO or relevant MS topics affected by the proposed change or emerging
information. Such a NESS relies on at least one other previously-approved NESS
(operation-specific or MS) to provide the context for the subject evaluated.
NNSA SD 452.2 VII-1
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CHAPTER VII
NUCLEAR EXPLOSIVE SAFETY EVALUATION FINDINGS
1. FINDINGS AND DELIBERATION TOPICS. Findings derive from process deficiencies
that jeopardize NES. NES deficiencies applicable to an approved NEO, a proposed NEO,
or a proposed change to a NEO are characterized as findings. NES evaluation reports
may also include Deliberation Topics summarizing substantive NESSG discussions that
did not result in a finding. Coverage of an issue as a Deliberation Topic does not
necessarily mean that action is not warranted. It only reflects a NESSG judgment that no
corrective action is needed for the studied operations. Non-NES deficiencies and
problems in NEOs that are outside the scope of the NES evaluation are documented in
deliberation topics for use by the responsible managers, as appropriate.
a. NES deficiencies identified by the NESSG will be documented as findings. The
guidance in Attachment 2 will be used by the NESSG in making these judgments.
Any deficiency that indicates a DOE NES requirement is not met must be
categorized as a finding, and must identify the requirement not met, if applicable.
b. For all identified findings, the NESSG will determine if the NES Standards
specified in DOE O 452.1D, Nuclear Explosive and Weapon Surety Program, are
met. If one or both NES Standards are not met, the NESSG will document how
the NES Standard is not met in the finding discussion.
c. If the NESSG determines that a NES Standard is not met for an ongoing
operation, the NESSG Chair must promptly notify appropriate NNSA
management.
d. The NESSG chair will allow the Project Team time to perform a factual accuracy
review of the finding discussion and deficiency statement in order to provide the
NESSG with information to explain what, if any, positive measures are, or could
be put, in place to address the deficiency identified in the finding. Additionally,
the NESSG chair may choose to temporarily adjourn the NES evaluation to allow
sufficient time for the Project Team to respond.
e. If the NESSG adjourns to allow the Project Team appropriate time to perform a
factual accuracy review of a finding, the NESSG chair may notify the Authorizing
Official and the ADASM that the NESSG has temporarily adjourned while
waiting for the Project Team to review the information.
f. Once a NES report is signed by the NESSG, the report is transmitted to the
Authorizing Official with a copy to the ADASM. The AO must respond to
findings in accordance with Section 2 below.
NESSGs must refer to the guidance and criteria in Attachment 2 to characterize issues
identified in NES evaluations and to help document their rationale. If a NES evaluation
VII-2 NNSA SD 452.2
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finding is challenged, the challenger must consider the same guidance and criteria in
developing and documenting their positions on NES evaluation results.
2. RESPONSE TO FINDINGS.
The process for NNSA management response to NES Findings is shown in Figure 3 and
further explained in Paragraphs 2a through 2n below:
Figure 3: NNSA Management Response to Findings
Section 35
a. The NESSG Chair transmits the signed NESSG report to the Authorizing Official
(NPO, ADAST, or FO), the ADASM, and the Associate Administrator for Safety
and Health.
b. The Authorizing Official, the ADASM, and the M&O Contractor each retain the
unilateral authority to determine that a NES Standard is not met, or to take action
on any issue raised by the NESSG. This includes effectively elevating the
categorization of any finding or deliberation topic identified in the NESSG report.
c. Following the receipt of the signed NESSG report (or memo for NCEs), the
Authorizing Official will review the report, including all minority opinions.
d. The Authorizing Official has the authority to refer any report finding(s) to the
ADASM for additional review. The request for an additional review must occur
NNSA SD 452.2 VII-3
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no later than 30 calendar days following transmission of the report to the
Authorizing Official. The request for an addition review must include any
technical basis or rationale for the request.
e. In particular, Authorizing Official may consider any findings with minority
opinions for this review process. This process is intended to bring additional
scrutiny and investigation to any issue that warrants further review prior to a
management decision. The responsible NNSA Manager may choose to involve
the NESSG or subset of the NESSG in reviewing any additional information.
f. When a NESSG generates a finding that impacts ongoing operations and states
that a NES standard is not met, the Authorizing Official must evaluate the
potential implications and provide direction to appropriate operations personnel
regarding the required response. Options include:
(1) Suspending the involved operations.
(2) Implementing corrective or compensatory measures that ensure the NES
Standards are met.
(3) Allowing operations to continue unchanged pending completion of the
additional review.
One of these options must be exercised no later than 30 calendar days following
transmission of the signed NESSG report to the Authorizing Official.
g. Within two weeks of a request for additional review, the ADASM must determine
whether the ADASM will convene a NES panel to review the issues involved.
The ADASM must notify the Associate Administrator of Safety and Health of the
approach to be taken to review a NES finding. If the ADASM does not convene a
NES panel, the ADASM must perform an independent review to determine
whether the NES Standards are met for the issues raised, and provide his decision
and the supporting technical basis to the Authorizing Official within 45 days of
the request for additional review. The Associate Administrator for Safety and
Health must concur with the decision to not convene a NES panel when a request
for additional review is made.
h. If a NES panel is convened:
(1) The NES panel, if formed, is appointed by the ADASM and must consist
of a minimum of three NES-knowledgeable, and competent NNSA or
M&O contractor personnel. Of these personnel, a minimum of one must
be NESSG-qualified. Additional technical personnel may be appointed to
support the panel as needed to ensure adequate review. It is desirable that
panel members are as independent as feasible, but true independence is
difficult to achieve in the NES community. An attempt should be made to
ensure the panel members do not have organizational or programmatic
VII-4 NNSA SD 452.2
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Section 36
interests that may unintentionally affect their judgment. The Associate
Administrator for Safety and Health must concur with panel membership.
(2) The NES panel’s primary task is to provide an opinion on whether the
NES Standards are met for the situation addressed by the finding(s). The
panel may agree or disagree with the NESSG on the subject finding(s),
some aspect of the finding(s), or the finding(s) categorization(s). The
panel documents their conclusions and basis in a report. The panel should
use the criteria in Attachment 2 as guidance for their decision.
(3) The NES panel report must be delivered no later than 30 calendar days
after the ADASM decision to form the NES panel.
(4) Upon receipt of the NES panel’s report, the ADASM must accept or reject
their opinion (in whole or in part), and provide a final decision on whether
the NES Standards are met.
(5) The ADASM will provide the Associate Administrator for Safety and
Health a copy of the NES panel report and the ADASM decision to accept
or reject the NES panel’s decision. The NES panel report must include the
basis for their conclusion.
(6) If the ADASM rejects a panel opinion on whether the NES Standards are
met, the ADASM must notify the CTA and the Administrator of that
decision.
(7) The ADASM must inform the Authorizing Official of the final decision
within 2 weeks of receiving the panel’s report.
i. If the ADASM concludes that a NES Standard is not met, for ongoing operations,
the Authorizing Official must implement measures that ensure the NES Standards
are met (or pause affected operations) within two weeks of the ADASM
conclusion.
j. If the ADASM concludes that a NES Standard is not met for operations (or
changes to operations) that are not ongoing, the Authorizing Official must not
start or restart the operation (or approve the change) until measures are taken to
ensure that the relevant NES Standard is met.
k. For findings where the NES Standards are met but where other DOE or NNSA
requirements are not met, the authorizing official must ensure corrective actions
are implemented to meet the requirement no later than one year following
transmission of the signed NESSG report, or ensure that an exemption to the
requirement is requested.
Note: Deficiencies in which a DOE NES requirement is deemed not met must be
rectified as soon as reasonably practicable. The provision of one year is not a
NNSA SD 452.2 VII-5
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temporary waiver or exemption to a NES requirement. It is added to ensure that
the appropriate risk acceptance official (the exemption approval official) is
involved in a decision to not meet a DOE NES requirement over a protracted
period. An exemption should be requested as soon as it is known that a year may
pass before it is possible to meet the associated requirement. As described in
Attachment 2, when documenting a NES deficiency, the NESSG must identify
any NES requirements that are not being met. Not all NES deficiencies can be
linked to a specific NES requirement.
l. For findings where the NESSG indicates that the finding is or may be applicable
to other nuclear explosive processes, the NNSA Field Element or OST, as
applicable, in concert with the associated NNSA M&O contractor, must review
those processes for finding applicability. Because the NESSG may not be aware
of all instances where a finding may be applicable to other programs or processes,
the NNSA Field Element or OST, as applicable, must review the NESSG report
and direct action or further review if it is determined that any finding applies to
other processes not identified by the NESSG.
Section 37
m. The NNSA Field Element Manager or Assistant Deputy Administrator for Secure
Transportation identifies an appropriate NNSA line manager for each NES
evaluation finding. That manager is responsible for tasking action agencies and
ensuring corrective actions are both timely and effective. In some cases, such as
when the action agency is not under the purview of the NNSA Field Element
Manager or Assistant Deputy Administrator for Secure Transportation, the NNSA
Field Element Manager or ADAST must engage the Assistant Deputy
Administrator for Stockpile Management who then assigns appropriate NNSA
oversight for the action.
n. The NESSG Chairs, NESSG members, or other qualified NES personnel may be
consulted as needed in support of effective corrective action development. Action
agencies should coordinate proposed corrective action plans (CAPs) with their
own NES personnel and must coordinate CAPs with the NNSA Nuclear
Explosive Safety Division before submittal to the responsible NNSA Field
Element Office Manager or Assistant Deputy Administrator for Secure
Transportation, as applicable. The primary purpose of CAP coordination with
NES personnel is to provide early assurance that the plan (if properly
implemented) would resolve the identified NES deficiency. It does not assure
either a well-balanced corrective action or one free of unintended consequences.
If the finding is determined to apply to other NEOs as described in Section l
above, the corrective action plan must also address corrective actions for those
NEOs. The Associate Administrator for Safety and Health and the Assistant
Deputy Administrator for Stockpile Management must be on distribution for
CAPs involving NESSG findings where a NES Standard is not met or findings
where a minority opinion argues that a NES Standard is not met.
VII-6 NNSA SD 452.2
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3. DISTRIBUTION OF FINDING DISPOSITION CORRESPONDENCE.
All correspondence related to the disposition of findings including the Authorizing
Officials direction on findings, ADASM’s decision on a finding, and any NES panel
reports must be distributed to the following:
• Associate Administrator for Safety and Health.
• Assistant Deputy Administrator for Stockpile Management.
• Director, Office of Nuclear Weapon Stockpile.
• Director, Office of Nuclear Weapon Surety and Quality.
• Director, Nuclear Explosive Safety Division.
• Responsible NNSA Field Element.
• OST (if applicable).
• Design agency NES organizations.
• Production agency NES organizations.
4. FINDING CLOSURE PROCESS. Responsible NNSA Field Element and OST must
ensure a process for closure of NES evaluation findings is defined and implemented.
Each NNSA Field Element and OST must:
a. Ensure closure of findings where a NES Standard is not met prior to initiation or
continuation of affected NEOs.
b. Require detailed CAPs that include assignment of responsibility, allocation of
resources, and timing for closure of findings.
c. Ensure that proposed CAPs requiring a change to NEOs or MS topic are
evaluated using the change control process detailed in Chapter VI.
d. Provide for tracking of findings to closure.
e. Ensure compilation of a closure package with all information needed to support
closure decisions, including the action agency's request for closure, supporting
rationale, and evidence that the corrective actions are complete and effective in
addressing the NES deficiency.
Section 38
5. STATUS REPORTS. For all open findings, the action agency must generate and
distribute quarterly status reports documenting the planned resolution, schedule for
closure, and actions taken since the previous quarterly report. Distribution includes:
NNSA SD 452.2 VII-7
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• Associate Administrator for Safety and Health.
• Assistant Deputy Administrator for Stockpile Management.
• Director, Office of Nuclear Weapon Stockpile.
• Director, Office of Nuclear Weapon Surety and Quality.
• Director, Nuclear Explosive Safety Division.
• Responsible NNSA Field Element.
• OST (if applicable).
• Design agency NES organizations.
• Production agency NES organizations.
6. CLOSURE APPROVAL. The approval authority for closure of findings is the
responsible NNSA Field Element Manager or Assistant Deputy Administrator for Secure
Transportation, as applicable.
The preferred basis for closure of findings is acceptance by the closure authority that
effective corrective actions have been implemented.
Based on appropriate substantiation, the closure authority may also close a finding based
on evidence that the factual basis for the finding as documented in the NESSG report is
incorrect.
When a NES evaluation finding is closed based on rationale other than documented
completion of effective corrective action, such as the argument suggested above, the
NNSA Field Element Manager or Assistant Deputy Administrator for Secure
Transportation must document the rationale in a notification to the Assistant Deputy
Administrator for Stockpile Management with copies to:
• NNSA Central Technical Authority.
• Associate Administrator for Safety and Health.
• Director, Office of Nuclear Weapon Stockpile.
• Director, Office of Nuclear Weapon Surety and Quality.
• Director, Nuclear Explosive Safety Division.
• Design Agency NES organizations
VII-8 NNSA SD 452.2
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NES finding closure authorities must maintain an auditable record of closure decisions
and rationale. The Director, Nuclear Explosive Safety Division must perform an annual
review of finding closures.
NNSA SD 452.2 VIII-1 (and VIII-2)
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CHAPTER VIII
EXEMPTIONS
EXEMPTIONS.
Requests for exemptions must be forwarded to the Assistant Deputy Administrator for
Stockpile Management, who is the final approval authority.
The final approval authority may decide to deny the exemption request, in which case no other
concurrences are necessary.
Should the final approval authority decide to approve the request, the concurrence of the NNSA
Central Technical Authority (CTA) must be obtained prior to approval.
For time critical decisions, requests for approval and CTA concurrence may be made
concurrently, but approval may not be granted prior to receiving CTA concurrence.
THIS PAGE INTENTIONALLY LEFT BLANK
NNSA SD 452.2 Attachment 1
11-17-14 Page 1-1
CONTRACTOR REQUIREMENTS DOCUMENT
NNSA SD 452.2, NUCLEAR EXPLOSIVE SAFETY EVALUATION PROCESSES
Regardless of the performer of the work, the contractor is responsible for complying with the
requirements of this contractor requirements document (CRD) and flowing down CRD
requirements to subcontractors at any tier to the extent necessary to ensure contractor
compliance. This Contractor Requirements Document (CRD) establishes the requirements for
National Nuclear Security Administration (NNSA) contractors with responsibilities for operation
and/or management of sites or facilities and whose responsibilities include performing,
managing, overseeing, or directly supporting nuclear explosive operations (NEOs) or associative
activities.
Section 39
All contractors with this CRD incorporated in their contracts must comply with the following
requirements:
1. Ensure the training of and certify contractor nuclear explosive safety study group
(NESSG) members and contractor nuclear explosive safety (NES) representatives per the
requirements in CRD Appendix A.
2. Participate in NES evaluation planning meetings.
3. Ensure timely availability of Project Team, laboratory, and contractor personnel to
support NES evaluations.
4. Provide Technical Advisors (TAs) as requested by NESSG chair to support NES
evaluations.
5. Provide study-specific NESSG training in accordance with NESS planning meeting
decisions.
6. Lead the development of safety supporting documentation for NES evaluations and
ensure the completeness and accuracy of the information.
7. Provide NES evaluation input, briefings, and demonstrations as required, and certify the
completeness and accuracy of the information.
8. Ensure the Single Integrated Input Document (SIID) is delivered or presented to the
NESSG for their use at the orientation meeting, and available to members for
comprehensive review and evaluation during the NESSG preparation period prior to the
NESS.
9. Collaborate with NESSGs to refine plans and schedules for NES evaluations as needed.
10. For those organizations responsible for conducting NEOs, conduct CNCEs to assess
proposed changes or emerging information affecting an approved Nuclear Explosive
Operation (NEO) or associated Master Study topic.
Attachment 1 NNSA SD 452.2
Page 1-2 11-17-14
11. For those organizations responsible for conducting NEOs, establish a process for
approving and implementing contractor-allowable changes.
12. For those organizations responsible for conducting NEOs, evaluate the safety
implications of a proposed change in two ways: (1) an Unreviewed Safety Question
(USQ) screen by personnel trained to provide the safety basis perspective, and (2) a NES
review by a NES-certified representative. If the NES review indicates that a NESSG
review is required, the NNSA must approve the proposed change prior to
implementation, regardless of the outcomes of the USQ screen or USQ determination.
13. Develop the Corrective Action Plan (CAP) and take appropriate action on NES
evaluation findings as directed by NNSA.
14. For NES findings which cite a NES requirement is not met and cannot be corrected
within one year, develop an exemption request as directed by NNSA.
15. For all open findings for which they are an action agency, generate, and distribute
quarterly status reports documenting the planned resolution, schedule for closure, and
actions taken since the previous quarterly report. Distribution will include:
• Assistant Deputy Administrator for Stockpile Management.
• Associate Administrator for Safety and Health.
• Director, Office of Nuclear Weapon Surety and Quality.
• Director, Nuclear Weapons Stockpile.
• Director, Nuclear Explosive Safety Division.
• Responsible NNSA field offices.
• OST (if applicable).
• Design agencies (if applicable).
• M&O contractors (if applicable).
16. Ensure that NES evaluation personnel selected for a given NES evaluation will be able to
devote their time for the duration of the NES evaluation. Conflicting assignments must
be resolved in favor of NES evaluation duties from the date the input documentation is
made available until conclusion of the NES evaluation.
Section 40
17. For those organizations responsible for conducting NEOs, if a NESS will not be
conducted within the timeframe specified, ensure that requests for extensions are
submitted to the Assistant Deputy Administrator for Stockpile Management in writing,
with a copy to the Director, Office of Nuclear Weapon Stockpile, Director, Office of
NNSA SD 452.2 Attachment 1
11-17-14 Page 1-3
Nuclear Weapon Surety and Quality, and Director, Nuclear Explosive Safety Division, at
least 30 days prior to the deadline.
18. For those organizations responsible for conducting NEOs, ensure CNCEs are used to
determine whether the contractor is the responsible approval authority, or whether the
proposal or issue must be elevated to a NESSG for NES evaluation.
19. For those organizations responsible for conducting NEOs, CNCEs elements are as
follows:
a. Focus. CNCEs consider the NES implications of:
• proposed changes to procedures, materials, tooling, testers, other equipment,
facilities, facility interfaces, or management programs associated with
approved NEOs and
• emerging information affecting approved NEOs.
b. Documentation. The contractor takes the lead in developing the safety support
documentation and compiling inputs that may be needed from the design agencies
and NNSA. The contractor ensures the completeness of the documentation, if
any, as well as the explicit certification of its technical accuracy by the providing
organizations.
Sufficient information must be provided to establish that proposed changes are
not a threat to NES including, as applicable:
(1) A complete description of the proposal or issue with process flow
representations and detailed written procedures, as appropriate.
(2) Rationale for the proposed change, with concurrence from responsible
management personnel and design agency representatives, as appropriate.
(3) Relevant safety basis information as needed to support a determination
c. Determination Process. With a particular emphasis on potentially adverse
impacts on NES, a contractor NES representative must review the submitted
documentation and presented information, and answer the following questions to
determine if the proposal must be elevated to NNSA for NES evaluation in an
NCE or NESS.
(1) Does the proposed change add, delete, or modify a nuclear explosive
safety rule (NESR), immediate-action procedure (IAP), or other positive
measure identified as important to NES in a previous NES evaluation
report?
(2) Does the proposed change involve new Category 1 electrical equipment or
the addition of an electrical test of a nuclear explosive?
Attachment 1 NNSA SD 452.2
Page 1-4 11-17-14
(3) Does a proposed change to Category 1 electrical equipment involve more
than minor modifications that clearly do not affect the functionality,
quality, safety analysis, or security controls for the equipment?
(4) Does the proposed change to a NEO involve a procedure, tooling, tester,
other equipment, transportation activity, facility interface or other process
or feature that is not bound by activities examined in a previous NES
evaluation?
(5) Does the proposed change involve the potential application of additional
electrical, mechanical, thermal, chemical, or electromagnetic energy to a
nuclear explosive (NE), or the application of the above energy types to
other circuitry or components of a NE in a manner or in an amount that is
not bound by activities examined in a previous NES evaluation?
(6) Could the proposed change affect one-point safety?
Section 41
(7) Does the proposed change affect lifting, rotating, or other NE movement
operations not bound by activities examined in a previous NES
evaluation?
(8) Does the proposed change require an implementation of the Two-Person
Concept that does not meet the requirements set forth in DOE M 452.2-1A
(or its successor directive)?
(9) Does the proposed change involve a NEO relocation that would adversely
impact NES?
(10) Does the proposed change involve an implementation of permanent
markings or NELA verifications that does not meet the requirements set
forth in DOE M 452.2-1A (or its successor directive)?
(11) Does the proposed change involve a management program or process,
including any form of work instructions or operating standards that could
adversely affect NES?
(12) Has information been presented that could alter previous NES evaluation
conclusions in a manner that could adversely affect NES?
An NNSA NES evaluation is required if the answer to one or more of the
preceding questions is "yes" or "unknown.” If the answer to each of the
preceding questions is "no," an NNSA NES evaluation is not required.
The contractor must document the basis for, and maintain an auditable record of
all CNCE determinations according to National Archives and Records
Administration (NARA)-approved DOE Records Schedules. These auditable
records are subject to NNSA oversight.
NNSA SD 452.2 Attachment 1
11-17-14 Page 1-5
d. Determination Outcomes.
1. NESSG Evaluation Required. Once a contractor NES representative has
determined that evaluation by a NESSG is required, the NNSA contractor
can decide whether or not to pursue the proposed changes or response to
emerging information. For proposed changes or response to emerging
information that line management decides to pursue, the NNSA
Production/Field Office Manager works with the Director, Nuclear
Explosive Safety Division to jointly determine whether a NESS or NCE is
the appropriate NES evaluation. Once the appropriate evaluation is
determined, the contractor submits a request to the Director, Nuclear
Explosive Safety Division to schedule the appropriate NES evaluation.
2. NESSG Evaluation Not Required. When it is determined that evaluation
by a NESSG is not required, the contractor is the approval authority. The
NNSA contractor must establish a process for approving and
implementing changes and responses to emerging information that do not
require NESSG evaluation. The contractor must maintain auditable
records subject to NNSA oversight clearly establishing that NES is not
adversely impacted by changes for which they have cognizance.
20. Responsible NNSA contractors must ensure a process for closure of NES evaluation
findings is defined and implemented. Each contractor must:
a. Assess whether findings are relevant to NEOs in addition to that which produced
the finding. If so, include associated corrective actions in the CAP.
b. For those organizations responsible for conducting NEOs, ensure closure of
findings where a NES standard is not met prior to initiation or continuation of
affected NEOs.
c. Develop detailed CAPs that include assignment of responsibility, allocation of
resources, and timing for closure of findings.
d. For those organizations responsible for conducting NEOs, ensure that proposed
CAPs requiring a change to NEOs or MS topic are evaluated using the change
control process detailed in paragraphs 17 and 18 above.
e. Track and report status of findings to closure.
Section 42
f. Compile a closure package with all information needed to support closure
decisions, including the action agency's request for closure, supporting rationale,
and evidence that the corrective actions are complete and effective in addressing
the NES deficiency.
g. For all open findings for which the contractor is an action agency, generate, and
distribute quarterly status reports documenting the planned resolution, schedule
Attachment 1 NNSA SD 452.2
Page 1-6 11-17-14
for closure, and actions taken since the previous quarterly report. Distribute these
reports to:
• Associate Administrator for Safety and Health.
• Assistant Deputy Administrator for Stockpile Management.
• Director, Office of Nuclear Weapon Stockpile.
• Director, Office of Nuclear Weapon Surety and Quality.
• Director, Nuclear Explosive Safety Division.
• Responsible NNSA Field Element.
• OST (if applicable).
• Design agency NES organizations.
• Production agency NES organizations.
NNSA SD 452.2 Attachment 1, Appendix A
11-17-14 A- 1
NNSA CONTRACTOR NESSG MEMBER AND NES REPRESENTATIVE
QUALIFICATION REQUIREMENTS
1. PURPOSE. This Appendix establishes requirements for NNSA Contractor NES-certified
personnel (NESSG members and NES representatives) to attain the competencies needed
to fulfill their NES duties and responsibilities. The NESSG member requirements are
intended to ensure that NNSA Contractor NESSG members have at least the same level
of competency as established for federal employee NESSG members in DOE-STD-1185,
Nuclear Explosive Safety Study Functional Area Qualification Standard.
2. IMPLEMENTATION REQUIREMENTS. Organizations providing NES-certified
personnel must establish a process, subject to NNSA oversight, to ensure each of its
NESSG members and NES representatives meets the education, experience, personal
characteristics, independence, and technical competence requirements specified in this
Appendix.
a. Personal characteristics. All NNSA contractor NES-certified personnel must –
(1) bring reasoned judgment to NEO evaluations;
(2) have the ability and willingness to question and challenge NNSA line
management safety statements and rationale for issues with the potential to
impact NES;
(3) be able and willing to actively participate as part of a team and to take
unpopular stands when warranted;
In addition, NNSA contractor NESSG members must –
(4) have the ability to—
(a) develop appropriate NES evaluation approaches; contribute to
effective planning meeting decisions;
(b) critically assess input documentation, briefings, and
demonstrations;
(c) develop and pursue relevant lines of inquiry; articulate NES
concerns;
(d) develop appropriate feedback; and
(5) have oral communication skills to participate effectively in deliberations
and written communication skills to clearly document conclusions.
b. Training. NNSA contractors providing NES-certified personnel must ensure their
NESSG members and NES representatives receive the training required to
achieve and maintain the proficiencies needed to meet the requirements
Attachment 1, Appendix A NNSA SD 452.2
A-2 11-17-14
established in this Appendix. Contractors must also ensure that a process exists
for experienced NES personnel to convey useful knowledge to less experienced
NES personnel.
c. Independence. All NNSA contractor NES-certified personnel must make
objective, independent judgments regarding the NES adequacy of systems,
operations, and processes. NES-certified personnel must not be subject to
management influence in performing their NES obligations, and must not—
Section 43
a. have current responsibility for the design, development, production, or
testing of the specific nuclear explosive, NEO, facility, or management
system under evaluation;
b. have responsibility for advocacy of special interests of any organization,
or for defending the specific nuclear explosive, NEO, facility, or
management system under evaluation; or
c. participate in the preparation of NESS input technical documentation,
OSR supporting documentation, NCE input, or the preparation or
presentation of briefings or demonstrations.
d. Certification.
NES personnel certifications must be based on satisfaction of the requirements for
personal characteristics, training and independence (paragraphs 2a to 2c, above)
and the requirements for education, experience, technical competencies, and
proficiency activities (paragraphs 3 to 7 below). NNSA contractors must
designate certification authorities who can objectively judge whether their NES-
certified personnel meet these requirements. Certification is documented by a
certification letter to the Director, Nuclear Explosive Safety Division and is valid
for two years.
Certification authorities must document attainment of required competencies
using the following methods:
(1) Documented evaluation of equivalencies
(2) Written examination
(3) Documented oral evaluation
(4) Documented observation of performance
(5) Documented interview by Senior Management in the applicable
organization
3. EDUCATION AND EXPERIENCE. The levels of education and experience for NNSA
Contractor NES-certified personnel are:
NNSA SD 452.2 Attachment 1, Appendix A
11-17-14 A- 3
a. Education:
(1) NESSG Members: Bachelor of Science degree in engineering, physics,
materials science, or chemistry with a strong preference for individuals
with advanced engineering degrees. Other technical degrees, in
conjunction with the appropriate experience, may be considered by the
Director, Nuclear Explosive Safety Division. NESSG members that were
certified prior to the initial release of this supplemental directive are
exempt from meeting these education requirements.
(2) NES Representatives: Bachelor of Science in a technical field with a
preference for degrees in engineering, physics, materials science, or
chemistry. Other technical degrees, in conjunction with the appropriate
experience, may be considered by Director, Nuclear Explosive Safety
Division. NES Representatives that were certified prior to the initial
release of this supplemental directive are exempt from meeting these
education requirements.
b. Experience:
(1) NESSG Members: Five (5) years of industrial, military, Federal, state, or
other directly related experience that has provided specialized experience
in nuclear explosive safety, design, assembly/disassembly, maintenance,
testing, transportation, handling, or storage; or other similar experience in
high consequence explosive or nuclear safety operations. Specialized
experience can be demonstrated through possession of the competencies
outlined below.
(2) NES Representatives: Three (3) years of industrial, military, Federal, state,
or other directly related experience that has provided specialized
experience in nuclear explosive safety, design, assembly/disassembly,
maintenance, testing, transportation, handling, or storage; or other similar
experience in high consequence explosive or nuclear safety operations.
Specialized experience can be demonstrated through possession of the
competencies outlined below. Prior experience with nuclear explosive
assembly/disassembly operations, nuclear explosive operating procedure
development, or nuclear explosive facilities is preferred.
Section 44
4. TECHNICAL COMPETENCIES. NES-certified personnel technical competency
requirements are as follows:
a. Expert-level Knowledge. NESSG-certified personnel must have an extensive
depth and breadth of knowledge in the following areas so they can provide sound
advice in the absence of procedural guidance:
(1) DOE O 452.1D Admin Chg 1, Nuclear Explosive, and Weapon Surety
Program¸ dated 07-10-13, or most recent successor document.
Attachment 1, Appendix A NNSA SD 452.2
A-4 11-17-14
(2) DOE O 452.2D Admin Chg 1, Nuclear Explosive Safety, dated 07-10-13,
or most recent successor document.
(3) DOE M 452.2-1A Admin Chg 1, Nuclear Explosive Safety Manual, dated
7-10-13, or most recent successor document.
(4) NNSA SD 452.2, Nuclear Explosive Safety Evaluation Processes, most
recent revision.
b. Working-level Knowledge. NES-certified personnel must have sufficient
knowledge in the following areas to ensure they are able to effectively monitor
and assess operations and activities; apply performance and safety standards; and
recognize the need to consult appropriate reference materials and/or seek expert-
level advice:
(1) Physics of nuclear weapons and explosives.
(2) Materials used in nuclear weapons and nuclear explosives, and their
respective hazardous properties.
(3) Internal design of nuclear explosives.
(4) Nuclear detonation safety design concepts.
(5) Effects of abnormal environments on nuclear explosives.
(6) One-point safety and related issues.
(7) Fusing, arming, control, and ancillary systems in nuclear weapons.
(8) Explosives and pyrotechnics and their applicability in nuclear explosives.
(9) Detonators.
(10) Hazards of squibs, propellants, and other pyrotechnics used in nuclear
explosives.
(11) Facilities used to assemble, disassemble, stage, test, and handle nuclear
explosives.
(12) Facility safety equipment that interfaces with nuclear explosives.
(13) Electrical isolation systems and their importance to NES.
(14) Fire protection systems and their importance to NES.
(15) Threats such as seismic disturbances, extreme weather, external fires,
other natural phenomena, and aircraft crashes.
NNSA SD 452.2 Attachment 1, Appendix A
11-17-14 A- 5
(16) Tooling, rigging, and hoisting equipment used for handling nuclear
explosives.
(17) Control of electrical equipment used in nuclear explosive areas.
(18) Requirements for the safe offsite and onsite transportation of nuclear
explosives.
(19) Nuclear safety requirements for the safety of nuclear explosive operations
at NNSS.
(20) NESRs for NEOs conducted at the Device Assembly Facility at NNSS.
(21) Technical communications, including demonstrated proficiency in written
communication, oral communication, interpersonal communications, and
proficiency in writing a defensible NESS finding.
(22) Explosive safety requirements in DOE-STD-1212-2012, Explosives
Safety, dated June 2012; associated with general operations safety
guidelines, work environment, area controls, electrical storms, lightning
protection, static electricity, electrostatic discharge (ESD), electrical
equipment and wiring, material handling, transportation, stand-off
distance.
(23) Requirements in DOE O 452.4B, Security and Control of Nuclear
Explosives and Nuclear Weapons, dated 1-22-10, for protection, security,
and control of nuclear explosives and nuclear weapons.
(24) Requirements in 10 CFR Part 712, Human Reliability Program.
Section 45
c. Familiarity-level Knowledge. NES-certified personnel must have adequate
knowledge of, or exposure to, the following subjects and processes to permit
effective discussions with individuals having greater knowledge:
(1) U.S. nuclear stockpile.
(2) DOE STD 3009-94, Change Notice 3, Preparation Guide for U.S.
Department of Energy Nonreactor Nuclear Facility Safety Analysis dated
March 2006.
(3) DOE-NA-STD-3016-2006, Hazard Analysis Reports for Nuclear
Explosive Operations, dated May 2006.
(4) DOE O 420.1C, Facility Safety.
(5) 10 CFR Part 851, Worker Safety and Health.
(6) 10 CFR Part 830, Subpart A, Quality Assurance Requirements.
Attachment 1, Appendix A NNSA SD 452.2
A-6 11-17-14
(7) Documented Safety Analysis requirements of 10 CFR Part 830, Nuclear
Safety Management, Subpart B, Safety Basis Requirements.
(8) The USQ process with respect to its impact on NEOs and associated
activities and facilities.
(9) TSRs as described in 10 CFR 830.205, Technical Safety Requirements.
(10) The impact of software quality assurance on NES.
(11) Safety analysis techniques and their application to NEOs, facilities, and
associated activities.
5. PERFORMANCE REQUIREMENTS.
a. NESSG Members. NESSG members-in-training must be under the guidance and
direction of a certified NESSG member from the candidate’s organization. The
certified NESSG member and NESSG chair must provide feedback to the
candidate and the appropriate certification authority regarding the candidate's
performance. Members-in-training may not sign NES evaluation reports.
NESSG candidates must participate in a minimum of two NES evaluations (NESS
or OSR) as a member-in-training in the three years preceding documented
completion of the competency requirements of this Appendix. Two NCEs may be
substituted for one NESS/OSR with the concurrence of the certifying official.
b. NES Representatives: NES representative candidates must observe one NESS or
OSR and one NCE prior to certification. NES representative candidates must
demonstrate the ability to perform CNCEs under the guidance and direction of
NES-certified personnel prior to certification.
6. EVALUATION REQUIREMENTS. Certification authorities must maintain records of
attainment of the required competencies including documented evaluation of
equivalencies as appropriate, written examination, documented oral evaluation, and
observation of performance.
7. CONTINUING EDUCATION, TRAINING, AND PROFICIENCY.
a. NESSG Members: NESSG members must participate in two major NESSG
activities (NESSs or OSRs), every three years to remain certified. Two NCEs,
Nuclear Weapon System Safety Group (NWSSG) studies, or ARG exercises may
be substituted for one NESS/OSR with concurrence of the certifying official.
NESSG members must participate in a minimum of 30 hours of
office/facility/position specific continuing training per year.
b. NES Representatives: NES representatives must maintain proficiencies through
continuing training.
NNSA SD 452.2 Attachment 1, Appendix A
11-17-14 A- 7
c. Continuing Training. Continuing training for NES-certified personnel may be
satisfied by office/facility/position specific training that includes technical
education and/or training covering topics directly related to the duties and
responsibilities of the candidate as determined by NNSA line management. This
may include courses and/or training provided by:
(1) DOE
(2) National Laboratories
(3) Management and Operating Contractors
Section 46
(4) Annual Nuclear Explosive Safety Workshops
(5) Other government agencies
(6) Outside vendors, or
(7) Educational institutions
d. Training covering topics that address identified deficiencies in the knowledge
and/or skill of the candidate.
e. Training in areas added to the technical competencies after initial qualification.
f. Training in new technical developments in nuclear explosive safety.
g. Specific continuing training requirements must be documented, retained, and
available for external audit.
8. EQUIVALENCIES AND EXEMPTIONS. Equivalences to, and exemptions from,
specific competencies for individual candidates for NES certification (NESSG member or
NES representative) must be justified, documented, and submitted to the appropriate
certification authority. In accordance with the spirit and intent of this Appendix,
equivalencies and exemptions should be granted sparingly following rigorous assessment
of a candidate's:
a. Knowledge, including advanced education such as graduate level courses directly
related to these competency requirements.
b. Experience and skills.
c. Training, especially that which included examinations.
d. Certifications, such as a Professional Engineering license.
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NNSA SD 452.2 Attachment 1, Appendix B
11-17-14 B-1
NESS INPUT DOCUMENTATION
1. Existing documents containing required information may be acceptable as NESS inputs.
Examples include the following documents as well as their contained references: safety
analysis reports (SARs), hazard analysis reports (HARs), technical safety requirements
(TSRs), basis for interim operations, and weapon safety specifications (WSSs). Existing
documents used as NESS inputs should be appropriately indexed to facilitate topical
searches. The organization compiling the input documentation includes explicit
certification of the technical accuracy and completeness of the input documentation from
each organization providing input.
Explicit certification must be provided formally in a letter, memorandum, or engineering
authorization. Completeness is determined by the inclusion of the appropriate documents
listed in this Appendix. Accuracy means that information will be verified to be correct
and current. The requirement for current information does not preclude historical
documents which may be pertinent to NES from being included in the SIID. The Project
Team will identify any historical documents included in the SIID to the NESSG.
2. Input documentation, compiled in a single integrated input document (SIID) and tailored
as appropriate for each NESS, must include the following, if applicable.
a. A description of the specific nuclear explosive for an operation-specific study. As
appropriate to each NESS, the description must include paragraphs 2a(1)-(10) and
consideration of significant differences in these items at different levels of
assembly.
(1) A general overview and a detailing of associated modifications and
alterations and their NES implications.
(2) One-point safety analyses, including a summary of test results and
analysis of interfaces between the nuclear explosive and process tooling.
(3) NES theme and description of the nuclear explosive design safety features.
(4) Unique or unusual conditions related to the specific nuclear explosive or
its components.
(5) Electrical circuits and their functions within the nuclear explosive.
Section 47
(6) Characteristics of energetic devices and materials, including explosives,
detonators, actuators, propellants, reactive materials, batteries, high-
pressure vessels, and flammable and combustible materials.
(7) Weapon response data for inadvertent nuclear detonation (IND) and high
explosive violent reaction (HEVR) scenarios.
Attachment 1, Appendix B NNSA SD 452.2
B-2 11-17-14
(8) Susceptibilities of the nuclear explosive to energy sources, including, but
not limited to electrostatic discharge (ESD), electromagnetic radiation, and
other electrical, thermal, mechanical, and chemical energy sources.
(9) Potential hazards associated with, but not limited to spin rockets,
parachute deployment systems, telemetry features and connectors, use
control features, and instrumentation for nuclear explosive test devices.
(10) Non-NNSA-supplied components that are a part of the nuclear explosive
while it is in NNSA custody.
b. A description of the operation-specific NEO, including:
(1) Process Flow.
(2) Written procedures that are under change control and sufficiently
developed to be used in the NEO upon approval.
(3) Unique or unusual features relating to a process, tooling, or other utilized
equipment.
(4) Drawings, descriptions, and safety analyses of process tooling, other
equipment, and interfaces with the nuclear explosive.
(5) Drawings, descriptions, and safety analyses of Category 1 and 2 electrical
equipment (including use control equipment), including an independent
safety assessment of the Category 1 electrical equipment and their
interface with the nuclear explosive.
(6) Drawings, descriptions, and safety analyses of transportation equipment
and operations including, but not limited to, shipping containers and
restraint schemes.
(7) Proposed tests and inspections, including supporting rationale.
(8) Process and equipment engineering evaluation findings that may impact
NES.
c. Safety basis information including, but not limited to:
(1) The safety basis for evaluated NEO facilities, including seismic analyses,
lightning analyses, description of fire protection and detection systems,
and definition of design basis accidents.
(2) A hazards assessment for specific NEOs.
NNSA SD 452.2 Attachment 1, Appendix B
11-17-14 B-3
(3) Identification of all postulated accident scenarios that result in inadvertent
nuclear detonation (IND) or high explosive (HE) violent reaction in a
nuclear explosive area.
(4) Analysis and vulnerability assessment of pathways leading to inadvertent
nuclear detonation.
(5) Isolation of nuclear explosives from unwanted energy sources internal or
external to the facility, including electrical, thermal, mechanical,
electromagnetic, and chemical energy sources.
(6) Potential threats to NES from security operations, surveillance and other
inspection requirements, software-controlled equipment, human error, and
such weapon-associated systems as spin rockets, parachute deployment
systems, use control features, and instrumentation for nuclear explosive
test devices.
(7) Identification of controls for inadvertent nuclear detonation and HEVR
hazards, including supporting rationale, test data and analyses, their
respective source documents, and implementing procedures.
d. Relevant information from existing NES evaluation reports including both open
and closed findings and status of implemented and pending corrective actions for
NES evaluation findings.
Section 48
e. Relevant occurrence reports, significant finding investigations (SFIs), and DoD
unsatisfactory reports (URs).
f. Relevant Weapon Safety Specifications, Final Weapon Development Reports,
weapon response documents, and documentation containing similar weapon
safety-related information.
g. For facility MSs, for each item in paragraph (1) below (Facility Master Study
Items), provide the information in paragraph (2) below (Information Required), as
applicable.
(1) Facility Master Study Items.
(a) Facility safety basis documents, including applicable site-wide
safety basis documentation and TSRs.
(b) Facility structure and support areas such as electrical and
mechanical rooms, loading/unloading docks, and ramps.
(c) Facility/zone/site utilities, such as heating, ventilation and air
conditioning, uninterruptible power supply, compressed air,
vacuum, lighting, and water.
Attachment 1, Appendix B NNSA SD 452.2
B-4 11-17-14
(d) Facility/zone/site safety systems such as fire protection, lightning
protection, radiation alarms and monitors, blast door interlock,
emergency lighting, criticality, public address, telephone,
conductive flooring, and waste management.
(e) Facility special processing equipment such as the paint booth and
fume hood, gas manifolds, dynamic balancer, and linear
accelerator and associated general NEOs.
(f) Facility general purpose support equipment such as flammable
storage cabinets, tooling cabinets, materials requirements planning
terminal, and emergency wash.
(g) General use handling and transportation equipment such as hoists,
cranes, modified transportation vehicles and trailers, forklifts, tow
motors, pallet jacks, loading/unloading equipment, restraints and
associated general NEOs.
(h) Facility/zone/site weapon process approved equipment including
special and commercial tooling, electrical testers, supplemental
electrical equipment, and qualified containers.
(i) Support materials such as controlled consumables and other
commercially-derived materials that may come in contact with a
nuclear explosive.
(j) Facility/zone/site support operations including security forces,
radiation safety responders, fire protection and emergency medical
service personnel, emergency management responders, facility
engineers, maintenance and crafts personnel which impact NES.
(k) Nearby facilities, vehicles, railways, and airfields which impact
NES.
(2) Information Required.
(a) Description and overview.
(b) Associated management programs (e.g., training programs,
emergency responses programs, preventive maintenance programs,
procedure development and change control, etc.).
(c) Design requirements, codes, and standards.
(d) Design process and criteria, including natural phenomena, blast,
radiation shielding, electrical grounding, and any credible
abnormal events.
NNSA SD 452.2 Attachment 1, Appendix B
11-17-14 B-5
(e) Construction, procurement, and fabrication processes.
(f) Deviations from design.
(g) Readiness assessment and/or safety and quality qualifications.
(h) NES change control process.
(i) Modifications, upgrades, and re-qualification.
(j) Maintenance, repair, and surveillance processes and re-
qualification.
(k) Use, storage, access, and emergency egress controls.
(l) Retirement process.
(m) Engineer, technician, and first-line supervisor qualifications and
training.
(n) Emergency communications.
(o) Hazards and controls, including those applicable to unauthorized
acts.
(p) Proposed enhancements and recommendations.
Section 49
(q) Associated technical procedures and manuals.
h. For other MSs, the input document requirements must be jointly determined by the
Project Team and NESSG chair during planning meetings.
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NNSA SD 452.2 Attachment 2
11-17-14 Page 2-1
CRITERIA FOR CATEGORIZING ISSUES FROM NUCLEAR EXPLOSIVE SAFETY
EVALUATIONS
1. This Attachment provides guidance for characterizing issues identified by Nuclear
Explosive Safety Study Groups (NESSGs) performing NES evaluations. The criteria in
this Attachment is also used to guide and inform other personnel who prepare for NES
evaluations or respond to the NES evaluation results.
2. The following criteria are tools intended to aid the thought process when categorizing
issues arising in NES evaluations. They are not absolute gauges. This is a guide to good
judgment not a substitute for it. When categorization of an issue seems difficult,
uncertain, or controversial, the criteria can be used to help focus the debate and arrive at a
logical conclusion. Even when categorization of an issue seems obvious, the criteria can
be used as a crosscheck of the rationale and to help document the NES evaluation
conclusions effectively.
a. An issue might have different aspects that warrant different categorizations. In
that case, the NESSG should consider if it would be helpful to split the write-up to
segregate deficiencies and deliberation topics for which the NES Standards
remain met, from deficiencies that indicate that NES Standards are not met.
b. When the NESSG concludes that positive measures for a credible hazard are
deficient or missing and review of existing analyses does not reveal adequate
nuclear explosive safety, positive measures should be treated as inadequate for the
purpose of issue categorization.
c. A suggested approach is to begin with the criteria in Table 1 which poses
questions associated with fundamental SS-21 process design goals. The answers
to those questions are then assessed using measures of merit related to the two
DOE O 452.1D NES Standards.
d. Table 2 provides criteria for Deliberation Topics.
Attachment 2 NNSA SD 452.2
Page 2-2 11-17-14
Table 1
SS-21 Based Criteria
Is the scenario credible?
See Section 4 of this Attachment.
Yes – Continue.
No – Consider for a Deliberation Topic.
1. Does the deficiency reflect
inadequate positive measures to
prevent application of unauthorized
or unanalyzed external energy to a
nuclear explosive (NE)? If so, could
that external energy cause release of
internal energy from the NE?
Apply the following guidance to each
question:
Yes, with gaps or weaknesses in positive
measures to prevent nuclear detonation
(ND) or high explosive violent reaction
(HEVR) of the NE
–– Categorize as finding. Identify which
NES Standard is not met.
Yes, but gaps or weaknesses in positive
measures to prevent ND and HEVR
were not identified. Deficiency reflects
(1) a condition that if allowed to persist
could weaken positive measures relied
upon for NES or (2) failure to meet the
intent of NES requirements
–– Categorize as finding. NES
Standards are met. Identify specific
requirements, if any, that are not met.
Yes, possibly leading to non-NES adverse
consequences
–– Categorize as Deliberation Topic
No to all seven questions
–– Consider for a Deliberation Topic.
2. Does the deficiency reflect a single-
point failure that could cause an
energy source in the NE to be
activated or released?
Section 50
3. Does the deficiency reflect a poorly
written procedure that could
contribute to an incorrect or
unauthorized act, or to missing a
detectable significant abnormal
condition?
4. Does the deficiency reflect a possible
bypass or compromise of safety
attributes relied upon (NE, tooling,
tester, other equipment, facility,
procedure, management system, or
personnel)?
5. Does the deficiency reflect
inadequate characterization or control
of the facility, equipment, material,
energy sources, or personnel that
support nuclear explosive operations?
6. Does the deficiency reflect
inadequate personnel selection,
training, qualification, or reliability?
7. Does the deficiency reflect a potential
threat to NES other than those above?
NNSA SD 452.2 Attachment 2
11-17-14 Page 2-3
Table 2
Criteria for Deliberation Topics
Deliberation Topics document NESSG discussions on selected lines of inquiry that did not result
in a finding. That is, the issue was determined not to be a NES deficiency––at least within the
scope of the evaluation; the issue requires no further corrective action for the studied operations.
These issues are considered significant because of the importance of the topic (or its resolution
rationale) for this evaluation or future NES evaluations. This includes:
1. Issues that were resolved by additional input or deliberations.
2. Issues for which adequate corrective actions were proposed by line management, accepted by
the NESSG, and implemented before the end of the NES evaluation. The NESSG report
should highlight these topics and include sufficient information to support assessment of the
extent of condition as is done for findings.
3. Issues that do not reflect current NES deficiencies for the studied operations, but which
might be considered deficiencies by other disciplines or other operations.
The key attribute of a Deliberation Topic is that the NESSG determined the issue is not a NES
deficiency for the studied operations. The Resolution section of the write-up must explain why,
typically with rationale centered on items 1, 2, or 3 above.
Note that coverage of an issue as a Deliberation Topic in a NESSG report does not necessarily
mean that action is not warranted. It only reflects a NESSG judgment that no corrective action
is needed for the studied operations. Cognizant managers must determine if action is needed to
address non-NES deficiencies or to correct problems in NEOs outside the scope of the NES
evaluation.
3. CONTENT OF NES EVALUATION FINDINGS.
a. It is critical that all findings be written in a manner that clearly communicates to
managers and to those charged with developing and implementing corrective
action the nature of the issue and the relative urgency of corrective action. It
should be clear what hazard environment, positive measures, consequence, or
NES requirement is at issue. Suggested content for NES findings follows.
(1) Factual Basis. Identify what was observed (event, condition, activity,
documentation, equipment, etc.), and when and where it was observed
(bay, cell, input document, NEOP, briefing, etc.).
(2) Adverse Environment. Identify the factors contributing to the adverse
environment, source and form of energy, relevant nuclear explosive
configurations, and why the environment is considered adverse with
respect to NES. The write-up should also discuss the credibility of the
hazardous environment/energy source.
Attachment 2 NNSA SD 452.2
Page 2-4 11-17-14
Section 51
(3) Limitations of Positive Measures. Explain how the positive measures
incorporated in the governing procedures are considered inadequate to
prevent or mitigate the adverse environment (i.e., where the gaps or
weaknesses are). The write-up should identify whether the inadequacy is
a result of the absence of relevant positive measures, lack of effective flow
down to operating procedures, lack of protection against future adverse
changes, or other factors that bring into question the enduring
effectiveness of the positive measures.
(4) Consequence. Clearly state the NES consequences from the hazard
identified.
(5) NES Requirements. If applicable, the write-up should identify the NES
Standard or other NES criterion in question and discuss the NES impact of
the specific situation. Some issues might clearly relate to one or both of
the NES Standards and sometimes the distinction between the two
Standards is not particularly informative. However, when nuclear
detonation or main charge high explosive violent reaction is a credible
consequence, the write-up should make that clear. If the issue is
conformance to NES criteria other than the two NES Standards, the write-
up should convey the NESSG’s judgment on the NES impact of the
nonconformance.
(6) Issue Categorization. Based on the information in (1) through (5) and
application of the finding categorization criteria, the NESSG makes its
judgment on whether a NES Standard is not met. The NESSG rationale
for this judgment should be made clear to readers, typically in terms of the
NES finding criteria and other guidance in this Attachment.
(7) Extent of Condition. If the issue is known by the NESSG to extend to
other programs or operations, the NESSG should state that fact in the
deficiency.
b. Effective use of the guidance above does not necessarily require a lengthy write-
up with discrete sections for each topic. The outline above might be a logical
presentation for many instances, but not for all. Authors should consider the
information above and then tailor content, format, and length as needed to convey
most effectively the NESSG conclusions and rationale for each finding. The
objective is to write so that an informed reader who was not present at the NES
evaluation can understand the NESSG conclusions and rationale.
c. Once a finding is drafted, Table 3 can be used to assess the quality and
completeness of the write-up.
NNSA SD 452.2 Attachment 2
11-17-14 Page 2-5
Table 3
Finding Checklist
1. Is the scenario credible? See Section 4 of this
Attachment.
Yes – Continue.
No – Consider for Deliberation
Topic.
2. Considering everything the NESSG has seen, heard,
read, and deliberated––is the issue a NES deficiency?
Yes – Continue.
No – Consider for Deliberation
Topic.
3. Is the issue within the scope of the NES evaluation?
(See note* below.)
Yes – Continue.
No – Consider for Deliberation
Topic.
For Questions 4 through 5, try to set aside all the background and impressions gained in the
course of the NES evaluation; focus on the written words. Critically assess whether the words
effectively convey the NESSG conclusions and rationale.
4. Does the NES Deficiency statement provide a concise
summary of the NES issue and make the objective clear
without prescribing a solution?
Yes – Continue.
No – Rewrite NES Deficiency
statement.
5. Does the written discussion support the NES
Deficiency statement? Does it:
• Identify the factual basis? (i.e., observations, input
Section 52
documents, briefings, written procedures, etc.)
• Clearly describe the issue and communicate logical
rationale?
• Identify the expected benefit for NES of taking
corrective action?
• Cite DOE or NNSA requirements that are not met (if
any)?
• Explicitly state how the NES Standard is not met (if
applicable)?
• Reflect relevant criteria from Table 1 or other
reasonable rationale?
Yes –Done.
No – Clarify the write-up (so that
an informed reader can
understand the NESSG
conclusion).
*Note: The NESSG should stay focused on the scope of the review. However, obvious NES
deficiencies must not be ignored and should be appropriately documented and reported to
NNSA. If a NES concern is beyond the scope of the NES evaluation and requires significant
time to research or deliberate, then the NES concern should be documented in the report with a
recommendation to NNSA management that the NES concern be evaluated in a separate NES
evaluation in order to determine if a deficiency exists.
4. CREDIBILITY OF SCENARIOS.
A credible scenario is a scenario that has a credible initiating event, and is itself credible
in the absence of controls. That is, qualitatively, it is reasonable to believe that the
scenario could happen considering the nature of the process involved, available energy
Attachment 2 NNSA SD 452.2
Page 2-6 11-17-14
sources, materials, material quantities, form and location, but without taking safety
measures into account that would prevent or mitigate the scenario.
A credible NES scenario is a scenario that could be reasonably believed to produce an
environment capable of initiating the main charge high explosive in a nuclear explosive
(i.e. IND or HEVR), also in the absence of controls, considering only the nature of the
process involved, available energy sources, materials, material quantities, form and
location, but without taking safety measures into account that would prevent or mitigate
the scenario.
Using those definitions, the NES orders and manuals only require demonstration that the
NES Standards are met for credible NES scenarios.
Thus, very low probability initiating events such as meteor strikes must not be considered
as credible events when evaluating against the NES Standards. Similarly, scenarios
triggered by natural phenomena hazards (NPH) must not be considered credible NES
scenarios if they are caused by structural failures with likelihoods less than the associated
NPH performance goals in relevant DOE facility design standards.
NNSA SD 452.2 Attachment 3
11-17-14 Page 3-1
ACRONYMS AND ORGANIZATIONAL DESIGNATIONS
AB authorization basis
ADASM Assistant Deputy Administrator for Stockpile Management
ADAST Assistant Deputy Administrator for Secure Transportation
AO Authorizing Official
CAP corrective action plan
CNCE contractor NES change evaluation
CFR Code of Federal Regulations
CTA Central Technical Authority
DOE US Department of Energy
ESD electrostatic discharge
FO Field Office
HE high explosive
HED/D high explosive detonation/deflagration
HEVR high explosive violent reaction
HQ Headquarters
IAP immediate-action procedures
M Manual
M&O management and operating
MS Master Study
NARA National Archives and Records Administration
NCE NES change evaluation
ND nuclear detonation
NE nuclear explosive
NEO nuclear explosive operation
Attachment 3 NNSA SD 452.2
Page 3-2 11-17-14
NES nuclear explosive safety
NESS nuclear explosive safety study
NESSG Nuclear Explosive Safety Study Group
NESR nuclear explosive safety rule
Section 53
NNSA National Nuclear Security Administration
NNSS Nevada National Security Site
NPO NNSA Production Office
O Order
OSR operational safety review
OST Office of Secure Transportation
P.L. Public Law
SAR safety analysis report
SFI significant finding investigation
SIID single integrated input document
SS-21 seamless safety for the 21st century
STA senior technical advisor
STD Standard
TA technical advisor
TSR technical safety requirement
USQ unreviewed safety question
USQD unreviewed safety question determination
WSS weapon safety specification
CHAPTER I
INTRODUCTION AND RESPONSIBILITIES
CHAPTER II
NUCLEAR EXPLOSIVE SAFETY EVALUATION OVERVIEW
CHAPTER III
NUCLEAR EXPLOSIVE SAFETY EVALUATION PERSONNEL
CHAPTER IV
NUCLEAR EXPLOSIVE SAFETY STUDY PROCESS
CHAPTER V
OPERATIONAL SAFETY REVIEW PROCESS
CHAPTER VI
NUCLEAR EXPLOSIVE SAFETY CHANGE CONTROL PROCESSES
CHAPTER VII
NUCLEAR EXPLOSIVE SAFETY EVALUATION FINDINGS
CHAPTER VIII
EXEMPTIONS
CONTRACTOR REQUIREMENTS DOCUMENT
NNSA CONTRACTOR NESSG MEMBER AND NES REPRESENTATIVE QUALIFICATION REQUIREMENTS
NESS INPUT DOCUMENTATION
CRITERIA FOR CATEGORIZING ISSUES FROM NUCLEAR EXPLOSIVE SAFETY EVALUATIONS
ACRONYMS AND ORGANIZATIONAL DESIGNATIONS