NNSA SD 251.1A Appendix B

NNSA SD 251.1A Appendix B 1-17-18 APB-1 APPENDIX B: DEVELOPMENT OR REVISION OF NNSA DIRECTIVES (SDs, NAPs, BOPs) 1. BACKGROUND. National Nuclear Security Administration (NNSA) directives consist of Supplemental Directives (SDs), Policies (NAPs), Advance Change Directives (ACDs), and Business Operating Procedures (BOPs). Directives are used to establish, communicate, and institutionalize policies, requirements, responsibilities, and procedures specific to NNSA federal organizations and contractors. To illustrate the processes described in this appendix, a set of flowcharts is included as the last pages of the appendix. NAPs, SDs, and BOPs are mandatory carry equal weight, and affect more than one NNSA organization. Although each of these directives has different levels of approval, all have the same review and comment process described in this appendix. ACDs are also mandatory, carry the same weight as an SD, NAP, or BOP, and affect more than one NNSA organization. Appendix E describes the process for developing an ACD. High level flowcharts depicting the processes described herein follow this appendix. 2. REQUIREMENTS. a. Process described in Appendix D must be followed when administrative changes are made to NAPs, SDs, and BOPs. b. NAPs and BOPs must be numbered according to Department of Energy’s (DOE) numbering system as described in the Crosswalk of Directives Numbering System. SDs must be numbered according to the DOE Order being supplemented. c. SDs, NAPs, ACDs, and BOPs must trace to parent requirements defined in laws, regulations, DOE Orders, Memoranda of Understanding, or Interagency Agreements, with the exception of requirements established by the Administrator under the authorities provided by the NNSA Act. d. SDs and NAPs that impose requirements on contractors must contain a Contractor Requirements Document (CRD) as Attachment 1 to the directive. e. The following Naval Reactors equivalency must be added to all NNSA directives: In accordance with the responsibilities and authorities assigned by Executive Order 12344, codified at 50 United States Code, sections 2406 and 2511, and to ensure consistency throughout the joint Navy/DOE Naval Nuclear Propulsion Program, the Deputy Administrator for Naval Reactors (Director) will implement and oversee requirements and practices Appendix B NNSA SD 251.1A APB-2 1-17-18 pertaining to this directive for activities under the Director's cognizance, as deemed appropriate. 3. PROCESS. a. Development of Review and Comment Draft. OPI consults with the Policy Division, Business Services, Management and Budget (Policy Division) after the need to develop or revise a directive is identified. Policy Division: Confirms there is no overlap or conflict with existing directives; Recommends whether the proposed directive is an SD, NAP, or BOP; and Determines if the proposed revision of an existing directive is administrative in nature. 1 Administrative changes (e.g., typographical errors, organizational name changes, reference changes, and the addition of minimal content, as determined by the Deputy Associate Administrator for Management) do not alter the directive’s requirements or responsibilities and do not need to be distributed for review. (Appendix D) 2 Non-administrative changes must be distributed for full review because changes alter the directive’s requirements or responsibilities or add substantial content. This process is described in the steps below.

OPI must establish a writing team: Exemptions to the writing team requirement can be requested from the Policy Division. Writing team is chaired by the OPI. Writing team members must represent a cross-section of subject matter experts (SMEs) and senior management with representatives from at least half of the program offices affected, one field office employee, and the appropriate NNSA counsel. Contractor subject matter experts (SMEs) may be part of the writing team at the discretion of the OPI, but must not be involved in final policy decisions. NNSA SD 251.1A Appendix B 1-17-18 APB-3 OPI must consult with the technical editor assigned by the Policy Division to refine the initial draft of the directive. OPI sends the following items to the NNSA Directives Mailbox for review when the OPI and the technical editor agree that the draft is ready for distribution: Microsoft Word file of the draft directive, including appropriate attachments, appendixes, etc. Justification for creating the directive. The justification must include statutory or other drivers, identify any known significant costs, and list the organizations and individuals that were involved in the directive’s development. Approval from the OPI’s Authorizing Official (AO) that the draft is ready to be distributed for review. b. Review and Comment. The Policy Division establishes the due date for receiving comments. The draft is distributed via RevCom to NNSA’s AOs, AO Delegates, and Authorization Coordinators (ACs), the Department’s Representative to the Defense Nuclear Facilities Safety Board (DNFSB), and the NNSA Central Technical Authority (CTA). NAPs and SDs are also distributed to DOE for review. ACs and the respective AO or AO Delegate must identify SMEs within the organization to review the draft directive. ACs and the AOs or AO Delegates have discretion to ask M&O contractor SMEs to review the entire body of a directive. Contractor- originated comments that are accepted by AOs must be entered and defended by the federal organizations. ACs distribute the draft directive to SMEs for review and comment. SMEs provide comments by the due date set by the AC. If needed, ACs can request a due date extension from the Policy Division via the NNSA Directives Mailbox. SMEs must categorize comments as either major or suggested. SMEs must contact the OPI to clarify any questions the SMEs have related to potential major comments. Appendix B NNSA SD 251.1A APB-4 1-17-18 Major comments from SMEs must contain the following information: a description of the issue, reason for the major issue, and proposed resolution (i.e., the rationale for concerns raised and suggestions for addressing those concerns). ACs must review SMEs’ comments for clarity and relativity to the directive and must also check that each comment is labeled as major or suggested. When SMEs’ comments do not meet the definition of a major comment, the AC must change the comment to suggested. When comments are changed, the AC must inform the SME. If the SME disagrees with the change, the issue is raised to the AO or AO Delegate for decision. ACs must obtain approval from the AO before transmitting the organization’s official comments. The AO’s approval must be documented in RevCom. If this step is not completed, the organization’s comments will not be accepted. c. Comment Resolution.

Policy Division must return major comments from SMEs which do not contain the justification information required in the Review and Comment Section to the SME and the SME’s AO, AO Delegate, and AC for action. The OPI is not obligated to address the SME’s major comments if the comments are re-sent without the required information. OPI reviews the comments received from all NNSA organizations. OPI must respond to major comments that include language to improve the directive. OPI must address suggested comments in one of the following ways: Note: Classified directives must not be entered into RevCom or be transmitted by unclassified email systems. Classified directives must be distributed as paper copies that are marked and controlled, or transmitted through classified email systems. The Policy Division provides instructions on distributing the draft. The Policy Division also instructs the intended recipients on securing a copy of the draft when it cannot be transmitted through or posted on classified messaging or collaborative portal systems. The OPI can post an unclassified version of the directive in RevCom. NNSA SD 251.1A Appendix B 1-17-18 APB-5 Accept the comment without change, Accept the comment with modification, or Reject the comment. The OPI is not obligated to obtain the SME’s concurrence on the resolution of suggested comments. OPI must address major comments in one of the following ways: Accept the comment without change, Accept the comment with modification, or Reject the comment. In the latter two cases, the OPI must obtain concurrence from the SME. OPI must document in RevCom the SME’s concurrence on the resolution of major comments. Proceed to the Post-Comment Resolution Review section (10) after major comments have been resolved to the satisfaction of both the OPI and SME. Proceed to the Impasse Process section below if major comments cannot be resolved. Impasse Process for Comment Resolution (if needed). Policy Division facilitates discussions between the OPI and the SME when a major comment cannot be resolved. If this effort fails, the Policy Division facilitates a meeting between the OPI’s Office Director and the SME’s Office Director. If resolution cannot be achieved at the Office Director level, the Policy Division elevates discussions up the OPI’s and SME’s executive management chains until agreement is achieved. Elevating discussions continues until the disagreement reaches the OPI’s and SME’s AO. In the event that the AOs cannot reach resolution, the impasse is elevated to the Management Council for discussion and decision by the Principal Deputy Administrator (as chair of the Management Council). Appendix B NNSA SD 251.1A APB-6 1-17-18 OPI collaborates with the Policy Division to prepare a brief summary of the impasse that describes the OPI’s and SME’s positions; the summary must be signed by the OPI’s AO. The OPI must also obtain concurrence from the SME’s AO on the summary. Policy Division requests a meeting with the Management Council for the OPI’s and SME’s AOs. The OPI sends the summary and any required paperwork to the Policy Division for transmittal to the Management Council prior to the meeting. OPI collaborates with the Policy Division to develop a record of decision (a simple memo to file) which documents the Management Council’s discussion and the Principal Deputy Administrator’s decision. The Policy Division provides a copy of the record of decision to the SME’s AO, AO Delegate, AC, and the SME. The OPI revises the directive to reflect the record of decision.

Post-Comment Resolution Review (if needed). Policy Division determines, in consultation with the OPI, if changes made to the directive resulting from the comment resolution stage were administrative or substantive in nature. Proceed to Appendix D when the changes are administrative. Directive is distributed via RevCom to each NNSA organization’s AC, AO, and AO Delegate for a concurrence review if significant changes were made to the directive to address comments received. The review period is 2 weeks; only major comments will be accepted. Return to the Review and Comment and Comment Resolution sections. d. Development of the Final Draft. After the comment resolution step and the impasse step (if needed) are complete, the OPI sends the following documents to the NNSA Directives Mailbox: Comment resolution matrix from RevCom, which documents the resolution of major comments. Documentation confirming SMEs concurred on how major comments were resolved. NNSA SD 251.1A Appendix B 1-17-18 APB-7 Redlined Microsoft Word version of the draft directive (including appropriate attachments, appendixes, etc.). Record of decision documenting the Management Council Meeting and the resulting Principal Deputy’s decision. Policy Division reviews the documents for completeness. If any information is missing, the Policy Division works with the OPI to finalize the directive package for signature. e. Signature. NAPs and SDs: OPI and the Policy Division collaborate to write the memo that transmits the directive to the Administrator. (Appendix L) Policy Division: 1 Assembles the signature package, which includes the transmittal memo, a clean copy of the final draft directive, the comment resolution report, a concurrence page, and any background documentation in eDocs. 2 Obtains the signatures of OPI’s AO and the Associate Administrator for Management and Budget on the transmittal memo. 3 Delivers the signature package to NNSA’s Executive Secretariat for transmittal to the Administrator. Executive Secretariat returns the signed package to the Policy Division for processing. Policy Division notifies the OPI that the directive has been signed and proceeds to publish the directive. Policy Division works with the OPI to determine the path forward to address the Administrator’s concerns if the directive is not approved. BOPs: Policy Division obtains the signature of the responsible AO for the finalized directive. f. Publish. The Policy Division places a sunset date on the title page of the directive prior to posting it. Appendix B NNSA SD 251.1A APB-8 1-17-18 Policy Division posts current and archived NNSA directives on the NNSA directives website. (Appendix K) The OPI and NNSA’s ACs, AOs, and AO Delegates are notified through RevCom that the directive has been published and is available on the directives website. (Appendix K) Policy Division will inform the NNSA workforce upon directive issuance and via quarterly updates on new, revised, and cancelled directives. N N S A S D 2 51 .1 A A pp en di x B 1- 17 -1 8 A PB -9 A pp en di x B N N S A S D 2 51 .1 A A P B -1 0 1- 17 -1 8 N N S A S D 2 51 .1 A A pp en di x B 1- 17 -1 8 A PB -1 1 THIS PAGE INTENTIONALLY LEFT BLANK