**\[SOE LETTERHEAD\]**

October 28, 2002

The Honorable John T. Conway

Chairman

Defense Nuclear Facilities Safety Board

625 Indiana Avenue, NW, Suite 700

Washington, D.C. 20004

Dear Mr. Chairman:

Enclosed are changes to the Department of Energy's implementation plan
in response to the Defense Nuclear Facilities Safety Board
Recommendation 98-2 and an Implementation Plan with these changes
inserted.

The changes to Revision 1 of the plan update several milestones for
existing commitments to reflect changes in programmatic priorities and
an increased understanding of the effort required to meet the
commitments. The plan also establishes a new commitment to accelerate
implementation of tooling enhancements for the W78 and W88 weapon
disassembly programs to the greatest extent possible. The Department
remains committed to effective and efficient implementation of Seamless
Safety for the 21^st^ Century at the Pantex Plant.

We are confident that the updated plan will achieve the objectives of
Recommendation 98-2. If further information is desired, please contact
me or Ambassador Linton Brooks, Acting Administrator, National Nuclear
Security Administration, at (202) 586-5555.

Sincerely,

# Spencer Abraham

Enclosure

**Change Instructions Implementation Plan for Defense Nuclear
Facilities**

**Safety Board Recommendation 98-2, Safety Management of the Pantex
Plant**

1.  Revise the due date for commitment 4.3.3 (Develop site-wide TSR
    controls for on-site transportation of nuclear explosives) to June
    30, 2003.

**Basis for Change:** The nature of this action has changed
significantly since the latest revision to the implementation plan.
Whereas the original plan called for a single authorization basis
document approved once in its entirety, the magnitude of the analysis
and engineered controls make it more feasible to manage this activity in
three phases: Phase I (weapons in their ultimate user configuration);
Phase II (partial assemblies); and Phase III (nuclear material). The
Department has approved the authorization basis for Phase I and its
implementation plan. The commitment date above also reflects the large
amount of authorization basis document review and approval required of
the Office of Amarillo Site Operations in the months preceding and
immediately after the 10 CFR 830 April 10, 2003, deadline.

2.  Delete commitments 4.3.10 and 4.3.11 (Conceptual design report and
    line-item construction project to replace the Pantex Plant Fire
    Alarm panel).

**Basis for Change:** These two commitments were for preliminary steps
toward approval of a site-wide project for replacement of the Pantex
Plant's aging fire alarm system. In a June 15, 2002, letter to the
Chairman, the Department informed the Board that an acquisition
strategy, based on a series of expense-funded projects, would replace
the fire alarm system sooner and potentially at lower total costs. In a
February 4, 2002, letter the Department provided the Board a copy of the
program execution plan for the series of expense-funded projects. These
projects have started, and the Board's staff is being kept informed of
our progress. The intent of the original commitments \-- to initiate
actions to replace the fire alarm system \-- has been met.

3.  Revise the due dates for commitments 4.4.5 and 4.4.6 (Authorize
    startup of W78 and B83 SS-21 processes) as follows:

> W78: August 28, 2003
>
> B83: May 30, 2004
>
> **Basis for Change:** The due dates of Revision 1 to the
> implementation plan were estimated prior to completion of all
> prerequisite work and prior to initiation of detailed planning.
> Information developed during prerequisite work and detailed planning
> indicates that dates above are more accurate target dates for
> completion. The schedule for these projects has also been affected by
> emerging work, new technical requirements, heightened security
> measures, and refocusing of resources to meet the April 10, 2003,
> deadline of 10 CFR 830. The B83 project was also delayed by FY 2001
> financial constraints. Both projects have met Milestone 1 and are on
> schedule to meet the new target dates.

4.  Add a new commitment 4.4.7 (Accelerated critical tooling). The
    Department will accelerate implementation of critical tooling for
    two Conventional High Explosive (CHE) weapons to the greatest extent
    possible within the scope of the SS-21 authorization basis efforts
    currently in progress.

> Lead Responsibility: Director, Office of Amarillo Site Operations

Deliverable: Delivery of accelerated critical tooling for the W78 and 88
programs to the Pantex contractor.

> Due Date: W78: January 31, 2003

W88: October 1, 2002

> Deliverable: Implementation of accelerated critical tooling for the
> W78 and W88 weapon programs.
>
> Due Date: W78: August 28, 2003
>
> W88: May 21, 2003

Basis for Change: The W78 SS-21 project will implement the bay and cell
tooling for disassembly and inspection and repairs at the accelerated
conclusion of the project. This acceleration is made possible by the
quality of the Step I Hazard Analysis Report and is dependent on the use
of an abbreviated validation process (Nuclear Explosive Safety Study and
Authorization Basis Change Control per Chapter 11 of the Development and
Production Manual). The W88 will have bay tooling accelerated and
validated in a similar fashion (Cell tooling for the W88 must be
redesigned around a revised production process and cannot be implemented
without the full set of validation activities).

5.  Modify commitment 5.2.2 (Quarterly IP status reports and briefings)
    to have the reports submitted by NA-12, HQ SS-21 Champion.

> **Basis for Change:** Due to recent organizational changes within NNSA
> and designation of NA-12 as the HQ SS-21 Champion, these reports will
> now be submitted by NA-12.

6.  Change the delivery date for Commitment 4.5.1 (Final Implementation
    Plan Assessment Report) to August 31, 2004.

> **Basis for Change:** This allows 3 months after delivery of the final
> commitment for preparation and approval of the final report.

## 

## **U. S. Department of Energy**

**Implementation Plan**

**Revised Implementation Plan for**

**Accelerating Safety Management Improvements**

**at the Pantex Plant**

### **Change 1**

**October 1, 2002**

**(Board Recommendation 98-2)**

![](media/image1.png){width="1.7472222222222222in"
height="1.7430555555555556in"}

  ----------------------------------- -----------------------------------
  **Washington, DC**                  **20585**

  ----------------------------------- -----------------------------------

**Executive Summary**

On November 20, 1998, the Department of Energy (DOE) accepted Defense
Nuclear Facilities Safety Board (DNFSB) Recommendation 98-2, which
addresses the need to accelerate safety improvements for nuclear
explosive operations, conducted at the Pantex Plant. The Department's
Implementation Plan for Accelerating Safety Improvements at the Pantex
Plant was issued on April 23, 1999, and accepted by the Board on June
16, 1999. The commitments in the Implementation Plan represented a
significant effort by DOE and the Pantex Plant Operating Contractor to
simplify and standardize activity level safety management processes for
nuclear explosive work. Overall, the objective of the plan was to ensure
practical and timely implementation of safety improvements and tailoring
of the Seamless Safety for the 21 Century principles.

The Department first undertook implementation of the process referred to
as "Seamless Safety for the 21^st^ Century" (SS-21) for all nuclear
explosive operations at the Pantex Plant in 1993. During the past seven
years, the SS-21 process has evolved, but the fundamental objective
remains the same: eliminate hazards in assembly, disassembly, and
testing of nuclear explosives through process and tooling design. Other
substantial benefits derived from SS-21 include the development of
operational controls through a systematic analysis of the hazards, and
implementation of the operational controls through improved procedures
written in a format more conducive to production technician
understanding and adherence. The SS-21 process was applied to several
older weapon programs being dismantled (e.g., W56), resulting in marked
improvements in safety. However, application of the SS-21 process to
achieve the same benefits for all ongoing nuclear explosive operations
at Pantex has been slow.

Change 1. In a letter of October 23, 2000, the Board responded that they
were encouraged with the technically sound structure of Revision 1 to
the plan and exhorted the Department to begin implementing it. The
letter also stated, "However, the Board is not able to judge the overall
acceptability of the plan because we do not have sufficient information
concerning the details of its execution." The letter requested briefings
to demonstrate how actions required within fiscal year 2001 to fulfill
the commitments in the plan had been captured in work authorizations
directives for the Pantex Plant contractor and other appropriate weapon
laboratories and contractors. The Department provided the briefings and
has been working to meet all commitments of the Revision 1 IP.

In the two years since Revision 1 was negotiated with the Board changing
priorities, new information, and revised acquisition strategies have
changed five commitments - two concerning upgrades to the Pantex fire
alarm system, one to complete the Pantex Transportation Safety Analysis
Report, and two to complete the SS-21 process on specific weapon
systems. The intent of the first two - to initiate replacement of the
Pantex fire alarm system - has been met by a series of expense-funded
projects. During the planning phase for the Transportation Safety
Analysis Report the contractor found that considerably more analysis was
required than originally thought. Change 1 revises this completion date
to June 2003. Two SS-21 projects (B83 and W78), to have been completed
in May and December of 2002 respectively, were reprioritized in July
2001, and the revised dates briefed to the Board. Change 1 further
revises the dates for completion of the W78 weapon startup to reflect
recent changes in the industrial processes addressed by the projects and
responds to the Board's informal request for a new commitment to
accelerate implementation of some critical tooling for two

Conventional High Explosive (CHE) weapons.

Changes made in "Change 1" are indicated by a "bar" in the right margin.

#### Implementation Plan Issued April 23, 1999

In the original Implementation Plan the Department identified the
following actions to improve the rate of SS-21 implementation:

-   Fully define the safety management processes to be used for nuclear
    explosive operations through revision or issuance of Department
    standards and requirements

-   Strengthen the role of line management in safety management
    processes

-   Reduce the heavy reliance upon multiple task teams and shift greater
    responsibility for safety to the Pantex Plant Operating Contractor

-   Establish a well-defined work scope for the actions needed to make
    safety improvements

-   Upgrade the quality of hazard analyses and operational controls for
    nuclear explosive operations

-   Improve the technical competence of both DOE and Pantex Plant
    Operating Contractor personnel involved in the preparation, review,
    and approval of safety documentation

-   Emphasize the role of the nuclear explosive safety (NES) studies to
    an independent review of the adequacy of operational controls
    established by line management

-   Alter the structure and membership of the nuclear explosive safety
    study group and strengthen the training and qualification
    requirements

-   Integrate line management into the nuclear explosive safety change
    control process, and integrate the nuclear explosive safety change
    control process with the unreviewed safety question process

-   Improve the efficiency with which new tooling concepts developed
    successfully for one nuclear explosive process can be implemented
    for another

-   Reduce the time required to perform hazard analyses and derive
    operational controls

The Department committed to undertake the improvements listed above as
linked components of integrated safety management. In addition to the
above actions, the Implementation Plan also included specific
commitments for the W62 weapon program. The Department implemented
compensatory actions identified in the W62 Step 1 Project Plan to
realize part of the potential SS-21 benefits as soon as possible on the
W62. The commitments for the W62 weapon program are complete and the
disassembly and inspection process has safely restarted.

As with any plan of the scope and complexity of 98-2, the Department and
Pantex Plant Operating Contractor have achieved results with mixed
success. Since issuance of the original Implementation Plan, the
Department has made significant progress in revising or issuing a number
of directives related to the safety of nuclear explosive operations. In
many cases, the revised directives represent fundamental changes in
processes or roles and responsibility, aimed at simplicity and
efficiency. The Pantex Plant Operating Contractor has completed
implementation for a number of these changes, and the remaining changes
are in-progress.

Line management both within the Department and the Pantex Plant
Operating Contractor are now directly involved in the analysis of
hazards and decisions involving the selection of operational controls.
Primary responsibility for management of weapon program project teams
has been transitioned to the Pantex Plant Operating Contractor,
including responsibility for hazard analysis and operational controls.
The Nuclear Explosive Safety Study Group (NESSG) is fulfilling its
appropriate role by independently reviewing operations to assess the
adequacy of controls established by line management.

The technical basis for DOE-approved controls used in nuclear explosive
operations at the Pantex Plant is gradually improving. The controls are
derived from a systematic analysis of hazards versus subjectively
imposed by experts. The controls are now prepared in a format consistent
with other DOE nuclear facilities (i.e., technical safety requirements).
The formality and rigor of safety controls established in such areas as
fire protection and lightning protection have been substantially
improved. In both cases these include engineered controls. Although a
number of technical challenges remain, the Department is encouraged by
the progress made and remains committed to further improvements in these
two critical areas of safety.

Both process changes and changes in organizational responsibilities have
been applied to varying degrees on several nuclear weapon programs
(e.g., W62, W87, W76, and W88). Although the Department, Pantex Plant
Operating Contractor, and the national laboratories have occasionally
struggled with execution of some changes, the Department remains
confident that additional experience will yield consistent application
and efficiency gains will be realized.

#### Revised Implementation Plan

This revision to the implementation Plan reflects the progress made by
the Department in closing previous commitments (under the original
Implementation Plan), carries forward several commitments with revised
completion dates or scope (where appropriate), and includes additional
commitments needed to fulfill both the spirit and intent of the
Recommendation.

The planned actions and commitments in the Implementation Plan are
organized into the five core functions of the Department model for
integrated safety management. This approach in presentation reflects the
Department commitment to achieve resolution of the issues identified
under Recommendation 98-2 as linked components of integrated safety
management.

The fundamental change in the Department's approach is to provide
increased focus and priority to making "generic" safety improvements
applicable to multiple nuclear weapon processes "across the board."
Thus, the Department will use a "two-pronged" attack for accelerating
safety improvements in nuclear explosive operations at the Pantex Plant.
The Department will continue efforts to apply the concepts of SS-21 to
individual weapon processes in accordance with the schedules
established.

However, the Department believes the most rapid way to gain major safety
improvements is to attack the problem on a "hazard by hazard" basis,
focusing on improved engineered controls applicable to multiple weapon
programs and processes. In this manner, the Department can achieve
tangible improvements in safety on a near-term basis, allowing weapon
project teams to focus on further eliminating or reducing the remaining
hazards through total process redesign, as required.

This approach should also alleviate unnecessary schedule pressures
traditionally applied to weapon project SS-21 teams and focus the
efforts of the Department and its contractors where the greatest
benefits lie. That is, accelerating safety improvements that are generic
in nature and which address the dominant hazards encountered in nuclear
explosive operations at the Pantex Plant. The Department believes this
approach is more consistent with the original theme and intent of
Recommendation 98-2.

**Table of Contents**

1.  **BACKGROUND 1**

2.  **CONTRIBUTING CAUSES TO REVISION OF THE IMPLEMENTATION PLAN 1**

3.  **BASELINE ASSUMPTIONS 2**

4.  **SAFETY ISSUE RESOLUTION 3**

    4.  **DEFINE SCOPE OF WORK 6**

> Commitment 4.1.1 7

Commitment 4.1.2 7

**4.2 ANALYZE HAZARDS 8**

Commitment 4.2.1 10

Commitment 4.2.2 10

Commitment 4.2.3 10

Commitment 4.2.4 11

Commitment 4.2.5 11

Commitment 4.2.6 11

**4.3 DEVELOP AND IMPLEMENT CONTROLS 11**

Commitment 4.3.7 13

Commitment 4.3.2 13

Commitment 4.3.3 13

Commitment 4.3.4 13

Commitment 4.3.5 14

Commitment 4.3.6 14

Commitment 4.3.7 15

Commitment 4.3.8 15

Commitment 4.3.9 15

Commitment 4.3.10 16

Commitment 4.3.11 16

**4.4 PERFORM WORK 17**

Commitment 4.4.1 18

Commitment 4.4.2 18

Commitment 4.4.3 18

Commitment 4.4.4 18

Commitment 4.4.5 19

Commitment 4.4.6 19

Commitment 4.4.7 19

**4.5 FEEDBACK AND IMPROVEMENT 20**

Commitment 4.5.1 21

**5.0 ORGANIZATION AND MANAGEMENT 21**

5.1 ORGANIZATION 21

5.2 MANAGEMENT SYSTEMS 22

5.2.1 CHANGE CONTROL 22

5.2.2 REPORTING 22

**6.0 IMPLEMENTATION PLAN COMMITMENT CROSSWALK 23**

**7.0 APPENDICES I**

**7.1 APPENDIX A: ABBREVIATIONS AND ACRONYMS I**

**7.2 APPENDIX B: HISTORY-DNFSB BOARD RECOMMENDATIONS AND**

**LETTERS II**

1.  **Background**

Over the past seven years, the Defense Nuclear Facilities Safety Board
(hereafter referred to as "the Board") transmitted a number of formal
recommendations and observations to the Department of Energy (hereafter
referred to as "the Department") related to the safety of nuclear
explosive operations at the Pantex Plant. In some instances, the Board
provided broad recommendations applicable to multiple sites within the
Department (e.g., Recommendation 95-2). In other cases, the
recommendations or observations were more directly related to nuclear
explosive operations conducted at the Pantex Plant.

Appendix B, "Historical View: DNFSB Recommendations and Letters,"
discusses some of the prior Board recommendations and summarizes
observations transmitted through correspondence to the Department during
the past four years. These recommendations and observations provide both
insight to the "genesis" of DNFSB Recommendation 98-2 (hereafter
referred to as "Recommendation 98-2" or "the Recommendation"), and
insight to the Department's progress subsequent to the Recommendation.

Recommendation 98-2 describes actions the Board considers necessary to
improve the safety of nuclear explosive operations conducted at the
Pantex Plant. The Board recommended:

1.  "A practice be instituted that delivers the principle benefits now
    sought from the SS-21 process, but that promises to consume less
    time and resources. Use of this practice should start as soon as
    possible for all activities involving nuclear explosives at the
    Pantex Plant and the W62 activities in particular. To the extent
    possible, the Nuclear Explosive Safety Study in this practice should
    include reevaluation of the basis for and the current validity of
    previous safety judgments in light of new understandings and
    expectations.

2.  An administrative process be instituted, similar to the Unreviewed
    Safety Question process used elsewhere by DOE, that would offer to
    tailor the nuclear explosive safety process when a change is
    proposed in fooling, procedures, etc. that would enhance safety
    assurance. This should permit enabling improved safety measures
    developed for operations with one weapons system to be used (if
    appropriate) for another weapons system without the need for a new
    nuclear explosive safety study.

3.  Practices for developing the authorization basis and associated
    control measures for an operation at Pantex be refined to ensure
    that the Pantex contractor assumes the position of the organization
    issuing the documentation and operational plan for operations at
    Pantex, and defending them before external review groups.

4.  Instructions be issued that formal safety reviews by NESS groups
    should consider proposals for actions which have been made by the
    organization that will do the work and should advise as to perceived
    shortcomings but should not be empowered to dictate specific
    remedies. If a proposed action is not found by the independent
    review group to be acceptably safe, the organization making the
    proposal can always be requested to put forward an alternative for
    consideration.

5.  DOE establish a standing committee of NESS reviewers to replace the
    ad hoc groups now used; the membership of this body being centered
    on individuals of emeritus status with experience and proven stature
    in the nuclear weapons field. This body would be expected to conduct
    the safety reviews of the future.

6.  Work planning/safety planning processes for operations with nuclear
    explosives at the Pantex Plant be organized and pursued as linked
    components of Integrated Safety Management on the lines of
    implementation of the Board's Recommendation 95-2.

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2.  **Contributing Causes to Revision of the Implementation Plan**

The Implementation Plan issued on April 23, 1999 contained 25
commitments (not counting the commitment for periodic briefings or
progress reports to Board). Each of the twenty-five commitments included
one or more formal deliverables from the Department to the Board.
Several of the commitments remain open with eight deliverables past due
(see Section 6).

The Department has kept the Board informed of both the progress and the
delays in achieving the previous commitments. However, the rate of
progress and number of outstanding commitments warranted revision of the
original Implementation Plan.

The following are underlying causes for the problems encountered:

-   The scope of actions necessary for the Department and the Pantex
    Plant Operating Contractor to rectify a number of problems cited by
    the Board in Recommendation 98-2 were either unknown at the time the
    original Implementation Plan was developed, or were underestimated
    in terms of complexity and resources required. Both the Department
    and the Pantex Plant Operating Contractor committed to completing
    some actions within a prescribed timeframe without the full scope of
    work completely defined.

-   The Department and the Pantex Plant Operating Contractor modified
    both processes and organizational responsibilities related to the
    safety of nuclear explosive operations, particularly development of
    hazard analyses and readiness reviews. These changes were put into
    effect on ongoing activities, effectively "mid-stream", such as the
    W62, W76, and W88 nuclear weapon programs. As the Department and
    Pantex Plant Operating Contractor strove to implement these
    improvements, delays were naturally encountered as personnel learned
    new roles and responsibilities, and applied new requirements.

-   The Department and the Pantex Plant Operating Contractor have not
    yet achieved the "end-state" of several process definitions. This
    has resulted in both Department and contractor personnel
    "learning-as-they-go", resulting in some natural inefficiencies and
    performance problems. Additional definition is warranted both in
    Department directives and in contractor standards and manuals to
    achieve the level of prescription and guidance necessary to achieve
    consistent, repeatable processes. This is true in a number of areas
    ranging from hazard analysis development to preparation for and
    execution of readiness reviews. The Department is committed to
    continual feedback and improvement of its directive system by
    incorporating changes based upon lessons learned through field
    application.

-   In some cases, a single deliverable may be outstanding which is
    required to complete or "close" multiple commitments (e.g.,
    DOE-STD-3015 revision and issuance). In other cases, a deliverable
    has been transmitted to the Board, but the Department did not
    consider the "spirit and intent " of the commitment fully satisfied.
    These situations represent examples where the structure of the
    original commitments could have been better, and constitute an
    opportunity for improvement through this revision to the
    Implementation Plan.

3.  **Baseline Assumptions**

The Department made the following assumptions in revising the original
Implementation Plan:

-   The Department does not anticipate the Pantex Plant operating budget
    to significantly increase above current funding levels in the
    foreseeable near-term (i.e., within the next five years). The
    Department has evaluated the potential for investing significant
    resources in terms of additional tooling engineers, procedure
    writers, hazard analysts, etc. at the Pantex Plant. Although a
    significant increase in available Pantex Plant resources could
    potentially provide some gains, the Department does not believe
    these are the only factors limiting the rate of SS-21
    implementation. Critical resources within the design laboratories
    are also limited in terms of weapon system expertise. Thus,
    application of additional resources solely at the Pantex Plant would
    not be sufficient to rectify the problems with the rate of SS-21
    implementation. Lawrence Livermore National Laboratory (LLNL) and
    Los Alamos National Laboratory (LANL) can each support only 2-3
    weapon programs concurrently that are undergoing SS-21 process
    redesign. The Department does not consider it feasible to rectify
    these problems near-term solely though the investment of additional
    funding resources. This fundamental assumption is reflected in the
    Integrated Weapons Activity Plan (IWAP) as discussed in Section 4.0.
    Particularly in the case of the Pantex Plant, the Department also
    does not want to increase the number of tooling engineers, procedure
    writers, and hazard analysts near term only to face potential
    staffing reductions as the workload diminishes after the bulk of
    SS-21 implementation is completed. The Department considers a more
    prudent management approach is to sustain SS-21 process redesign at
    the maximum rate afforded by current staffing levels in these key
    areas of expertise. This does not mean the Department will not seek
    to increase these staffing levels to ensure attrition does not
    exceed the rate of replacement, or add staff to achieve a
    satisfactory level of expertise. It simply means the Department does
    not consider a rapid and significant ramp-up in these critical areas
    of expertise either feasible or advisable.

-   The Department has an obligation to national security to support the
    enduring stockpile. In addition, the Department has made substantial
    investments in the programs to dismantle W56 and W79 units. The
    Department intends to meet its national security obligations and
    also protect the investment made in the programs to dismantle W56
    and W79 units. The Department believes continued dismantlement of
    older weapon systems improves the overall safety posture for the
    weapons program. The Department is committed to sustaining some rate
    of dismantlement concurrently with SS-21 implementation. Therefore,
    the Department will not divert resources from dismantlement
    processes to accelerate SS-21 implementation without careful
    consideration of the overall benefits achieved.

-   This Implementation Plan establishes commitments to institutionalize
    improved safety management processes. The Department will manage
    these commitments in accordance with the processes described in
    Section 5.2. This implementation plan also refers to schedules for
    implementation of SS-21 processes for specific weapon systems and
    improving hazard analysis and controls for all weapon systems.

4.  **Safety Issue Resolution**

In 1993, the Department established the concept of seamless safety for
the 21^st^ century ("SS-21") for nuclear weapon systems. The major
objective of SS-21 was to achieve safety through design of processes
used at the Pantex Plant for assembly, disassembly, and testing of
nuclear weapon components. SS-21 was envisioned to evolve the nuclear
weapons community away from the historical approach of simply reviewing
a process in order to determine the relative safety. Such reviews
traditionally occurred just prior to authorization of the work by the
DOE. This approach afforded little or no time to accommodate changes at
the end of process design, particularly in terms of engineering
solutions through changes to tooling and equipment. The original
technical safety objectives established for SS-21 in 1993 were:

-   Prevent the application of unauthorized/unanalyzed external energy
    sources to the weapon so as to prevent release of internal energy
    sources in the weapon. This means all forms of mechanical,
    electrical, electro-mechanical, and thermal energy. Lifting and
    transport operations are considered to be potential and kinetic
    energy sources.

-   No single point failure in operations will cause energy sources in
    the weapon to be activated or released, abnormal radioactive
    contamination, or serious injury to operating personnel. This means
    energy sources even if self-contained, radioactive contamination
    above thresholds set in procedures, and lost workday injuries to
    operating personnel.

-   Exposure to radiation and hazardous substances will be "as low as
    reasonably achievable (ALARA)."

The Department considers the original safety objectives established for
SS-21 still technically sound, and they have been expanded upon during
the past few years. Through AL Supplemental Directive 56XB, Development
and Production Manual, Chapter 11.5, "Target Level of Controls," the
Department established the following general expectations for
controlling hazards associated with nuclear explosive operations:

-   Elimination of hazards where practical using an iterative process of
    analysis and design.

-   Preference for relied upon engineered safety features versus
    administrative controls.

-   Preference for relied upon passive engineered features versus active
    features (i.e., requiring human intervention).

-   Reliance upon design and control features for prevention of
    accidents versus mitigation.

In the original version of this implementation plan, the Department
attacked the problem of simplifying and improving the efficiency of
implementation by closely examining all of the various steps of the
SS-21 process. This included not only the iterative analysis and design
aspects, but also leadership and composition of project teams, hazard
analyses, derivation of operational controls, and subsequent reviews to
evaluate the adequacy of the proposed controls and their implementation.

The initial approach applied by the Department and the Pantex operating
contractor was to attack

redesign of each weapon process on its own merit, focusing on systems
with conventional high explosives (CHE) first to obtain the greatest
reduction in risk. This approach effectively limits the safety
improvements to "one system at a time." The resource constraints, in
terms of tooling engineers, procedure technical writers, hazard
analysts, and design laboratory engineers limits the ability of the
Department to gain improvements across multiple weapon programs
simultaneously. The Department anticipates these constraints on key
resources will not be alleviated over the next several years. As a
result, the Department will not complete SS-21 for all nuclear weapon
programs in the enduring stockpile until 2005. As SS-21 is defined
above, this means re-design of each nuclear explosive process used for
assembly, disassembly, and testing of components at the Pantex Plant.
However, the Department believes substantial safety improvements can be
accelerated in nuclear explosive operations at the Pantex Plant in a
"generic," or "across-the board" fashion, as explained in the following
paragraphs.

Until such time weapon systems with conventional high explosives (CHE)
could undergo SS-21 process redesign, the Department committed to
performing systematic hazard analyses of the existing process.
Development of a systematic hazard analysis report (HAR) was planned for
each existing CHE weapon program. Each HAR was intended to establish a
technical basis for line management to derive the appropriate set of
operational controls. In this manner, subsequent reviews performed by
the nuclear explosive safety study group (NESSG) could serve as
independent reviews to confirm the adequacy of proposed controls, rather
than the historical approach where such reviews served to establish the
required controls.

The Department attempted to accomplish the development of HAR for the
existing CHE weapon processes in parallel with developing safety
analyses and operational controls (technical safety requirements) for
all Pantex Plant nuclear explosive facilities. Attempts to develop the
HAR, safety analyses and technical safety requirements (TSR) in parallel
led to a complex authorization basis configuration at Pantex. The
parallel efforts also represented significant challenges in terms of
timing and integration. A number of problems resulted, including
duplication of analytical effort, inconsistencies in analytical
approach, and gaps caused by reliance upon other scheduled analyses
which failed to occur within the anticipated time frame. With multiple
hazard analysis efforts ongoing simultaneously, the Department and
Pantex Plant Operating Contractor struggled to establish a foundation
upon which to build.

Because no foundation of analyses or controls existed upon which to
build, each weapon program HAR was developed as a "stand alone"
analysis. In doing so, the collection of HAR developed for various
weapon programs soon represented overlapping analyses, using different
analytical approaches or yielding different conclusions for the same or
similar potential accident scenarios. With multiple HAR being developed
in parallel with the facility analyses, project teams frequently derived
slightly different approaches in terms of operational controls. This
resulted in confusion and implementation problems.

Initial development of a HAR for CHE systems was intended to establish a
sound technical basis for the safety of the "existing" process. It was
never envisioned that such "Step 1" HAR plans would incorporate time for
project teams to completely redesign the existing process. Although
project teams were expected to identify any major safety concerns with
current tooling and equipment, they were not given the latitude to
essentially start with a "clean sheet of paper." This approach
effectively limited the project team's ability to propose engineering
solutions to further improve safety. In many cases the project teams
compensated by imposing more rigorous administrative controls on
existing aspects of the process to minimize hazards. Project teams were
expected to have the full latitude to pose engineering solutions through
total process redesign in "Step 2" using the "Step 1" HAR as a valuable
input tool. In other words, fully apply the objectives of SS-21 using
information from the Step 1 HAR on those areas of the process which pose
major hazards.

With the recent implementation of site-wide TSR, the Department and
Pantex Plant operating contractor have finally established a foundation
upon which to build. The TSR represent operational controls that are
generically applicable to all nuclear explosive operations. These
controls address hazards that are common to all nuclear explosive
operations: fire, lightning, electrical energy, and mechanical impacts
due to tooling failures and human error.

Through the site-wide TSR, the Department and Pantex Plant operating
contractor are achieving tangible improvements in safety. These safety
improvements are being achieved through better tooling and equipment
designs, and greater rigor in administrative controls as defined in
written operating procedures.

Examples of recent safety improvements achieved through tooling and
equipment:

-   Hoisting and lifting devices provide insulation or isolation for
    nuclear explosive configurations from potential sources of large
    electrical energy (such as a direct lightning strike to the
    facility);

-   Bonding or surge suppression of physical and electrical penetrations
    into the bays and cells used for nuclear explosive operations
    preclude potential pathways for large electrical energy sources;

-   Insulation/isolation devices are installed in physical
    configurations where equipment attaches to the nuclear explosive for
    testing or evaluation of components to afford protection from large
    electrical energy sources;

-   Transportation carts establish an effective "Faraday cage" around
    nuclear explosive configurations providing insulation from potential
    sources of large electrical energy.

Examples of safety improvements planned through changes to facility
systems and weapon processes:

-   Ultra-violet (UV) sensors capable of activating a water-based deluge
    system within seconds (15-20) of detecting a fire in Pantex Plant
    operating bays and cells used for nuclear explosive operations;

-   Reduction in the usage of flammable solvents and combustible
    materials in assembly, disassembly, and testing processes and
    facilities through a risk-cost benefit assessment of flammable
    solvent and combustible material elimination, minimization or
    substitution to further minimize the potential for fire in proximity
    to nuclear explosives;

-   Transportation carts designed to afford protection of partially
    assembled (or disassembled) nuclear weapons from potential sources
    of mechanical insults such as collisions; and

-   Re-design of lifting configurations that require cranes and hoists
    to either eliminate or further minimize the potential for
    catastrophic load-path failures that could result in kinetic energy
    being imposed on the nuclear explosive through mechanical insult.

The Department and Pantex Plant operating contractor have either
completed or are pursuing the above improvements "generically" across
all nuclear explosive operations and weapon programs. The Department
considers this approach will result in accelerating many of the safety
improvements originally envisioned by SS-21 in a much faster time frame
than otherwise would be achieved "one program at a time."

Thus, the Departments revised approach, as further described in the
remaining sections of this

Implementation Plan, is to pursue accelerating the rate of safety
improvements through a "two-pronged" approach. The Department will place
increased emphasis and priority on generic improvements being gained
through the efforts outlined above. These efforts are already yielding
substantial safety improvements for all nuclear explosive operations
conducted at the Pantex Plant. The Department believes pursuit of these
generic safety improvements will more rapidly fulfill the original
intent of SS-21.

In parallel with these efforts, the Department will continue emphasis
and efforts to re-design existing weapon program processes in accordance
with the established schedule for SS-21, as identified in the integrated
weapons activity plan (IWAP). The Department considers by placing
increased emphasis and priority on generic safety improvements that
project teams can be allowed to focus on the original intent of SS-21:
elimination or further minimization of hazards through process
re-design. In this manner, the Department and the Pantex Plant operating
contractor will not be dependent upon each weapon program project team
to develop unique solutions for all hazards. By establishing a generic
basis upon which to build, the project teams can focus on eliminating
remaining hazards or building upon the generic baseline of tooling,
equipment, and controls.

The Department completed a number of actions identified in the original
Implementation Plan. The following sections describe those achievements
within the framework of the core functions and guiding principles of
integrated safety management, and their relevance in accelerating the
rate of safety improvements at the Pantex Plant. A discussion is
provided in each section for situations where the Department considers
original commitments or deliverables provided marginal effect in
accelerating safety improvements. In some instances, the Department has
future actions planned, including new or revised commitments and
deliverables that are warranted to fulfill the spirit and intent of
Recommendation 98-2. Section 6 includes a cross-reference between the
commitments contained in the original version of the Implementation Plan
and those contained in this revision.

**4.1** **Define Scope of Work**

> ***[Actions Completed:]{.underline}***

The Department recognized the lack of an effective mechanism to
establish priorities and define work scope detail for safety
improvements needed in nuclear explosive operations. Previous efforts
were focused at various organizational levels and involved weapon
processes and facilities, but were not integrated into a single plan.
The lack of an integrated organizational approach led to competing
resources, inefficiencies, and numerous project start and stops with
minimal safety enhancements achieved. The Department developed an
Integrated Weapons Activity Plan (IWAP) to serve as a tool to improve
planning and prioritization. The Department established requirements for
the IWAP in Albuquerque Operations Office (AL) supplemental directive
56XB, Chapter 11.2, Integrated Weapons Activity Plan. (AL supplemental
directive 56XB is commonly referred to as the "Development and
Production Manual" or "D&P Manual"). The IWAP consists of project plans
for generic safety improvements across multiple weapon program
processes, and safety improvements for individual weapon processes. The
IWAP includes a resource-loaded schedule for accomplishing the
improvements.

The Department is using the IWAP and associated project plans to set
clear expectations for each improvement initiative. The Department is
also using the IWAP schedule to establish the priority of safety
improvement initiatives. Safety improvements for weapon processes are
sequenced based upon the type of high explosive in the weapon, the
degree of intrusion into the weapon required by the work, and the
quantity or frequency of the work. For example, priority is given to
enhancing process safety for weapons containing conventional high
explosive (CHE) before those containing insensitive high explosive
(IHE). Similarly, the Department is sequencing generic safety
improvements for those tasks or processes providing the largest
potential safety improvements scheduled earliest (e.g., improved
controls for lightning protection and fire protection that are
applicable to multiple weapon programs and nuclear explosive
operations). This approach enables acceleration of safety improvements
across multiple weapon programs to be achieved simultaneously versus
"one program at a time."

> The Department recognized the responsibility for various aspects of
> nuclear explosive operations is vested in different organizations. The
> Pantex Plant Operating Contractor is responsible for the safety of
> operations and the adequacy of the technical basis for associated
> controls, the design laboratories are responsible for evaluation of
> weapon response to accident stimuli, and the Department is responsible
> for risk acceptance decisions. Previously, these roles were not
> clearly defined. The Department delineated these organizational
> responsibilities by issuance of D&P Manual Chapter 11.3, *Seamless
> Safety (SS-21) for Assembly and Disassembly of Nuclear Weapons at the
> Pantex Plant*.

The Department did not have an effective mechanism in place to enable
leadership of this multi-organizational effort and to ensure balanced
priorities. The Department established a Standing Management Team (SMT)
consisting of senior managers from DOE, the design laboratories, and the
Pantex contractor. Representatives from the laboratories and Pantex
contractor serve both as advisors and as representatives to provide
institutional commitments on behalf of their organizations. The Chairman
of the SMT is the Director, Weapon Programs Division (WPD). The
Co-Chairman is the Area Manager, Amarillo Area Office (AAO). The SMT
provides the DOE line managers (WPD Director for weapon processes, AA0
Area Manager for site operations) a mechanism to execute their line
management responsibilities for safety and balanced priorities. The SMT
Charter was delineated through issuance of D&P Manual Chapter 11.l,
Standing Management Team. The Department is using the IWAP to identify
resource conflicts for safety improvement tasks, and the SMT Chair and
Co-Chair make decisions on which work to complete first based upon
advice and feedback from the contractor representatives on the SMT.

The Department issued D&P Manual Chapter 11.3, Seamless Safety (SS-21)
for Assembly and Disassembly of Nuclear Weapons at the Pantex Plant, to
establish the high level expectations for SS-21. The Department approved
interagency technical business practice (TBP) 901, Integrated Safety
Process for Nuclear Weapons Operations and Facilities. Development of
TBP 901 was facilitated by Sandia National Laboratory and replaced
engineering procedure (EP) 401110, Integrated Safety Process for
Assembly and Disassembly of Nuclear Weapons. TBP-90l clarifies
expectations for SS-21 by incorporating experience gained from
application of EP401110. TBP-901 simplifies the SS-21 process and
eliminates prescription for the myriad of functional sub-teams.

Taken in combination, the above changes in project team roles and
responsibilities and the SS-21 process had little or no effect in
accelerating safety improvements. However, the Department considers
these actions were necessary to establish consistency with the guiding
principles of integrated safety management: clear roles and
responsibilities, and line management responsibility for safety.
Similarly, although not yet perfected, the IWAP provides an important
mechanism for the Department, Pantex Plant operating contractor, and the
design laboratories to establish balanced priorities.

> ***[Future Actions:]{.underline}***

Although the IWAP currently includes the program plan for generic safety
documentation upgrades (e.g., SAR facility modules and associated TSR),
it does not include the associated plans and schedules necessary for
implementation of the improved controls. The IWAP and BIO/SAR Program
Plan do not include commitments and schedules for engineering
improvements such as fire detection and suppression system upgrades
(UV-activation capability), transportation carts, or eliminate,
minimize, or substitute flammable solvent and combustible material. The
Department will rectify this problem through commitment 4.1.1 and the
commitments in section 4.3.

##### Commitment 4.1.1

The Department will revise the BIOISAR Program Plan to include all of
the project plans, schedules and resources necessary to accomplish
generic safety improvements. This includes out-year schedules to achieve
full compliance with DOE Order 5480. 22 and 5480.23, and the associated
resource estimates and schedules for implementation of safety
improvements needed in administrative controls and tooling, or equipment
upgrades. The BIO/SAR Program Plan will also include schedules for
performing nuclear explosive safety (NES) master studies aligned with
the upgrade modules.

> Lead Responsibility: Area Manager, AA0
>
> Deliverable: BIO/SAR Program Plan
>
> Due Date: August 2000

Further changes are anticipated to TBP-901, Integrated Safety Process
for Nuclear Weapons Operations and Facilities, to address remaining
organizational comments or issues. The Department will assess the
adequacy of contractor and design laboratory implementation of the
changes to SS-21 as delineated in TBP-901.

###### Commitment 4.1.2

> Lead Responsibility: Director, WPD
>
> Deliverable: Assessment of TBP-901 Implementation
>
> Date Due: November 2001
>
> **4.2 Analyze Hazards**
>
> ***[Actions Completed:]{.underline}***
>
> For nuclear facilities, the Department requirements for hazard
> analyses are defined in DOE Order 5480.23, *Nuclear Safety Analysis
> Report*. Guidance for compliance with DOE Order 5480.23 is provided
> through DOE-STD3011-94, *Guidance for Preparation of DOE 5480.22 (TSR)
> and DOE 5480.23 (SAR)* *Implementation Plans*, and DOE-STD-3009-94,
> *Preparation Guide for U.S. Department of Energy Nonreactor Nuclear
> Facility Safety Analysis Reports*.

Efforts are ongoing to upgrade the current Pantex Plant Basis for
Interim Operation (BIO) to a SAR that is compliant with DOE Order
5480.23. As part of the IWAP effort, a program plan was developed for
the BIO upgrade. The program plan identifies the individual project
activities required to upgrade the BIO, in modular fashion, to a SAR.
The upgrade modules are structured around the predominant hazards (fire,
lightning, etc.) that affect all nuclear explosive processes, and the
different types or classes of facilities at Pantex (bays, cells, etc.).
Similarly, the program plan includes the development of operational
controls that are compliant with DOE Order 5480.22. The Department and
Pantex Plant operating contractor have transitioned previous controls
found in the Critical Safety System Manual (CSSM) and the BIO to TSR. As
discussed earlier, this provides the foundation upon which future
analyses and operational controls can be built.

> For specific nuclear explosive operations, the Department established
> requirements for hazard analysis through DOE Order 452.2A, *Safety of
> Nuclear Explosive Operations*, and provided guidance through
> DOE-DP-STD-3016-99, *Hazard Analysis Reports for Nuclear Explosive
> Operations*. In addition to the general format and content guidance
> provided in DOE-DP-STD-3016-99, AL provided further guidance through
> D&P Manual Chapter 11.4, *Authorization Basis for Pantex P/ant Nuclear
> Explosive Operations*.
>
> The Pantex contractor developed process-specific hazard analysis
> reports (HAR) for the 56, W87, W62, W76, and W88 programs. DOE has
> approved the HAR for the W56, W87, W62, W76 and W88 (with conditions
> of approval specified on the W76 and W88). The Department has
> conducted "lessons learned" workshops following the development of a
> number of HAR. Information garnered from the workshops has translated
> into additional guidance in the form of changes to AL supplemental
> directives, improved procedures for review and approval, and a manual
> developed by the Pantex Plant operating contractor. The Department
> plans to develop HAR for all other weapon programs in the enduring
> stockpile, consistent with the schedules in the IWAP.
>
> AL established a review process for the HAR that parallels the
> approach used elsewhere in the DOE complex for SAR. The review team
> works for the approval authority. This approach enables the approval
> authority to provide timely direction and guidance to the review team,
> and to resolve technical issues raised during the review. The review
> approach is intended to provide continuity and build upon lessons
> learned through each development and review process by using a core
> group of personnel to perform such reviews. The review team documents
> their results in a safety evaluation report (SER). The SER contains
> the conclusions reached from the review and serves as the basis for
> DOE approval of the contractor HAR. The SER is developed using the
> guidance of DOE-STD-1104-96, *Review and Approval of Nonreactor
> Nuclear Facility Safety Analysis Reports*. AL defined the review
> process, including roles and responsibilities, in D&P Manual Chapter
> 11.4, *Authorization Basis for Pantex Plant Nuclear Explosive
> Operations*.
>
> As AL undertook implementation of this review process, the need for
> additional resources and a formal training and qualification program
> were recognized. Qualification standards were established for AL
> personnel involved in the review of authorization basis documents to
> provide competence commensurate with responsibilities. Additional
> staffing positions were created within the appropriate AL
> organizations involved in the reviews. Where appropriate, AL has used
> the Departments authority to establish excepted service positions, in
> order to recruit the requisite level of experience and talent. An
> excepted service level staff position was established and filled in
> 1999 at AAO.
>
> Personnel are currently working to achieve full qualification and AL
> is tracking the status of qualification in accordance with DOE Order
> 360.1, *Training*. The Department included these actions as commitment
> 5.8.4 in the original implementation plan. Given the actions taken and
> the tracking system in place, the Department considers the previous
> commitment satisfied.
>
> The AL Manager delegated approval authority for HAR and
> weapon-specific TSR to the Area Manager, AAO on March 9, 2000.
> Combined with the previous delegation of authority from the Office of
> Defense Programs (through the AL Manager) for nuclear facility safety
> analyses and controls, this will consolidate approval authority at the
> Area Manager, AAO. The Department believes consolidation of approval
> authority at the Area Manager will promote better integration between
> the facility-level and process-specific analyses and the operational
> controls derived therefrom. The Department also considers it important
> that personnel who are assigned to perform such reviews are located
> closest to the work. In this manner personnel can perform walk-downs
> of facilities or processes to validate the accuracy of the hazard
> analyses and the adequacy of proposed operational controls. AL has
> transferred two (2) additional positions to AAO to implement this
> approach. AL is establishing an additional excepted service position
> at AAO to support review of authorization basis documents for nuclear
> explosive operations.
>
> The Department issued D&P Manual Chapter 11.7, *Nuclear Explosive
> Operations Change Control Process*, to define expectations for
> evaluating potential hazards of proposed changes. The process defined
> in Chapter 11.7 enables the evaluation of proposed changes,
> irrespective of whether a particular weapon process has an approved
> HAR. Chapter 11. 7 reinforces use of the process defined in DOE Order
> 5480.21, *Unreviewed Safety Questions* to evaluate the impacts of a
> proposed change on the existing authorization basis, whether it
> includes a HAR, or is at the facility or site level (e.g., Basis for
> Interim Operation, site-wide TSR). As a sub-element of commitment
> 5.3.2 in the original IP, the Department committed to combining the
> requirements on change control from AL supplemental directive 452.2A
> and D&P Manual Chapter 11.4 into a single "manual". Instead, the
> Department developed D&P Manual Chapter 11.7 to address all aspects of
> change control, in an effort to better integrate the traditional
> change control process used by the nuclear explosive safety community
> with the USQ process traditionally used in other DOE nuclear
> facilities.

In parallel with the efforts taken by the Department, the Pantex Plant
Operating Contractor established a task force to address the continuing
problems associated with development of authorization basis (AB)
documents for nuclear explosive operations (e.g., HAR). The AB Task
Force produced a report in May 1999, which contained an extensive number
of recommendations for improvements. The recommendations were structured
around six major categories of identified needs: (1) definitions, terms,
and communication; (2) processes, methodology, tools, and techniques;
(3) leadership and management; (4) training and professional
development; (5) funding and budgeting; and (6) business execution. Some
of the corrective actions taken include:

-   Development of a Master Authorization Agreement for all hazard
    category 2 nuclear operations and activities at the Pantex Plant
    defining the authorization basis for each activity,

-   Development of a Pantex Plant Integrated Safety Management
    Authorization Basis (AB) Manual to provide site-specific guidance on
    form and content for all authorization basis documents and to define
    organizational roles and responsibilities,

-   Establishment of AB training for risk analysts, Project Team
    members, reviewers and other plant personnel.

> The Pantex Plant Operating Contractor completed a number of the
> corrective actions identified by the AB Task Force. The contractor
> recruited a senior technical advisor and established an organizational
> element specifically responsible for the development of authorization
> basis documents. Additional personnel with hazard analysis experience
> have been hired and support contractors are being used to augment
> staff for critical projects.
>
> ***[Future Actions:]{.underline}***
>
> A number of the actions described above have served to reduce the
> complexity and time required for developing hazard analyses for
> nuclear explosive operations. The Department now has a hazard analysis
> development, review, and approval process for nuclear explosive
> operations that closely parallels processes used elsewhere in the
> complex for nuclear facilities. The quality and rate of HAR
> development has gradually improved. As noted previously, the
> Department attempted to apply expectations for developing a HAR (and
> TSR) effectively "mid-stream" to a number of weapon processes
> simultaneously. As a result, the project teams and the weapons
> community were afforded little if any opportunity to apply the lessons
> learned except in a "real time" environment. The Department believes
> as the process established for HAR (and TSR) development, review, and
> approval matures, further efficiencies will be gained in terms of
> reduction in the time required.
>
> The Department acknowledges further work is required to achieve the
> level of high quality analysis envisioned. One area of particular
> importance is the fidelity of weapon response to hypothetical accident
> environments and stimuli. Each of the respective design laboratories
> applies a slightly different approach to evaluating weapon response.
> Additionally, there is great variability in the degree of supporting
> documentation that serves as the technical basis for conclusions drawn
> by laboratory experts. The Department has tasked the design
> laboratories and MHC to jointly develop a consistent approach and to
> provide consensus expectations for supporting documentation.

###### Commitment 4.2.1

> The Department will issue formal guidance on developing and
> classifying controls for nuclear explosive operations at the Pantex
> Plant.
>
> **Lead Responsibility:** Area Manager, AAO
>
> **Deliverable:** D&P Manual, Chapter 11.8
>
> **Due Date:** October 2000

###### Commitment 4.2.2

> Further guidance on expectations for the evaluation and documentation
> of weapon response to potential accident environments and stimuli will
> be issued through a TBP.
>
> **Lead Responsibility:** Area Manager, AAO
>
> **Deliverable:** TBP guidance on weapon response
>
> **Due Date:** January 2001

###### Commitment 4.2.3

The Department will ensure the requirements for weapon response
evaluation are incorporated into the management and operating contract
for the Pantex Plant. The Department will require the Pantex Plant
operating contractor to develop an impact analysis and implementation
plan for compliance with the D&P 11.8 and TBP requirements. As part of
this commitment the Department will track contractor implementation
until completion.

> **Lead Responsibility:** Area Manager, AAO
>
> **Deliverable:** 11.8 and TBP Impact Analysis and DOE-approved
> Implementation Plan
>
> **Due Date:** March 2001
>
> The Pantex Plant operating contractor plans to provide additional
> training on the USQ process and to transition the performance of such
> reviews more to line management and personnel intimately familiar with
> the work being proposed. For example, this would include tooling
> engineers, weapon program engineers, project managers, maintenance
> package planners and others. This will allow the operating contractor
> to evolve from a centralized USQ review group that has traditionally
> functioned in a support role to increased responsibility on line
> management for evaluating (and documenting) the safety of a proposed
> activity prior to authorization. By increasing the number of plant
> personnel who are knowledgeable and proficient with the USQ process,
> the Department believes the contractor will be more efficient at
> evaluating proposed improvements in safety and in implementing such
> improvements. This is the major item remaining from corrective actions
> taken in response to the AB Task Force report (commitment 5.3.1 in the
> original implementation plan).

###### Commitment 4.2.4

> The Pantex Plant operating contractor will complete transition of the
> USQ process to line management and personnel. The Department will
> assess the adequacy of contractor actions and the effectiveness of the
> USQ process used at the Pantex Plant.
>
> **Lead Responsibility:** Area Manager, AA0
>
> **Deliverable:** Assessment of the USQ process
>
> **Due Date:** January 2001

###### Commitment 4.2.5

The tooling and procedure assessment performed by the Pantex Plant
operating contractor identified the need to ensure failure analyses
performed on tooling provide suitable input for hazard analyses.
Integration of these analyses is required to ensure appropriate
operational controls are derived for safety features or aspects of the
tooling design that prevent accidents.

The Pantex Plant Operating Contractor developed an Integrated Safety
Management Authorization Basis Manual to provide more detailed guidance
to hazard analysts and other plant personnel. Although the Department
agreed the manual is adequate for initial application and use, a number
of areas require additional improvement. The Department will work with
the Pantex Plant Operating Contractor to revise the manual. This will
include additional guidance on the integration of fire hazard analyses
and tooling failure analyses with the overall safety analyses for
nuclear explosive operations.

> **Lead Responsibility:** Area Manager, AAO
>
> **Deliverable:** Revision #2 to the Integrated Safety Management
> Authorization Basis Manual
>
> **Due Date:** October 2000

###### Commitment 4.2.6

> With the promulgation of D&P Manual Chapter 11.7, the Department
> attempted to integrate elements of the nuclear explosive change
> control process with the USQ process. As the Department, design
> laboratories, and Pantex Plant operating contractor applied the
> requirements of D&P Manual Chapter 11. 7, a number of problems have
> arisen. The Department will evaluate Chapter 11.7 for improvements.
> Specifically, establishment of clearer criteria/guidance for the NES
> Change Evaluation process, better linkage to the USQ process, and more
> explicit processing of new safety information will be considered for
> incorporation into Chapter 11.7. The Department will consider recent
> experiences, such as the command disablement operation of the B61-10,
> in this review
>
> **Lead Responsibility:** Director, WSD
>
> **Deliverable:** Revision to D&P Manual Chapter 11. 7
>
> **Due Date:** November 2000

3.  **Develop and Implement Controls**

***[Actions Completed:]{.underline}***

> Perhaps the most difficult problem associated with the rate of SS-21
> implementation is the time and resources required for the iterative
> re-design and analysis of each weapon process. The lead-time required
> for design and procurement or fabrication of new tooling, coupled with
> the time required to develop written procedures become the key
> limiting factors for successful SS-21 implementation.
>
> The Pantex Plant operating contractor performed an assessment of their
> processes for tooling and procedure development in an effort to
> identify potential inefficiencies or needed enhancements. A number of
> opportunities for improvement were identified with corresponding
> recommendations. These included both short term and long term actions.
> Some of the changes implemented were:

-   Expedited process for raw material procurement (to improve the rate
    of in-house tooling manufacture)

-   Doubled the number of tooling planners (to improve coordination of
    material needs, tooling repair or redesign scheduling, etc)

-   Development of the capability to electronically transmit tooling
    drawings to prospective manufacturers or suppliers (to accelerate
    the bid and selection process for vendor fabrication of tooling)

-   Consolidation of previous multiple writers guides into a single
    guide

The Pantex Plant Operating Contractor also identified the need to
improve the process knowledge of procedure writers (to improve their
ability to assess and determine needed changes with less input required
from the weapon engineers). Resource reviews were included as part of
the assessment and additional staffing needs were identified for key
positions. The Pantex Plant operating contractor has either completed
action or is taking additional action to fill these critical positions
within the limitations of the current fiscal year funding.

Previous Pantex Plant operational controls established in the BIO and
the critical safety systems manual (CSSM) were converted into site-wide
TSR. The Department approved the Lightning BIO and the associated TSR on
April 17, 2000. The Pantex Plant Operating Contractor completed
implementation of the new TSR. For selected controls, an adequate
technical basis was established by previous analyses. For other
controls, the technical basis needs to be strengthened or established by
additional analyses. The modular improvements of the BIO/SAR upgrade
program are intended to provide the requisite analyses and improved
controls. The TSR controls established through the BIO/SAR upgrade
efforts would be applicable to multiple facilities and weapon processes.

In conjunction with the development of HAR for a given weapon process,
the Department required development of an activity based control
document (ABCD). The ABCD identifies all of the controls required to
either prevent or mitigate the effects of potentially serious accidents
identified in the HAR. The controls contained in the ABCD are intended
to meet the format and content requirements of DOE Order 5480.22 (i.e.,
TSR). ABCD have been developed and approved for the W79, W56, W87, W62,
W76, and W88 programs. Ultimately, those TSR specific to a given weapon
operation will simply represent an addendum to the site-wide TSR for
Pantex. Previous ABCD attempted to serve as a compensatory measure by
identifying all of the requisite controls.

AL defined requirements for ABCD in the D&P Manual Chapter 11.4,
Authorization Basis for Pantex P/ant Nuclear Explosive Operations. AL is
applying the same review process described above on both the HAR and
ABCD. To assist both contractor personnel who prepare ABCD and DOE
personnel involved in the review, AL provided additional guidance in D&P
Manual 11.5, Target Levels of Controls. The target levels of control
(TLC) concept provides a tool for personnel to gauge the relative level
of defense-in-depth incorporated into a proposed set of operational
controls (i.e., site-wide TSR coupled with weapon-specific TSR).
Fundamental to the TLC concept is the desired hierarchy of controls and
precedence for selection: (1) re-design the process to remove the
hazard, (2) reliance upon passive engineered features, (3) reliance upon
active engineered features, and (4) reliance upon administrative
controls.

> ***[Future Actions:]{.underline}***

The BIO/SAR upgrade program will serve to establish the technical and
analytical basis for the site-wide TSR. This program is anticipated to
result in changes to the existing site-wide TSR, in the form of new or
improved controls. A BIO/SAR module is ongoing to address hazards
associated with fire in areas containing nuclear explosives. Another
BIO/SAR module is ongoing to address hazards associated with the on-site
transportation of nuclear explosives. The scope of this module was
expanded to analyze both full-up and partial weapon configurations.
Additional BIO/SAR modules are planned to address other hazards posed to
nuclear explosive operations conducted in bays, cells, and special
purpose facilities.

###### Commitment 4.3.1

> Develop improved site-wide TSR controls for fire protection.
>
> **Lead Responsibility:** Area Manager, AAO
>
> **Deliverable:** DOE-approved BIO Module on Fire Protection and
> associated TSR and develop a resource-loaded schedule for
> implementation of improved TSR controls for fire protection.
>
> **Due Date:** October 2000

###### Commitment 4.3.2

> The Department will validate implementation of the improved site-wide
> TSR controls for fire protection.
>
> **Lead Responsibility:** Area Manager, AA0
>
> **Deliverable:** DOE RA Report
>
> **Due Date:** Upon completion of the DOE RA identified by the
> Implementation Plan schedule under Commitment 4.3.1 above.

###### Commitment 4.3.3

> Develop improved site-wide TSR controls for on-site transportation of
> nuclear explosives
>
> The Department will develop site-wide TSR controls for on-site
> transportation of nuclear explosives through a BIO module. Some work
> has already been completed with respect to transportation hazards
> analysis, but additional weapon response information is required. As
> an interim compensatory measure, DOE will establish some additional
> controls based on the work already completed. These controls will be
> incorporated into the site-wide TSR until the BIO module is completed.
>
> **Change 1.** The nature of this action has changed significantly
> since approval of Revision 1. Revision 1 anticipated a single
> authorization basis document approved once in its entirety, the
> magnitude of the analysis and engineered controls required make it
> more feasible to manage this activity as three phases, Phase I
> (weapons in their ultimate user configuration), Phase II (partial
> assemblies) and Phase III (nuclear material). The Department has
> approved the authorization basis for Phase I and its implementation
> plan. The commitment date below also reflects the large amount of
> authorization basis document review and approval required of the
> Office of Amarillo

Site Operations in the months preceding and immediately after the 10 CFR
830 April 10, 2003, deadline.

> **Lead Responsibility:** Director, OASO
>
> **Deliverable:** 10 CFR 830 Compliant Documented Safety Analysis and
> DOE-approved
>
> Implementation Plan for transportation controls
>
> **Due Date:** June 30, 2002

###### Commitment 4.3.4

> The Department will validate implementation of the improved site-wide
> TSR controls for on-site transportation of nuclear explosives.
>
> **Lead Responsibility:** Area Manager, AAO
>
> **Deliverable:** DOE RA Report
>
> **Due Date:** Upon completion of the DOE RA identified by the
> Implementation Plan schedule under Commitment 4.3.3 above.

###### Commitment 4.3.5

The experience gained through the development of weapon-specific HAR and
the performance of Nuclear Explosive Safety Master Studies has
demonstrated the need for additional "generic" TSR applicable to nuclear
explosive operations involving multiple weapon programs. The Nuclear
Explosive Safety Master Studies identified a number of positive
measures. Some of these positive measures may warrant inclusion as TSR
controls prior to completion of all BIO/SAR module upgrades. Therefore,
in parallel with the BIO/SAR upgrade modules, the Department will review
previous NES Master Studies to determine if any controls warrant
inclusion in the site-wide TSR. These include controls either explicitly
or implicitly credited in the NES Master Studies. The Department will
apply the criteria and guidance of DOE Order 5480.22 and
DOE-STD-3009-94, in order to determine if any of the credited controls
warrant inclusion in the TSR.

> **Lead Responsibility:** Area Manager, AAO
>
> **Deliverable:** Additional DOE-approved TSR controls derived from the
> NES Master Studies.
>
> **Due Date:** November 2000
>
> Based upon the analytical work performed through several CHE weapon
> program HAR, the Department has identified the need to place increased
> emphasis and priority to eliminate, minimize, or identify and
> implement suitable substitutes through a risk-cost benefit assessment
> for flammable solvents and combustible materials currently used in
> proximity to and in nuclear explosive operations. The flammable
> solvents targeted are those with flashpoints less than 140°F corrected
> to a barometric pressure of 760-mm Hg. As an example, the Department
> has noted a historical tendency to use isopropyl alcohol in several
> applications where it is relatively ineffective as solvent. In this
> situation, the isopropyl alcohol should be eliminated, minimized, or
> replaced with a more suitable, non-flammable solvent to further
> minimize the potential for fire. Another recent example involved the
> W62 program. The rubber floor mats used to cushion the impact from the
> assembly being potentially dropped on the floor were found to be
> combustible in conjunction with the presence of alcohol. A suitable
> replacement floor mat design was successfully found, tested, and
> determined to be fire retardant. The Department will work with the
> Pantex Plant operating contractor and the design laboratories to
> pursue more expeditious elimination, minimization, or evaluation,
> testing, and replacement of flammable solvents and other materials
> used in nuclear explosive processes for assembly, disassembly, and
> testing.

###### Commitment 4.3.6

> Develop a plan to systematically reduce the usage of flammable
> solvents and combustible materials used in proximity to and in nuclear
> explosive operations through a risk-cost benefit assessment of solvent
> and combustible material elimination, minimization or substitution.
> The plan will require identification of operations where those
> flammable solvents and combustible materials used in proximity to and
> in nuclear explosive processes for two weapon programs on a trial
> basis. Based upon a risk-cost benefit assessment, the plan will then
> provide proposed actions that will need to be initiated to eliminate,
> minimize or substitute those flammable solvents and combustible
> materials.
>
> **Lead Responsibility:** Area Manager, AAO
>
> **Deliverable:** Flammable Solvent and Combustible Material Reduction
> Plan
>
> **Due Date:** October 2000
>
> Based upon needs identified through recent analyses, the Department
> will pursue improved transportation carts for various nuclear
> explosive configurations. Carts have already been designed,
> fabricated, and put into use on several weapon systems to provide a
> "Faraday cage" that affords partially assembled nuclear weapons
> protection against large electrical energy sources such as a direct
> lightning strike to the surrounding facility or structure. The
> Department will pursue design, fabrication and use of additional carts
> to provide similar protection for all other nuclear warhead weapon
> systems. Sandia National Laboratory is currently evaluating the
> protection afforded nuclear weapons in their special shipping
> containers and "full-up" or completely assembled weapon configurations
> outside their shipping container. The SNL analysis is expected to
> conclude such configurations provide some level of protection
> equivalent to a "Faraday cage." Therefore, the Department anticipates
> continued focus of transport cart design on protection for partially
> assembled weapon configurations. These configurations would be more
> vulnerable to large electrical energy sources, such as lightning
> strikes.

The draft transportation SAR/BIO module indicates several partial weapon
configurations are similarly vulnerable to mechanical insult from
collisions that might occur during transport, or accidental discharge of
firearms carried by security personnel. The Department will pursue
design, fabrication and use of carts suitable to provide protection
against such mechanical insults. Currently, several design concepts or
"families" of transportation carts are envisioned to fulfill this need.
Every attempt will be made to design and fabricate the carts using
commonality and economy of scale considerations. This approach should
yield the most rapid deployment.

###### Commitment 4.3.7

> The Department will develop a plan for the design, fabrication, and
> use of carts for partially assembled nuclear weapons affording
> protection against the range of potential hazards envisioned in
> transport at the Pantex Plant (e.g., electrical, mechanical).
>
> **Lead Responsibility:** Area Manager, AAO
>
> **Deliverable:** Plan for transportation carts
>
> **Due Date:** October 2000
>
> The draft fire SAR/BIO module, coupled with several weapon-specific
> HAR, indicates the need to establish UV-activated deluge capability
> for a number of areas at the Pantex Plant involved in the assembly and
> disassembly of nuclear explosives. The response time of the current
> system for heat detection and activation of suppression is not
> adequate for the potential situation where a fire might be initiated
> in a bay or cell containing a nuclear weapon with conventional high
> explosive. For the majority of affected facilities, the ongoing
> project to upgrade the capability and reliability of the fire
> detection and suppression systems has been expanded to include UV
> detection as the actuator of deluge systems. In this manner, the speed
> of detection and actuation can be rapid enough to prevent propagation
> of a fire. Rapid detection and suppression activation would prevent
> all fire scenarios except those initiated in very close proximity from
> potentially causing a thermal reaction in the high explosive of a
> nuclear weapon. However, the Building 12-44 cells are not encompassed
> by the current upgrade and a separate project will be required. The
> Department will develop and complete a project for upgrading the fire
> detection and suppression system in Building 12-44 to provide
> UV-activated deluge capability.

###### Commitment 4.3.8

The Department will develop a project design statement (PDS) to upgrade
the fire detection and suppression system in Building 12-44 to provide
UV-activated deluge capability.

> **Lead Responsibility:** Area Manager, AAO
>
> **Deliverable:** PDS for 12-44 Fire Protection Upgrade
>
> **Due Date:** December 2000

##### Commitment 4.3.9

> The Department will modify the fire detection and suppression system
> in Building 12-44 to provide UV-activated deluge capability.
>
> **Lead Responsibility:** Area Manager, AAO
>
> **Deliverable:** Completion of physical modifications to Building
> 12-44
>
> **Due Date:** December 2002

As discussed above, the draft fire SAR/BIO module and weapon-specific
HAR indicate the need for a safety class (or safety significant) fire
detection and suppression system in a number of Pantex Plant facilities
used for the assembly and disassembly of nuclear weapons. The required
reliability of the fire detection and suppression systems must be
determined through further analyses. However, the current maintenance
backlog for the fire alarm system indicates the need for increased
attention, particularly with respect to the number of components
designed or provided by a previous vendor. A number of system components
are no longer available. A project is needed to systematically identify
the upgrades needed to rectify this problem and to ensure the
reliability required to support the intended safety function.

> In the interim (i.e., until a line item capital project can be funded
> and physical replacements completed), the Department will replace fire
> alarm panels and components no longer vendor supported in nuclear
> explosive facilities (based upon failure rate histories) through the
> preventive maintenance program. These obsolete components will provide
> a limited inventory of spare parts for less critical facilities at the
> Pantex Plant until such time replacements can be made through the
> capital line item. In conjunction with this effort, the Department
> will develop potential contingencies for the obsolete vendor computer
> portion of the fire alarm system. This component is recognized as the
> most critical and potentially vulnerable aspect of the overall fire
> alarm system.

###### Commitment 4.3.10

> The Department will develop a conceptual design report (CDR) for a
> project to replace the Pantex Plant fire alarm system. The replacement
> system will provide the needed reliability for fire protection of
> nuclear explosive areas involved in the assembly and disassembly of
> nuclear explosives.
>
> **Change 1.** This commitment was for a preliminary decisional step.
> In a June 15, 2001, letter to the Chairman the Department informed the
> Board that an acquisition strategy based on a series of expense funded
> projects would replace the fire alarm system sooner and potentially at
> lower total costs. In a February 4, 2002 letter the Department
> provided the Board a copy of the program execution plan for the series
> of expense-funded projects. These projects have started and the
> Board's staff is being kept informed of our progress. The intent of
> the original commitments -- to initiate actions to replace the fire
> alarm system - has been met.
>
> **Lead Responsibility:** Area Manager, AAO
>
> **Deliverable:** CDR for fire alarm system replacement
>
> **Due Date:** None

###### Commitment 4.3.11

The Office of Defense Programs (DP) will authorize a line item
construction project for the fire alarm replacement in the budget for
fiscal year 2003. In the interim, the Department will maintain the
reliability of the Pantex Plant fire alarm system through preventive
maintenance for critical facilities, such as those used for assembly,
disassembly, testing, and storage of nuclear explosives. Selective
replacement of facility fire alarm panels and high failure rate
components will be used to establish an inventory of spare parts for
less critical facilities.

> **Change 1.** In a June 15, 2001, letter to the Chairman the
> Department informed the Board that an acquisition strategy based on a
> series of expense funded projects would replace the fire alarm system
> sooner and potentially at lower total costs. In a February 4, 2002
> letter the Department provided the Board a copy of the program
> execution plan for the series of expense-funded projects. These
> projects have started and the Board's staff is being kept informed of
> our progress. The intent of the original commitment -- to initiate
> actions to replace the fire alarm system -- has been met.
>
> **Lead Responsibility:** DP-20
>
> **Deliverable:** DP authorization of Title I
>
> **Due Date:** None
>
> **4.4 Perform Work**
>
> ***[Actions Completed:]{.underline}***

The original Implementation Plan included specific commitments for the
W62 weapons program. The Department implemented compensatory actions
identified in the W62 Step 1 Project Plan to realize part of the
potential SS-21 benefits as soon as possible on the W62. These benefits
included some improvements in the safety and function of key tooling
used to hoist and handle the partially assembled nuclear explosive and
improved procedures more conducive to reader understanding and
adherence. The commitments for the W62 weapons program are complete and
the disassembly and inspection process has safely restarted.

> The Department has reduced the number of independent reviews conducted
> to ensure the contractor has adequately prepared a safe process to
> assemble, disassemble, or test a nuclear explosive prior to
> authorizing startup or resumption. These are a readiness assessment
> and a nuclear explosive safety (NES) review. (As discussed in section
> 4.2, the Department conducts a review to approve the hazard analysis
> and proposed operational controls, prior to implementation and final
> preparations to startup or restart.) The Department is conducting the
> readiness assessment in accordance with DOE Order 425.1A, *Startup and
> Restart of Nuclear Facilities*. AL has promulgated additional guidance
> on readiness assessments through AL supplemental directive 425.1A,
> *Startup and Restart of AL Activities*, and D&P Manual Chapter 11.6,
> *Coordinated Review Process for Nuclear Explosive Operations at the
> Pantex Plant*.
>
> One of the key purposes of the readiness assessment as defined in DOE
> Order 425.1A, is to validate DOE approved operational controls to
> ensure safety are effectively implemented. The purpose of the NES
> review is to question whether the proposed operation is adequately
> controlled from a NES perspective. The NES review serves as an
> additional layer of defense for activities with potential nuclear
> explosive safety consequences.
>
> The Department has revised the requirements for the nuclear explosive
> safety review process to ensure the proper role of an independent
> review. DOE line management is responsible for decisions regarding the
> need for and type of corrective actions stemming from review findings.
> The Department has clarified the delineation of roles and
> responsibilities through revision of AL supplemental directive 452.2A
> and D&P Manual Chapter 11.7. Proposed revisions to DOE Order 452.2A
> and DOE-STD-3015-97 (beyond those comments incorporated into the draft
> released December 2, 1999) are in process to accomplish similar
> clarifications.
>
> The Department also recognized the need to align the NES review scope
> to match with that of the authorization basis developed by line
> management (i.e., HAR, BIO/SAR, and TSR). This allows the NES study to
> serve as an independent review to confirm the safety of the proposed
> operation. This approach corrects the historical practice of using the
> NES study as the primary basis for why the operation is safe enough.
> The Department granted temporary relief to NES expiration dates for
> systems with insensitive high explosive, and restructured the current
> scope of NES Master Studies to align with the scope of programmatic
> elements established in the Pantex BIO/SAR upgrade program. The
> BIO/SAR Program Plan will be updated to include schedules for the
> corresponding NES Master Studies, consistent with this approach (see
> Commitment 4.1.1).
>
> The qualification of the NES review group is key to addressing quality
> and consistency of the studies. To achieve the guiding principle of
> competence commensurate with responsibilities, the structure and
> qualification requirements for the nuclear explosive safety study
> group (NESSG) are being strengthened. This is being accomplished
> through revision of DOE-STD-3015.
>
> ***[Future Actions:]{.underline}***
>
> The allowance for revalidation will be deleted from DOE Order 452.2,
> DOE-STD-3015, and AL SD 452.2. It should be noted that the Department
> plans to use the revalidation process for the W88 program. This review
> will use the same approach as the revalidation of the W62 operation
> conducted in November-December, 1999. The W88 review will be the last
> revalidation conducted.
>
> The minimum core membership for the Nuclear Explosive Safety Study
> Group (NESSG) will be an AL or Nevada Operations Office (NV) chairman
> (depending upon study topic and/or site location of nuclear explosive
> operation), members from each of the design laboratories (SNL, LANL,
> and LLNL), and involvement by senior members. For the studies at
> Pantex Plant, the operating contractor will also have a member on the
> NESSG. This will be specified in a revision to DOE-STD-3015.
>
> AL has taken steps towards implementing the use of senior personnel on
> the NESSG. A list of potential candidates was developed by AL with
> input from the Air Force, HQ, the DNFSB, SNL, LLNL, and LANL. The
> Department will establish a pool of four senior members. The AL
> Manager will interview and select four senior members from the list of
> potential candidates.
>
> More explicit qualification requirements shall be included in the next
> version of DOE-STD-3015 for NES Study chairmen and members. Each
> organization will be responsible for establishing a process to ensure
> their NES personnel meet these requirements prior to participation on
> an NESSG. Further, in order to preserve NV NES expertise, a
> requirement shall be added that NV maintain a minimum of two
> individuals proficient as NESSG members.

##### Commitment 4.4.1

> The Department will develop revisions to DOE Orders 452.1, 452.2, and
> DOE-STD-3015. The proposed revisions to these directives will be
> coordinated with the DNFSB prior to submission into the Department's
> directives system for formal review, in accordance with DOE Manual
> 251.1-lA.
>
> **Lead Responsibility:** DP-20
>
> **Deliverable:** Proposed revisions submitted into directives system
> for formal review
>
> **Due Date:** August 2000

##### Commitment 4.4.2

> The Orders and Standard will be processed and issued concurrently, and
> consistently with DOE Manual 251.1-1A which affords a 30 - 60 day
> comment period followed by a 30 - 60 day comment resolution period.
>
> **Lead Responsibility:** DP-20
>
> **Deliverable:** Revisions to DOE Orders 452.1,452.2, and DOE-STD-3015
> issued
>
> **Due Date:** November 2000

##### Commitment 4.4.3

> AL will issue revisions to supplemental directives to align with the
> changes to DOE Orders 452.1, 452.2, and DOE-STD-3015. The Department
> will invoke applicability of the revised directives through the
> existing contract structure for the Pantex Plant. The management and
> operating contractor will provide an impact analysis and an
> implementation plan, if warranted, to achieve compliance with the new
> requirements.
>
> **Lead Responsibility:** AL Manager
>
> **Deliverable:** Revisions to AL Supplemental Directives 452.1 and
> 452.2 issued and Impact Analysis and DOE-approved Implementation Plan
> (as required)
>
> **Due Date:** February 2001

##### Commitment 4.4.4

> Nevada Operations Office (NV) will issue revisions to the NV Orders to
> align with the changes to DOE Orders 452.1, 452.2, and DOE-STD-3015.
> The Department will invoke applicability of the revised directives
> through the existing contract structure for the Nevada Test Site. The
> management and operating contractor and the design laboratories will
> provide an impact analysis and implementation plan, if warranted, to
> achieve compliance with the new requirements.
>
> **Lead Responsibility:** NV Manager
>
> **Deliverable:** Revisions to NV Orders issued and Impact Analysis and
> DOE-approved
>
> Implementation Plan (as required)
>
> **Due Date:** February 2001
>
> A number of deliverables contained in section 4. 3 of this
> implementation plan are intended to demonstrate the Departments
> commitment to achieving accelerated safety improvements that affect
> multiple weapon programs (i.e., generic improvements or "across the
> board"). Consistent with the approach taken in the original version of
> the implementation plan, the Department believes the startup (or
> restart) of one or more individual weapon systems will be required to
> demonstrate changes made to the "SS-21 process" have been effective in
> promoting the acceleration of safety improvements.

###### Commitment 4.4.5

> The Department will authorize startup of the W78 SS-21 process. The
> startup will reflect improvements in tooling and process design, and
> successful execution of all other aspects of the SS-21 process for a
> weapon system with conventional high explosive (CHE).
>
> **Change 1.** The due dates of Revision 1 to the implementation plan
> were estimated prior to completion of all prerequisite work and prior
> to initiation of detailed planning. Information developed during
> prerequisite work and detailed planning indicates the dates above are
> more accurate target dates for completion. The schedule for this
> project has also been affected by emerging work, new technical
> requirements, heightened security measures, and refocusing of
> resources to meet the April 10, 2003 deadline of 10 CFR 830. The W78
> project has met Milestone 1 and is on schedule to meet the new target
> date.
>
> **Lead Responsibility:** Director, OASO
>
> **Deliverable:** W78 SS-21 Startup Authorization
>
> **Due Date:** August 28, 2003

##### Commitment 4.4.6

> The Department will authorize startup of the B83 SS-21 process. The
> startup will reflect improvements in tooling and process design, and
> successful execution of all other aspects of the SS-21 process for a
> weapon system with insensitive high explosive (IHE).
>
> **Change 1.** The due dates of Revision 1 to the implementation plan
> were estimated prior to completion of all prerequisite work and prior
> to initiation of detailed planning. Information developed during
> prerequisite work and detailed planning indicates the dates above are
> more accurate target dates for completion. The schedule for this
> project has also been affected by emerging work, heightened security
> measures, refocusing of resources to meet the April 10, 2003 deadline
> of 10 CFR 830 and FY 2001 financial constraints. The B83 project has
> met Milestone 1 and is on schedule to meet the new target date.
>
> **Lead Responsibility:** Director, OASO
>
> **Deliverable:** B83 SS-21 Startup Authorization
>
> **Due Date:** May 30, 2004

###### Change 1. Commitment 4 4.7

The Department will accelerate implementation of critical tooling for
two Conventional High Explosive (CHE) weapons to the greatest extent
possible within the scope of the SS-21 authorization basis efforts
currently in progress.

The W78 SS-21 project will implement the bay and cell tooling for
disassembly and inspection and repairs at the accelerated conclusion of
the project. This acceleration is made possible by the quality of the
Step I Hazard Analysis Report and is dependent on the use of an
abbreviated validation process (Nuclear Explosive Safety Study and
Authorization Basis Change Control per Chapter 11 of the Development and
Production Manual). The W88 will have bay tooling accelerated and
validated in a similar fashion. (Cell tooling for the W88 must be
redesigned around a revised production process and cannot be implemented
without the full set of validation activities.)

> **Lead Responsibility:** Director, OASO
>
> **Deliverable:** Delivery of accelerated critical tooling for the W78
> and W88 programs to the Pantex contractor.
>
> **Due Date:** W78: January 31, 2003
>
> W88: October 1, 2002
>
> **Deliverable:** Implementation of accelerated critical tooling for
> the W78 and W88 weapon programs.
>
> **Due Date:** W78: August 28, 2003
>
> W88: May 21, 2003.
>
> **4.5 Feedback and Improvement**
>
> ***[Completed Actions:]{.underline}***
>
> The Department has conducted a number of workshops with several aimed
> specifically at applying lessons learned from one project to another.
> These included such topics as HAR development, weapon response
> information, nuclear explosive safety study group (NESSG) structure
> and membership, and readiness reviews. Using the feedback gained from
> the workshops, the Department has revised or issued a number of
> directives, including D&P Manual Chapters, AL Supplemental Directives
> (425.1A, 452.2A), and DOE-STD-3015. As discussed earlier in this plan,
> the Department anticipates additional directive changes will be
> required to incorporate lessons learned through field application.
>
> In addition to these workshops, the Department has used feedback from
> the Pantex Plant integrated safety management system verification
> (ISMSV) review conducted between July and August 1998. The ISMSV
> review identified a number of the same problems and issues later
> contained in Recommendation 98-2. In response to the ISMSV findings,
> the Amarillo Area Office and the Pantex Plant operating contractor
> have made an extensive number of changes to their procedures and
> standards. These include areas such as: (1) project management; (2)
> prioritization of work; (3) organizational roles and responsibilities;
> (4) hazard analyses development, review and approval; (5) readiness
> preparation and reviews; and, (6) development and use of performance
> measures. The Department completed a repeat Phase I ISMSV review,
> April 3-14, 2000, and approved the Pantex Plant Operating Contractor's
> ISMS Description on May 12, 2000. The Department also completed a
> repeat Phase II ISMSV review at the Pantex Plant, June 19-27, 2000,
> and the team noted significant improvement from the verifications
> conducted in 1998. (Reference previous commitments 5.6.1 and 56.2)
>
> ***[Future Actions:]{.underline}***

The Department included commitment 5.3.3 in the original implementation
plan to evaluate the effectiveness of the review and approval process
for the W88 HAR and the transportation SAR/BIO module. DOE has not
approved either the W88 HAR or the transportation SAR/BIO module. The
intent of the original commitment was to gauge the effectiveness of
changes made in the DOE review and approval processes. This included the
qualification and composition of review teams, review approach used, and
adequacy of review documentation and conclusions.

> In March 1999, the Albuquerque Operations Office conducted a
> self-assessment of the authorization basis document review and
> approval process. This self-assessment was followed by an assessment
> by the Office of Defense Programs in April 1999. On May 26, 1999, the
> Assistant Secretary for Defense Programs delegated approval authority
> of authorization basis documents to the AL Manager for nuclear
> explosive facility operations. On May 28, 1999, the AL Manager further
> delegated approval authority to the Area Manager, AAO.

On March 9, 2000, the AL Manager delegated approval authority of
authorization basis documents to the Area Manager, AAO, for nuclear
explosive processes. With this delegation, the approval authority for
all Pantex Plant authorization basis documents is now vested with the
Area Manager, AAO.

> The Office of Oversight, Environment, Safety and Health (EH-2)
> recently conducted an authorization basis evaluation specific to the
> Pantex Plant. The review was a follow-up evaluation by the Office of
> Environment, Safety and Health stemming from "opportunities for
> improvement" identified during an earlier review (Independent
> Oversight Evaluation of Headquarters and Albuquerque Operations Office
> Management of Environment, Safety, and Health Programs at the Pantex
> Plant, October 1996). The recent assessment evaluated management
> systems associated with the development, approval and maintenance of
> the authorization basis at the Pantex Plant. Given the recent EH
> assessment, the Department does not consider an additional assessment
> of authorization basis review is warranted.

Upon completion of all the actions identified in this plan, the
Department will perform a final comprehensive assessment. The intent of
the assessment will be to gauge how effective the actions were at
accelerating safety improvements at the Pantex Plant. Obviously, not all
safety improvements are anticipated to be complete at that time. SS-21
projects will be ongoing for several IHE weapon systems for several
years thereafter. However, the Department believes such an assessment
should serve as an important indicator to determine the effectiveness of
the approach described within this implementation plan.

###### Commitment 4.5.1

> The Department will complete a comprehensive assessment of the actions
> taken in response to Recommendation 98-2.
>
> **Lead Responsibility:** NA-12
>
> **Deliverable:** Final Assessment Report
>
> **Due Date:** August 31, 2004

**5.0 Organization and Management**

> **5.1 Organization**

The Department has designated the Deputy Assistant Administrator for
Military Applications and Stockpile Operations (DP-20) as the
responsible manager for the Recommendation 98-2 Implementation Plan.
Responsibilities for execution of commitments identified in this
Implementation Plan are assigned to senior managers responsible for the
specific activity

> **5.2 Management Systems**

1.  **Change Control**

> Complex, long-range plans require sufficient flexibility to
> accommodate changes in commitments, actions, or completion dates that
> may be necessary due to additional information, improvements, or
> changes in baseline assumptions. The Departments policy is to:

-   bring to the Board's attention any substantive changes to this IP
    98-2 as soon as identified and prior to the passing of the milestone
    date;

-   have the Secretary approve all revisions to the scope and schedule
    of plan commitments; and,

-   clearly identify and describe the revisions and bases for the
    revisions.

> Fundamental changes to the plan's strategy, scope, or schedule will be
> provided to the Board through formal revision of the IP 98-2. Other
> changes to the scope or schedule of planned commitments will be
> formally submitted in appropriate correspondence approved by the
> Secretary, along with the basis for the changes and appropriate
> corrective actions.
>
> The Department previously provided information copies of several
> action plans to give the Board additional insight to the approach the
> Department is taking to address safety management concerns at Pantex.
> The Department will continue to provide the Board with periodic
> updates of these plans.

2.  **Reporting**

> To ensure that the various Department implementing elements and the
> Board remain informed of the status of plan implementation, the
> Departments policy is to provide periodic progress reports until IP
> 98-2 commitments are completed. For this plan, the Department will
> provide quarterly briefings to the Board and/or its staff, within 1
> month of the close of each quarter during plan implementation.
> Quarters will coincide with the calendar and fiscal year quarters:
> January-March, April-June, July-September, and October-December. The
> AL Manager will transmit the quarterly status report to the Board. The
> frequency of reports and briefings may be revised pursuant to mutual
> agreement of the parties.
>
> The Department will continue to provide quarterly briefings and
> reports
>
> **Lead Responsibility:** NA-12
>
> **Deliverables:** Briefing and written report
>
> **Due Date:** Each quarter

0.  **Implementation Plan Commitment Crosswalk**

Crosswalk between commitments contained in the original Implementation
Plan, and commitments

contained in this revised Implementation Plan

+-----+--------------+----+-------+---------------------------+-------+
| ##  |              |    |       |                           |       |
| ### |              |    |       |                           |       |
| ##  |              |    |       |                           |       |
| Out |              |    |       |                           |       |
| sta |              |    |       |                           |       |
| ndi |              |    |       |                           |       |
| ng  |              |    |       |                           |       |
| Act |              |    |       |                           |       |
| ion |              |    |       |                           |       |
| s C |              |    |       |                           |       |
| arr |              |    |       |                           |       |
| ied |              |    |       |                           |       |
|  Ov |              |    |       |                           |       |
| er  |              |    |       |                           |       |
| or  |              |    |       |                           |       |
| Rev |              |    |       |                           |       |
| ise |              |    |       |                           |       |
| d a |              |    |       |                           |       |
| s a |              |    |       |                           |       |
|  Re |              |    |       |                           |       |
| sul |              |    |       |                           |       |
| t o |              |    |       |                           |       |
| f 9 |              |    |       |                           |       |
| 8-2 |              |    |       |                           |       |
|  Re |              |    |       |                           |       |
| vis |              |    |       |                           |       |
| ion |              |    |       |                           |       |
+-----+--------------+----+-------+---------------------------+-------+
| **9 |              |    | **Re  |                           |       |
| 8-2 |              |    | vised |                           |       |
| Im  |              |    | 98-2  |                           |       |
| ple |              |    | Impl  |                           |       |
| men |              |    | ement |                           |       |
| tat |              |    | ation |                           |       |
| ion |              |    | Plan  |                           |       |
| Pla |              |    | (June |                           |       |
| n** |              |    | 20    |                           |       |
|     |              |    | 00)** |                           |       |
| **  |              |    |       |                           |       |
| (Ap |              |    |       |                           |       |
| ril |              |    |       |                           |       |
| 1   |              |    |       |                           |       |
| 999 |              |    |       |                           |       |
| )** |              |    |       |                           |       |
+-----+--------------+----+-------+---------------------------+-------+
| **D | ########     | ** | **New | ######## Description      | *     |
| eli |  Description | St | Co    |                           | *98-2 |
| ver |              | at | mmitm |                           | Rev   |
| abl |              | us | ent** |                           | ision |
| e** |              | ** |       |                           | Sta   |
|     |              |    | **Num |                           | tus** |
| *   |              |    | ber** |                           |       |
| *No |              |    |       |                           |       |
| .** |              |    |       |                           |       |
+-----+--------------+----+-------+---------------------------+-------+
| 5   | AB Actions   | F  | 4.2.4 | Assessment of USQ process | See   |
| .3. | Complete     | or |       |                           | Se    |
| 1#3 |              | wa |       |                           | ction |
|     |              | rd |       |                           | 4.2   |
+-----+--------------+----+-------+---------------------------+-------+
| 5   | Issue        | F  | 4.4.1 | DOE Order 452.1A and      | See   |
| .4. | revised DOE  | or |       | 452.2A Revisions          | Se    |
| 2#3 | Order 452.2  | wa | 4.4.2 | Submitted                 | ction |
|     |              | rd |       |                           | 4.4   |
|     |              |    | 4.4.3 | Formal Review Cycle &     |       |
|     |              |    |       | Orders Issued             |       |
|     |              |    | 4.4.4 |                           |       |
|     |              |    |       | Issue Revised Site        |       |
|     |              |    |       | Directives, Impact        |       |
|     |              |    |       | Analysis & AL Approved    |       |
|     |              |    |       |                           |       |
|     |              |    |       | IP                        |       |
|     |              |    |       |                           |       |
|     |              |    |       | Revisions to NV Orders    |       |
|     |              |    |       | Issued, Impact Analysis,  |       |
|     |              |    |       | NV Approved IP            |       |
+-----+--------------+----+-------+---------------------------+-------+
| 5   | Issue        | F  | 4.4.1 | DOE-STD-3015-97 Revisions | See   |
| .5. | DOE-STD-3015 | or |       | Submitted                 | Se    |
| 1#4 |              | wa | 4.4.2 |                           | ction |
|     |              | rd |       | Formal Review Cycle &     | 4.4   |
|     |              |    | 4.4.3 | Orders Issued             |       |
|     |              |    |       |                           |       |
|     |              |    | 4.4.4 | Issue Revised Site        |       |
|     |              |    |       | Directives, Impact        |       |
|     |              |    |       | Analysis & AL Approved IP |       |
|     |              |    |       |                           |       |
|     |              |    |       | Revisions to NV Orders    |       |
|     |              |    |       | Issued, Impact Analysis,  |       |
|     |              |    |       | NV Approved IP            |       |
+-----+--------------+----+-------+---------------------------+-------+
| 5   | Approved     | F  | 4.3.3 | DOE-Approved BIO          | See   |
| .6. | BIO/TSR      | or |       | Module/TSR for On-Site    | Se    |
| 3#3 | Upgrade for  | wa | 4.3.4 | Transportation and        | ction |
|     | tr           | rd |       | DOE-Approved IP for       | 4.3   |
|     | ansportation |    |       | On-Site Transportation    |       |
|     | hazards      |    |       | Controls                  |       |
|     |              |    |       |                           |       |
|     |              |    |       | DOE RA Report for On-Site |       |
|     |              |    |       | Transportation            |       |
+-----+--------------+----+-------+---------------------------+-------+
| 5   | A            | F  | 4.4.6 | W78 SS-21 Start-up        | See   |
| .6. | uthorization | or |       | Authorization             | Se    |
| 4#2 | of an SS-21  | wa |       |                           | ction |
|     | process for  | rd |       |                           | 4.4   |
|     | the W78 in   |    |       |                           |       |
|     | accordance   |    |       |                           |       |
|     | with the     |    |       |                           |       |
|     | tasks and    |    |       |                           |       |
|     | time         |    |       |                           |       |
|     | interval     |    |       |                           |       |
|     | identified   |    |       |                           |       |
|     | in the IWAP  |    |       |                           |       |
+-----+--------------+----+-------+---------------------------+-------+
| 5   | Review plan  | F  | 4.5.1 | IP 98-2 Final Assessment  | See   |
| .6. | and criteria | or |       | Report                    | Se    |
| 5#1 | for final    | wa |       |                           | ction |
| & 2 | assessment   | rd |       |                           | 4.5   |
|     | of 98-2      |    |       |                           |       |
|     | actions and  |    |       |                           |       |
|     | Final report |    |       |                           |       |
+-----+--------------+----+-------+---------------------------+-------+
| NA  | New          | N  | 4.1.1 | BIO/SAR Program Plan      | See   |
|     | Commitment   | ew |       |                           | Se    |
|     |              |    |       |                           | ction |
|     |              |    |       |                           | 4.1   |
+-----+--------------+----+-------+---------------------------+-------+
| NA  | New          | N  | 4.1.2 | Assessment of TBP-901     | See   |
|     | Commitment   | ew |       | Implementation            | Se    |
|     |              |    |       |                           | ction |
|     |              |    |       |                           | 4.1   |
+-----+--------------+----+-------+---------------------------+-------+
| NA  | New          | N  | 4.2.1 | D&P Manual Chapter        | See   |
|     | Commitment   | ew |       | 11.8--Weapon Response     | Se    |
|     |              |    |       | Guidance                  | ction |
|     |              |    |       |                           | 4.2   |
+-----+--------------+----+-------+---------------------------+-------+
| NA  | New          | N  | 4.2.2 | TBP Guidance on           | See   |
|     | Commitment   | ew |       | expectations &            | Se    |
|     |              |    |       | documentation of weapon   | ction |
|     |              |    |       | response (Follows 11.8)   | 4.2   |
+-----+--------------+----+-------+---------------------------+-------+
| NA  | New          | N  | 4.2.3 | 11.8 &TBP Impact Analysis | See   |
|     | Commitment   | ew |       | & DOE-Approved            | Se    |
|     |              |    |       | Implementation Plan       | ction |
|     |              |    |       |                           | 4.2   |
+-----+--------------+----+-------+---------------------------+-------+
| NA  | New          | N  | 4.2.5 | Revise ISM AB Manual      | See   |
|     | Commitment   | ew |       |                           | Se    |
|     |              |    |       |                           | ction |
|     |              |    |       |                           | 4.2   |
+-----+--------------+----+-------+---------------------------+-------+
| NA  | New          | N  | 4.2.6 | Revise D&P 11.7--Nuclear  | See   |
|     | Commitment   | ew |       | Explosive Operations      | Se    |
|     |              |    |       | Change Control Process    | ction |
|     |              |    |       |                           | 4.2   |
+-----+--------------+----+-------+---------------------------+-------+
| NA  | New          | N  | 4.3.1 | DOE-Approved BIO          | See   |
|     | Commitment   | ew |       | Module/TSR for Fire       | Se    |
|     |              |    |       | Protection and            | ction |
|     |              |    |       | DOE-Approved              | 4.3   |
|     |              |    |       | Implementation Plan for   |       |
|     |              |    |       | Fire Protection Controls  |       |
+-----+--------------+----+-------+---------------------------+-------+
| NA  | New          | N  | 4.3.2 | DOE Readiness Assessment  | See   |
|     | Commitment   | ew |       | Report for Fire           | Se    |
|     |              |    |       | Protection                | ction |
|     |              |    |       |                           | 4.3   |
+-----+--------------+----+-------+---------------------------+-------+
| NA  | New          | N  | 4.3.5 | Additional DOE-Approved   | See   |
|     | Commitment   | ew |       | TSR controls derived from | Se    |
|     |              |    |       | the NES master Studies    | ction |
|     |              |    |       |                           | 4.3   |
+-----+--------------+----+-------+---------------------------+-------+
| NA  | New          | N  | 4.3.6 | Flammable Solvent and     | See   |
|     | Commitment   | ew |       | Combustible Material      | Se    |
|     |              |    |       | Reduction Plan            | ction |
|     |              |    |       |                           | 4.3   |
+-----+--------------+----+-------+---------------------------+-------+
| NA  | New          | N  | 4.3.7 | Plan for Transportation   | See   |
|     | Commitment   | ew |       | Carts                     | Se    |
|     |              |    |       |                           | ction |
|     |              |    |       |                           | 4.3   |
+-----+--------------+----+-------+---------------------------+-------+
| NA  | New          | N  | 4.3.8 | PDS for 12-44 Fire        | See   |
|     | Commitment   | ew |       | Protection Upgrade        | Se    |
|     |              |    |       |                           | ction |
|     |              |    |       |                           | 4.3   |
+-----+--------------+----+-------+---------------------------+-------+
| NA  | New          | N  | 4.3.9 | Completion of physical    | See   |
|     | Commitment   | ew |       | Modifications to Bldg.    | Se    |
|     |              |    |       | 12-44 Completed           | ction |
|     |              |    |       |                           | 4.3   |
+-----+--------------+----+-------+---------------------------+-------+
| NA  | New          | N  | 4     | Conceptual Design for     | See   |
|     | Commitment   | ew | .3.10 | Fire Detection and        | Se    |
|     |              |    |       | Suppression Systems       | ction |
|     |              |    |       | Upgrades                  | 4.3   |
+-----+--------------+----+-------+---------------------------+-------+
| NA  | New          | N  | 4     | ESAAB Authorization for   | See   |
|     | Commitment   | ew | .3.11 | Title 1                   | Se    |
|     |              |    |       |                           | ction |
|     |              |    |       |                           | 4.3   |
+-----+--------------+----+-------+---------------------------+-------+
| NA  | New          | N  | 4.4.6 | B83 SS-21 Start-up        | See   |
|     | Commitment   | ew |       |                           | Se    |
|     |              |    |       |                           | ction |
|     |              |    |       |                           | 4.4   |
+-----+--------------+----+-------+---------------------------+-------+
| NA  | Change 1 New | N  | 4.4.7 | Accelerated Critical      | See   |
|     | commitment   | ew |       | Tooling for W78 and W88   | Se    |
|     |              |    |       |                           | ction |
|     |              |    |       |                           | 4.4   |
+-----+--------------+----+-------+---------------------------+-------+

+------+------------+----+-------------------+-------+-------+-------+
| *    |            |    |                   |       |       |       |
| *Out |            |    |                   |       |       |       |
| stan |            |    |                   |       |       |       |
| ding |            |    |                   |       |       |       |
| Act  |            |    |                   |       |       |       |
| ions |            |    |                   |       |       |       |
| S    |            |    |                   |       |       |       |
| ugge |            |    |                   |       |       |       |
| sted |            |    |                   |       |       |       |
| for  |            |    |                   |       |       |       |
| Rem  |            |    |                   |       |       |       |
| oval |            |    |                   |       |       |       |
| ---  |            |    |                   |       |       |       |
| D    |            |    |                   |       |       |       |
| epen |            |    |                   |       |       |       |
| dant |            |    |                   |       |       |       |
| on   |            |    |                   |       |       |       |
| ano  |            |    |                   |       |       |       |
| ther |            |    |                   |       |       |       |
| pro  |            |    |                   |       |       |       |
| cess |            |    |                   |       |       |       |
| or   |            |    |                   |       |       |       |
| i    |            |    |                   |       |       |       |
| mple |            |    |                   |       |       |       |
| ment |            |    |                   |       |       |       |
| ed** |            |    |                   |       |       |       |
|      |            |    |                   |       |       |       |
| *    |            |    |                   |       |       |       |
| *thr |            |    |                   |       |       |       |
| ough |            |    |                   |       |       |       |
| ano  |            |    |                   |       |       |       |
| ther |            |    |                   |       |       |       |
| acti |            |    |                   |       |       |       |
| on** |            |    |                   |       |       |       |
+------+------------+----+-------------------+-------+-------+-------+
| **   |            |    |                   | **Re  |       |       |
| 98-2 |            |    |                   | vised |       |       |
| Im   |            |    |                   | 98-2  |       |       |
| plem |            |    |                   | Impl  |       |       |
| enta |            |    |                   | ement |       |       |
| tion |            |    |                   | ation |       |       |
| Plan |            |    |                   | P     |       |       |
| (A   |            |    |                   | lan** |       |       |
| pril |            |    |                   |       |       |       |
| 199  |            |    |                   | **    |       |       |
| 9)** |            |    |                   | (June |       |       |
|      |            |    |                   | 20    |       |       |
|      |            |    |                   | 00)** |       |       |
+------+------------+----+-------------------+-------+-------+-------+
| **D  | **Des      | ** | **Remarks**       | **    | **Des | *     |
| eliv | cription** | St |                   | New** | cript | *98-2 |
| erab |            | at |                   |       | ion** | Revis |
| le** |            | us |                   | **Co  |       | ion** |
|      |            | ** |                   | mmitm |       |       |
| **N  |            |    |                   | ent** |       | **Sta |
| o.** |            |    |                   |       |       | tus** |
|      |            |    |                   | **Num |       |       |
|      |            |    |                   | ber** |       |       |
+------+------------+----+-------------------+-------+-------+-------+
| 5.2  | Implement  | Re | 90% complete as   | NA    | NA    | See   |
| .3#2 | process    | mo | of 6/30/00. 98-2  |       |       | Se    |
|      | im         | ve | Revision          |       |       | ction |
|      | provements |    | addresses this    |       |       | 4.0   |
|      | (tooling   |    | and suggests      |       |       |       |
|      | /procedure |    | removal of this   |       |       |       |
|      | processes) |    | item.             |       |       |       |
+------+------------+----+-------------------+-------+-------+-------+
| 5.3  | Assessment | Re | EH-2 is           | NA    | NA    | See   |
| .3#2 | for review | mo | conducting an     |       |       | Se    |
|      | of         | ve | authorization     |       |       | ction |
|      | tran       |    | basis evaluation. |       |       | 4.5   |
|      | sportation |    | In light of the   |       |       |       |
|      | BIO        |    | extent and scope  |       |       |       |
|      | upgrade    |    | of the EH-2       |       |       |       |
|      |            |    | review and the    |       |       |       |
|      |            |    | April 1999 Office |       |       |       |
|      |            |    | of Defense        |       |       |       |
|      |            |    | Program review,   |       |       |       |
|      |            |    | the Department    |       |       |       |
|      |            |    | does not consider |       |       |       |
|      |            |    | further           |       |       |       |
|      |            |    | evaluations       |       |       |       |
|      |            |    | warranted. 98-2   |       |       |       |
|      |            |    | Revision          |       |       |       |
|      |            |    | addresses this    |       |       |       |
|      |            |    | and suggests      |       |       |       |
|      |            |    | removal of this   |       |       |       |
|      |            |    | item.             |       |       |       |
+------+------------+----+-------------------+-------+-------+-------+
| 5.6  | Re-aut     | Re | W88 is discussed  | NA    | NA    | See   |
| .4#1 | horization | mo | in 98-2 Revision  |       |       | Se    |
|      | of the     | ve | as last           |       |       | ction |
|      | existing   |    | revalidation.     |       |       | 4.3   |
|      | W88        |    | Final result will |       |       | and   |
|      | process in |    | be reported to    |       |       | 4.4   |
|      | accordance |    | the Board.        |       |       |       |
|      | with the   |    | However, 98-2     |       |       |       |
|      | tasks and  |    | Revision suggests |       |       |       |
|      | schedule   |    | removal of this   |       |       |       |
|      | identified |    | item since not    |       |       |       |
|      | in the     |    | effective measure |       |       |       |
|      | IWAP       |    | of process        |       |       |       |
|      |            |    | improvements.     |       |       |       |
+------+------------+----+-------------------+-------+-------+-------+
| 5.8  | Long term  | Re | The course        | NA    | NA    | See   |
| .1#3 | personnel  | mo | development was   |       |       | Se    |
|      | plan for   | ve | completed on      |       |       | ction |
|      | project    |    | 4/28/00. The core |       |       | 4.5   |
|      | management |    | team has received |       |       |       |
|      |            |    | training. Project |       |       |       |
|      |            |    | and Program       |       |       |       |
|      |            |    | Managers due to   |       |       |       |
|      |            |    | complete training |       |       |       |
|      |            |    | in June. This is  |       |       |       |
|      |            |    | the last action.  |       |       |       |
|      |            |    | 98-2 Revision     |       |       |       |
|      |            |    | discusses and     |       |       |       |
|      |            |    | suggests removal  |       |       |       |
|      |            |    | of this action.   |       |       |       |
+------+------------+----+-------------------+-------+-------+-------+
| 5.8  | Complete   | Re | This is the last  | NA    | NA    | See   |
| .2#2 | defined    | mo | action. 98-2      |       |       | Se    |
|      | actions    | ve | Revision          |       |       | ction |
|      |            |    | discusses and     |       |       | 4.2   |
|      |            |    | suggests removal  |       |       |       |
|      |            |    | of this action.   |       |       |       |
|      |            |    | ECD for           |       |       |       |
|      |            |    | completing        |       |       |       |
|      |            |    | training is       |       |       |       |
|      |            |    | 10/1/2000.        |       |       |       |
+------+------------+----+-------------------+-------+-------+-------+

+------+---------------------------+---------+--------+------+-------+
| **C  |                           |         |        |      |       |
| ompl |                           |         |        |      |       |
| eted |                           |         |        |      |       |
| Act  |                           |         |        |      |       |
| ions |                           |         |        |      |       |
| P    |                           |         |        |      |       |
| rior |                           |         |        |      |       |
| to   |                           |         |        |      |       |
| Appr |                           |         |        |      |       |
| oval |                           |         |        |      |       |
| of   |                           |         |        |      |       |
| the  |                           |         |        |      |       |
| 98-2 |                           |         |        |      |       |
| Re   |                           |         |        |      |       |
| visi |                           |         |        |      |       |
| on** |                           |         |        |      |       |
+------+---------------------------+---------+--------+------+-------+
| **   |                           |         | **R    |      |       |
| 98-2 |                           |         | evised |      |       |
| Im   |                           |         | 98-2   |      |       |
| plem |                           |         | Im     |      |       |
| enta |                           |         | plemen |      |       |
| tion |                           |         | tation |      |       |
| Plan |                           |         | Plan   |      |       |
| (A   |                           |         | (June  |      |       |
| pril |                           |         | 2      |      |       |
| 199  |                           |         | 000)** |      |       |
| 9)** |                           |         |        |      |       |
+------+---------------------------+---------+--------+------+-------+
| **D  | ######### Description     | **S     | *      | **D  | *     |
| eliv |                           | tatus** | *New** | escr | *98-2 |
| erab |                           |         |        | ipti | Revis |
| le** |                           |         | **     | on** | ion** |
|      |                           |         | Commit |      |       |
| **N  |                           |         | ment** |      | **Sta |
| o.** |                           |         |        |      | tus** |
|      |                           |         | **Nu   |      |       |
|      |                           |         | mber** |      |       |
+------+---------------------------+---------+--------+------+-------+
| 5    | Plant Standard 7401 &     | De      | NA     | NA   | See   |
| .1.1 | 7403                      | livered |        |      | Se    |
|      |                           | 5/30/99 |        |      | ction |
|      |                           |         |        |      | 4.1   |
+------+---------------------------+---------+--------+------+-------+
| 5    | Issue D&P Manual Chapter  | De      | NA     | NA   | See   |
| .1.2 | 11.1, Rev. 1              | livered |        |      | Se    |
|      |                           | 6/30/99 |        |      | ction |
|      |                           |         |        |      | 4.1   |
+------+---------------------------+---------+--------+------+-------+
| 5    | Issue TBP 901             | De      | NA     | NA   | See   |
| .1.3 |                           | livered |        |      | Se    |
|      |                           | 2/10/00 |        |      | ction |
|      |                           |         |        |      | 4.1   |
+------+---------------------------+---------+--------+------+-------+
| 5    | Project Plans and         | De      | NA     | NA   | See   |
| .1.4 | Schedules (IWAP)          | livered |        |      | Se    |
|      |                           | 2/7/00  |        |      | ction |
|      |                           |         |        |      | 4.1   |
+------+---------------------------+---------+--------+------+-------+
| 5.2  | Issue D&P Manual Chapter  | De      | NA     | NA   | See   |
| .1#1 | 11.3                      | livered |        |      | Se    |
|      |                           | 4/19/99 |        |      | ction |
|      |                           |         |        |      | 4.1   |
+------+---------------------------+---------+--------+------+-------+
| 5.2  | Issue TBP 901             | De      | NA     | NA   | See   |
| .1#2 |                           | livered |        |      | Se    |
|      |                           | 2/10/00 |        |      | ction |
|      |                           |         |        |      | 4.1   |
+------+---------------------------+---------+--------+------+-------+
| 5    | Modify associated plant   | De      | NA     | NA   | See   |
| .2.2 | documents to meet new TBP | livered |        |      | Se    |
|      | 901 standards             | 4/28/00 |        |      | ction |
|      |                           |         |        |      | 4.1   |
+------+---------------------------+---------+--------+------+-------+
| 5.2  | Review report with        | De      | NA     | NA   | See   |
| .3#1 | recommendations           | livered |        |      | Se    |
|      | (tooling/procedure        | 5/30/99 |        |      | ction |
|      | processes)                |         |        |      | 4.0   |
+------+---------------------------+---------+--------+------+-------+
| 5.3  | AB Task Force Report      | De      | NA     | NA   | See   |
| .1#1 |                           | livered |        |      | Se    |
|      |                           | 5/30/99 |        |      | ction |
|      |                           |         |        |      | 4.2   |
+------+---------------------------+---------+--------+------+-------+
| 5.3  | AB Action Plan            | De      | NA     | NA   | See   |
| .1#2 |                           | livered |        |      | Se    |
|      |                           | 6/30/99 |        |      | ction |
|      |                           |         |        |      | 4.2   |
+------+---------------------------+---------+--------+------+-------+
| 5.3  | Issue AL SD 452.2A        | De      | NA     | NA   | See   |
| .2#1 |                           | livered |        |      | Se    |
|      |                           | 6/30/99 |        |      | ction |
|      |                           |         |        |      | 4.2   |
+------+---------------------------+---------+--------+------+-------+
| 5.3  | Revise D&P Manual Chapter | De      | NA     | NA   | See   |
| .2#2 | 11.4                      | livered |        |      | Se    |
|      |                           | 6/30/99 |        |      | ction |
|      |                           |         |        |      | 4.2   |
+------+---------------------------+---------+--------+------+-------+
| 5.3  | Combine requirements into | De      | NA     | NA   | See   |
| .2#3 | one manual                | livered |        |      | Se    |
|      |                           | 6/30/99 |        |      | ction |
|      |                           |         |        |      | 4.2   |
+------+---------------------------+---------+--------+------+-------+
| 5.3  | Assessment for review of  | De      | NA     | NA   | See   |
| .3#1 | W88 HAR                   | livered |        |      | Se    |
|      |                           | 1       |        |      | ction |
|      |                           | 2/13/99 |        |      | 4.5   |
+------+---------------------------+---------+--------+------+-------+
| 5    | D&P Manual Chapter 11.6   | De      | NA     | NA   | See   |
| .4.1 |                           | livered |        |      | Se    |
|      |                           | 6/30/99 |        |      | ction |
|      |                           |         |        |      | 4.4   |
+------+---------------------------+---------+--------+------+-------+
| 5.4  | Initial issue of DOE-AL   | De      | NA     | NA   | See   |
| .2#1 | SD 452.2A                 | livered |        |      | Se    |
|      |                           | 6/30/99 |        |      | ction |
|      |                           |         |        |      | 4.4   |
+------+---------------------------+---------+--------+------+-------+
| 5.4  | Submit revisions to DOE   | De      | NA     | NA   | See   |
| .2#2 | Order 452.2               | livered |        |      | Se    |
|      |                           | 6/30/99 |        |      | ction |
|      |                           |         |        |      | 4.4   |
+------+---------------------------+---------+--------+------+-------+
| 5.4  | Develop NESS process      | De      | NA     | NA   | See   |
| .3#1 | changes & provide         | livered |        |      | Se    |
|      | recommendations           | 6/30/99 |        |      | ction |
|      |                           |         |        |      | 4.4   |
+------+---------------------------+---------+--------+------+-------+
| 5.4  | Revise DOE STD-3015       | De      | NA     | NA   | See   |
| .3#2 |                           | livered |        |      | Se    |
|      |                           | 1       |        |      | ction |
|      |                           | 2/10/99 |        |      | 4.4   |
+------+---------------------------+---------+--------+------+-------+
| 5.5  | Provide NESS              | De      | NA     | NA   | See   |
| .1#1 | recommendations           | livered |        |      | Se    |
|      |                           | 5/28/99 |        |      | ction |
|      |                           |         |        |      | 4.4   |
+------+---------------------------+---------+--------+------+-------+
| 5.5  | Senior level workshop     | De      | NA     | NA   | See   |
| .1#2 |                           | livered |        |      | Se    |
|      |                           | 6/30/99 |        |      | ction |
|      |                           |         |        |      | 4.4   |
+------+---------------------------+---------+--------+------+-------+
| 5.5  | Decision Report           | De      | NA     | NA   | See   |
| .1#3 |                           | livered |        |      | Se    |
|      |                           | 8/23/99 |        |      | ction |
|      |                           |         |        |      | 4.4   |
+------+---------------------------+---------+--------+------+-------+
| 5.5  | Recommendations (NESS)    | De      | NA     | NA   | See   |
| .2#1 |                           | livered |        |      | Se    |
|      |                           | 5/28/99 |        |      | ction |
|      |                           |         |        |      | 4.4   |
+------+---------------------------+---------+--------+------+-------+
| 5.5  | Revise & Issue            | De      | NA     | NA   | See   |
| .2#2 | DOE-STD-3015              | livered |        |      | Se    |
|      |                           | 1       |        |      | ction |
|      |                           | 2/10/99 |        |      | 4.4   |
+------+---------------------------+---------+--------+------+-------+
| 5.6  | ISMSV Phase 1 Review Plan | De      | NA     | NA   | See   |
| .1#1 |                           | livered |        |      | Se    |
|      |                           | 9/10/99 |        |      | ction |
|      |                           |         |        |      | 4.5   |
+------+---------------------------+---------+--------+------+-------+
| 5.6  | ISMSV Phase 1 Review      | De      | NA     | NA   | See   |
| .1#2 | Report                    | livered |        |      | Se    |
|      |                           | 4/13/00 |        |      | ction |
|      |                           |         |        |      | 4.5   |
+------+---------------------------+---------+--------+------+-------+
| 5.6  | Approved ISMS Description | De      | NA     | NA   | See   |
| .1#3 |                           | livered |        |      | Se    |
|      |                           | 6/30/00 |        |      | ction |
|      |                           |         |        |      | 4.5   |
+------+---------------------------+---------+--------+------+-------+
| 5.6  | ISMSV Phase II Review     | De      | NA     | NA   | See   |
| .2#1 | Plan                      | livered |        |      | Se    |
|      |                           | 6/30/00 |        |      | ction |
|      |                           |         |        |      | 4.5   |
+------+---------------------------+---------+--------+------+-------+
| 5.6  | ISMSV Phase II Report     | De      | NA     | NA   | See   |
| .2#2 |                           | livered |        |      | Se    |
|      |                           | 6/30/00 |        |      | ction |
|      |                           |         |        |      | 4.5   |
+------+---------------------------+---------+--------+------+-------+
| 5.6  | CSSM to TSR Conversion    | De      | NA     | NA   | See   |
| .3#1 |                           | livered |        |      | Se    |
|      |                           | 3/13/00 |        |      | ction |
|      |                           |         |        |      | 4.2   |
+------+---------------------------+---------+--------+------+-------+
| 5.6  | Approved BIO/TRU Upgrade  | De      | NA     | NA   | See   |
| .3#2 | for lightning hazards     | livered |        |      | Se    |
|      |                           | 4/17/00 |        |      | ction |
|      |                           |         |        |      | 4.3   |
+------+---------------------------+---------+--------+------+-------+
| 5    | Reauthorization of        | De      | NA     | NA   | See   |
| .7.1 | existing W62 process in   | livered |        |      | Exec  |
|      | accordance with the IWAP  | 1/6/00  |        |      | utive |
|      | project plan.             |         |        |      | Su    |
|      |                           |         |        |      | mmary |
+------+---------------------------+---------+--------+------+-------+
| 5.8  | SWOT analysis (project    | De      | NA     | NA   | See   |
| .1#1 | management)               | livered |        |      | Se    |
|      |                           | 5/30/99 |        |      | ction |
|      |                           |         |        |      | 4.5   |
+------+---------------------------+---------+--------+------+-------+
| 5.8  | Compensatory measure      | De      | NA     | NA   | See   |
| .1#2 | action plan (project      | livered |        |      | Se    |
|      | management)               | 6/30/99 |        |      | ction |
|      |                           |         |        |      | 4.5   |
+------+---------------------------+---------+--------+------+-------+
| 5.8  | Revise training programs  | De      | NA     | NA   | See   |
| .2#1 | and complete training     | livered |        |      | Se    |
|      |                           | 6/30/99 |        |      | ction |
|      |                           |         |        |      | 4.5   |
+------+---------------------------+---------+--------+------+-------+
| 5.8  | Long term personnel plan  | De      | NA     | NA   | See   |
| .3#3 | for project management    | livered |        |      | Se    |
|      |                           | 2/7/00  |        |      | ction |
|      |                           |         |        |      | 4.2   |
+------+---------------------------+---------+--------+------+-------+
| 5.8  | SWOT analysis (AB         | De      | NA     | NA   | See   |
| .3#1 | personnel)                | livered |        |      | Se    |
|      |                           | 5/30/99 |        |      | ction |
|      |                           |         |        |      | 4.2   |
+------+---------------------------+---------+--------+------+-------+
| 5.8  | AB Compensatory measure   | De      | NA     | NA   | See   |
| .3#2 | action plan               | livered |        |      | Se    |
|      |                           | 6/30/99 |        |      | ction |
|      |                           |         |        |      | 4.2   |
+------+---------------------------+---------+--------+------+-------+
| 5.8  | Complete staffing actions | De      | NA     | NA   | See   |
| .4#1 |                           | livered |        |      | Se    |
|      |                           | 2/5/00  |        |      | ction |
|      |                           |         |        |      | 4.2   |
+------+---------------------------+---------+--------+------+-------+
| 5.8  | Complete qualification    | De      | NA     | NA   | See   |
| .4#2 | standards                 | livered |        |      | Se    |
|      |                           | 2/5/00  |        |      | ction |
|      |                           |         |        |      | 4.2   |
+------+---------------------------+---------+--------+------+-------+
| 5.8  | Complete qualification    | De      | NA     | NA   | See   |
| .4#3 |                           | livered |        |      | Se    |
|      |                           | 4/28/00 |        |      | ction |
|      |                           |         |        |      | 4.2   |
+------+---------------------------+---------+--------+------+-------+

7.  **Appendices**

> **7.1** **APPENDIX A: Abbreviations and Acronyms**

+-----------------+----------------------------------------------------+
| AAO             | Amarillo Area Office (Currently called OASO, See   |
|                 | below.)                                            |
| ABCD            |                                                    |
|                 | Activity Based Control Document                    |
| AL              |                                                    |
|                 | Albuquerque Operations Office                      |
| BIO             |                                                    |
|                 | Basis for Interim Operation                        |
| CSSM            |                                                    |
|                 | Critical Safety Systems Manual                     |
| DNFSB           |                                                    |
|                 | Defense Nuclear Facilities Safety Board            |
| DOE             |                                                    |
|                 | Department of Energy                               |
| DP              |                                                    |
|                 | Office of Defense Programs                         |
| D&P             |                                                    |
|                 | Development & Production (Manual)                  |
| EH              |                                                    |
|                 | Office of Environment, Safety and Health           |
| HAR             |                                                    |
|                 | Hazard Analysis Report                             |
| ISMS            |                                                    |
|                 | Integrated Safety Management System                |
| ISMSV           |                                                    |
|                 | Integrated Safety Management System Verification   |
| ISP             |                                                    |
|                 | Integrated Safety Process                          |
| IWAP            |                                                    |
|                 | Integrated Weapons Activity Plan                   |
| LANL            |                                                    |
|                 | Los Alamos National Laboratory                     |
| LLNL            |                                                    |
|                 | Lawrence Livermore National Laboratory             |
| MHC             |                                                    |
|                 | Mason and Hanger Corporation                       |
| MIC             |                                                    |
|                 | Management, Integration and Control                |
| NES             |                                                    |
|                 | Nuclear Explosive Safety                           |
| NV              |                                                    |
|                 | Nevada Operations Office                           |
| OAK             |                                                    |
|                 | Oakland Operations Office                          |
| SBRT            |                                                    |
|                 | Safety Basis Review Team                           |
| SD              |                                                    |
|                 | Supplemental Directive                             |
| SIRR            |                                                    |
|                 | Single Integrated Readiness Review                 |
| SMT             |                                                    |
|                 | Standing Management Team                           |
| SNL             |                                                    |
|                 | Sandia National Laboratory                         |
| S/RID           |                                                    |
|                 | Standards/Requirements Identification Document     |
| SS-21           |                                                    |
|                 | Seamless Safety for the 21" Century                |
| TBP             |                                                    |
|                 | Technical Business Practice                        |
| TSR             |                                                    |
|                 | Technical Safety Requirements                      |
| WPD             |                                                    |
|                 | Weapon Programs Division, AL                       |
| WSD             |                                                    |
|                 | Weapons Surety Division, AL                        |
| WSS             |                                                    |
|                 | Weapon Safety Specification                        |
+-----------------+----------------------------------------------------+

> **7.2 APPENDIX B: History---DNFSB Board Recommendations and Letters**
>
> This appendix provides additional background on Board recommendations
> and correspondence issued before and after the Departments acceptance
> of Recommendation

98-2.

> ***[Previous Board Recommendations]{.underline}***
>
> Elements of Recommendation 98-2 are closely related to several earlier
> recommendations made by the Board.

-   Recommendation 93-1, Standards Utilization in Defense Nuclear
    Facilities, was transmitted by the Board on January 21, 1993, and
    was accepted by the Department on February 2, 1993.

    -   In the Implementation Plan to Recommendation 93-l, the
        Department committed "to undertake a formal program to evaluate
        and enhance, where appropriate, the standards that govern
        nuclear weapon assembly, disassembly, and testing operations."

    -   The Department has completed all of the specific actions
        committed to in response to Recommendation 93-l.

        -   Recommendation 93-3, *Improving DOE Technical Capability in
            Defense Nuclear Facilities Programs*, was transmitted by the
            Board on June 1, 1993, and was accepted by the Department on
            July 23, 1993. The Board stated "*the most important and far
            reaching problem affecting the safety of DOE defense nuclear
            facilities is the difficulty in attracting and retaining
            personnel who are adequately qualified by technical
            education and experience to provide the kind of management,
            direction and guidance essential to safe operation of DOE's
            defense nuclear facilities*."

            -   Through the Implementation Plan for Recommendation 93-3,
                the Department is revising technical qualification
                programs for Federal employees that will increase
                confidence that these employees have competence
                commensurate with responsibility. Recommendation 93-3 is
                directly related to Recommendation 98-2 In addition to
                updating the technical qualification program as it
                applies to Federal NESSG members, the same competencies
                will be applied to non-Federal NESSG members and
                codified in the revised DOE-STD-3015.

                -   Recommendation 93-6, Maintaining Access to Nuclear
                    Weapons Expertise, was transmitted by the Board on
                    December 10, 1993, and was accepted by the
                    Department on February 2, 1994. Among the eight
                    sub-recommendations made by the Board under
                    Recommendation 93-6, three were precursors to
                    similar elements in Recommendation 98-2. Under
                    Recommendation 93-6, the Board identified the
                    following needs:

                    -   *"(1) A formal process be started to identify
                        the skills and knowledge needed to develop or
                        verify safe dismantlement or modification
                        procedures specific to all types of U.S. nuclear
                        weapons (retired, inactive, reserve, and
                        enduring stockpile systems). Included among the
                        skills and knowledge should be the ability to
                        conduct relevant safety analyses...*

                    -   *(4) DOE and its defense nuclear contractors
                        negotiate the continued availability (through
                        retention, hiring, consulting, etc.) of those
                        personnel scheduled to depart whose skills and
                        knowledge have been determined to be important
                        in accordance with the above...*

                    -   *(6) Procedures for safe disassembly of weapons
                        systems be developed while the personnel with
                        system-specific expertise on the original
                        development of the weapons are still available.
                        Likewise, analyses of the possibility of hazard
                        from degradation of remaining nuclear weapons
                        with time should be expedited, while these
                        individuals are available. In addition, the
                        current participation of design laboratory
                        experts in the safety aspects of disassembly of
                        weapons at the Pantex Site should be
                        strengthened."*

> Through the Implementation Plans for Recommendations 93-l and 93-6,
> the Department established a formal process (known as Seamless Safety
> for the 21^st^ Century or "SS-21") that specifies the safety criteria
> for developing weapon operation processes. However, the pace of SS-21
> implementation has been slow and affected in part by the lack of clear
> standards and criteria, as identified under Recommendation 93-l.
> Additionally, the Department has struggled to integrate the design
> laboratory personnel into appropriate roles for the hazard analysis
> process.

-   Recommendation 95-2, *Safety Management*, was transmitted by the
    Board on October 11, 1995, and accepted by the Department on January
    17, 1996. In response to Recommendation 95-2, the Department
    established a model for integrated safety management consisting of
    five core functions:

    -   define the scope of work,

    -   analyze the hazards,

    -   develop and implement hazard controls,

    -   perform work within controls, and

    -   provide feedback and continuous improvement.

        -   The Department established the following guiding principles
            related to integrated safety management:

            -   line management responsibility for safety,

            -   clear roles and responsibilities,

            -   competence commensurate with responsibilities,

            -   balanced priorities,

            -   identification of safety standards and requirements,

            -   hazard controls tailored to work being performed, and

            -   operations authorization.

The Department conducted an Integrated Safety Management System
Verification (ISMSV) review at the Pantex Plant on July 27-31, and
August 17-28, 1998. The purpose of the review was to verify that the
Mason and Hanger Corporation (MHC) ISMS:

-   fulfilled the expectations of the DOE-AL Manager,

-   met the requirements of the Department of Energy Acquisition
    Regulations (DEAR) and the DOE Policy for Safety Management Systems,
    and

-   is implemented, through selected sampling of facilities and
    activities.

> A number of opportunities for improvement were identified as a result
> of the review. The opportunities for improvement that were identified
> during the ISMSV are consistent with the Recommendation. The actions
> described in this implementation plan are intended to be sufficient to
> address the fundamental findings of the ISMSV relating to nuclear
> explosive operations.
>
> ***[Prior Board Letters to the Department]{.underline}***
>
> The following letters (with staff trip reports identified where
> applicable) include several issues closely related to Recommendation
> 98-2 and indicate precursor interest by the Board. The letters are
> listed in chronological order from earliest to the most recent. The
> excerpts are provided to illustrate their relevance in establishing
> the basis for Recommendation 98-2.

-   [April 19, 1996]{.underline} - The letter summarizes Board
    observations on the revalidation of prior Nuclear Explosive Safety
    Study (NESS) for W76 and B61 modification 3/4/l 0 operations at
    Pantex. "Revalidation, as presently implemented, does not provide a
    technical review of the potential impact of changes that have
    occurred since the last NESS and does not appear to consistently
    require resolution of potential safety issues before operations are
    authorized to continue.

    -   [April 30, 1996]{.underline} - The letter summarizes Board
        observations relative to Department actions taken to improve the
        Nuclear Explosive Safety Study (NESS) process. *"Although
        corrective measures have been developed, they have not been
        implemented. The Board urges that the identified improvements in
        the nuclear explosive operations safety management process,
        including the NESS, be implemented expeditiously. Implementing
        actions needed include the issuance of revised Orders,
        standards, and guides that govern the integrated safety of
        nuclear explosive operations."*

    -   [March 14, 1997]{.underline} - The letter transmitted Board
        comments on the application of interagency engineering procedure
        (EP) 401110, [Integrated Safety Process for Assembly and
        Disassembly of Nuclear Weapons]{.underline}. *"It is not clear
        that all organizations with a role in developing a weapon
        process and its safety basis are represented on the SS-21
        project/task teams or at the Milestone Reviews. It is also not
        clear how the process will ensure that all appropriate
        organizations provide institution-level commitment to, rather
        than simply representation during, the process . . . The EP does
        not clearly state that an expectation of the hazard analysis is
        to provide data that would allow line management to make
        informed decisions on the development of controls, such as
        fooling and equipment design and procurement requirements."*

    -   [July 25, 1997]{.underline} - The letter summarizes Board
        observations regarding the W69 authorization basis. *"The
        performance of the hazard analysis needs to be better integrated
        info the SS-21 process . . . The interface between the
        activity-based (HAR) and facility-based (Safety Analysis
        Report/Basis for Interim Operations) hazard analysis documents
        needs to be better defined. Taken together, the HAR and the
        SAR/BIO would constitute the authorization basis for the
        activities, and ideally would identify a complete set of
        controls that need to be implemented for safe operation."*

    -   [August 8, 1997]{.underline} - The letter summarizes Board
        observations based upon a review of the W69 Dismantlement Hazard
        Analysis Report (HAR). *"First, the performance of the hazard
        analysis does not appear to have been smoothly integrated into
        the SS-21 process. As a result, the HAR does not appear to have
        the support of all the different agencies involved in its
        production. Second, some potentially significant hazards in the
        W69 dismantlement process were not fully analyzed. Without a
        comprehensive analysis, it is uncertain whether the appropriate
        set of safety controls has been identified."*

    -   [September 5, 1997]{.underline} - The letter summarizes Board
        observations concerning the Single Integrated Readiness Review
        (SIRR) for the W79 dismantlement program*. "It was clear that
        the Project Team for the W79 Dismantlement Program had declared
        its readiness to proceed (prior to the SIRR) without adequate
        validation . . . appears to have undermined the utility of the
        SIRR as a confirmatory review. The hope that time might be saved
        through coincident reviews clearly was not realized; the Board
        believes that such a finding would be common, and this belief
        underlies the Boards emphasis on the preference for serial
        processes. "*

    -   [September 16, 1997]{.underline} - The letter summarizes Board
        observations on the W78 SS-21 Milestone I review. *"The DOE-AL
        Assistant Manager recognized that there was a great deal of
        variation in the understanding and knowledge of guidance
        contained in EP 401110, [Integrated Safety Process for Assembly
        and Disassembly of Nuclear Weapons]{.underline}, among meeting
        participants . . ."*

    -   [December 5, 1997]{.underline} - The Board expressed a general
        concern with the rate of progress in implementing improved
        directives for nuclear explosive operations. In the letter, the
        Board expressed specific concern with the lack of progress in
        the development and implementation of a hazard analysis report
        (HAR) standard referenced by the 452-series directives.

    -   [December 31, 1997]{.underline} - The letter summarizes Board
        concerns with the Nuclear Explosive Safety Evaluation (NESE)
        process*. "However, in using this NESE process, the Albuquerque
        Operations Office has created a new type of nuclear explosive
        safety study group evaluation that is inconsistent with both DOE
        Order 452.2A and DOE Standard 3015-1997, Nuclear Explosive
        Safety Study Process."*

    -   [June 1, 1998]{.underline} - The Board requested additional
        information on the process by which the Department performs
        change control for its nuclear explosive operations at the
        Pantex Plant*. "The DOE-AL memorandum authorizing the plan to
        use the NESE \[Nuclear Explosive Safety Evaluation\] process
        states that the complexity of a proposed change is to be the
        criterion for determining whether an NESE is the appropriate
        vehicle for evaluating and recommending approval of a new
        process or piece of equipment for a nuclear explosive operation.
        However, a very simple change could have a dramatic impact on
        nuclear explosive safety, whereas a relatively complex change
        could have no effect. Therefore, complexity is questionable as
        the sole criterion for selecting the level of analytical rigor
        and approval authority against which a change will be evaluated.
        . . The Board believes a USQ-like process for evaluating the
        nuclear explosive safety implications of proposed changes to
        weapons activities is appropriate and necessary."*

> ***[Subsequent Board Letters to the Department]{.underline}***
>
> Subsequent to the issuance of Recommendation 98-2, the Board
> transmitted the following letters to the Department:

-   [November 30, 1998]{.underline} - The letter summarizes Board
    observations relative to the ongoing W87 and W62 disassembly and
    inspection operations, and the Nuclear Explosive Safety Master Study
    of the electrical equipment control program. *"During the study, it
    appeared that Mason & Hanger Corporation (MHC) was abdicating its
    line management responsibilities to the nuclear explosive safety
    study group by asking them to perform a line management function. In
    passing issues to the nuclear explosive safety study group, line
    management appeared to have been uncertain about the adequacy of the
    authorization basis for the electrical control program. This
    compromises the independence of the nuclear explosive safety study
    group. . . . The major issues appear to be (1) lack of clear
    guidance from the Department of Energy (DOE) on what an
    authorization basis for nuclear explosive operations should contain,
    and (2) a lack of sufficient technical expertise at MHC to perform
    the analysis. . . . The Board notes that a number of the specific
    issues discussed in the enclosed reports relate to more fundamental
    issues previously communicated in the Board's Recommendation 98-2,
    [Safety Management at the Pantex Plant]{.underline}."*

-   [January 6, 1999]{.underline} - In this letter, the Board
    re-iterated their concerns relative to the Departments progress in
    issuing a standard for Hazard Analysis Reports for nuclear explosive
    operations*. "This standard is critical to ensuring a comprehensive,
    defensible, and repeatable hazard analysis process for the selection
    and presentation of the operation-unique controls needed to define
    the authorization basis for nuclear explosive operations at Pantex
    and the Nevada Test Site."*

-   [January 15, 1999]{.underline} - The letter transmitted Board
    observations concerning the readiness review program at the Pantex
    Plant. *"The Board's staff noted that both reviews \[readiness
    reviews for W56 and W87\] were conducted prior to satisfying the
    Department of Energy (DOE) prerequisites for starting the reviews. .
    . . This situation is inconsistent with the intent of DOE Order
    425.1, Startup and Restart of Nuclear Facilities, which applies to
    the readiness review process for nuclear explosive operations. . . .
    Thus, this W56 and W87 experience should be considered by DOE in
    defining plans for addressing issues raised by Recommendation 98-2
    and in strengthening the readiness review process at Pantex."*

-   [March 12, 1999]{.underline} - The letter transmitted three trip
    reports containing staff observations related to nuclear explosive
    operations at the Pantex Plant. The reports raise issues with
    certain elements of the integrated safety process: identification of
    hazards, derivation of controls, and readiness assessment. *"In
    general, the Board's staff concluded that the HA \[hazard analysis\]
    process did not adequately meet its objective - if did not provide
    systematic assurance that the hazards associated with the W62 D&I
    \[disassembly and inspection\] had been identified in a manner that
    would allow development of a comprehensive integrated set of
    controls . . . The staffs principal concern with the W56
    dismantlement program involved the process of deriving,
    characterizing, and preserving the controls for this activity. An
    Activity Based Controls Document (ABCD) was initially developed that
    included hundreds of controls derived from the hazard analysis. This
    first set of controls did not place any special emphasis on those
    controls upon which the greatest reliance is placed . . . Derivation
    of controls should be an iterative process in which controls for
    each category of risk are identified and evaluated to assess whether
    the control effectively reduces the estimated risk to acceptable
    levels . . . . "DOE has not consistently applied a process to
    develop, validate, and start nuclear weapon dismantlement activities
    . . . . The documentation governing the Integrated Safety Process is
    ad hoc and vague in its description of the necessary line management
    reviews, as well as the scope of independent readiness reviews . . .
    The Pantex contractor was not involved intimately enough or early
    enough in the development of the W79 Dismantlement Program, even
    though it performs the dismantlement operations and is the sole
    contractor responsible for assembly and disassembly of nuclear
    weapons at Pantex.. In contrast, it is a principle of integrated
    safety management that those doing the work should plan the work and
    identify the hazards."*

-   [March 25, 1999]{.underline} - The letter transmitted Board staff
    observations related to lightning protection at Pantex. The Board
    expressed concern with rate of progress in improving lightning
    protection controls. "The Board's staff has reported considerable
    progress on some upgrade initiatives, such as the electrical bonding
    of Zone 12 facilities. Overall, however, the upgrade effort has been
    lagging. In a recent review by the Board's staff of the lightning
    protection systems and the lightning warning and detection system at
    the Pantex Plant, it was seen that progress has been slow in
    resolving many open lightning protection issues."

-   [May 18, 1999]{.underline} - The letter transmitted Board staff
    observations on the readiness review process at Pantex. The Board
    acknowledged ongoing DOE efforts to improve the readiness process.
    "Over the past few months, the staff has noted several issues while
    observing readiness reviews at Pantex. These issues, detailed in the
    enclosed issue report, should be considered as you revise your
    readiness review process and move forward to ensure the adequacy of
    the "confirm readiness" safety function at the Pantex Plant."

-   [July 30, 1999]{.underline} - The letter transmitted Board staff
    observations on the W62 disassembly and inspection program at the
    Pantex Plant. The Board expressed concern with a number of technical
    issues, and the rate of progress. "In response to Defense Nuclear
    Facilities Safety Board (Board) Recommendation 98-2, *Safety
    Management at the Pantex Plant*, the Department of Energy (DOE) has
    been working to improve the safety basis and controls for nuclear
    explosive operations at Pantex, particularly the W62 Disassembly and
    Inspection (D&I) Program. It is vital that these efforts be
    completed in a timely and effective manner to support safe and
    reliable operations of the nations enduring nuclear weapons
    stockpile. To achieve this objective, DOE needs to ensure the
    quality of each individual initiative to analyze operations and
    develop controls, and also to carefully coordinate the
    interdependence among safety improvement initiatives."

-   [August 10, 1999]{.underline} - The letter transmitted Board staff
    observations on the W79 dismantlement program. "The Defense Nuclear
    Facilities Safety Board (Board) is encouraged by recent observations
    of the W79 Dismantlement Program being conducted at the Pantex Plant
    . . . As a result of the considerable effort to develop a safe and
    controlled process and to implement that process in practice, the
    W79 operations were started safely on June 3, 1998. It appears that
    the W79 Dismantlement Program continues to be conducted with the
    appropriate attention to safety."

-   [September 21, 1999]{.underline} - The letter transmitted Board
    staff observations on lightning protection controls for nuclear
    explosive operations at Pantex. "The Department of Energy (DOE) and
    its contractor at Pantex during the past year have responded in a
    very substantial way to Defense Nuclear Facilities Safety Board
    (Board) observations and suggestions for the upgrading of lightning
    protection measures during operations with explosives. However, as
    indicated by the enclosed Board staff report, further upgrade
    efforts appear warranted."

-   [September 22, 1999]{.underline} - The letter transmitted Board
    staff observations from a review of the weapon safety specifications
    (WSSs) for the W76, B83, and W56 nuclear weapon programs. ". . . the
    WSSs reviewed by the Board's staff appear to fall short of meeting
    the requirements set by the D&P Manual. In particular, these WSSs
    appear to have limited value for use in performing hazard analyses
    for nuclear weapon operations. The WSSs capture design agency data,
    but data from lessons learned at the production plants and
    substantive archival data are lacking. Additionally, even though the
    WSS is intended to form the technical foundation for the safety
    basis for a particular nuclear weapons operation, these is no
    effective provision to ensure that the authorization basis is
    updated following a revision of the WSS."

-   [October 15,1999]{.underline} - The letter was in response to the
    DOE proposal regarding changes to the membership and structure of
    Nuclear Explosive Safety Study Groups (NESSGs). "The level of detail
    contained in this proposal is not yet sufficient for the Board to
    ascertain that the intent of its recommendation of NESSG membership
    has been adequately addressed. Therefore, the Board will examine the
    details of actual implementation of this proposal to see whether the
    resulting structure and operation of the NESSGs in the future will
    effectively use the knowledge and talents of the broad base of
    emeritus personnel who may be able to provide significant value to
    the reviews. The Board remains hopeful that DOE's proposal will
    result in a standing committee of highly-experienced personnel with
    significant stature in the nuclear weapons community or related ones
    (such as the commercial nuclear or explosive industries)."

-   [November 22, 1999]{.underline} - The letter expressed Board concern
    with problems threatening the schedule for stockpile stewardship.
    "The Board and its staff have maintained an interest in the schedule
    for such safety reviews of operations at the Pantex Plant, in part
    to ensure that it is compatible with the schedule for planned
    operations. More than a year ago, it began to be clear that the
    schedule for safety reviews during the next few years could not be
    met because of conflicts in demands for separate reviews and a
    general shortage of DOE and contractor technical personnel familiar
    with nuclear explosive systems and skilled in safety practices. The
    Board concluded that a large part of the problem was attributable to
    the complexity of the processes used. Furthermore, the delays caused
    by the cumbersome and time-consuming process resulted in deferment
    of safety improvements and a prolonged reliance on less reliable or
    less robust safety controls and processes."

-   [December 1, 1999]{.underline} - The letter transmitted Board staff
    observations from reviews of the W62 disassembly and inspection
    program and the transportation module of the basis for interim
    operation (BIO) at the Pantex Plant. "Instead of becoming simpler,
    the safety basis at Pantex is actually becoming more complex.
    Significant issues associated with the integration and completeness
    of the various hazards analyses and associated controls are being
    observed. In some cases, voids exist in which one analysis depends
    on another to assess the activity, but it is later discovered that
    the follow-on analysis has not been completed or implemented . . .
    In addition, both enclosed reports highlight deficiencies with
    information on warhead response being provided to the Pantex
    contractor by the nuclear design laboratories for use in determining
    the hazards and resulting controls associated with nuclear explosive
    activities."

-   [December 6, 1999]{.underline} - The letter transmitted
    DNFSB/TECH-24, Safe Handling of Insensitive High Explosive Weapon
    Subassemblies at the Pantex Plant. "\...the Board's staff notes that
    the technical basis for performing operations on composite IHE and
    CHE weapon subassemblies does not fully support the assumptions used
    in establishing safety controls."

-   [January 11, 2000]{.underline} - The letter transmitted Board staff
    observations on lightning protection controls for nuclear explosive
    operations at the Pantex Plant. The Board noted, ". . . significant
    improvement has occurred in the Pantex lightning protection program
    in response to the Board's suggestions and encouragement. In
    particular, the recently approved Evaluation of Lightning Hazards
    and Justification for Continued Operation of Nuclear Explosive
    Operations, if properly implemented, represents a sound initial
    effort at providing a set of uniform, technically justified controls
    for all nuclear explosive operations at Pantex. The Department of
    Energy should consider the additional improvements discussed in the
    enclosed staff issue report as the Basis for Interim Operation for
    lightning protection is finalized. As discussed in the enclosed
    staff issue report, the Department of Energy and its Pantex
    contractor should give careful consideration to increasing the
    utilization of subject matter experts in lightning protection during
    the development of authorization bases for specific weapon
    activities."

-   [March 8, 2000]{.underline} - The letter transmitted Board staff
    observations on the W62 disassembly and inspection program and
    continued problems in the implementation of DOE Order 425.1A,
    Startup and Restart of Nuclear Facilities. The Board expressed
    concern with repeated premature declaration of readiness by line
    management. "It appears that this problem is often due to line
    management's failure to develop and apply a well-defined set of
    prerequisites for certifying readiness. Often the prerequisites are
    little more than a reiteration of the "core requirements" of DOE
    Order 425.1A. Lacking is a reasonable set of executable actions
    under each applicable "core requirement" that, when performed by
    line management could be expected to bring the operation into a
    state of readiness for that area. The application of the
    prerequisites by line management has also been problematic.
    Satisfaction of the prerequisites has not been tracked and verified
    with the rigor necessary for senior managers to declare readiness
    with confidence.

-   [March 29, 2000]{.underline} - The letter transmitted Board staff
    observations on fire protection at the Pantex Plant. The Board noted
    two issues of special concern. "The plant-wide fire alarm system at
    Pantex is deteriorating because it no longer has vendor support. It
    is the Board's understanding that no funding has been provided in
    fiscal year 2000 and beyond to replace the obsolete alarm system.
    Because the alarm system at Pantex is safety-significant, it must
    remain functional during nuclear explosive operations. While the
    contractor is making efforts to prevent this problem from affecting
    the safety and continuity of operations, action is needed by DOE to
    solve this problem on a long-term basis. Further delay in replacing
    this system could result in curtailment of operations and a
    potential impact on national security programs. As a result of an
    extensive review of the fire protection programs at Pantex,
    conducted by a team from Mason and Hanger Corporation and design
    laboratory experts, DOE decided to reconnect the ultraviolet (UV)
    detection system as the actuator of deluge systems in high explosive
    operations areas. This safety enhancement, however, is not currently
    possible for some older facilities such as Building 12-44, which is
    not equipped with an UV detection system. The Board understands that
    subsequent to its staffs visit to Pantex, DOE decided to install an
    UV detection/deluge activation system in Cells 2-6, in Building
    12-44. The Board supports this decision and believes that nuclear
    explosive operations involving conventional high explosives will
    significantly benefit from this safety enhancement if the upgrade is
    completed in an expeditious manner."

-   [May 2, 2000]{.underline} - The letter transmitted Board staff
    observations on fire hazard analyses of Pantex Plant operations
    involving nuclear explosives. The Board noted two issues of concern.
    "Analyses performed at the Y-12 Plant indicate that the canned
    subassembly (CSA) for certain weapon systems may react energetically
    in thermal environments less severe than those evaluated for high
    explosives at Pantex. However, none of the safety analyses at Pantex
    considers the CSA as a potential hazard or as an initiator for
    scenarios involving the high explosive . . . The administrative
    controls currently in use do not provide for limitations on all
    combustible materials in the bays and cells; therefore, fires may be
    larger or more intense than those analyzed. The fire hazard analysis
    also appears to underestimate the heat content of the process
    combustibles . . . Review of fire hazard analyses for other weapon
    systems reveals that these are generic issues for the fire hazard
    analyses performed at Pantex."