Nuclear Security: NNSA Needs to Better Manage Its Safeguards and Security Program
Published: 2003-05-30T00:00:00

Fast Facts:

Highlights:
section_title: Why GAO Did This Study
paragraphs: The attacks of September 11, 2001, intensified long-standing concerns about the adequacy of safeguards and security at four nuclear weapons production sites and three national laboratories that design nuclear weapons--most of these facilities store plutonium and uranium in a variety of forms. These facilities can become targets for such actions as sabotage or theft. The Department of Energy (DOE) and the National Nuclear Security Administration (NNSA)--a separately organized agency within DOE--are responsible for these facilities. NNSA plays a crucial role in managing the contractors operating many of these facilities to ensure that security activities are effective and in line with departmental policy. GAO reviewed how effectively NNSA manages its safeguards and security program, including how it oversees contractor security operations.
section_title: What GAO Found
paragraphs: NNSA has not been fully effective in managing its safeguards and security program in four key areas. As a result, NNSA cannot be assured that its contractors are working to maximum advantage to protect critical facilities and material from individuals seeking to inflict damage. Defining clear roles and responsibilities: NNSA still has not fully defined clear roles and responsibilities for its headquarters and site operations. Assessing sites' security activities: Without a stable and effective management structure and with ongoing confusion about roles and responsibilities, inconsistencies have emerged among NNSA sites on how they assess contractors' security activities. Consequently, NNSA cannot be assured that all facilities are subject to the comprehensive annual assessments that DOE policy requires. Overseeing contractors' corrective actions: To compound the problems in conducting security assessments, NNSA contractors do not consistently conduct required analyses in preparing corrective action plans. As a result, potential opportunities to improve physical security at the sites are not maximized because corrective actions are developed without fully considering the problems' root causes, risks posed, or cost versus the benefit of taking corrective action. Allocating staff: NNSA has shortfalls at its site offices in the total number of staff and in expertise, which could make it more difficult for site offices to effectively oversee security activities.

section_title: Letter
paragraphs: Over the past decade, we and others have raised concerns about the  adequacy of security at nuclear weapons facilities within the Department  of Energy (DOE) and the National Nuclear Security Administration  (NNSA)—a separately organized agency within DOE. For example, we  reported in 2002 that DOE had not addressed problems in implementing  security initiatives, while an independent study by the Commission on  Science and Security, conducted at the request of DOE, found deficiencies  in cyber security. Concerns over security within the nuclear weapons  complex were brought into sharper focus by the September 11, 2001,  terrorist attacks. These attacks highlighted the importance of effective  physical security in response to a potentially large and well-organized  threat.
NNSA relies upon its safeguards and security program to ensure the  physical security of the nation’s nuclear weapons complex. Currently, the  complex has four production sites: the Pantex Plant, Amarillo, Texas; the  Y-12 Plant, Oak Ridge, Tennessee; the Kansas City Plant, Kansas City,  Missouri; and the Savannah River Site, Aiken, South Carolina. In addition  to the production sites, the complex includes the Nevada Test Site and  three national laboratories that design nuclear weapons: Lawrence  Livermore National Laboratory, Livermore, California; Los Alamos  National Laboratory, Los Alamos, New Mexico; and the Sandia National  Laboratories, Albuquerque, New Mexico, and Livermore, California. To  implement its safeguards and security program, NNSA relies on site  contractors that are responsible for conducting day-to-day security  activities and adhering to DOE policies as they operate the complex’s  laboratory and production facilities. The contractors’ activities are subject  to DOE-NNSA oversight. NNSA has offices—site offices—co-located with  each site. Many of these sites possess Category I special nuclear material.  Category I material includes plutonium and uranium in the following  forms: (1) assembled nuclear weapons and test devices; (2) products  containing higher concentrations of plutonium or uranium, such as major  nuclear components, and recastable metal; and (3) high-grade materials,  such as carbides, oxides, solutions, and nitrates. The risks this radioactive  material poses vary, but include the potential for sabotage, or theft for  illegal use in a nuclear weapon. Because these materials pose such risks,  NNSA’s management of the safeguards and security program, which  includes overseeing contractor activities, is essential to preventing an  unacceptable, adverse impact on national security.
DOE’s Office of Security develops and promulgates orders and policies  that guide NNSA’s safeguards and security program. NNSA is responsible  for ensuring that its contractors’ security activities are effective and  conform to DOE’s orders and policy requirements. In conducting this  oversight, NNSA generally uses certain key processes intended to identify  specific weaknesses at contractor-operated sites and ensure that  weaknesses are corrected. These processes include, among other things,  (1) annual, comprehensive surveys conducted by subject matter experts  from across the complex and (2) ongoing reviews of one or more aspects  of contractors’ program (surveillance) by NNSA site officials.
DOE’s Office of Independent Oversight and Performance Assurance also  assesses contractor security activities. In response to NNSA surveys and  assessments conducted by the Office of Independent Oversight and  Performance Assurance, DOE policy requires contractors to prepare  corrective action plans for identified problems and to ensure that these  actions are based on documented root cause analysis, risk assessment,  and cost-benefit analysis.
You asked us to review physical security at NNSA and DOE facilities that  contain Category I materials. Specifically, as agreed with your office, this  report examines how NNSA manages its safeguards and security program.  This report is the first of two that we will be issuing to you on various  aspects of physical security at NNSA and DOE facilities. Our followup  report will focus on the extent to which physical security has improved;  the effectiveness of the process for establishing safeguards and security  requirements following the September 11, 2001, attacks; and the remaining  vulnerabilities.
To evaluate the overall safeguards and security oversight process, we  reviewed DOE policy and planning documents, including orders,  implementation guidance, and reports. We looked at what the orders and  guides prescribed, particularly DOE Order 470.1, and compared this to  how operations and site offices were following and implementing the  policies to see if there were any deficiencies. To determine how NNSA  organizes and conducts overall safeguards and security oversight, we met  with officials from DOE and NNSA headquarters and NNSA site offices.  The primary offices from which we obtained information were from DOE’s  Office of Security, Office of Independent Oversight and Performance  Assurance, and NNSA’s Office of Defense Nuclear Security and Nuclear  Safeguards and Security Program. We also evaluated the NNSA  reorganization with regard to the potential impact on oversight roles and  responsibilities of NNSA headquarters and site offices.
We visited 7 site offices from March 2002 to October 2002, to determine  how federal contractor oversight and the safeguards and security program  is managed. Specifically, we visited Los Alamos National Laboratory and  the Office of Los Alamos Site Operations in New Mexico, Sandia National  Laboratory and the Office of Kirtland Site Operations in New Mexico,  Department of Energy’s Albuquerque Operations Office in New Mexico,  the Office of Transportation Safeguards in New Mexico, Y-12 Plant, and  the Y-12 Site Office in Tennessee, Pantex Plant and the Office of Amarillo  Site Operations in Texas, the Savannah River Site and the Savannah River  Site Office in South Carolina, and Lawrence Livermore National  Laboratory and the Livermore Site Office in California. At each location  we met with both federal and contractor officials and obtained pertinent  supporting documentation.
To determine how NNSA sites prepare and document corrective action  plans and related analyses, we examined 43 closed and open corrective  action plans dated from 1999 through 2002 that we selected at random  from each of the 6 NNSA sites (as well as the DOE Savannah River Site,  which is expected to come under NNSA’s jurisdiction in the future) that  contain category I special nuclear materials. We reviewed these plans to  determine the extent and type of analyses that support the corrective  actions in the plans. These plans generally represent the contractors’  actions to address high priority findings in contractors’ security and  safeguards program. To understand how the corrective action process  currently works, we compared the processes in place at each NNSA site  we visited during 2002.
We performed our review from December 2001 through April 2003 in  accordance with generally accepted government auditing standards.
subsections: section_title: Background
paragraphs: Since its creation in 1977, DOE has been responsible for developing,  producing, and maintaining nuclear weapons; preventing the proliferation  of weapons of mass destruction; designing, building, and maintaining  naval nuclear propulsion systems; and ensuring the security of the nuclear  weapons complex. In 2000, however, the Congress created a separately  organized agency within DOE—the NNSA.
NNSA’s Office of Defense Nuclear Security is primarily responsible for  developing the agency’s security programs, including protecting,  controlling, and accounting for material and ensuring physical security for  all facilities in the complex. Historically, NNSA has conducted  comprehensive annual surveys of contractors’ operations for safeguards  and security. These surveys, which can draw upon subject matter experts  throughout the complex, generally take about 2 weeks to conduct and  cover 5 “topical” areas and 32 subtopical areas. The topical areas include  program management, protection program operations, information  security, nuclear materials control and accountability, and personnel  security. The survey team assigns ratings of satisfactory, marginal, or  unsatisfactory. Currently, NNSA’s facilities have been rated satisfactory in  most topical areas. All deficiencies (findings) identified during a survey  require the contractors to take corrective action, and both findings and  corrective actions are to be entered in the Safeguards and Security  Information Management System—a DOE-wide, integrated tracking  database for findings of surveys and other safeguards and security  activities.
In addition, NNSA’s Office of Facilities and Operations is expected to  provide policy guidance for safeguards and security. This office is also  expected to be responsible for the Nuclear Safeguards and Security  Program, which oversees the implementation of safeguards and security in  NNSA facilities. The office is expected to integrate and defend the budget  for safeguards and security to ensure that program components can  achieve mission objectives. Through various contract mechanisms, NNSA  provides financial incentives, such as award fees, for contractor  performance. NNSA assesses this performance based on the extent  contractors meet a set of measures, which are generally established in  annual performance plans—so-called performance measures.
DOE’s Office of Independent Oversight and Performance Assurance  supports NNSA in safeguards and security assessments and conducts  independent oversight activities in line with DOE and NNSA policies and  priorities. Among other things, the office is responsible for evaluating the  effectiveness of contractors’ performance in safeguards and security. To  carry out this function, this office periodically assesses both federal and  contractor operations at a site and identifies findings, issues, and  opportunities for improvement. It also performs follow-up reviews to  ensure corrective actions are effective and that weaknesses in safeguards  and security are appropriately addressed.
section_title: NNSA’s Lack of Safeguards and Security Direction in Key Areas Results in Inconsistent Management of Contractors
paragraphs: NNSA has not been fully effective in managing its safeguards and security  program in four key areas, and therefore, it cannot be assured that its  contractors are working to maximum advantage to protect its sites. First,  NNSA has not fully defined safeguards and security roles and  responsibilities. Second, without an effective management structure, site  offices are uncertain about how to conduct their safeguards and security  responsibilities. This uncertainty has resulted in inconsistencies in how  site offices comply with DOE orders in assessing contractors. Third, even  when assessments are done, NNSA contractors do not consistently  conduct required DOE analyses in preparing corrective action plans.  Finally, NNSA’s shortfalls at its site offices in the total number of staff and  expertise could make it more difficult for the site offices to oversee  safeguards and security effectively.
subsections: section_title: NNSA Has Not Clearly Defined Roles and Responsibilities, Resulting in Confusion at Sites
paragraphs: Since its creation in March 2000, NNSA’s management structure has been  in a state of flux, and NNSA expects it will take at least to September 2004  to implement a new management structure. However, NNSA needs a  stable structure to establish clear roles and responsibilities for its  headquarters and site offices, including safeguards and security oversight.  In May 2001, NNSA’s Administrator proposed a management structure for  his organization, but in December 2001, we reported that a clearly  delineated overall management structure still did not exist. In February  2002, NNSA reported in more detail to Congress on its outline for a new  management structure to improve NNSA’s effectiveness and efficiency.  NNSA expected to implement the new structure later in the year.
Since then, NNSA headquarters and field officials have been defining  safeguards and security roles and responsibilities. In December 2002,  NNSA fundamentally changed the management structure for safeguards  and security. It abolished operations offices, which had been responsible  for conducting the annual, comprehensive surveys as well as other  safeguards and security activities. It divided these operations offices’  responsibilities among the site offices and a service center, formerly the  Albuquerque operations office; headquarters will oversee the performance  of the site offices. The restructuring brings day-to-day federal oversight of  laboratories and plants closer to the site offices. However, these changes  do not complete the management structure. NNSA plans to further  streamline its oversight of contractors by reducing site activities. Among  other things, NNSA plans to focus more on ensuring that contractors’  management systems are valid. Furthermore, NNSA plans to review its  policies and practices and decide which site office oversight activities can  be reduced or eliminated in order for the site offices to work more  efficiently. It has not yet identified which specific activities will be  modified. At the time of our review, headquarters could not provide details  on how it intends to monitor the NNSA site offices’ performance with  respect to safeguards and security or address deficiencies.
In creating this new management structure, NNSA has not yet developed a  Functions, Responsibilities, and Authorities Manual (FRAM), an  organizational tool used by managers at federal agencies, including DOE,  for defining roles and responsibilities. This manual is to address the  functions, responsibilities, and authorities of all elements within NNSA.  NNSA headquarters security officials agree that this guidance is crucial  and stated that they are currently developing the components of a FRAM,  which should be finalized in 2003. NNSA told us that completing the FRAM  takes significant time because of the highly detailed planning necessary for  determining staff functions at the various sites.
According to NNSA site office officials, as they wait for formal guidance  from headquarters on conducting security oversight, each office is  carrying out oversight activities as it deems appropriate. In addition, these  officials told us that they have not received formal notification about the  change in their safeguards and security oversight responsibilities, such as  responsibilities for the survey program. Officials at several site offices  expressed frustration with this lack of direction.
section_title: NNSA’s Security Assessment Processes Differ among Sites and Are Inconsistent with DOE Requirements
paragraphs: NNSA site offices are not consistent in how they assess contractor  safeguards and security activities, and they may not be conducting these  assessments in accordance with DOE policy. The lack of consistency and  the failure to implement DOE policy occurs in part because the site offices  have had to assume new oversight responsibilities without, among other  things, clear guidance from headquarters on how to carry out these  responsibilities. As a result, three offices of the seven NNSA site offices we  visited continue to use the traditional survey approach to oversee security  activities (Oak Ridge, Savannah River, and NNSA’s Office of  Transportation Safeguards), while the remaining four have adopted or are  adopting a surveillance model—-Amarillo, Kirtland, Livermore, and Los  Alamos. The distinction between these two activities is important: A  survey provides a comprehensive annual review, by a team of experts, of  contractor safeguards and security and generally takes about 2 weeks;  formerly, the operations offices generally conducted surveys, assisted by  experts from throughout the complex, as necessary. In contrast,  surveillance relies on a single or small number of NNSA site officials  overseeing one or more aspects of a contractor’s safeguards and security  activities throughout the year, and the documentation from a surveillance  or a group of surveillance activities may be used as part of the survey.
By relying on surveillance, NNSA may have less assurance that it fully  knows the condition of security at its sites and therefore potentially  cannot act to correct deficiencies undisclosed by this limited review.  Surveillance allows subject matter experts at the sites to evaluate areas of  contractor safeguards and security performance more often than the  traditional survey process and therefore potentially identify deficiencies  faster. However, according to DOE officials, reliance on surveillance is not  consistent with DOE orders calling for a comprehensive survey of a  contractor’s safeguards and security performance. This survey provides a  unified assessment of all security-related topical areas. Officials from  DOE’s Office of Security—which developed the policy for conducting  surveys—believe the surveillance model does not comply with DOE order  survey requirements because it is not comprehensive. Officials from DOE’s  Office of Independent Oversight and Performance Assurance expressed  concern about the site offices’ ability to conduct surveillance because of  shortfalls in available expertise. Furthermore, the director of NNSA’s  Office of Defense Nuclear Security acknowledged that although some  NNSA site offices, such as the Los Alamos site office, are using the  surveillance model, this site and others lacked the necessary personnel to  conduct surveillance.
According to officials from DOE’s Office of Independent Oversight and  Performance Assurance and one site office, surveillance is not compatible  with the current Safeguards and Security Information Management  System, a DOE information database system used to track findings and  associated corrective actions, and therefore could pose problems for sites  in entering information. On the other hand, NNSA officials at site offices  and headquarters argue that using the surveillance model for oversight will  produce an annual end of the year survey report and should have the same  end result as an annual survey. However, NNSA could have difficulty  ensuring consistent and comprehensive assessments because of the  difficulties posed by using the surveillance model without appropriate  NNSA-wide implementation guidance, site office staffing shortfalls, and  database compatibility problems.
section_title: NNSA’s Corrective Action Practices Are Inconsistent with DOE Requirements
paragraphs: Contractors have not consistently prepared effective, formal root cause  analyses in developing corrective action plans for identified deficiencies,  as DOE policy requires. An effective, formal, root cause analysis can  enhance the development of corrective actions, as we observed while  reviewing some plans. However, less than half of the 43 corrective action  plans we reviewed, dated between 1999 and 2002, showed that the  contractor had performed the required root cause analysis. Furthermore,  in a few cases corrective action plans were based on root cause analyses  that were poorly prepared, resulting in confusion and contradictions. For  example, NNSA had identified a deficiency at one site of potential entry  into a critical facility. The contractor did not fully develop a root cause for  this problem but merely rebutted the finding’s validity. Nevertheless, the  contractor took a corrective action in response to this deficiency— spending about $150,000. However, because the root cause analysis was  not fully developed, we could not determine how, or if, the contractor’s  corrective actions would correct the deficiency. Furthermore, the  contractor’s staff preparing the analysis did not have formal training in  how to conduct root cause analyses. NNSA site officials agreed that the  root cause analysis was performed incorrectly and that their oversight  review of the analysis had not detected this problem.
Despite the problems some contractors have had in preparing root cause  analyses, corrective action processes in 2002 at all 7 sites showed that  some sites are making progress. For example, in late 2000, the Office of  Transportation Safeguards, which is responsible for securely transporting  critical NNSA items and material, had begun to correct significant  weaknesses in its process for preparing and tracking corrective actions.
According to an official responsible for corrective actions at the office, the  new process has already resulted in documented improvements to the  quality and completeness of its corrective action plans. For example, the  new process for root cause analyses identified additional reasons for a  recurring NNSA finding on problems in how three federal agent facilities  in NNSA’s Office of Transportation Safeguards inspected the vehicles used  to transport critical materials across the nation. These inspections are  crucial in preventing individuals from attaching explosives or other foreign  devices to the vehicles in potential attempts at sabotage or theft. The new  process enabled NNSA to identify specific actions to ensure consistent  interpretation and implementation of vehicle inspection procedures  among the three facilities. Because the finding has not been repeated since  July 2000, it appears that the additional corrective actions proved  effective. Another site, Sandia National Laboratories, has developed a  process for root cause analysis that other sites may find useful. Sandia  uses a designated root cause analyst to systematically lead teams of  subject matter experts at the laboratory through the steps for determining  root cause. With this expert in root cause analyses, Sandia helps ensure  that these analyses are consistent and effective.
Other analyses and assessments that are critical to planning corrective  actions are also not consistently prepared at NNSA sites. In particular, less  than 25 percent of the corrective action plans we reviewed showed  documentation of other analyses required by the DOE order for corrective  action, such as risk assessment or cost-benefit analysis. Without this  documentation, we found it difficult to determine what process, if any, the  sites had used to determine the risk level of the problem or the cost and  relative benefit of implementing corrective actions.
Consistency problems are likely to continue without effective NNSA  guidance for corrective actions. For example, at four sites we visited, the  sites either did not require a risk assessment and cost-benefit analyses or  stated that they were optional, depending on the site’s evaluation of the  need for an analysis. However, the remaining three sites we visited  required these analyses for all corrective action plans. This inconsistency  resulted in part from differing interpretations of the DOE order governing  corrective actions. As a result, NNSA cannot be assured that all  contractors are considering the costs of corrective actions in conjunction  with the risk posed or the potential benefits to be gained. NNSA officials at  some sites stated that, without implementation guidance, the intent of the  DOE order requiring these analyses can be interpreted differently from site  to site, which contributes to the inconsistent practices we observed. Since  we provided our draft report to NNSA in April 2003, it has sent a brief  guidance letter on corrective action plans to its site offices, clarifying its  analysis and documentation requirements. An NNSA headquarters official  stated that issuance of additional guidance for implementing DOE security  policies is expected in 2003.
And finally, NNSA sites do not consistently measure all performance  aspects of contractors’ preparation of corrective action plans and may  reward contractors simply for closing the finding on schedule. According  to our review of performance measures concerning corrective actions,  four of the six contractor-operated sites we visited had measures that  were primarily based on whether the contractor met the schedule for  completing corrective actions, not on whether and how well the  contractor had performed the analyses. The other two sites did not  consider any corrective action performance measures in assessing  contractor performance—not even the schedule. However, DOE guidance  encourages sites to measure qualitative factors, whenever possible, to  minimize the need to rely solely on schedule-driven measures. Effective  qualitative performance measures would essentially reflect how well the  contractor completes root cause analyses, risk assessment, and cost- benefit analyses.
The lack of qualitative performance measures affects the quality of the  correction plan. For example, in fiscal year 1999, DOE’s Office of  Independent Oversight and Performance Assurance criticized a site that  had schedule-driven performance measures for poorly prepared corrective  action plans. Out of the 50 plans reviewed for that site, 27 had inadequate  root cause determinations, and 15 had corrective actions that were  unlikely to fix the deficiency cited. The performance measures in place for  this contractor in fiscal year 1999—and then again in fiscal years 2000 and  2001—did not reflect qualitative aspects of these analyses; instead, they  were primarily focused on schedule-driven outcomes. Some contract  provisions permit the contractor to forfeit some of the award fee based on  other generic performance factors, such as “management failure.”  However, these generic provisions may not be fully effective in motivating  contractors in all aspects of their corrective action performance because  these provisions are not explicitly focused on corrective action and are  therefore not highly visible.
section_title: Difficulties in Allocating Staff Could Hinder Effective Safeguards and Security Oversight
paragraphs: NNSA’s site offices have shortfalls in the total number of staff and in the  expertise for effectively overseeing contractors, including covering all  topical areas in the annual surveys. At five of the seven sites we visited,  NNSA officials told us that they currently have, or will have, two to six  vacancies in safeguards and security positions once NNSA fully  implements its new management structure; each site believes that it needs  from 10 to 14 security-related positions in order to carry out its oversight  activities under NNSA’s new organization. In particular, some of the site  offices are experiencing difficulty in filling positions because some staff  consider the site locations less desirable than others and because NNSA  has instituted a hiring freeze. Some of these vacancies are for specialists in  particular subject areas, such as industrial security systems—a key  specialty needed for conducting physical security inspections. Officials in  the Office of Independent Oversight and Performance Assurance  concurred that NNSA’s reorganization and the shifting of responsibilities  to the site offices has the potential to weaken security oversight.
To offset the lack of some subject matter experts at sites, NNSA field  officials indicated that they frequently rely on subject matter experts from  headquarters or other site offices to cover site offices that do not have  expertise locally. With only a limited number of subject matter experts in  the complex, the sites have to coordinate oversight carefully. Coordination  is particularly complicated at those sites that have switched to a  surveillance model since they may have to rely on particular subject  expertise that is only available during certain times.
NNSA’s new management structure further complicates the problems in  staff allocation. NNSA expects to reduce headquarters and field staff by 20  percent by the end of fiscal year 2004. In this restructuring, NNSA plans to  share staff expertise, creating a “virtual” organization to cover the needs of  site offices and other areas within the complex until a final move of  personnel can be made. Headquarters officials told us that it may take 1 to  2 years to move the appropriate safeguards and security persons to the  areas where they are needed. Until then, they expect the virtual  organization to meet the complex’s needs. The virtual organization will  include subject matter experts whose knowledge will be needed  throughout the nuclear weapons complex and not just at their current  sites. Some of these experts will work from the service center or be  detailed to site offices as needed. With competing demands for the  experts, it is unclear how they will successfully provide assistance to site  offices in their surveillance processes. The assistance may be unavailable  when needed since components of surveillance are ongoing and may span  an entire year.
section_title: Conclusions
paragraphs: Without effectively managing its safeguards and security program, NNSA  cannot be assured that its contractors are working to maximum advantage  to protect its nuclear weapons sites. These sites may have critical  materials that could be prime terrorist targets. Several factors contribute  to this lack of assurance. NNSA continues to change its management  structure, making it difficult to define roles and responsibilities clearly.  Without a functional management structure, some site offices and  contractors may not be carrying out their security responsibilities, as DOE  orders require. In particular, NNSA has not fully assured itself that the four  sites that rely on surveillance activities, rather than on the DOE-required  surveys, are overseeing contractors’ security activities in the integrated,  comprehensive fashion that are called for in the annual surveys. Moreover,  when NNSA site offices allow and reward contractors for closing findings  without ensuring that the contractors have correctly identified the root  cause, assessed risk, and conducted a cost-benefit analysis, NNSA cannot  be assured that the security problem identified was adequately addressed.  Finally, to provide effective oversight, NNSA needs to develop an  approach, beyond its “virtual” organization, that ensures its limited  security resources are able to provide oversight, over the long term, where  and when it is needed.
section_title: Recommendations for Executive Action
paragraphs: In order to strengthen the safeguards and security program of the nuclear  weapons complex, we recommend that the NNSA Administrator and  Secretary of Energy  formalize the roles and responsibilities of site offices and headquarters  for conducting oversight;    ensure that sites are performing oversight using a survey approach that  provides an integrated comprehensive view of security conditions and  is consistent with DOE orders;    ensure that contractors’ corrective action plans are prepared and  documented consistently and are based on qualitative root-cause, risk-  assessment, and cost-benefit analyses, and that appropriate incentives  are used to help motivate contractors toward effectively addressing  findings; and    develop and implement a plan to ensure that NNSA allocates  safeguards and security staff so that it provides effective safeguards  and security oversight over the long term.
section_title: Agency Comments and Our Evaluation
paragraphs: We provided the DOE’s NNSA with a draft of this report for review and  comment. Overall, NNSA concurred with two of our four  recommendations, disagreed with one, and did not indicate agreement or  disagreement with the fourth. In the area of concurrence, NNSA concurred  with our recommendation to formally establish roles and responsibilities,  and it plans to do so in 2003. NNSA also concurred that corrective action  plans must be prepared in accordance with established standards and  policy and based on documented root cause analysis, risk assessments,  and cost-benefit analysis. Since we provided our draft report to NNSA, it  has sent its site offices a guidance letter on corrective action plans that  clarifies its analysis and documentation requirements. NNSA now allows  required elements to be omitted from corrective action plans, but only if  the contractors document the rationale for the exclusion as a formal part  of their plan. We believe this guidance letter is a positive step in clarifying  some implementation aspects of the DOE requirements, and we encourage  continued management attention to this area. NNSA did not comment on  the portion of this recommendation concerning the use of appropriate  incentives to motivate contractors to address findings effectively.
NNSA disagreed with the conclusion that led to our recommendation to  conduct oversight using a survey approach, which provides an integrated,  comprehensive view of security conditions and is consistent with DOE  orders. Specifically, NNSA disagreed with our conclusion that it was not  ensuring the comprehensive annual assessments of contractors’  performance that DOE policy requires. As we reported, four of the seven  site offices no longer conduct comprehensive, integrated surveys to assess  security but instead rely on surveillance activities. NNSA believed that  these surveillance activities were also comprehensive; however, NNSA  provided no evidence—such as implementation guidance to the sites that  are conducting surveillances—that would ensure that the sites’  surveillance activities conform to DOE’s policies. Without such guidance,  NNSA cannot be fully assured that surveillance activities, as presently  conducted, provide the comprehensive assessment DOE requires in its  surveys. Our recommendation therefore is intended to focus NNSA  management attention on ensuring that site offices conduct security  assessments that are integrated, comprehensive, and on par with the  survey approach previously used and currently described in DOE orders.  Furthermore, NNSA asserted, incorrectly, that we found its security  posture to be at risk. Assessing NNSA’s security posture was not the  objective of this report. Rather, our objective was to assess the way NNSA  manages its overall security program. We have clarified the report, where  appropriate.
Finally, regarding our recommendation that NNSA develop and implement  a plan to ensure that it effectively allocates staff to provide safeguards and  security oversight, NNSA commented that managers have staffing plans  and that its virtual organization and additional hiring will address sites’  need for certain types of skilled personnel. Reliance on the virtual  approach may be effective in the short term. However, the continuing  vacancies at some sites indicate that NNSA may have difficulty attracting  and retaining necessary expertise at specific, understaffed locations over  the long term. NNSA’s comments do not indicate that it fully understands  the need to address this longer-term problem. We have modified our  recommendation to target this specific long-term concern.
We modified our report, where appropriate, to reflect NNSA’s comments  and to clarify some of our conclusions. NNSA’s comments on our draft  report are presented in appendix I.
As arranged with your office, unless you publicly announce its contents  earlier, we plan no further distribution of this report until 30 days after the  date of this letter. At that time, we will send copies of the report to the  Secretary of Energy, the Administrator of NNSA, the Director of the Office  of Management and Budget, and appropriate congressional committees.  We will make copies available to others on request. In addition, the report  will also be available at no charge on the GAO Web site at  http://www.gao.gov.
If you or your staff have any questions about this report, please call me at  (202) 512-3841. Major contributors to this report are listed in appendix II.
section_title: Appendix I: Comments from the National Nuclear Security Administration
section_title: Appendix II: GAO Contact and Staff Acknowledgments
subsections: section_title: GAO Contact
section_title: Acknowledgments
paragraphs: In addition to the individual named above, Christopher R. Abraham, Jill  Berman, Jonathan M. Gill, Andrea R. Miller, Christopher M. Pacheco, and  Carol Herrnstadt Shulman made key contributions to this report.