CHAPTER III

1. IMPLEMENTATION PLAN DEVELOPMENT. The Secretary must submit an implementation plan to the Board within 90 days of the date the Secretary's acceptance of the recommendation is published in the Federal Register (see Chapter I, paragraph 2a). The response team should begin implementation plan development (Figure 3) immediately after the recommendation is received and conduct plan development in parallel with development of the Department's response. The cognizant Secretarial Officer, Responsible Manager, and response team that developed the Department's response should develop the associated implementation plan.

a. Team Leadership. Regardless of whether the Responsible Manager delegates coordination of implementation planning to a technical lead, he/she must maintain clear sponsorship and open communications with the response team. The Responsible Manager should engage in the development process by interacting with the team, reviewing progress, ensuring adequate technical basis, making key decisions, advocating the Department's position to the Board and its staff, and keeping the cognizant Secretarial Officer informed. He/she should also ensure that the implementation plan is complete, responsive, and achievable and that the resource impact of the implementation plan is understood, acceptable, and consistent with the associated safety improvement.

b. Internal Coordination.

(1) Organizations that have an interest in the outcome of an implementation plan should be identified by the Responsible Manager early in the development process and should be included in or represented on the response team and be kept fully informed of the team's activities. The members of the response team should possess the necessary technical background and skills to effectively develop the implementation plan.

(2) To ensure effective coordination, the Responsible Manager should prepare early in the process a schedule for plan development that identifies milestones and responsibilities. The Responsible Manager should identify Departmental resources that will be required for developing the implementation plan (such as travel funds) and identify sources for these resources. The Responsible Manager should use periodic status reports to keep everyone informed of progress, upcoming activities, action items, and responsibilities.

Figure 3A Implementation Planning Process Overview
Figure 3B Implementation Planning Process Overview (Part 2)

(3) As requested, the affected points of contact should assist the Responsible Manager and response team, by coordinating review and comment, comment resolution, and concurrence within their respective organizations.

(4) The response team should meet frequently to ensure effective progress in developing the implementation plan. Team participants should be prepared to represent the views of their respective organizations. As necessary, the Responsible Manager should ensure that these meetings include participation by the appropriate managers to obtain decisions on resolution approaches, responsibilities, and schedules.

(5) As an organizational change effort, implementation planning requires development of a clear case for action, establishment of a coalition of key players to lead the action, formation of a clear vision of the objectives and path forward, and repeated communication and articulation of the vision through a variety of means to the parties involved. A primary objective of the response team is to obtain the buy-in, ownership and commitment of resources from the affected organizations to fulfill their portions of the implementation plan.

c. Interaction with the Board and its Staff.

(1) The response team should interact with the Board staff during implementation plan development to the extent necessary to understand the Board's recommendation. The Responsible Manager should focus early meetings on gaining a full understanding of the recommendation's content and intent, and avoid discussing the Department's planned resolution approach until the Department has developed an adequate framework and basis for resolution.

(2) In communicating the framework and basis for resolution, the response team should discuss underlying causes and assumptions, potential resolution alternatives, and advantages and disadvantages of the various alternatives.

(3) In developing potential resolution alternatives, the response team should try to build on existing programs and activities and invent new ones only when necessary.

(4) The response team should request the Board staff's opinion, to the extent possible, on whether proposed resolution alternatives satisfy the intent of a recommendation. The response team should not request the Board staff to define or select resolution alternatives.

(5) The response team should provide the Board staff with sufficient opportunities (typically at least two) to review draft plan information during the development process. The response team should request the staff to provide its comments on the draft plan in writing.

(6) The Responsible Manager should participate in major interactions and be cognizant of all interactions with the Board or its staff. The Issue Lead should assist the Responsible Manager in arranging for and conducting interactions with the Board staff.

(7) The Issue Lead should provide to the Responsible Manager and response team any public comments received via the Board in response to the Federal Register notice.

(8) Toward the close of the development period, the response team should seek closure with the Board staff on the scope of commitments and an indication that the staff will recommend to the Board that the planned activities are sufficient to address the identified safety issues. If such indication is not received, the Responsible Manager should inform the cognizant Secretarial Officer so that interaction with one or more Board members can be arranged to brief them on the Department's position.

(9) When interactions with one or more of the Board members are necessary, the Departmental Representative should support the cognizant Secretarial Officer in arranging for and conducting interactions at this level. The cognizant Secretarial Officer and Responsible Manager should brief the Board member or members on the Department's approach prior to finalization and formal transmittal of the implementation plan.

d. Schedule, Cost, and Funding.

(1) The response team should prepare a planning-quality schedule and cost estimate prior to plan submittal for Secretary approval. To accomplish the schedule and cost estimate within the allotted time window, the response team should:

(a)  begin development work as soon as possible,

(b) include a person with cost/schedule expertise,

(c) develop a reasonably accurate preliminary scope of work early in the 90-day window (see Figure 3).

Departmental senior management will need a planning-quality schedule and cost estimate (i.e., rough order-of-magnitude estimate) so that they can analyze the resource impact of the plan before committing to it. The cost estimate will also be used to assess cost-benefit and relative priorities among various potential safety improvements. The desired degree of accuracy for this planning estimate is minus 50 percent to plus 100 percent (see DOE G 430.1-1, COST ESTIMATING GUIDE, dated 3-28-97). In addition, the Board will review the Department's implementation plan to determine whether it provides a realistic and achievable schedule for plan implementation (see Chapter I, subparagraph 2b).

(2) Resolution of an issue (i.e., completion of all actions identified in the implementation plan) should result in tangible improvement to safety within the Departmental defense nuclear facilities complex. If possible, the Responsible Manager should establish the resolution scope based on the goal of completion within 1 year of plan issuance. To accomplish this goal, the resolution focus may need to be on gaining substantive control of an issue rather than closing all loose ends. For example, issue resolution may need to be defined in the implementation plan as developing training and conducting initial sessions, rather than as completing training of all Departmental personnel and performing a follow-up evaluation. The goal of resolution within 1 year, based on the expectations of Congress in establishing the Board, should be strictly pursued by the Responsible Manager for recommendations that are narrowly focused and affect only one site and one Headquarters office. Recommendations that involve major systemic changes, multiple Headquarters offices, and multiple sites can require more than 1 year for resolution. The Responsible Manager must carefully consider exceptions to the 1-year goal.

(3) The response team, with the direction of the cognizant Secretarial Officer, should identify how the implementation plan will be funded. Resources will likely need to be reallocated to ensure funding during the initial phases of implementation; the sources of these resource reallocations should be identified by the affected Secretarial Officers. Funding allocations beyond the initial phases of implementation should be established by the affected Secretarial Officers through the Departmental budget process to ensure that sufficient resources will be available to meet the Secretary's commitment to the Board. The Responsible Manager should apply schedule and cost performance monitoring techniques to improve management effectiveness during plan implementation.

2. IMPLEMENTATION PLAN FORMAT AND CONTENT.

a. The primary purpose of the implementation plan is to describe the appropriate actions and schedule for ensuring that the accepted recommendation is resolved. The Board uses the following six substantive criteria to judge the adequacy of an implementation plan (see Chapter I, subparagraph 2b).

(1) Understanding. The implementation plan must show an understanding of the safety issues raised by the Board's recommendation.

(2) Responsiveness. The Department's planned course of action must address the complete Board recommendation and accomplish satisfactory resolution of the underlying safety issues.

(3) Assumptions. The important (engineering, technical, administrative, or legislative) baseline assumptions for successful plan implementation must be detailed.

(4) Planning Detail. The Department's approach to resolve the associated safety issues must be described in sufficient detail to permit the Board to independently determine that the approach and schedule are reasonable and achievable.

(5) Technical Basis. The Department's plan must be based on sound evaluation, including identification of the underlying causes.

(6) Focus on Closure. The Department's plan must define completion deliverables for demonstrating safety issue resolution in a verifiable manner.

b. Response teams should prepare implementation plans consistent with the Format and Content Guide provided in Attachment 3 to address these six substantive criteria. Attachment 3 applies to recommendations received after 1994; this guidance may be considered for major revisions of previous implementation plans. In some cases, exceptions and additions to this recommended format may be appropriate and should be made on a case-by-case basis.

3. TRANSMITTAL OF IMPLEMENTATION PLANS. The implementation plan is a Secretarial commitment. The Responsible Manager must obtain final concurrence and approval of the implementation plan in accordance with established Departmental procedures. The points of contact should assist in expeditiously acquiring concurrence within their respective organizations. After the implementation plan is approved and signed by the Secretary, the Executive Secretariat will formally transmit it to the Board. As with other outgoing correspondence to the Board, the Departmental Representative's staff will distribute copies of the transmitted implementation plan to the affected Secretarial Officers and Operations/Area Office Managers.

4. EXTENSION NOTIFICATION.

a. The Secretary may obtain one 45-day extension for submitting an implementation plan by notifying the Board, the Speaker of the House of Representatives, and the Senate Committees on Armed Services and Appropriations. These extension requests by the Secretary should be reserved for exceptional circumstances. If an extension is needed, the Responsible Manager, supported by the Issue Lead, should begin drafting a notification letter at least 30 days prior to the expiration of the original 90-day time period.

b. The Responsible Manager must prepare the notification letter to provide the following information:

(1) the reasons for the delay,

(2) the current status of the draft implementation plan, and

(3) the actions being taken by the Department to complete the implementation plan.

c. The Responsible Manager, supported by the Issue Lead, should ensure that the notification letter is finalized and signed by the Secretary at least 2 weeks prior to expiration of the original time period.

5. BOARD ACCEPTANCE. The Board's practice is to review and formally accept or not accept each implementation plan submitted by the Department. Upon receipt of an acceptance letter from the Board, the Departmental Representative should notify the affected Secretarial Officers and Operations/Area Office Managers of the acceptance. If the Board does not accept an implementation plan, the cognizant Secretarial Officer must evaluate the Board's comments, determine whether the implementation plan should be revised, and initiate actions to expeditiously resolve the Board's comments. Response actions will vary significantly depending on the content of the Board's observations. The cognizant Secretarial Officer, the Responsible Manager, and the Departmental Representative should establish the strategy, assignments, and timetable for the response actions.

6. PLAN IMPLEMENTATION.

a. The Responsible Manager must ensure that the associated safety issues are resolved as described in the implementation plan and that the associated commitments are managed to closure. The Safety Issues Management System must be used as a tool to identify, track, and close Departmental commitments to the Board. As committed actions are completed, the Responsible Manager must prepare a closure package and transmit this package to the Board.

b. The Responsible Manager should periodically inform the various Department implementing elements and the Board regarding the status of plan implementation. As needed, the Responsible Manager should also provide oral presentations, topical reports, and documents to the Board and its staff to update them on implementation progress.

c. The Responsible Manager should anticipate and manage implementation problems so that they have a minimum impact on plan commitment dates. The Responsible Manager and the Issue Lead should inform the cognizant Board staff member in advance of any planned milestone due dates that will be missed. The cognizant Secretarial Officer should periodically review implementation progress and assist in solving implementation problems.

d. The Responsible Manager should ensure that sufficient funding and other necessary resources are available to satisfy the Departmental commitments contained in the implementation plan. If sufficient resources are not available, the Responsible Manager must notify the cognizant Secretarial Officer and the Departmental Representative to seek resolution. The Secretarial Officer, in consultation with the Departmental Representative, should evaluate relative priorities and resource availability and take appropriate steps to effect a resolution. Issues and disagreements over priorities and resources that cannot be resolved should be raised to the Deputy Secretary for resolution.

e. For implementation plans involving cross-organizational activities, the Responsible Manager should consider establishing a formal vehicle, such as a memorandum of understanding, to define agreements on the budgeting process and responsibilities for out-year activities. The formal vehicle should ensure that: (1) the Secretarial commitments in the Department's implementation plan are met, (2) the Responsible Manager can oversee the availability and expenditure of funds sufficient to fulfill the implementation plan commitments, and (3) a stable, implementable, and enforceable funding structure is established within the current Departmental budget. This vehicle should be established before the next budget cycle is initiated, when Headquarters provides budget targets to field organizations (typically in November of each fiscal year). Such a vehicle may also be used to clarify the boundaries of authority and decision making conferred on the Responsible Manager and other key implementation leaders.

f. The Responsible Manager should provide prior, written notification to the Board on the status of any implementation plan commitment that will not be completed by the planned milestone date. This written notification should describe the reason(s) for the schedule variance to the Department's implementation plan, current actions underway to fulfill the commitment, and an estimated completion date. If commitment completion will be delayed by a substantial period (e.g., more than 3 months) from the committed due date, or if the approach to fulfilling the commitment has been or needs to be changed, the Responsible Manager should initiate a change to the Department's implementation plan and obtain Secretarial approval. Periodic reports may not be used to report changes to plan commitments unless these reports are approved by the Secretary.

g. If the Department's implementation plan for an active Board recommendation is no longer valid or responsive, the Responsible Manager for that plan must aggressively pursue development of a valid plan.

7. REPORTING THAT IMPLEMENTATION IS IMPRACTICABLE.

a. If the Secretary determines implementation of a recommendation is impracticable because of budgetary considerations or impact on the Secretary's ability to meet the Annual Nuclear Weapons Stockpile requirements, the Secretary must submit a report to the President of the United States, the Speaker of the House, and the Senate Committees on Armed Services and Appropriations, containing the recommendation and the Secretary's determination (see Chapter I, subparagraph 2a).

b. If such a report is required, the cognizant Secretarial Officer, supported by the Departmental Representative, must prepare this report. The affected Secretarial Officers, the Departmental Representative, and the Office of the General Counsel must concur on the final report. The Departmental Representative must present the report to the Secretary through the Deputy Secretary for approval and transmittal to the President and Congress.

8. CHANGES TO IMPLEMENTATION PLANS.

a. Changes to commitments, actions, or completion dates may be necessary due to additional information, improvements, or changes in baseline assumptions. The Responsible Manager should identify necessary changes and, with the support of the Issue Lead, bring to the Board staff's attention any substantive changes to an implementation plan as soon as identified. The Responsible Manager and Issue Lead should discuss with the Board staff any proposed changes to implementation plan commitments before making a formal submittal.

b. Any revision to the scope or schedule of plan commitments must be approved by the Secretary (see Chapter I, subparagraph 2a). Commitment revisions must be clearly identified and described by the Responsible Manager along with the basis for the revisions. Fundamental changes to the strategy, scope, or schedule of the plan must be prepared by the Responsible Manager and provided to the Board through formal revision and reissuance of the implementation plan approved by the Secretary. Other changes to the scope or schedule of planned commitments must be prepared by the Responsible Manager and formally submitted in appropriate correspondence signed by the Secretary, along with the basis for the changes and appropriate corrective actions. Examples of this type of change include:

(1) a change in approach, based on new knowledge, that still fulfills the committed objective, scope, and schedule, but in a different manner than originally planned, or

(2) a change in intermediate milestone dates for a plan commitment for which the original plan commitment scope and ultimate completion date are preserved.

c. The Responsible Manager should carefully consider the cumulative effect of the plan changes made through correspondence from the Department to the Board so that the fundamental approach, scope, and schedule of the plan are not altered; if these are altered in a fundamental way, the Responsible Manager must prepare a formal plan revision and reissuance. In order to maintain the implementation plan as an accurate and useful management tool, no more than two plan changes should be approved and provided to the Board without a complete plan revision and reissuance which incorporates the previously approved changes.

d. Responsible Managers should prepare complete plan revisions/reissuances of implementation plans consistent with the Format and Content Guide provided in Attachment 3. Completed actions that are still important to the resolution of the original safety issue should be described and identified as actions already completed.

e. The letter submitting implementation plan revisions should describe the Department's intentions regarding existing commitments under the existing implementation plan, if previously accepted by the Board. Suggested text: "With submittal of this revised plan, the Department will now focus its implementation efforts on the approach described herein, rather than that previously described and provided to the Board."

9. IMPLEMENTATION IN EXCESS OF 1 YEAR OF DURATION. The Secretary must submit a report to Congress if completion of activities described in the implementation plan requires longer than 1 year from the date it was transmitted to the Board (see Chapter I, subparagraph 2a). The report must state the reasons for needing more than 1 year and when implementation will be completed. This reporting requirement normally should be met by the Responsible Manager by addressing it as part of the Department's Annual Report to Congress, when the Responsible Manager knows that implementation will require more than 1 year. If the Annual Report is not used for this notification, the Responsible Manager should prepare and submit this report to Congress prior to exceeding the 1-year period, if possible, and no later than 30 days following the end of the 1-year period.

10. CLOSURE OF RECOMMENDATIONS.

a. The Board reserves the right to close recommendations and commitments based on their assessment of the actions completed by the Department. Responsible Managers should identify to the Board when Departmental actions are complete on a given commitment or recommendation. Responsible Managers must closely monitor implementation plan progress and pursue closure of recommendations when issues are resolved.

b. When all actions and commitments in an implementation plan are complete and corresponding closure packages have been transmitted to the Board, the Secretary must propose closure of the original recommendation in a letter to the Board and should include the following sentence or equivalent: "The Department has completed the commitments identified under its implementation plan for this recommendation, and proposes closure of the recommendation." Alternatively, proposed recommendation closure may be based on resolution of the original safety concerns on some other basis than completion of the associated implementation plan commitments. For such cases, the Department's rationale for proposing closure must be spelled out for the Board's consideration.

c. In evaluating closure of Board recommendations, the Board usually considers the effectiveness of Departmental actions to ensure the fundamental issues will continue to be adequately addressed in the future. The Responsible Manager should be prepared to show that the Department's actions have been adequately institutionalized such that a future recurrence of the subject safety concerns is unlikely. The Responsible Manager should consider the following factors in demonstrating institutionalization:

(1) Departmental line management ownership of the safety issue and actions for resolution;

(2) clearly defined roles and responsibilities;

(3) engagement and attention of senior Departmental managers on the issue;

(4) incorporation and integration of issue resolutions into standard practices, procedures and directives;

(5) continued funding at sufficient levels into the near future; and

(6) overall safety culture and mindset relative to the subject safety issue.

The Responsible Manager should consider including the discussion of institutionalization either in the Department's letter proposing closure or in a briefing to the Board to facilitate discussion on closure.

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