Departmental Representative to the Defense Nuclear Facilities Safety Board

2.0 IMPLEMENTATION PLANS

2.1 Format and Content

The DOE IP for a specific Board Recommendation that is accepted in whole by the Secretary is due to the Board within 90 days after the Secretary’s acceptance of the recommendation is published in the Federal Register. If the Department only accepts part of a Recommendation, following a reaffirmation or modification to the recommendation by the Board, DOE’s IP is due within 90 days after the Secretary’s Final Decision on the Recommendation is published in the Federal Register. DOE does not publish the IP in the Federal Register.

The primary purpose of the IP is to describe the appropriate actions and schedule for ensuring that the accepted recommendation issues are addressed. Attachment 4 provides guidance on IP format and content. The Department owns the IP and there is no legislative requirement for the DNFSB to accept it; however, the Board uses the following six criteria to judge the adequacy of the Department’s IP (ref. DNFSB Policy Statement 1 (PS-1), Criteria for Judging the Adequacy of DOE Responses and Implementation Plans for Board Recommendations):

1. Understanding. The IP should show an understanding of the safety issues raised by the Board’s recommendation.
   
   
2. Responsiveness. The Department’s planned course of action should 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 should be detailed.
   
   
4. Planning Detail. The Department’s approach to resolve the associated safety issues should 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 should be based on sound evaluation, including identification of the underlying causes.
   
   
6. Focus on Closure. The Department’s plan should define completion deliverables for demonstrating safety issue resolution in a verifiable manner.
   
   

2.2 Transmittal of an Implementation Plan

The IP is a Secretarial commitment. The Responsible Manager should obtain final concurrence and approval of the IP in accordance with established Departmental procedures and using the DOE Executive Secretariat process. After the IP is approved and signed by the Secretary, the DR staff should coordinate with the Executive Secretariat to formally transmit it to the Board.

2.3 Extension Notification

The Secretary may obtain one 45-day extension for submitting an IP “if the Secretary submits to the Board and to the Committees on Armed Services, Appropriations, and Energy and Commerce of the House of Representatives and the Committees on Armed Services, Appropriations, and Energy and Natural Resources of the Senate a notification setting forth the reasons for the delay and describing the actions the Secretary is taking to prepare an implementation plan” (ref. 42 U.S.C. § 2286d (f)). 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, in order to ensure that the notification is properly reviewed and issued prior to the expiration of the 90-day deadline.

2.4 Changes to Implementation Plans

Changes to commitments, actions, or completion dates may be necessary due to additional information, improvements, funding limitations, or changes in baseline assumptions. The Responsible Manager should identify necessary changes and, with the support of the Program Interface and DR Issue Lead, bring to the Board staff’s attention any substantive changes to an IP. The Responsible Manager, Program Interface and DR Issue Lead should discuss with the Board staff any proposed changes to IP commitments before making formal changes to the IP.

Any revision to the IP scope, schedule, and/or commitments, should be documented and approved by the Secretary. Commitment revisions should be clearly identified and described by the Responsible Manager along with the basis for the revisions, through a formal revision and reissuance of the IP approved by the Secretary and provided to the Board.