December 5, 2005
MEMORANDUM FOR LINTON F. BROOKS
SECRETARY FOR NUCLEAR SECURITY
FOR ENERGY, SCIENCE, AND ENVIRONMENT
SECRETARY, ENVIRONMENT, SAFETY, AND HEALTH
A. C. KOLB
OFFICE OF MANAGEMENT
FROM: CLAY SELL
SUBJECT: Integrating Safety into Design and
The following information
outlines my expectations regarding effectively integrating safety into projects.
We must identify and resolve safety
issues as early in the design process as is practicable. By so doing, we can address safety in a manner
that will result in minimal project delays and fewer cost overruns. This is what sound project management is
about, and this is why the Secretary and I have placed such importance on
effective project management. This is
not only good safety; it is also good business. As stewards of the country’s defense nuclear
facilities, we cannot have one without the other.
Program Strengths. The Department is focused on effective implementation
of our project management program. I see
five major strengths we can build upon in better integrating safety into design
early in our project lifecycle.
- Our project management program has the right goal - “to deliver capital assets on schedule, within budget,
and fully capable of meeting mission performance and environmental,
safety, and health standards”.
- Our project management order and manual are significant
steps moving us forward in instilling the required discipline into the
acquisition of major capital assets.
- The Department is moving forward with the certification
of our Federal project directors.
- The Department has a strong set of safety rules and
directives, and we need to build on this foundation by making necessary
clarifications and amplifications.
- The Department has strong Integrated Safety Management
systems implemented at our facilities, and we are implementing the
Secretary’s 2004-1 implementation plan to institutionalize and revitalize
our safety management implementation.
Program Weaknesses. Recent history shows that we can improve our performance
by adequately identifying and resolving safety issues early in the design cycle.
Although safety is an integral part of
the project management, we need to improve how safety is incorporated into
design, especially in the early project planning phases. Projects such as the Waste Treatment Plant at
Richland, the Salt Waste Processing Plant at Savannah River, and the Sandia
Underground Reactor Facility make clear the need to better incorporate safety
into early design activities.
- In terms of policy, we need to revise and reissue the
DOE Order 413.3, Project Management for the Acquisition of Capital Assets, originally
issued in October 2000, to bring it into agreement with the Manual. Based on experience and feedback, we have
identified a number of worthwhile improvements to clarify and strengthen
the project management order, including the following: (a) more complete description of safety expectations
for early design steps as well as for project completion and turnover; (b)
clarification of the expected use of the graded approach by identifying
clear expectations, including more complete expectations for acceptable
use of design/build approaches; (c) clear requirements regarding safety
qualification of individuals involved in project management and integrated
project teams; (d) clear references to the required safety rules,
directives, and standards; (e) more complete coverage of tailoring and
safety issues at ESAAB meetings; (f) provisions for safety oversight by the Chiefs of
Nuclear Safety; (g) provisions for safety
engineering reviews by the Office of Environment, Safety and Health for
projects over $4 million; and (h) more complete requirements for after-action
reports to promote effective learning from experience.
- While we pursue changes to the project management order
to better control and verify that safety is being adequately addressed, we
know that line management, not the project management staff organization,
owns the responsibility for developing designs using sound engineering
practices. In terms of
implementation, the line programs need to better staff their project teams
with the necessary design engineering and safety expertise to ensure safety
requirements are properly identified, translated into the project’s design
documents, and maintained in effect throughout the procurement,
construction, and testing phases of the project. Where this expertise is not readily
available within the Department, I expect the line programs to contract
this expertise. Line programs also
need to more clearly define contractual expectations regarding the early
integration of safety into the alternative studies and project design.
- In terms of safety oversight, the Chiefs of Nuclear
Safety are implementing their milestones in the Secretary’s 2004-1
implementation plan and will soon begin providing effective oversight on
the selection of safety requirements and standards for design and
construction, and translation of expectations into contract requirements. I also expect the Chiefs to review
project team make-up and contractor oversight, and sample safety hazard
analyses, facility hazard categorization, safety analyses, safety system
identification and performance categorization, and resolution of design
and construction safety issues so that they can provide feedback and input
to their Central Technical Authorities regarding whether they have
confidence that the project teams have effectively integrated safety considerations
into design and construction work activities.
Expectations. Please find below my top-level expectations
regarding integrating safety into project design and construction. To the extent that you have not fully realized
these expectations, I am now directing the responsible organization parties to
identify specific actions to close the gaps between our performance and our
expectations, and take those actions on a deliberate pace to fully meet these expectations.
- I expect safety to be fully integrated into design
early in the project. Specifically,
by the start of the preliminary design, I expect a hazard analysis of
alternatives to be complete and the safety requirements for the design to
be established. I expect both the
project management and safety directives to lead projects on the right
path so that safety issues are identified and addressed adequately early
in the project design.
- I expect my line organizations to follow the
requirements defined in the project management order and manual. The Secretary’s August 2005 memo made it
clear that he expects compliance with these directives.
- I expect line project teams to have the necessary
experience, expertise, and training in design engineering, safety
analysis, construction, and testing.
- I expect that the Chiefs of Nuclear Safety will provide
safety oversight during the design, construction, and testing phases of
- I expect staff work and presentations to the ESAAB to
be sufficiently complete so that they highlight tailoring issues and
safety issues that need management attention. I expect every ESAAB review to include a discussion
of relevant safety issues.
- I expect that we will learn effectively from our
project experience so that future projects are more likely to be completed
on time and on budget with all mission and safety objectives satisfied.
I want the OECM to begin needed
revisions of the project management order in January 2006 and develop and issue
this revision as a priority task during the upcoming year. I also want EH to review the existing safety
directives and identify those that need to be revised to provide clear requirements
regarding safety into early project phases. I do not expect line offices to await issuance
of the revised order before they move forward on implementing the expectations
I have described above. Other programs
are requested to identify any specific implementation actions you will take to
address the weaknesses and the expectations described above. Please provide a listing of your
implementation actions and schedules by January 31, 2006,
to Ms. Ingrid Kolb.
In closing, the Department has a
solid foundation and is moving in the right direction in improving its project
management practices. We need to make
the needed improvements in effectively incorporating safety into design and construction
so that we can reach our goal of world-class project management.
Mark B. Whitaker, DR-1
James A. Rispoli, EM-1
Robert L. McMullan, MA-50
Thomas P. D’Agostino, NA-10
R. Shane Johnson, NE-1
Raymond L. Orbach, SC-1
C. Russell H. Shearer, EH-1