National Nuclear Security Administration
August 20, 2007
The Honorable A. J. Eggenberger
Defense Nuclear Facilities Safety Board
625 Indiana Avenue NW, Suite 700
Washington, D.C. 20004-2901
Dear Mr. Chairman:
This letter is to report on progress made in developing a directives system for the National Nuclear Security Administration (NNSA) that will replace the current NNSA policy letter system. In a letter dated November 3, 2006, NNSA provided a path forward and target schedule for implementation of an NNSA Directives System. In that letter, we outlined a directives program that largely paralleled, but was independent of the Departmental Directives Program. We included a schedule with the following milestones:
Consistent with this schedule, incorporation of an initial round of comments on the draft directive was completed by February 15, 2007. Comment resolution led to some process considerations that took longer to resolve than previously estimated. However, those comments have now been resolved and the revised draft document was circulated for review on July 20, 2007. We also provided the document on July 20, 2007, to Defense Nuclear Facilities Safety Board (DNFSB) staff for comment. The comment review period closes on August 17, 2007. Depending on the number and complexity of the comments received, we expect to resolve the comments within about a month. Following resolution, we will submit the NNSA directive to the Secretary for his consideration.
The key features of the system that were described in the November 3, 2006, letter remain unchanged, although we have made some substantive improvements. We have removed Technical Standards from the NNSA system, because the requirements for Technical Standards are somewhat different than for other directives, and NNSA has no plans to issue Technical Standards outside the DOE Technical Standards program at this time. We have added a discussion of Supplemental Directives for use in NNSA to better regulate their use. We also included a provision for Supplemental Directives that have NNSA-wide applicability to ensure that they receive the same review by the DNFSB as do other directives.
We look forward to continuing to work with you and your staff as we develop the NNSA Directives System. Please contact me or have your staff contact Mr. Michael C. Kane, Associate Administrator for Management and Administration, at (202) 586-5753, if you have any questions.
Thomas P. D'Agostino
M. Whitaker, Jr., HS-1.1