[DOE LETTERHEAD]

May 5, 1998

The Honorable John T. Conway
Chairman
Defense Nuclear Facilities Safety Board
625 Indiana Avenue, NW, Suite 700
Washington, D.C. 20004

Dear Mr. Chairman:

I have enclosed the revised Implementation Plan (Plan) for Defense Nuclear Facilities Safety Board (Board) Recommendation 93-3, Improving DOE Technical Capability in Defense Nuclear Facilities Programs. This Plan renews the Department's commitment to maintaining the technical capability necessary to safely manage and operate defense nuclear facilities.

The Department applied the principles of integrated safety management to develop this Plan, which describes our commitment to recruit, develop, and retain technical personnel responsible for safety at defense nuclear facilities. The Plan reflects current initiatives, addresses previous actions that did not have the desired effect, and identifies realistic commitments that account for significant changes in the Department's mission, resources, and personnel constraints. Of primary importance is the Plan's focus on senior leadership, line management ownership, and management of the Department's essential technical capabilities.

The Plan builds upon recent accomplishments, including, a two-year extension of the Department's Defense Act Excepted Service personnel authority, development of a model set of policies and procedures to preserve critical technical capability in a downsizing environment, noteworthy progress under the existing Technical Qualification Program, and initiation of a technical career path pilot program.

By implementing this Plan, the Department will continue to consolidate its ongoing efforts to improve Federal workforce technical capability. We look forward to the continued involvement of your staff as a means of keeping you informed of our progress.

Sincerely,

Federico Peņa

U. S. Department of Energy
Implementation Plan

Revised Implementation Plan for

Improving DOE Technical Capability in
Defense Nuclear Facilities Programs

(Revised Implementation Plan for Board Recommendation 93-3)

Washington, D.C. 20585

Revision 1.d March 31, 1998

Table of Contents

Near-Term Focus

This revised Implementation Plan identifies four areas where improvements are required to improve technical capability. The four areas are:

1. Executive Commitment and Line Management Ownership
2. Recruiting and Deploying Technically Capable Personnel
3. Developing and Demonstrating Technically Capable Personnel
4. Retaining Technically Capable Personnel

Some immediate actions are necessary to focus on issues relating to the above functions.

The Department has been under pressure to "downsize" the workforce as a result of budget reductions and Strategic Alignment Initiative (SAI) targets assigned to the various offices. This downsizing pressure has highlighted critical issues that currently affect the Department's ability to demonstrate technical capability through recruitment, deployment, development, and retention of technically capable personnel to safely accomplish the Department's mission in defense nuclear facilities programs. The Defense Nuclear Facilities Safety Board (Board) also recognized these issues in its letter to the Secretary dated October 15, 1997. These critical issues and a synopsis of actions defined in this Implementation Plan are as follows:

Issue I: A long period of downsizing, budget reductions, and the attendant uncertainties that have surrounded decreases in resources has eroded the Department's overall ability to maintain critical technical skills (areas 2 and 4 above).

Immediate Actions

1. Each defense nuclear facility office will perform a workforce analysis to identify shortages and gaps in required critical technical skills, including Senior Technical Safety Managers. These actions will be completed by May 1998.
2. Where shortages of critical technical skills are identified, offices will use available reassignments, details, retraining and hiring flexibilities (including Excepted Service Authorities) to recruit, redeploy, and upgrade workforce skills to meet the required technical capabilities. Critical staffing needs will be identified by May 1998, with recruitment and hiring commencing soon thereafter. Necessary critical hiring will take place under established Departmental procedures consistent with available resources.
3. The Department will strive to reduce attrition of key technical personnel by employing retention allowances and other incentives for critical technical positions. The handbook entitled "RECRUITING, HIRING, AND RETAINING HIGH QUALITY TECHNICAL STAFF: A Manager's Guide to Administrative Flexibilities" will be revised to highlight all available personnel tools and flexibilities and to emphasize the above initiatives by July 1, 1998. A team consisting of senior representatives from the Federal Technical Capability Panel and the human resources community will conduct workshops, beginning mid-1998, in the field and at Headquarters with affected senior office managers to increase awareness of the flexibilities outlined in the handbook.

Long-range actions to address this issue include improving retention through programs such as continuing education, professional certifications and licenses, and rotational assignments. Improvement opportunities will also be sought through legislative initiatives if other specific relief measures are needed.

Issue II: A recent experience with threatened Reductions-In-Force demonstrated that certain critical technical skills areas (e.g., Facility Representatives, Senior Technical Safety Managers, Criticality Safety Engineers, Fire Protection Engineers, and Nuclear Explosives Safety Engineers) were vulnerable to "unintended consequences" of the Reductions-In- Force process within existing laws and regulations. Steps need to be taken to preserve key critical technical skills threatened by Reductions-In-Force (areas 2 and 4 above).

Immediate Action:

1. Develop and implement model policies and procedures for preserving critical technical skills. The model policies and procedures will be based upon, and applied to Facility Representative positions by June 1998. The Facility Representative Personnel Guide will be revised to reflect this initiative and other personnel flexibilities by June 1998. Concurrently, Field Office and Headquarters Program Office Managers will assess technical positions within their organizations to identify those which represent essential capabilities critical to protecting the health and safety of the public and workers. The Facility Representative-based model policies and procedures will then be applied, as feasible, to these critical technical positions.

Issue III: The Department has not provided sufficient management oversight and executive commitment to securing, overseeing, and maintaining required technical capabilities for the defense nuclear facilities and associated missions (areas 1 and 3 above).

Immediate Actions:

1. Charter the Federal Technical Capability Panel which will report to the Deputy Secretary and will be composed of senior line managers from the affected Field Offices and Headquarters Program Offices, and representatives from the Office of Human Resources and Administration and the Office of Environment, Safety and Health. The Panel will receive advice and support from the Office of the Deputy Secretary, and active participation by the Office of the Chief Financial Officer, Office of Congressional and Intergovernmental Affairs, Office of Field Management, Office of the General Counsel, and other supporting organizations as appropriate. The Panel will be chartered by April 1998 and will conduct its first meeting no later than the end of May 1998. An individual in the Deputy Secretary's office will be identified as a focal point for the Panel and coordinate with the Board on related issues.
2. Designate a senior line manager for each Field Office and Headquarters Program Office, who will function as the Federal Technical Capability Agent representing the cognizant field office manager or secretarial officer, to perform the duties and acquire the responsibilities now being executed by the "alter egos." Each Field Office and Headquarters Program Office will identify the manager responsible for technical capability and these duties and responsibilities will be included in the incumbent's position description and performance evaluation plan. Designation of these individuals will occur by April 1998.

Executive Summary

Board Recommendation 93-3 was issued on June 1, 1993, and accepted by the Department of Energy on July 23, 1993. The Recommendation discussed the need to improve the technical capability of federal employees associated with defense nuclear facilities. The Department's Implementation Plan for Improving Technical Capability in Defense Nuclear Facilities Programs, and Training and Qualification, was issued on November 4, 1993. The Implementation Plan commitments represented a significant and fundamental change in the Department's training and qualification programs. Since that time, the Department has made considerable progress on several aspects of these commitments. However, in their April 2, 1997, letter, the Board requested that the Implementation Plan be revised to reflect current Departmental initiatives, to address those actions that had not achieved the desired results, and to provide realistic milestones for open commitments. In his April 25, 1997, letter, the Secretary of Energy agreed to revise the Implementation Plan and noted that involvement of Department's senior line managers is essential to the success of this effort. In June 1997, the Department convened the "Recommendation 93-3 Implementation Plan Recast Working Group" with the charter of developing the content and structure of the revised Implementation Plan. The group was fashioned after the Federal Technical Workforce Review Group and includes several of its members. The group met several times during 1997 and early 1998, and developed this revised Implementation Plan. This determination is captured in the Department's Strategic Plan strategy to "ensure that all Department of Energy employees are appropriately trained and technically capable commensurate with their environment, safety and health responsibilities."

This revised Implementation Plan enhances current Departmental initiatives to establish a Federal Technical Capability Program for federal technical employees with safety responsibilities at defense nuclear facilities.

The objective of the Federal Technical Capability Program is to: recruit, deploy, develop, and retain federal personnel with the demonstrated technical capabilities to safely accomplish the Department's safety missions and responsibilities. The Department is determined to continue making improvements in the capabilities of the federal workforce and to fully utilize all of the tools at its disposal.

The principles of the program are:

• As stated in the Department's Integrated Safety Management Guiding Principles, federal personnel possess the experience, knowledge, skills, and abilities that are necessary to discharge their safety responsibilities;
• Line managers are accountable and have the responsibility, authority, and flexibility to achieve and maintain technical excellence;
• Supporting organizations (personnel, training, contracts, finance, etc.) recognize line managers as customers and effectively support them in achieving and maintaining technical capabilities; and,
• An integrated corporate approach is required to assure that necessary technical capabilities and resources are available to meet the overall needs of the Department's defense nuclear facility missions.

This revised Implementation Plan builds upon the successes of the original Implementation Plan while recognizing that several areas require increased emphasis and line management ownership. The integrated program functions for the Federal Technical Capability Program as defined in the revised Implementation Plan are:

• Executive Commitment and Line Management Ownership;
• Recruiting and Deploying Technically Capable Personnel;
• Developing and Demonstrating Technically Capable Personnel; and,
• Retaining Technically Capable Personnel.

This revised Implementation Plan incorporates line management flexibility into the Technical Qualification Program to ensure that technical capabilities are met for specific job assignments (e.g., criticality engineer). This revised Implementation Plan also institutes assessments for the Department's overall Federal Technical Capability Program as well as the individual Technical Qualification Programs in place for each site or office. The Federal Technical Capability Panel will monitor these assessments and will report directly to the Deputy Secretary. Based upon the results of these assessments, the Federal Technical Capability Panel may direct additional assessments of a specific line organization's performance in meeting the goals of the program, direct that specific actions be implemented by the line organization, or recognize that the organization's performance is acceptable.

1.0 BACKGROUND

Board Recommendation 93-3 was issued on June 1, 1993, and subsequently accepted by the Department of Energy on July 23, 1993. The Implementation Plan prepared in response was issued by the Department on November 3, 1993, and accepted by the Board on November 4, 1993. The initiatives and commitments contained in the Implementation Plan represented significant and fundamental changes in the training and qualification programs in the Department. Although elements of some of these initiatives have not realized the success intended, significant progress has been made in many areas.

• For the first time in the Department's history, a standardized technical qualification program was developed and implemented for approximately 1,800 federal employees Department-wide. Although the program must be further refined, a baseline qualification program has been established.
• The Department identified the federal positions considered to constitute the unbroken chain of safety responsibility. The background, experience, and qualifications of the incumbents in each of these Senior Technical Safety Manager positions were evaluated by their line management and further reviewed by the Federal Technical Workforce Review Group. Shortfalls in training or experience were documented, and decisions on each individual's qualification were made.
• The Department pursued and was granted an Excepted Service Authority for an additional 200 positions (in addition to the 200 positions allowed under the Department of Energy Organization Act). This authority is being used to fill key engineering, scientific, and other technical positions with experts having outstanding credentials. The hiring authority for these additional positions was to expire in September 1997, but the Department was successful in obtaining from Congress an extension of the hiring authority for an additional 2 years through the end of FY 1999.
• DOE Order 360.1, Training, provides direction for the use of Individual Development Plans. The Individual Development Plan provides a mechanism to identify the employee's training, development, and qualification needs necessary to discharge their safety responsibilities.
• Although funding and federal staffing for most programs in the Department have dramatically decreased over the last several years, some offices have identified critical staffing needs and successfully hired technically outstanding employees (e.g., Richland Operations Office, the Oak Ridge Operations Office Y-12 Site Office, and Albuquerque Operations Office).

Despite significant progress in some cases, Department-wide implementation of commitments aimed at improving the technical capability of the Department was begun but not institutionalized. Additionally, some commitments made in the original Implementation Plan were recognized as not being feasible or not adding value in the changed environment in the Department. In its April 2, 1997, letter, the Board requested that the Department revise the Implementation Plan to reflect current issues and the initiatives to address them. The Secretary of Energy agreed in his April 25, 1997, letter to revise the Implementation Plan and chartered a group of senior line managers who developed this revised Implementation Plan. This group of senior line managers will be integral to the implementation of the commitments contained in this revised Implementation Plan.

2.0 CONTRIBUTING CAUSES TO THE REVISION OF THE IMPLEMENTATION PLAN

The mission of the defense nuclear complex has changed significantly since the Department issued the original 93-3 Implementation Plan, and it will continue to evolve. Severe funding cuts and federal and contractor staffing reductions have repeatedly been imposed in recent years and threaten to continue. In this environment the Department has learned that the focus must be on solutions that, if properly executed, will have significant impact and value added to the Department's technical capability. The effectiveness of the solutions must be evaluated as they are implemented, and opportunities for continuous improvement identified. This continuous evaluation element is essential for a successful program and was not included in the original 93-3 Implementation Plan.

As noted in the Board's April 2, 1997, letter, approximately 40 percent of the commitments made in the original 93-3 Implementation Plan have not been met, either literally or in the spirit of the commitment. Although there were many contributing factors, the lack of senior and line management support and accountability for the original Implementation Plan was integral to the failure to fully implement the 93-3 Implementation Plan commitments. Management support and accountability are considered the most critical elements to the success of this revised Implementation Plan.

3.0 BASELINE ASSUMPTIONS

The Department made the following baseline assumptions in developing the revised Recommendation 93-3 Implementation Plan.

• In recent years, the Department has experienced a series of substantial funding cuts and staffing reductions, both in its federal and contractor workforce, and further funding and staffing reductions are expected.
• The Department's missions have changed over the last several years and will continue to evolve.
• The Department will pursue the funds necessary to continue to recruit, develop, deploy, and retain technically capable personnel.
• Contractor technical capability issues, identified in Board Recommendations 92-7 and 93-3, will be addressed adequately during assessments of the Department's Integrated Safety Management System.
• This revised Implementation Plan is applicable only to offices with defense nuclear facility responsibilities.
• The Department will use mechanisms such as fellowships, residencies, industry exchange, mentoring, and Departmental intern programs, and make maximum effective use of Excepted Service and other personnel authorities to recruit, develop, and retain a technically capable federal workforce.
• Line management will have the flexibility to recruit, develop, and retain the necessary technical skills to meet specific job assignments and will use that flexibility to the maximum extent possible in the face of downsizing and other budgetary constraints.

4.0 ORGANIZATION AND MANAGEMENT

4.1 Organization

In April 1997, the Department chartered the "Recommendation 93-3 Implementation Plan Recast Working Group" to determine the content and structure of the revised Implementation Plan and to represent the Department in an off-site conference with the Board and its staff. This group was also tasked with communication and resolution of issues affecting successful implementation of the revised Implementation Plan. This Implementation Plan builds upon this concept and establishes a Federal Technical Capability Panel which reports to the Deputy Secretary. The initial Chair of this Federal Technical Capability Panel will be the current Chair of the Recommendation 93-3 Implementation Plan Recast Working Group.

The Federal Technical Capability Panel will consist of senior line managers, representing each office with defense nuclear facility responsibilities, to oversee and resolve issues affecting the Federal Technical Capability Program. The Federal Technical Capability Panel will include senior line managers from the affected Field Offices and Headquarters Program Offices, and representatives from the Office of Human Resources and Administration, and the Office of Environment, Safety and Health. The Panel will receive advice and support from the Office of the Deputy Secretary, and active participation by the Office of the Chief Financial Officer, Office of Congressional and Intergovernmental Affairs, Office of Field Management, Office of the General Counsel, and other supporting organizations as appropriate. The Federal Technical Capability Panel will replace the existing Technical Excellence Executive Committee. It is envisioned that the Federal Technical Capability Panel (and other senior Departmental management) will meet periodically with the Board and its staff to informally communicate achievements, issues, and expectations in the execution of this Implementation Plan.

This revised Implementation Plan recognizes that line managers are accountable and responsible for technical capability in their organizations. Impact and implementation of this revised Implementation Plan will be negotiated with employees' Unions in accordance with local collective bargaining agreements.

The Assistant Secretary for Human Resources and Administration (HR-1) organization will provide overall support and coordination for the implementation activities. The Office of Training and Human Resource Development (HR-31) organization will be an active participant on the Federal Technical Capability Panel and will provide overall logistical support for the Federal Technical Capability Panel.

4.2 Management Systems

4.2.1 Change Control

The Department will promptly notify the Board of anticipated significant changes in deliverable due dates (commitment dates) prior to the scheduled commitment date. Fundamental changes to the Implementation Plan strategy, scope, or schedule will be provided to the Board through formal revision of the Implementation Plan. Minor changes to the strategy, scope, or schedule will be formally submitted in appropriate correspondence approved by the responsible manager, along with the basis for the changes and appropriate corrective actions.

4.2.2 Reporting

The Chair of the Federal Technical Capability Panel will provide a semi-annual written report and periodic briefings to the Board to discuss status of this revised Implementation Plan. Line managers (e.g., Field Office or Program Office Managers) will provide an annual briefing to the Board on their initiatives to improve the technical capability of their workforce and their individual progress in meeting the revised Implementation Plan objectives.

DELIVERABLES/MILESTONES

5.0 SAFETY ISSUE RESOLUTION

5.1 RECOMMENDATION

Section 5.1.1 repeats the Recommendation of the Board, and Section 5.1.2 is an analysis of the Department's understanding of the fundamental concerns as expressed in the original Recommendation 93-3.

5.1.1 Recommendation 93-3

The entire text of Recommendation 93-3 follows:

RECOMMENDATION 93-3 TO THE SECRETARY OF ENERGY pursuant to
42 U.S.C. S 2286a(5) Atomic Energy Act of 1954, as amended.

Dated:June 1, 1993

Effective functioning of any organization, whether in the private sector or government, is highly dependent upon the capabilities of people and the way they are guided and deployed. Nowhere is this dependency more crucial than in the Department of Energy's defense nuclear complex, where the potential hazards inherent in nuclear materials production, processing, and manufacturing, require high quality technical expertise to assure public and worker safety.

Nuclear weapons development and production have progressed over the years from early efforts of a small group of highly talented, ingenious individuals in scientific laboratories to employment of thousands of workers in industrial-type production environments. While the national response to today's changing international scene is resulting in downsizing of the nuclear stockpile and a change in mission of many of the defense nuclear facilities, the need remains for continuing vigilance to protect public and worker health and safety. In fact, a case can be made for the need for greater vigilance now throughout the weapons complex because of: increased risk of equipment mishaps in aged facilities, loss of existing technical expertise through attrition and down-sizing, and a reduced inclination. for young engineers and scientists to get involved in the nuclear weapons field.

Nevertheless, the level of scientific and technical expertise in the DOE of defense nuclear facilities and operations has been declining. The Defense Nuclear Facilities Safety Board in its last three annual reports has observed that:

"... the most important and far reaching problem affecting the safety of DOE defense nuclear facilities is the difficulty in attracting and retaining personnel who are adequately qualified by technical education and experience to provide the kind of management, direction and guidance essential to safe operation of DOE's defense nuclear facilities."

The Board has not been alone in calling attention to the problem. Congressional perception of the need to upgrade DOE technical expertise is evident in the Board's enabling legislation. The need for such up-grading is further underscored by assessments made by a number of other groups over the past decade, as the attached excerpts from their reports indicate.

A reputation for technical excellence is a strong attraction for talented individuals. Organizations with strong technical missions commonly cite technical excellence as a goal towards which management should strive. However, sustained leadership emphasis and deliberate actions are required if the reality of technical excellence is to be achieved.

Actions by the Board, such as recommendations and public hearings, have resulted in some efforts on the part of certain DOE organizations and M & O contractors to upgrade existing staff and recruit better qualified personnel. However, such efforts have not been coordinated DOE-wide and have been well short of the need. The Board believes that a more aggressive, broad-based and well-coordinated program directed at the enhancement of the technical capabilities of the DOE staff should be defined and implemented.

The Board recognizes the difficulty any on-going organization faces in developing programs targeted at upgrading competence of staff. Such efforts rarely succeed without strong endorsement, involvement, and guidance by the organization's top management and without the impetus provided by objective appraisals made by outside, independent experts. Further, the sheer size, differing requirements, and dispersion of DOE staff complicates both the problem and the solution. Nonetheless, the strong correlation between technical excellence and assurance of public health and safety compels this Board to urge that DOE give high priority to the problem of attracting and retaining technical personnel with exceptional qualifications. More specifically the Board recommends that DOE:

1. Establish the attraction and retention of scientific and technical personnel of exceptional qualities as a primary agency-wide goal.
2. Take the following specific actions promptly in the interest of achieving this goal.
   1. Seek excepted appointment authority for a selected number of key positions for engineering and scientific personnel in DOE programmatic offices, in other line units and in the oversight units responsible for the defense nuclear complex.
   2. Establish a technical personnel manager within the Office of the Secretary to coordinate recruitment, classification, training, and qualification programs for technical personnel in defense nuclear facilities programs.
3. Develop a broadly-based program, giving consideration to the following:
   1. DOE Internal Initiatives.
      1. Develop a set of mutually supportive actions which DOE could take, within existing personnel structures, to enhance capabilities. Measures warranting consideration:
         1. Plan and execute a system for using attrition to build technical capability.
         2. Review the performance appraisal system for technical employees for its effectiveness in determining basic pay, training needs, promotions, reductions in grade, and reassignment/removal.
         3. Review and improve programs for training and assigning technical personnel. (This activity would be coordinated with actions taken, planned to be taken, in response to Board Recommendations 90-1, 91-6, 92-2, and 92-7.)
         4. Explore with the Secretary of Defense the possibility of assigning to DOE defense nuclear facilities activities a number of outstanding officers with nuclear qualifications who may now be surplus to DOD needs.
         5. Establish initiatives designed to take advantage of skills of marginal technical performers and re-train them.
         6. Expand Headquarters/Field personnel exchange programs for highly qualified junior technical staff to promote understanding of all aspects of technical issues including their resolution.
   2. Independent External Assessments.
      1. Use respected, independent, external organizations such as the National Research Council of the National Academy of Sciences, and the National Academy of Public Administration to assess DOE's ongoing and planned actions directed at attracting and retaining personnel with strong technical capabilities and to make recommendations for enhancements. Such assessment could include:
         1. Government-wide and/or DOE personnel recruitment and development policies and practices that may be effective inducements to government service.
         2. Comparison of DOE methods of building a qualified technical staff with qualifications comparable to those of other government agencies with predominant technical missions.
   3. DOE Internal Assessments.
      1. Perform an in-depth assessment of educational and experience requirements of key positions and develop both a short-term and long-term plan for key personnel development. Such assessment could include:
         1. Identification of qualifications (education and experience) required in key positions (above GS-14) in DOE Headquarters and field organizations with responsibilities for safely carrying out the defense nuclear program.
         2. Evaluation of incumbents for their ability to meet such qualification requirements.
         3. Evaluation of current availability within DOE of fully qualified personnel to fill these positions.
         4. Develop an action plan to meet needs thus identified.

John T. Conway, Chairman /s/

5.1.2 Department Analysis of Recommendation 93-3

In Recommendation 93-3, the Board noted that the Department's effectiveness in managing safe operations at defense nuclear facilities is highly dependent upon the technical capability of its workforce. In its analysis of the situation, the Board noted that the Department needs a broad, integrated program which addresses four issues:

1. Executive commitment and line management ownership are essential to the successful implementation of a corporate program to recruit, retain, and develop technical expertise at defense nuclear facilities.
2. It is imperative that the Department recruit and deploy highly qualified individuals when filling technical positions responsible for safe operations at defense nuclear facilities.
3. The technical capability of the existing federal staff needs to be upgraded, where necessary, to ensure that they possess the necessary knowledge, skills, and abilities to competently carry out their safety management responsibilities.
4. The Department must identify the critical technical capabilities that are essential to defense nuclear facility safety functions and retain highly qualified personnel in those positions.

In its Recommendation, the Board described 6 primary elements and 11 sub-elements intended to improve the technical capability of Department personnel. In the original Implementation Plan, the Department committed to a number of actions to address and resolve the elements and sub- elements recommended by the Board.

This revised Implementation Plan proposes an alternate approach which meets the intent of the overall Board Recommendation. This revised Implementation Plan outlines an integrated course of action employing a combination of current Department activities and new initiatives to address the four issues raised in the Board's Recommendation. The approach to resolving these issues will be achieved through the leadership of a corporate panel of senior executives charged with the responsibility of monitoring the Department's technical capability and empowered by the Secretary of Energy to take action when improvements are required. Unless otherwise noted, commitments made in this revised Implementation Plan are applicable to all offices with defense nuclear facility responsibilities.

The Board's Recommendation also addressed the need for the Department to ensure its contractors employ personnel with the technical expertise necessary to safely operate and maintain the Department's defense nuclear facilities. In the Implementation Plan addressing Board Recommendation 95-2, the Department outlined its approach for developing and implementing an integrated safety management system at its defense nuclear facilities. The Implementation Plan describes the guiding principles of integrated safety management, one of which is "competence commensurate with responsibility." Using the guidance of DOE G 450.4- 1, Integrated Safety Management System Guide for use with DOE P 450.4, Safety Management System Policy, and DEAR Safety Management System Contract Clauses, the Department will conduct 95-2 Phase I and Phase II Assessments of integrated safety management systems. The Criteria Review and Approach Documents which guide these assessments establish criteria for ensuring contractor personnel demonstrate technical capability commensurate with responsibility. That activity is considered to meet the intent of the Department's commitments within the Implementation Plans for Recommendations 92-7 and 93-3 regarding the technical capability of contractors operating defense nuclear facilities.

5.1.3 93-3 Federal Technical Capability Program Model

In Recommendation 95-2, the Board noted that the Department needed an integrated approach for managing defense nuclear facility safety. The Board also noted that successful implementation of the safety management system was highly dependent upon the application of technical expertise. Stated simply, successful implementation of integrated safety management is directly linked to the Department's ability to manage and develop its technical workforce.

In developing this revised 93-3 Implementation Plan, the Department concluded that the safety management system approach described in the 95-2 Implementation Plan could also be used as a basis for developing an integrated model for managing the recruitment, development, deployment, and retention of a highly capable federal technical workforce.

The safety management system's hierarchy of components was adapted to facilitate the development of an integrated program to address the capability of the Department's federal technical workforce. In developing a model for this Federal Technical Capability Program, five components were defined: 1) objective; 2) principles; 3) functions essential to improving technical capability; 4) mechanisms, or programs, which implement the program functions; and 5) implementation of the program mechanisms. (See Figure 1.)

Note: Figure 1 (Federal Technical Capability Program) is available in the [PDF] file.

The objective of the Federal Technical Capability Program is to: recruit, deploy, develop, and retain federal personnel with the demonstrated technical capabilities to safely accomplish the Department's safety missions and responsibilities.

The program objective was then used to develop the principles. The principles are the fundamental concepts guiding the development of mechanisms to recruit, develop, and retain the technical capability of the Department's workforce. The guiding principles are provided in Figure 2.

Figure 2: Federal Technical Capability Program Principles

Programs implemented to improve the Department's technical capability are grouped into four general functions:

1. Executive Commitment and Line Management Ownership: This function includes establishing policies and procedures, accountability, program direction, monitoring, and continuous improvement.
2. Recruiting and Deploying Technically Capable Personnel: This function includes career path planning, succession planning, defining position responsibilities, and filling technical positions with high-quality technical personnel.
3. Developing and Demonstrating Technically Capable Personnel: This function includes baselining existing technical capabilities as well as individual development planning and improvement.
4. Retaining Technically Capable Personnel: This function includes career path planning, succession planning, performance reviews, promotions, and rewards.

Figure 3 illustrates the conceptual model incorporating these functions, as well as the interrelationship and interdependence among the functions. For the Federal Technical Capability Program to succeed, all functions must succeed.

Note: Figure 3 (Federal Technical Capability Program Integrated Program Functions) is available in the [PDF] file.

After defining the four functions of the Federal Technical Capability Program, the next level of detail is the identification of mechanisms which define how a particular function will be performed. Some of the mechanisms which address technical capability functions would be applicable Complex-wide. At the Headquarters level, an example of these mechanisms would include the Department's Orders, Policies, and Standards which promulgate guidelines for the administration of technical training. For example, development and promulgation of a policy statement outlining the Secretary's expectations regarding technical recruiting and workforce development could be described as a Complex-wide mechanism directed at implementing functions to both recruit capable personnel or further develop the capabilities of existing employees.

Other mechanisms may vary from site to site or between Program Offices. For example, in implementing an Order directed at developing the technical capabilities of its workforce, each Field Office and Headquarters Program Office is expected to develop and implement a program which meets the Complex-wide guidelines defined in the Order. However, the offices would then be free to customize implementation details to meet the needs defined by line management at each site or Program Office.

In developing an integrated Federal Technical Capability Program, the Department recognizes that mechanisms identified within this Implementation Plan may impact and affect multiple functions. For example, development of staffing plans might be identified as a mechanism to identify technical needs under the recruitment of capable personnel function. However, in the integrated model, development of the staffing plans under a recruitment function would also affect mechanisms identified under development and retention functions. For example, once line management completes an analysis which projects a shortage in a set of critical technical capabilities, line management might determine that adequate time exists within which the Department can develop the necessary technical skills in its existing workforce. The staffing plan would then serve as a driver to direct resources to mechanisms aimed at developing the technical capabilities of the existing workforce. In that scenario, the staffing plan would also be a driver for line management to focus reward, incentive, and retention mechanisms on personnel with those critical capabilities to ensure that the Department retains the capabilities it currently has while new personnel with those capabilities can be developed or recruited.

The mechanism to develop staffing plans for each Field Office and Program Office would in turn interface with mechanisms identified under the executive commitment and line management ownership function. Development of the staffing plans would be an essential input into a corporate analysis of the technical needs of the Department. That corporate review would in turn be expected to generate feedback to the Field Offices and Program Offices which would affect implementation of recruitment, development, and retention mechanisms.

Mechanisms identified within this Implementation Plan to support the functions of the Federal Technical Capability Program are incorporated into the model in Figure 4 (see page 13). However, over time the mechanisms employed by the Federal Technical Capability Program are expected to respond to changes in the Department's technical needs. For example, a fundamental change to a strategic mission may result in shifting program emphasis from development and retention functions to mechanisms which rapidly obtain the necessary technical capabilities. In that situation, the Department might decide to develop new mechanisms to meet the challenge or shift resources to mechanisms which support the recruiting function.

Institutionalization of policy, criteria and guidance, based on the model and mechanisms identified within this Implementation Plan, is expected to establish a systematic, corporate process which will periodically assess technical needs and initiate action to recruit, develop, and retain the technical capability necessary to achieve the Department's missions.

Note: Figure 4 (Federal Technical Capability Program Mechanisms) is available in the [PDF] file.

Clear definition of responsibilities for implementing these mechanisms is the final level of detail described within this Implementation Plan. Implementation is addressed by defining specific commitments and deliverables which demonstrate the implementation of mechanisms identified within this Implementation Plan. Identification of individuals responsible for completing each deliverable assigns clear responsibility for Implementation Plan activities and is consistent with the guiding principle that line managers are responsible and accountable for achieving technical excellence.

The next four sections of this Implementation Plan provide a discussion of the Department's corporate approach to resolving the issues associated with recruiting, developing, and retaining technical capability. These sections describe the mechanisms to be employed in resolving each issue, list commitments to the Board that demonstrate implementation, and identify responsibility for implementation of commitments.

5.2 EXECUTIVE COMMITMENT AND LINE MANAGEMENT OWNERSHIP

ISSUE DESCRIPTION

Executive commitment and line management ownership are essential to the successful implementation of a corporate program to recruit, develop, deploy, and retain technical capability at defense nuclear facilities.

RESOLUTION APPROACH

The Department will provide the corporate leadership to ensure that federal employees have the necessary technical capabilities to safely accomplish the Department's missions and responsibilities. It is recognized that the overall approach for the Federal Technical Capability Program must be integrated across the different program functions and that senior Department management must oversee the program, and provide the necessary resources, to ensure effectiveness.

A senior line manager will be appointed at each Field Office and Headquarters Program Office, who will function as the Federal Technical Capability Agent representing the cognizant field office manager or secretarial officer, to perform the duties now executed by the "alter egos." The Federal Technical Capability Agent should serve as the member of the Federal Technical Capability Panel to oversee and resolve issues affecting the Federal Technical Capability Program. The Federal Technical Capability Panel will also include representation from the Office of Human Resources and Administration and the Office of Environment, Safety and Health. The Panel will receive advice and support from the Office of the Deputy Secretary, and active participation by the Office of the Chief Financial Officer, the Office of Congressional and Intergovernmental Affairs, Office of Field Management, Office of the General Counsel, and other supporting organizations as appropriate. The initial Chair of the Federal Technical Capability Panel will be the current Chair of the Recommendation 93-3 Implementation Plan Recast Working Group. This Federal Technical Capability Panel will replace the existing Technical Excellence Executive Committee and will report to the Deputy Secretary. It is envisioned that the Federal Technical Capability Panel (and other senior Departmental management) would meet periodically with the Board and their staff to informally communicate issues and expectations in the execution of this revised Implementation Plan.

The Federal Technical Capability Panel will review the current Technical Excellence Policy, and update the Policy as necessary, to ensure that the elements of the Federal Technical Capability Program regarding recruitment, development, deployment, and retention of technical personnel are properly established. The revised Policy statement will formally define the Secretary's expectations regarding the Department's technical capability, such as recognition of:

• line management's responsibility for assuring the technical capability of its workforce,
• the role of support organizations to assist line management in maintaining critical technical capabilities, and
• the importance of education and training in developing the technical capability of the federal workforce.

The Policy will be issued by the Secretary and incorporated into the Department's Directives Management System.

The Federal Technical Capability Panel will assure that the Functions, Responsibilities and Authorities Manual (FRAM) reflects federal line management responsibilities in the area of federal employee technical capabilities consistent with this Implementation Plan.

The Department will review the guide entitled "RECRUITING, HIRING, AND RETAINING HIGH QUALITY TECHNICAL STAFF; A Manager's Guide to Administrative Flexibilities," and make changes as necessary. In particular, the Federal Technical Capability Panel will reevaluate the level of responsibility and approval required for various staffing actions described in Appendix A of the document. Updates and changes to the guide will be consistent with deliverables outlined in this Implementation Plan and incorporate lessons learned from recent Reduction-In-Force planning exercises.

The Federal Technical Capability Panel will periodically assess the effectiveness of the four functions of the Federal Technical Capability Program using both internal and external experts. These external experts will be drawn from respected, independent, external organizations such as the National Research Council of the National Academy of Sciences, the National Academy of Public Administration, and other distinguished industry experts, as necessary. In addition, the Federal Technical Capability Panel will review the results of Phase I and Phase II Assessments to evaluate the effectiveness of the Technical Qualification Program as discussed in section 5.4.

The desired outcome for the resolution of this issue is a measurable commitment by the Department's executive management and senior line management toward improving technical competence for oversight of defense nuclear facility operations.

Performance measures will include:

• Federal Technical Capability Panel membership and attendance;
• Line management involvement in briefing the Board;
• Implementation Plan deliverable performance; and
• Outcomes of assessment team evaluations for each line organization.

DELIVERABLES/MILESTONES

5.3 RECRUITMENT

ISSUE DESCRIPTION

It is imperative that the Department recruit and deploy highly qualified individuals when filling technical positions responsible for safe operations at defense nuclear facilities.

RESOLUTION APPROACH

Line management is responsible for identifying, recruiting, and hiring personnel needed to fill critical safety positions. The effective support by human resources organizations that are familiar with government hiring requirements and procedures is, however, vital to the success of hiring programs. A handbook entitled "RECRUITING, HIRING, AND RETAINING HIGH QUALITY TECHNICAL STAFF; A Manager's Guide to Administrative Flexibilities" has been developed to assist line management in understanding their prerogatives and options within the government hiring process. Corporate commitment to further distribution and aggressive implementation of that handbook will result in greater awareness of the existing processes that line management can use to employ the best people for the work.

The Board noted the considerable progress on several aspects of the technical capabilities issues, but indicated concerns with regard to the continued viability of efforts such as evaluations of key technical personnel, the Technical Leadership Development (Intern) Program, and use of Excepted Service Authorities.

The Excepted Service Authorities have been used to fill some key technical positions and will continue to be used in the future. The Defense Act Excepted Service Authority was extended, at the request of the Department, through Fiscal Year 1999. The Department recognizes the value and flexibility of the Authority and will pursue its periodic renewal as needed.

The Federal Technical Workforce Review Group initiated a comprehensive peer review of incumbents in defined Senior Technical Safety Manager positions. The Federal Technical Capability Panel, as established by this revised Implementation Plan, will provide a comparable level of peer review to any changes in the Senior Technical Safety Manager positions and the personnel hired or assigned to those positions.

The Technical Leadership Development Program has been successful in attracting highly qualified and diverse entry level technical personnel. The current climate of downsizing and Reductions-In-Force have not allowed further expansion of the program and have heightened concerns about retention of Technical Leadership Development Program participants and recent graduates. The Technical Leadership Development Program will be examined, and the program guidance revised, to include procedures and methods that can be used by Department line organizations to address the current issues (e.g., retention of interns).

A Federal Technical Staffing Plan will be prepared by each defense nuclear facility field and program element and reviewed by the Federal Technical Capability Panel. A similar process was used to develop action plans for addressing unmet critical safety needs throughout the Department in late 1996. The staffing plan will identify critical safety needs and actions taken to address recruitment and deployment issues; projected staffing needs for technical positions; and the use of methods such as Excepted Service Authorities, redeployment, and the Technical Leadership Development Program to fill those positions with the best qualified individuals. The Federal Technical Capability Panel will provide a corporate perspective to the Secretary regarding potential technical workforce vulnerabilities, line management concerns, and resolution options.

Performance measures will include:

• Needs for technical personnel and hiring methods to complete the staffing process are established and implemented as a part of line management planning; and,
• Personnel are regularly hired into Technical Leadership Development Program positions as part of long-term staffing programs.

DELIVERABLES/MILESTONES

5.4 DEVELOPMENT

ISSUE DESCRIPTION

The technical capability of the existing federal staff will be upgraded, where necessary, to ensure that they possess the necessary knowledge, skills, and abilities to competently carry out their safety management responsibilities.

RESOLUTION APPROACH

The Department has a considerable amount of technical talent and an experience base which is uniquely suited to the Department's work. This expertise exists both at Headquarters and at the various Departmental field elements. Training, education, and experience combine to provide a workforce which assures safe operations of defense nuclear facilities. While technical training is a recognized necessity for job-specific functions, the value of formal education and professional certification and licenses also is recognized. Continuous development of our incumbent workforce is necessary to maintain their critical skills.

Fellowship Programs are important development tools that allow employees to pursue full-time study at the graduate or post-graduate level. The Programs are usually available only in subject areas directly related to the missions and functions of the sponsoring Office. An example of a successful Fellowship Program is the program in the Office of Defense Programs. In addition to developing technical employees, Fellowship Programs and formal continuing education opportunities are considered to be retention tools.

The Department has acted with some success to more effectively manage the development of the technical workforce through the use of a formal Technical Qualification Program. However, it is necessary to evaluate the existing approach to address identified problem areas. The Systematic

Approach to Training methodology will be used in any modification of the Technical Qualification Program. This methodology was generally used during the design of the current qualification program. However, the evaluation and feedback functions were not effectively conducted. The process elements of the Systematic Approach to Training are: Analysis, Design, Develop, Implement, and Evaluate. A detailed explanation of each of the elements and the process is contained in DOE HDBK-1078, "A Systematic Approach to Training."

The Technical Qualification Program principles that will be used as the basis for evaluating the Technical Qualification Program are provided below:

• Demonstration of Competence: The program must clearly identify and document the process used to demonstrate employee technical competence (e.g., professional certification, qualification cards, background and experience, etc.).
• Competency Levels: The competency levels within the program must be clearly defined and consistent with applicable industry standards for similar occupations.
• Plans and Procedures: Plans and procedures must be developed and implemented to govern the administration of the program.
• Qualification Tailored to Work Activities: The program must clearly identify unique Department and position-specific work activities, and the knowledge and skills necessary to accomplish the work.
• Credit for Existing Technical Qualification Program(s): The program should be structured to allow credit, where appropriate, for other technical qualification program accomplishments to date.
• Transportability: Competency requirements that have been identified as having Department-wide applicability must be transferable.
• Measurable: The program must contain sufficient rigor to demonstrate compliance to the principles.

The approach that will be followed to evaluate the effectiveness of the Technical Qualification Program will consist of an initial (Phase I) assessment of the existing Program for each office with defense nuclear facility responsibilities. Each assessment team will report to the Office Manager and the Chair of the Federal Technical Capability Panel, and will generally consist of a small group of personnel from the office being assessed, and other offices, and will include representation from the Federal Technical Capability Panel to provide mentoring, rigor, and to ensure a consistent approach. Phase I Assessments will be used as the basis for revising, as appropriate, the direction of the Technical Qualification Program for the office. This Assessment will be performance-based and will evaluate the following:

• Are the Technical Qualification Program principles embodied in the office's program?
• Are the roles and responsibilities defined?
• Does it require a rigorous job and task analysis to be performed for each identified position?
• Are related knowledge, skill, and ability elements defined?
• Is an assessment system in place that measures the technical competency of personnel?
• Are there feedback mechanisms included in the program?
• Does the program meet the office's mission needs?
• Are the appropriate positions included in the program?
• Has the technical competency of personnel been upgraded?
• Is the level of technical competency of personnel who have completed the program adequate and appropriate?
• Do the office programs identify job-specific requirements that focus on rules, regulations, codes, standards, and guides necessary to carry out the office's mission needs?
• Are the office-specific programs consistent with the office's roles and responsibilities?
• Have the office-specific programs verified the adequacy of each individual's experience and relevant experience?
• Does the Program provide for continuing training?

Information will be addressed in the Level 1 Functions, Responsibilities and Authorities Manual that defines the roles and responsibilities for each organization whose functions may affect the safe operations of a defense nuclear facility. Deficiencies in Technical Qualification Program Plans will be corrected using the Systematic Approach to Training methodology to identify position requirements, individual competence, and developmental needs. Qualification requirements for each position included in the Technical Qualification Program, and the offices' Technical Qualification Program Plan, will be based on the Systematic Approach to Training principles. The Systematic Approach to Training involves a system of analysis, design, development, implementation, and evaluation that addresses the roles and responsibilities of positions, the technical capability of persons filling those positions, and alternatives for addressing identified developmental needs. Revised Technical Qualification Program Plans will be provided to the Federal Technical Capability Panel for review to ensure that each office's Plan is consistent with the Technical Qualification Program principles. These requirements will identify the necessary basic technical knowledge; the technical discipline competency requirements; and the position-specific knowledge, skills, and abilities (discussed below). This will allow a flexible approach to meeting the principles of the Technical Qualification Program to upgrade the technical capabilities of personnel to achieve the site's mission. It should be noted that the current Technical Qualification Program will meet these requirements if effectively implemented.

Basic Technical Knowledge: This includes basic fundamental knowledge of radiation protection, occupational safety, chemical safety, nuclear safety, environmental regulations, and other areas. It is expected that these requirements will be applicable to all federal technical personnel.

Technical Discipline Competency: Competency in a technical discipline (e.g., mechanical engineering, chemical engineering) which can be demonstrated by education, professional certification, or examination.

Position Knowledge, Skills, and Abilities: Specific to the position and the office.

In a case where an office has performed a previous assessment of its Technical Qualification Program, it may be acceptable for the office to deliver its assessment results to the Federal Technical Capability Panel for an audit to assure that the intent of the policy, criteria and guidance for a Phase I Assessment has been met.

Phase II will consist of a follow-on assessment, to be conducted after the Technical Qualification Program is revised in accordance with the Phase I Assessment, and is being implemented. Phase II Assessments will continue periodically for the duration of the Program.

Policy, criteria, and guidance addressing the scope, team composition, and conduct of Phase I and II Technical Qualification Program Assessments will be institutionalized and promulgated through the Department's Directives System to ensure a systematic approach to these activities.

The desired outcome for the resolution of this issue is a measurable commitment by the Department to implement a flexible process, based on uniform principles, to appropriately enhance the technical capabilities of the federal workforce.

Performance measures will include:

• Revised DOE Order 360.1 issuance,
• Completion of all Phase I Assessments, and
• Successful completion of all Phase II Assessments that show the Technical Qualification Program principles are being met.

DELIVERABLES/MILESTONES

5.5 RETENTION

ISSUE DESCRIPTION

The Department must identify the critical technical capabilities which are essential to defense nuclear facility safety functions and retain highly qualified personnel in those positions.

RESOLUTION APPROACH

A highly competent technical workforce, such as qualified Facility Representatives, Senior Technical Safety Engineers, Criticality Safety Engineers, Fire Protection Engineers, and Nuclear Explosives Safety Engineers, represent valuable corporate assets which must be managed and preserved to effectively and safely carry out the Department's missions. The Department has concluded that three issues provide challenges to the retention of capable technical personnel:

• Future funding actions are likely to result in significant staffing changes;
• During Reduction-In-Force actions, technical line managers have little control of the personnel "bumping" and "retreating" process; and
• The scope of existing retention incentives are not sufficiently understood or used throughout the Department.

In the face of likely future funding actions, the Department will proactively manage and preserve the technical capabilities needed to perform functions essential to maintaining health and safety of the public and workers. While preparing for a Reduction-In-Force, some Departmental elements were able to complete actions to ensure that Facility Representative positions would remain filled by qualified personnel. Examples of such mechanisms include the revision of position descriptions and performance standards to reflect the selective qualifications required to perform the critical duties and responsibilities of the positions. Such qualifications can then justify different competitive levels from

those of general technical positions, and help ensure the Department's preservation of critical technical capabilities. A working group has begun preparing a model incorporating these mechanisms into Facility Representative position descriptions. This model will be included in the Facility Representative Personnel Guide, and discussed at information briefings for line managers. These mechanisms will be institutionalized and disseminated to all offices for use to ensure future funding actions do not adversely affect technical capabilities represented by these positions.

In conjunction with applying the standardized mechanisms to Facility Representative positions, the Department's senior line managers will review their organizational structure to identify other positions which possess critical technical capabilities. This list of critical technical positions will be provided to the Federal Technical Capability Panel for its review. The Department's standardized mechanisms for retention of highly qualified technical personnel will be applied to these additional critical positions.

Over the long-term, the Department must resolve the issue of the lack of senior line management control over personnel retention activities. Only line management can identify those technical capabilities critical to ensuring continued safe operations of defense nuclear facilities. The identification of these capabilities and positions must be merged with retention activity planning, and then integrated with the overall staffing plans. Position descriptions must accurately reflect the full spectrum of minimum standards and requirements for full qualification within that position, and supervisors need a mechanism to hold employees accountable for performance.

Existing processes and regulatory authority are in place, but not generally used, to support various retention efforts within the Department. Fellowships, residencies, industry-exchange, and student stipend programs are authorized in accordance with regulatory provisions found in 5 C.F.R. Part 410 governing academic degree training to relieve recruitment or retention problems. More informal activities can include rotational assignments, on-the-job training, and continuing education opportunities. The Department is currently piloting a dual-career path initiative at the Richland Operations Office which provides a promotion path for highly skilled technical employees who do not choose supervision or management as their long-term career field of choice. Once sufficient time and experience has been invested in the pilot to adequately measure outcomes, the results will be evaluated and referred to the Federal Technical Capability Panel to consider expanding the initiative at other locations.

Employees who continuously exhibit sustained superior performance in identified technical positions can be considered for these types of retention activities as a means of cultivating and maintaining critical technical expertise within the Department. Once the line organizations have identified their critical technical capabilities and positions, managers can use the tools available to enhance retention of personnel in those key positions. These mechanisms will be incorporated into the handbook entitled "RECRUITING, HIRING, AND RETAINING HIGH QUALITY TECHNICAL STAFF; A Manager's Guide to Administrative Flexibilities." The Servicing Personnel Office, Headquarters Human Resources offices, or the Office of Personnel Management can provide support in implementing these programs as required.

As the Department's Field Offices undertake decommissioning and closure, a challenge arises to maintain critical technical competence during the final shutdown phases at the office; and, after closure, to retain and redeploy these employees to other offices in the Department. In the case of the Pinellas Plant, the Office of Defense Programs, Office of Environmental Management, and the Albuquerque Operations Office effectively managed this challenge by addressing employment issues in its Transition Plan. Key employees who agreed to stay on at Pinellas until shutdown was complete were then transferred to mutually agreeable assignments at other offices. Other Field Offices and Program Offices should address this retention issue when developing Transition Plans.

The desired outcome related to this initiative is a marked increase in line management's systematic planning and implementation of a variety of retention activities to increase the Department's overall success in maintaining technical capability.

Performance measures include:

• The number of technically qualified personnel retained in technical safety positions,
• The number of critical positions which are identified and adequately preserved against loss of expertise, and
• Usage rate of retention tools and mechanisms to cultivate and retain critical technical personnel.

DELIVERABLES/MILESTONES

APPENDIX A: Glossary of Terms

This glossary is intended to provide clarity to the Implementation Plan. It is recognized that some of the terms listed below may be defined in other ways. The definitions provided below reflect the meaning of the term as used in this Implementation Plan.

APPENDIX B: Summary of Commitments

APPENDIX C: Summary of Department Internal Management Actions

The Department Internal Management Actions describe the critical actions which support the commitments described in section 5 of this Implementation Plan. It is intended that these interim actions can be changed without formal revision to the Implementation Plan, and without the formal commitments being affected. The following actions are for informational purposes only and are included in the Implementation Plan as internal management actions: