(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.
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.