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United States Government Accountability Office: 
GAO: 

Report to Congressional Requesters: 

February 2012: 

Nuclear Weapons: 

NNSA Needs to Improve Guidance on Weapon Limitations and Planning for 
Its Stockpile Surveillance Program: 

GAO-12-188: 

GAO Highlights: 

Highlights of GAO-12-188, a report to congressional requesters. 

Why GAO Did This Study: 

Most weapons in the U.S. nuclear stockpile were produced over 20 years 
ago and are being sustained beyond original design lifetimes. It is 
critical to ensure that these weapons are safe, secure, and reliable 
to perform as the nation’s nuclear deterrent. The National Nuclear 
Security Administration (NNSA), a semiautonomous agency within the 
Department of Energy, is responsible for the nation’s nuclear weapons 
program. NNSA identifies nuclear weapon limitations—areas where 
military requirements may not be met—and conducts nonnuclear tests to 
evaluate the condition and reliability of weapons through its nuclear 
stockpile surveillance program. GAO was asked to determine the (1) 
number and types of such limitations and any concerns raised by 
Department of Defense (DOD) officials, and (2) actions NNSA has taken 
to implement its prior recommendations for the nuclear stockpile 
surveillance program. GAO reviewed agency documents, analyzed 
limitations, and interviewed key NNSA and DOD officials. 

What GAO Found: 

For the 52 NNSA identified limitations for all weapons in the U.S. 
nuclear stockpile, 86 percent fall into six types: detonation safety 
under abnormal conditions, weapon reliability, weapon delivery, more 
frequent replacement of limited life components, nuclear yield, and 
worker safety. Some DOD officials expressed concern over the impact 
that certain weapon limitations have on weapon operation, maintenance, 
and war planning. According to DOD officials, current DOD mitigation 
actions, as well as the successful completion of ongoing and planned 
NNSA efforts, should address most limitations for which the officials 
raised concerns. DOD officials stated that the current stockpile 
allows sufficient flexibility to mitigate limitations. However, they 
told GAO that there may be less flexibility in the future as the 
stockpile continues to age and decreases in size. For each weapon 
system, NNSA provides DOD with guidance containing additional 
information on nuclear weapon limitations. However, GAO found that 
this guidance does not cover all limitations and some DOD officials 
said that it may not provide them with relevant information for some 
limitations. Specifically, the guidance addresses approximately 60 
percent of all limitations but does not include limitations based on 
certain weapon components. In addition, one senior DOD official stated 
that the guidance did not help clarify the potential impact that a 
particular limitation may have on weapon operation and maintenance. 
The applicable military service is now conducting its own analysis of 
this limitation’s potential impact. Furthermore, the national 
laboratories identified four existing weapon limitations (8 percent of 
all limitations) that are no longer valid because, among other 
reasons, corrective action to address the limitations is complete. In 
addition, it is uncertain if an ongoing DOD and NNSA review of nuclear 
weapon military requirements will be used to eliminate limitations 
based on potentially outdated military requirements. 

NNSA has begun to implement some recommendations from the agency’s 
draft October 2010 management review of the nuclear stockpile 
surveillance program but has not developed a corrective action plan to 
guide its multiple actions. For example, NNSA (1) created and staffed 
the position of Senior Technical Advisor for Surveillance in response 
to the review’s recommendation to establish strong NNSA leadership and 
(2) established a formal process for setting surveillance testing 
requirements. National laboratory and DOD officials GAO interviewed 
generally viewed NNSA’s actions as positive steps to improve the 
program. However, NNSA has not developed a corrective action plan, as 
called for by Office of Management and Budget Circular No. A-123. 
According to this circular on management controls, federal managers 
are to develop a corrective action plan to address program operations 
weaknesses identified through management reviews, among other things. 
Such plans are to include specific dates, assigned responsibilities, 
and metrics to measure progress and hold management accountable. 
According to a senior level NNSA official, the agency did not 
implement many of the recommendations from three prior surveillance 
program management reviews primarily because there was no specific 
approach for implementation. Without a corrective action plan, it is 
unclear how NNSA will (1) ensure that the draft October 2010 
management review’s recommendations are fully implemented and (2) 
demonstrate to key stakeholders, such as Congress and DOD, that NNSA 
is committed to improving the surveillance program. 

What GAO Recommends: 

Among other things, GAO recommends that NNSA, in appropriate 
collaboration with DOD, expand guidance on weapon limitations to 
include all limitations, revise this guidance to clearly describe the 
limitations’ potential impacts, and develop a corrective action plan 
for implementing surveillance program recommendations. NNSA generally 
agreed with GAO’s recommendations and outlined planned actions to 
address them. DOD agreed with GAO’s recommendations. 

View [hyperlink, http://www.gao.gov/products/GAO-12-188]. For more 
information, contact Gene Aloise at (202) 512-3841 or aloisee@gao.gov. 

[End of section] 

Contents: 

Letter: 

Scope and Methodology: 

Background: 

Action Being Taken to Address Limitations of U.S. Nuclear Weapons: 

NNSA Has Not Developed a Corrective Action Plan to Improve the Nuclear 
Stockpile Surveillance Program: 

Conclusions: 

Recommendations for Executive Action: 

Agency Comments and Our Evaluation: 

Appendix I: Comments from the National Nuclear Security Administration: 

Appendix II: Comments from the Department of Defense: 

Appendix III: GAO Contact and Staff Acknowledgments: 

Tables: 

Table 1: Nuclear Weapons in the U.S. Stockpile, as of September 2011: 

Table 2: Types of Nuclear Weapon Limitations for all U.S. Nuclear 
Weapons: 

Figure: 

Figure 1: NNSA's Stockpile Surveillance Program: 

Abbreviations: 

CT: computed tomography: 

DOD: Department of Defense: 

DOE: Department of Energy: 

LANL: Los Alamos National Laboratory: 

LLNL: Lawrence Livermore National Laboratory: 

MAR: major assembly release: 

NNSA: National Nuclear Security Administration: 

OMB: Office of Management and Budget: 

RMI: Requirements Management Integration: 

SNL: Sandia National Laboratories: 

STRATCOM: U.S. Strategic Command: 

[End of section] 

United States Government Accountability Office: 
Washington, DC 20548: 

February 8, 2012: 

Congressional Requesters: 

Arms control agreements and other policies since the 1960s have led 
the United States to maintain nuclear deterrence with decreasing 
numbers of weapons. Most nuclear weapons currently in the stockpile 
were produced over 20 years ago and are being sustained beyond their 
original design lifetimes. Consequently, it is critical to ensure that 
the weapons in the nuclear stockpile are safe, secure, and reliable. 

The National Nuclear Security Administration (NNSA), a semiautonomous 
agency within the Department of Energy (DOE), is responsible for, 
among other things, the nation's nuclear weapons, nonproliferation, 
and naval reactors programs.[Footnote 1] NNSA manages the nuclear 
stockpile through the three national nuclear weapons design 
laboratories--Los Alamos National Laboratory (LANL), Lawrence 
Livermore National Laboratory (LLNL), and Sandia National Laboratories 
(SNL); four production plants--Pantex Plant in Texas, Y-12 National 
Security Complex in Tennessee, Savannah River Site in South Carolina, 
and Kansas City Plant in Missouri; and the Nevada National Security 
Site. 

The U.S. Strategic Command (STRATCOM), part of the Department of 
Defense (DOD), has primary responsibility for targeting nuclear 
weapons, preparing the U.S. strategic nuclear war plan, and, if 
ordered by the President, executing the war plan. The Nuclear Weapons 
Council, established by Congress in 1986, is a joint DOD/DOE 
organization that facilitates high-level coordination to secure, 
maintain, and sustain the nuclear stockpile.[Footnote 2] The Nuclear 
Weapons Council charters a Project Officers Group for each weapon 
system to provide a technical forum for weapon development and 
management activities.[Footnote 3] Each Project Officers Group is led 
by a lead project officer from either the Navy or Air Force; both the 
Navy and Air Force (referred to in this report as military service) 
maintain and operate nuclear weapons. 

Weapons are designed and produced to meet DOD's military requirements--
key operational, nuclear yield, and maintenance requirements--
throughout the Stockpile-to-Target Sequence, which is the range of 
physical environments that could be encountered as the weapon travels 
from stockpile storage to a potential target.[Footnote 4] The 
responsible national laboratories prepare a major assembly release 
(MAR) when they determine that a nuclear weapon is satisfactory for 
release to the military service. Among other things, the MAR contains 
a list of the weapon's limitations, which are areas where the weapon 
may not meet certain military requirements throughout the Stockpile-to-
Target Sequence. Limitations may specify additional conditions for 
storing, maintaining, or operating the weapon. 

According to NNSA and DOD officials, identifying limitations is 
important to stockpile management because it provides a mechanism for 
explicitly knowing where DOD requirements may not be met and suggests 
strategies to mitigate risk. Some limitations are unique to a 
particular weapon, and other limitations may occur in multiple 
weapons. NNSA periodically updates a weapon's MAR for a variety of 
reasons, including a completion of a weapon alteration or a life 
extension program (referred to in this report as activities). A weapon 
alteration is a material change regarding assembly, maintenance, or 
storage that does not alter the weapon's operational capability. A 
life extension program, which can take up to a decade to complete, is 
a refurbishment intended to extend the lifetime of a weapon for an 
additional 20 to 30 years. When NNSA updates a weapon's MAR, existing 
limitations may either remain unchanged or be deleted, and new 
limitations may be added. 

Since 1992, the United States has observed a moratorium on underground 
testing of nuclear weapons. In 1995, the President established an 
annual stockpile assessment and reporting requirement to help ensure 
that the nation's nuclear weapons remain safe and reliable without 
underground nuclear testing. Subsequently, Congress enacted the 
National Defense Authorization Act for Fiscal Year 2003, which 
requires that the directors of the national laboratories and the 
Commander of STRATCOM each complete an annual nuclear weapons 
stockpile assessment report.[Footnote 5] These reports cover, among 
other things, issues of particular concern about the nuclear stockpile 
as a whole, as well as issues of concern for individual weapons. 
[Footnote 6] 

Shortly after the moratorium on underground testing, Congress required 
DOE to establish the Stockpile Stewardship Program to increase 
understanding of the basic phenomena associated with nuclear weapons 
and provide better predictive understanding of the safety and 
reliability of weapons, among other things.[Footnote 7] One element of 
the Stockpile Stewardship Program is NNSA's Stockpile Evaluation 
Program (surveillance program).[Footnote 8] Under this program, NNSA 
conducts a variety of nonnuclear tests that evaluate the condition, 
safety, and reliability of stockpiled weapons. NNSA's surveillance 
program is a critical information source for overall knowledge of the 
stockpile, as well as the annual assessment process. In the last five 
annual assessment reports (fiscal years 2006 through 2010), directors 
of the national laboratories consistently expressed concerns with the 
surveillance program, both about the overall direction of the program 
and the limited number of surveillance tests being conducted. The 
STRATCOM Commander reported similar concerns in his 2009 and 2010 
annual assessment reports. Furthermore, in 2009, the JASON panel of 
scientific experts recommended that NNSA revise the surveillance 
program to meet immediate and future stockpile needs.[Footnote 9] In 
its report accompanying the Fiscal Year 2011 National Defense 
Authorization Act, the House Armed Services Committee (1) stated that 
surveillance is essential to stockpile stewardship and that inadequate 
surveillance would place the stockpile at risk and (2) directed NNSA 
to submit a report by October 1, 2010, to the congressional defense 
committees on its plans to address the 2009 JASON recommendation. 
[Footnote 10] 

Recognizing the need for a revised surveillance program in the post 
Cold War era, NNSA has conducted management reviews of the 
surveillance program in 2001, 2004, 2007, and 2010. The latest 
management review, issued in draft in October 2010 and not yet made 
final, found that NNSA did not implement the majority of prior 
recommendations to revise the program because NNSA (1) does not have a 
well-defined, documented process for executing the surveillance 
program; (2) changed leadership of the surveillance program at 
critical points in the implementation of early recommendations; and 
(3) did not develop a metric to ensure full implementation of any 
recommendation, which resulted in a continuing emphasis on reassessing 
the program. The draft 2010 review observed that many prior 
recommendations were still applicable today and provided additional 
recommendations, such as establishing strong federal leadership, 
implementing formal processes to guide program planning and execution, 
and establishing communication and information pathways. 

In this context, you asked us to review nuclear weapon limitations and 
the state of the surveillance program. Specifically, we examined the 
(1) number and types of identified weapon limitations and any concerns 
raised by DOD officials (Navy, Air Force, and STRATCOM); and (2) 
actions NNSA has taken to implement its prior recommendations for the 
nuclear stockpile surveillance program. 

Scope and Methodology: 

To determine the number and type of nuclear weapon limitations, we 
reviewed each weapon's current MAR and associated NNSA guidance. We 
then interviewed officials from NNSA and the national laboratories to 
obtain clarification on technically complicated limitations. NNSA and 
DOD do not group limitations into types or categories. However, in 
order to report unclassified weapon limitation information in this 
report, we developed categories for types of limitations based on the 
MAR information. Using content analysis methodology, two analysts 
independently assessed each limitation and coded it as a certain type 
of limitation.[Footnote 11] To determine DOD officials' concerns with 
the limitations' impact for nuclear weapon operations, maintenance, 
and war planning, we interviewed officials in the Office of the Deputy 
Assistant Secretary of Defense for Nuclear Matters, Navy and Air Force 
lead project officers from each weapon's Project Officer Group and 
interviewed and received briefings from officials in STRATCOM's Joint 
Functional Component Command For Global Strike, the entity responsible 
for preparing and maintaining the nation's nuclear war plan. In 
addition, we reviewed and analyzed the last five annual assessment 
reports (fiscal years 2006 to 2010) to determine what limitations the 
STRATCOM Commander reported. We also interviewed the current chairman 
of a technical advisory group who is responsible for completing the 
majority of the STRATCOM Commander's annual assessment report and 
reviewed prior GAO work on the annual assessment process.[Footnote 12] 
To determine what, if any, mitigation actions DOD and NNSA currently 
engage in or plan to complete to address nuclear weapon limitations, 
we reviewed NNSA guidance and interviewed NNSA, national laboratory, 
and DOD officials. To determine how NNSA manages and reports on 
nuclear weapon limitations, we reviewed (1) established procedures 
governing the MAR development and revision process, (2) NNSA guidance 
on nuclear weapon limitations, and (3) documents associated with an 
ongoing joint DOD/NNSA review of nuclear weapon military requirements. 
We compared the documents with the Standards for Internal Control in 
the Federal Government.[Footnote 13] To determine if certain nuclear 
weapon limitations were potentially no longer applicable, we compared 
limitations with the most current information related to corrective 
actions as well as the current applicability of military requirements, 
as reported by NNSA guidance on limitations and officials from NNSA, 
the national laboratories, and DOD. 

To determine the extent to which NNSA has taken actions to address its 
recommendations on its surveillance program, we reviewed NNSA's draft 
October 2010 management review and analyzed key NNSA documentation 
related to implementation efforts. This documentation includes a draft 
version of NNSA's surveillance program manual; charters establishing 
the roles and responsibilities for entities responsible for managing 
the program; draft project management tools; and newly established 
procedures for establishing, executing, and tracking surveillance 
testing requirements. In addition, we interviewed key NNSA personnel, 
including the acting senior technical advisor for surveillance, about 
NNSA's planned efforts to address its recommendations. We also 
compared NNSA's actions against the federal standards for addressing 
recommendations from management reviews contained in the Standards for 
Internal Control in the Federal Government and Office of Management 
and Budget (OMB) Circular No. A-123, Management's Responsibility for 
Internal Control.[Footnote 14] To determine the national laboratories' 
role in the surveillance program, we conducted site visits, toured 
select facilities used to conduct surveillance tests, interviewed 
officials, and received briefings from officials at LLNL and SNL. 
[Footnote 15] We requested and received information in writing from 
LANL. 

We conducted our work from October 2010 to February 2012 in accordance 
with generally accepted government auditing standards. Those standards 
require that we plan and perform the audit to obtain sufficient, 
appropriate evidence to provide a reasonable basis for our findings 
and conclusions based on our audit objectives. We believe that the 
evidence obtained provides a reasonable basis for our findings and 
conclusions based on our audit objectives. 

Background: 

NNSA's Office of Defense Programs is responsible for the manufacture, 
maintenance, refurbishment, surveillance, and dismantlement of nuclear 
weapons. Most modern nuclear weapons consist of three sets of 
components--a primary, a secondary, and a set of nonnuclear components 
enclosed in a case. When detonated, the primary and secondary 
components, which together are referred to as the weapon's "nuclear 
explosive package," produce the weapon's explosive force, or "yield." 
LANL, located in Los Alamos, New Mexico, and LLNL, located in 
Livermore, California, have design responsibility for the nuclear 
explosive package. SNL, located in Albuquerque, New Mexico, and 
Livermore, California, has design responsibility for nonnuclear 
components. Some nonnuclear components--collectively called "limited-
life components"--have shorter service lives than the weapon itself 
and, therefore, must be periodically replaced. The U.S. nuclear 
weapons stockpile consists of eight weapons systems. Table 1 shows the 
weapon systems in the U.S. nuclear stockpile, their dates of entry 
into the stockpile, and the laboratories and military services 
responsible for each system. 

Table 1: Nuclear Weapons in the U.S. Stockpile, as of September 2011: 

Warhead or bomb: B61-3/4/10; 
Description: Tactical bomb; 
Military service: Air Force; 
Laboratory: LANL, SNL; 
Date of entry into stockpile: 1979/1979/1990. 

Warhead or bomb: B61-7/11; 
Description: Strategic bomb; 
Military service: Air Force; 
Laboratory: LANL, SNL; 
Date of entry into stockpile: 1985/1996. 

Warhead or bomb: W76-0/1; 
Description: SLBM warhead[A]; 
Military service: Navy; 
Laboratory: LANL, SNL; 
Date of entry into stockpile: 1978/2008. 

Warhead or bomb: W78; 
Description: ICBM warhead[B]; 
Military service: Air Force; 
Laboratory: LANL, SNL; 
Date of entry into stockpile: 1979. 

Warhead or bomb: W80-0/1[C]; 
Description: Cruise missile warhead; 
Military service: Navy/Air Force; 
Laboratory: LLNL, SNL; 
Date of entry into stockpile: 1984/1982. 

Warhead or bomb: B83-1; 
Description: Strategic bomb; 
Military service: Air Force; 
Laboratory: LLNL, SNL; 
Date of entry into stockpile: 1993. 

Warhead or bomb: W87; 
Description: ICBM warhead; 
Military service: Air Force; 
Laboratory: LLNL, SNL; 
Date of entry into stockpile: 1986. 

Warhead or bomb: W88; 
Description: SLBM warhead; 
Military service: Navy; 
Laboratory: LANL, SNL; 
Date of entry into stockpile: 1989. 

Source: NNSA. 

[A] Submarine-launched ballistic missile. 

[B] Intercontinental ballistic missile. 

[C] The Department of Defense concluded in 2010 that the Navy's W80-0 
serves a redundant purpose and should be retired. 

[End of table] 

In February 2007, we reported on the process that DOD and DOE have 
established for fulfilling the annual assessment of the safety, 
performance, and reliability of the nation's nuclear stockpile. 
[Footnote 16] We found that (1) the STRATCOM Commander's annual 
assessment of the nuclear stockpile is based primarily on the advice 
of a technical advisory group and provides an operational perspective; 
(2) the technical advisory group holds an annual conference where each 
entity involved in managing the stockpile--national laboratories, 
Project Officer Groups, NNSA, and DOD--present briefings to provide a 
complete perspective on the various issues affecting the stockpile; 
and (3) the laboratory director's annual assessment is derived 
primarily from ongoing activities associated with NNSA's Stockpile 
Stewardship Program, such as the results of weapon system and 
component level tests conducted by NNSA's stockpile surveillance 
program as well as data that provides an assessment of a weapon's 
current reliability. 

NNSA's stockpile surveillance program comprises the Core Surveillance 
Program and the Enhanced Surveillance Campaign, which are funded 
separately. Under the Core Surveillance Program, the national 
laboratories and production plants evaluate weapons and weapon 
components for the attributes of function, condition, material 
properties, and chemical composition through the following: 

* System-Level Laboratory Testing. For such tests, units from each 
stockpiled weapon are chosen annually, either randomly or 
specifically, and sent to the Pantex Plant for disassembly, 
inspection, reconfiguration, and testing by the national laboratories. 

* System-Level Flight Testing. These tests drop or launch a weapon 
with its nuclear material removed. NNSA coordinates flight testing 
with DOD, which is responsible for providing the military assets 
(e.g., aircraft and missiles) needed to drop or launch a weapon. 

* Component and Material Testing. These tests are conducted on nuclear 
and nonnuclear components and materials by both the national 
laboratories and the production plants that manufactured them. 
[Footnote 17] 

The mission of the Enhanced Surveillance Campaign--a research and 
development effort initiated in 1998--is to provide tools for 
assessing weapon aging by characterizing aging trends, develop 
predictive aging models, and develop new diagnostic 
capabilities.[Footnote 18] When the diagnostics developed by the 
Enhanced Surveillance Campaign reach maturity, they can be 
incorporated into the Core Surveillance Program's component and 
material tests. For example, in fiscal year 2009, the Enhanced 
Surveillance Campaign developed a high-resolution computed tomography 
(CT) image analysis tool for a particular nuclear component, which 
NNSA officials said they believe will enhance its ability to identify 
potential defects or anomalies. NNSA plans to conduct approximately 30 
of these CT component tests in fiscal year 2012 under Core 
Surveillance, according to planning documents. Figure 1 shows the 
interrelationships among the segments of NNSA's Stockpile Surveillance 
Program. 

Figure 1: NNSA's Stockpile Surveillance Program: 

[Refer to PDF for image: illustration] 

NNSA's Stockpile Surveillance Program: 

Research and development: 
Among other things, the Enhanced Surveillance Campaign develops new 
diagnostics that can be incorporated into component and material 
tests.  

Evaluation of weapon and weapon components: 
The Core Surveillance Program conducts system-level laboratory tests, 
system-level flight tests, and component and material tests. 
Source: GAO analysis of NNSA data. 

Source: GAO analysis of NNSA data. 

[End of figure] 

Action Being Taken to Address Limitations of U.S. Nuclear Weapons: 

For all U.S. nuclear weapons in the current nuclear stockpile, NNSA 
identified 52 weapon limitations, and of these, the majority fall into 
six types. DOD officials told us that a few limitations are a concern 
due to the potential impact on DOD weapon operation, maintenance, and 
war planning, but these officials also said that current and planned 
mitigation actions generally address their concerns with weapon 
limitations. We found that NNSA guidance to DOD on some limitations 
contains incomplete information, and DOD officials told us that the 
way NNSA communicates the potential impact of limitations on nuclear 
weapon operation, maintenance, and war planning is sometimes unclear. 
Furthermore, the national laboratories identified four existing weapon 
limitations (8 percent of all limitations) that are no longer valid--
because, among other things, corrective action to address the 
limitation is complete--while some limitations will remain in effect 
until DOD changes potentially outdated military requirements. 

Types of Limitations, DOD Concerns, and Mitigation Actions: 

We characterized the 52 limitations that NNSA identified for all U.S. 
nuclear weapons into 10 types of limitations based on our analysis of 
each weapon's MAR and associated guidance documents as well as through 
interviews with officials from NNSA, the national laboratories, and 
DOD. Eighty-six percent of these limitations fall into 6 types: 
detonation safety under abnormal conditions, weapon reliability, 
weapon delivery, more frequent replacement of limited life components, 
nuclear yield, and worker safety. According to DOD officials, a large 
majority of these weapon limitations do not impact DOD nuclear weapon 
operation, maintenance, and war planning activities. However, some DOD 
officials expressed concerns to us over the impact of a few weapon 
limitations, such as increased maintenance costs or additional issues 
to consider when developing war plans. For most limitations about 
which they raised concerns, DOD officials told us that current DOD 
mitigation actions, as well as the successful completion of ongoing 
and planned NNSA efforts, should address these concerns. DOD officials 
stated that the current stockpile allows sufficient flexibility to 
mitigate limitations. However, they told us there may be less 
flexibility in the future as the stockpile continues to age and 
decreases in size. Moreover, officials at one national laboratory told 
us that a smaller stockpile may not be able to support required 
mitigation actions if additional limitations, especially those that 
result in large decreases to weapon reliability, are identified in the 
future. The 2010 Nuclear Posture Review states that the United States 
is currently considering future stockpile reductions that would be 
based on a variety of factors, including the continuing implementation 
of NNSA's Stockpile Stewardship Program.[Footnote 19] Table 2 and the 
following discussion relates to the type of nuclear weapon limitations 
and the percentage of those limitations by type. 

Table 2: Types of Nuclear Weapon Limitations for all U.S. Nuclear 
Weapons: 

Type of nuclear weapon limitations: Detonation safety under abnormal 
conditions; Percentage of the 52 limitations for all U.S. nuclear 
weapons: 25%. 

Type of nuclear weapon limitations: Weapon reliability; 
Percentage of the 52 limitations for all U.S. nuclear weapons: 13%. 

Type of nuclear weapon limitations: Weapon delivery; 
Percentage of the 52 limitations for all U.S. nuclear weapons: 12%. 

Type of nuclear weapon limitations: More frequent replacement of 
limited life components; 
Percentage of the 52 limitations for all U.S. nuclear weapons: 12%. 

Type of nuclear weapon limitations: Nuclear yield; 
Percentage of the 52 limitations for all U.S. nuclear weapons: 12%. 

Type of nuclear weapon limitations: Worker safety; 
Percentage of the 52 limitations for all U.S. nuclear weapons: 12%. 

Type of nuclear weapon limitations: Weight; 
Percentage of the 52 limitations for all U.S. nuclear weapons: 6%. 

Type of nuclear weapon limitations: Transportation; 
Percentage of the 52 limitations for all U.S. nuclear weapons: 4%. 

Type of nuclear weapon limitations: Weapon testing unable to duplicate 
an Stockpile-to-Target Sequence environment; 
Percentage of the 52 limitations for all U.S. nuclear weapons: 4%. 

Type of nuclear weapon limitations: Reliability of use control system 
component[A]; 
Percentage of the 52 limitations for all U.S. nuclear weapons: 2%. 

Source: GAO analysis of NNSA's MAR documents. 

Notes: Percentage does not equal 100 due to rounding. 

[A] A use control system is a combination of design features, 
operational procedures, and other controls intended to allow 
authorized use and prevent unauthorized use of nuclear weapons. 

[End of table] 

* Detonation safety under abnormal conditions. Thirteen limitations--
25 percent of all nuclear weapon limitations--are associated with 
detonation safety under abnormal conditions (i.e., conditions not 
expected to occur during nuclear explosive operations and associated 
activities). DOD officials did not raise concerns with any limitations 
of this type. As established by DOD, the probability of a nuclear 
detonation must not exceed 1 in a million per exposure to abnormal 
conditions (i.e., detonation safety standard for abnormal conditions). 
NNSA has issued a safety limitation for each weapon concerning 
potential exposure to a certain combination of abnormal conditions. 
DOD officials told us that these safety limitations are not a concern, 
provided that established procedures are followed, because of the 
extremely low probability of a weapon's exposure to the abnormal 
conditions.[Footnote 20] Specifically, both the Air Force and Navy 
have established procedures and restrictions for storing, handling, 
and transporting a nuclear weapon to minimize, among other things, the 
potential that weapons are exposed to any abnormal conditions. In 
addition, there is another limitation, common across multiple weapons, 
concerning a weapon's high explosives being exposed to abnormal 
conditions. DOD officials told us that this limitation is not a 
concern and that there is a very low probability that a weapon would 
encounter the abnormal conditions. Furthermore, they said that there 
is infinite combination of possibilities for the specified abnormal 
conditions. As such, it is very difficult for NNSA to produce 
computational models that can verify DOD's detonation safety standard 
is met for each possibility.[Footnote 21] 

* Weapon reliability. Seven limitations--13 percent of all nuclear 
weapon limitations--are associated with weapon reliability.[Footnote 
22] DOD officials did not raise concerns with five weapon limitations 
of this type but did raise concerns with two specific weapon 
reliability limitations. DOD officials told us that one limitation 
could potentially impact DOD operations; however, no mitigation 
actions have been developed because the applicable military service 
and the national laboratories are still trying to understand the 
technical issues behind the limitation. DOD officials told us that 
another limitation, associated with a particular weapon system, could 
potentially impact war planning or operations, and the STRATCOM 
Commander stated in two recent annual assessments reports that he had 
concerns with this particular reliability limitation.[Footnote 23] DOD 
officials told us that both short-term and long-term mitigation 
actions address this limitation. Specifically, STRATCOM revised its 
planning to include actions that can increase the reliability of a key 
weapon component and thus increase the weapon's overall reliability. 
However, STRATCOM officials told us that these mitigation actions 
impact operational flexibility. According to these officials, NNSA's 
planned activities for this weapon, when completed, will address the 
reliability limitation, among other things. In the most recent annual 
assessment, the Commander wrote that NNSA's planned activities to 
address this limitation, among other things, faces schedule 
constraints and will likely require additional resources. 

* Weapon delivery. Six limitations--12 percent of all nuclear weapon 
limitations--relate to the delivery of a weapon to its intended 
target. DOD officials did not raise concerns with four weapon 
limitations of this type, and they told us that mitigation actions 
have addressed their concerns with potential impacts to DOD operation, 
maintenance, and war planning activities for two specific weapon 
delivery limitations. Specifically, one limitation states that a 
weapon may not perform as designed if delivered in a particular mode. 
STRATCOM officials told us that they no longer plan to deliver the 
weapon in that mode but would instead use an alternate delivery mode 
that can produce similar weapon effects. The second limitation states 
that a weapon no longer met what DOD officials described to us as a 
key weapon delivery requirement. STRATCOM officials told us that joint 
actions between the applicable military service and STRATCOM mitigate 
their concerns with this limitation, though at higher weapons 
maintenance and management costs. 

* More frequent replacement of limited life components. Six 
limitations--12 percent of all nuclear weapon limitations--are 
associated with the more frequent replacement of components that have 
a shorter service life than the weapon itself. DOD officials did not 
raise concerns with two weapon limitations of this type but did raise 
concerns with four specific limited life components replacement 
limitations. According to DOD officials, these four limitations 
significantly increase the military's maintenance burdens or costs for 
the affected weapons. For example, a military service lead project 
officer told us that each replacement activity imposes a substantial 
cost--in labor, equipment operation, and security risks--and that more-
frequent replacement activities further increase these already 
substantial costs. This lead project officer said that, within the 
next few years, NNSA plans activities that, when complete, will meet 
the replacement interval established by DOD. Furthermore, another 
military service lead project officer told us that more-frequent 
replacement complicates the coordination of maintenance schedules and 
stated that NNSA has not planned any actions to address this 
limitation because of expected changes to the nuclear force structure. 

* Nuclear yield. Six limitations--12 percent of all nuclear weapon 
limitations--concern a weapon's capability to produce the desired 
nuclear yield. DOD officials did not raise concerns with five weapon 
limitations for this type, and they told us that mitigation actions 
have addressed their concerns with potential impacts to war planning 
for one specific nuclear yield limitation. DOD officials said that 
most of the nuclear yield limitations reflect negligible differences 
from the yield requirements specified by DOD and do not affect war 
planning because of improved accuracy in delivering weapons to 
potential targets. However, DOD officials told us that one of these 
limitations, associated with a single weapon system, could affect DOD 
war planning but that the impact is mitigated in the short term by 
having the military service conduct more-frequent maintenance on the 
weapon. NNSA is also planning activities that, if successful, would 
address the limitation. 

* Worker safety. Six limitations--12 percent of all nuclear weapon 
limitations--concern workers' personal safety when conducting weapon 
operation and maintenance activities. DOD officials did not raise 
concerns with any limitations of this type. Specifically, these 
officials said that some of these limitations would be encountered if 
a low-probability event with multiple abnormal conditions occurred 
together and that some of these limitations have been addressed by 
established procedures for maintenance activities. For example, 
maintenance technicians working on a certain weapon are to follow 
procedures designed to limit the amount of energy present in the 
maintenance bay. 

* Weight. Three limitations--6 percent of all nuclear weapon 
limitations--concern a weapon's actual weight being greater than the 
weight specified by DOD. DOD officials did not raise concerns with any 
limitations of this type. These limitations are applicable to three 
weapon systems. DOD officials said that these limitations were present 
when the weapons were first produced. 

* Transportation. Two limitations--4 percent of all nuclear weapon 
limitations--relate to how a weapon can be transported. DOD officials 
did not raise concerns with any limitations of this type and said that 
NNSA has already addressed one of these limitations. Specifically, 
NNSA has developed a specialized transportation adaptor that enables 
transportation of the weapon in a manner consistent with DOD military 
requirements. 

* Weapon testing unable to duplicate a Stockpile-to-Target Sequence 
environment. Two limitations--4 percent of all nuclear weapon 
limitations--are associated with the inability of a single weapon 
system's testing program to duplicate two environments that the weapon 
could encounter as it travels from the stockpile to a possible target. 
DOD officials did not raise concerns with these two specific 
limitations and said that NNSA now believes that the agency can 
duplicate one of the specified environments. NNSA plans to conduct a 
computational simulation and analysis of this specified environment 
during fiscal year 2012. 

* Reliability of use control system components. One limitation--2 
percent of all nuclear weapon limitations--is associated with the 
reliability of use control system components. DOD officials did not 
raise any concerns with this type of limitation because of changes in 
operational plans. 

NNSA Guidance to DOD on the Potential Impact of Weapon Limitations Is 
Not Complete and Consistently Clear: 

Through Sandia National Laboratories, NNSA provides DOD guidance 
containing additional information on nuclear weapon limitations for 
each weapon. However, we found that this guidance does not cover all 
current limitations, and DOD officials said that it may not provide 
them with relevant information for some limitations. DOD officials 
told us that nuclear weapon limitations--which are primarily reported 
to DOD when NNSA issues or revises a weapon's MAR--can be statements 
that, in some instances, contain highly technical information and 
vague wording and may not clearly communicate a limitation's potential 
impact on stockpile operation, maintenance, and war planning. As 
stated previously, most modern nuclear weapons consist of the nuclear 
explosive package and nonnuclear components enclosed in a case. In 
general, limitations arise due to issues associated with either a 
weapon's nuclear components or nonnuclear components. For limitations 
that involve components for which Sandia National Laboratories has 
design responsibility (i.e., nonnuclear components), the guidance 
lists each limitation as written in the MAR; usually provides 
additional technical information about the limitation's cause, scope 
and impact; and lists a recommended mitigation action.[Footnote 24] 
The guidance includes information on 29 limitations--about three-
fifths of all current limitations. However, the guidance does not 
provide information for limitations that are associated with a 
weapon's nuclear explosive package. The guidance states that these 
limitations are for the two national laboratories with design 
responsibility for nuclear components to address, but neither NNSA nor 
its two laboratories (Los Alamos National Laboratory and Lawrence 
Livermore National Laboratory) provide DOD with such guidance on 
nuclear weapon limitations. 

GAO's Standards for Internal Control in the Federal Government states 
that management should comprehensively identify risks from both 
external and internal sources and that once risks have been 
identified, management should decide what actions should be taken to 
manage them.[Footnote 25] As stated previously, nuclear weapon 
limitations identify areas where DOD's military requirements may not 
be met. Potentially unmet DOD military requirements could present 
risks to nuclear weapon operation, maintenance, and war planning and 
require mitigation actions. It is critical that NNSA's guidance to DOD 
on nuclear weapon limitations identify all existing limitations to 
help ensure that risks are comprehensively identified and management 
has the information needed to determine what, if any, actions are 
needed to manage weapon limitations. 

In addition, NNSA's guidance on nuclear weapon limitations may not 
always provide DOD with sufficiently relevant information about the 
potential impact some nuclear weapon limitations may have on stockpile 
operation, maintenance, and war planning. For example, one military 
service lead project officer said that his efforts to clarify the 
impact that a particular limitation may have on weapon reliability 
with officials at a national laboratory were inconclusive and that the 
military service is now conducting its own analysis. For this 
particular limitation, NNSA's guidance provides little additional 
technical information and concludes that the weapon may not operate as 
required in a particular delivery mode, and the recommended mitigation 
action is to have laboratory staff brief STRATCOM war planners. 
Acknowledging that the guidance is relatively new, the military 
service lead project officer told us that the document is not very 
helpful in explaining this limitation's potential operational impact 
and that discussing a limitation in terms of military requirements and 
Stockpile-to-Target Sequence would be more helpful. GAO's Standards 
for Internal Control in the Federal Government states that information 
should be recorded and communicated to management and others within an 
entity in a form and within a time frame that enables them to carry 
out their responsibilities.[Footnote 26] Since military service lead 
project officers are senior managers responsible for a weapon's 
development and management activities, it is critical that NNSA's 
guidance provides information in a form that allows them to fully 
understand the potential impacts limitations have on nuclear weapon 
operations, maintenance, and war planning to determine what, if any, 
actions are needed to manage weapon limitations. 

The National Laboratories Identified Some Limitations That Are No 
Longer Valid, While Other Limitations Will Remain Valid until DOD 
Changes Military Requirements: 

The national laboratories identified 4 (8 percent) of the 52 current 
nuclear weapon limitations--affecting four weapons--as no longer valid 
and should be removed when NNSA revises the weapons' MAR.[Footnote 27] 
The national laboratories concluded that these 4 weapon limitations 
could be removed from the list of limitations contained in a weapon's 
MAR for various reasons, including that corrective action to address 
the limitation has been completed, that there is no military 
requirement, and that the replacement interval for limited life 
components currently meets and has always met military requirements. 
DOD and NNSA officials told us that if NNSA cannot prove that a weapon 
meets military requirements, a limitation must be listed for that 
weapon. Our review found and some DOD officials we spoke with said 
that certain military requirements for nuclear weapons that were 
applicable during the Cold War may not be applicable given the 
structure and role of today's nuclear stockpile. In addition, some DOD 
officials we spoke with said that the department can be reluctant to 
modify a weapon's established military requirements because there is 
little documentation or transparency about why some military 
requirements exist and that this issue is especially applicable to 
weapons that were designed to be delivered from multiple military 
assets. These officials said that DOD does not want to delete a 
requirement unless there is sufficient evidence for why it was 
established and it is clear that the basis for that requirement is no 
longer applicable. 

DOD and NNSA are currently jointly reviewing and considering changing 
DOD's nuclear weapon requirements to help align NNSA infrastructure 
planning with deterrent planning, according to documentation from the 
Nuclear Weapons Council. The findings of this joint review could also 
be used to ensure that limitations reflect the most current and 
accurate information. For example, one weapon delivery limitation that 
DOD officials did not raise concerns with could be eliminated if 
military requirements are updated because there is sufficient 
specificity as to the origin of that requirement to conclude that it 
is no longer applicable to today's current and planned nuclear force 
structure, according to STRATCOM officials. However, the joint DOD and 
NNSA requirements review does not have a specific completion date, and 
it is uncertain if the review's findings will be used to update 
limitations based on potentially outdated military requirements and, 
thereby, ensure a relevant and reliable counting of nuclear weapon 
limitations. 

NNSA Has Not Developed a Corrective Action Plan to Improve the Nuclear 
Stockpile Surveillance Program: 

NNSA has begun to implement some of the recommendations from its draft 
October 2010 management review of the nuclear stockpile surveillance 
program, but NNSA has not developed a formal corrective action plan to 
guide its multiple actions. The draft October 2010 review, conducted 
jointly by NNSA and the three national laboratories, makes multiple 
recommendations to NNSA to address a number of weaknesses in the 
surveillance program, such as the lack of federal leadership in 
program management and the absence of formal, documented processes for 
surveillance planning and management. Actions NNSA has taken to 
implement the recommendations include the following: 

* The creation of a Senior Technical Advisor for Surveillance (senior 
advisor) position. This position was created in response to the 
review's recommendation to establish strong NNSA leadership for the 
surveillance program. According to the official position description, 
the senior advisor is to serve as the agency's lead official for 
surveillance execution and integration and is responsible for 
providing direction and oversight to major surveillance modernization 
efforts. The senior advisor reports directly to the senior NNSA 
official responsible for overseeing stockpile activities related to 
research, development, design, and production.[Footnote 28] NNSA 
designated an acting senior advisor in October 2010 and hired a 
permanent senior advisor in July 2011. According to NNSA officials, 
the senior advisor has brought leadership to the surveillance program. 
For example, when a dispute between national laboratory and production 
plant officials on the appropriate safety standards for handling a 
toxic chemical caused a backlog of a key component test, the acting 
senior advisor was able to mediate this dispute, and the component 
testing was resumed. 

* Establishment of a formal requirements-setting process. NNSA 
formalized the process for having the national laboratories submit 
surveillance testing requirements and having NNSA's production plants 
evaluate the requirements. The process is being applied to 
surveillance testing requirements for fiscal years 2012 through 2017. 
Specifically, the national laboratories determine surveillance testing 
requirements; production plants review these requirements for 
technical feasibility and resource availability; and a new committee 
adjudicates unresolved conflicts in priorities. Previously, NNSA had 
set surveillance testing requirements informally and on an annual 
basis. National laboratories and production plant officials said that 
informal planning created problems in executing surveillance tests 
because, among other reasons, they did not have sufficient time to 
schedule tests around other stockpile work--such as life extension 
programs--that used the same personnel and equipment. 

* A new surveillance governance structure. This structure is intended 
to promote integrated planning and prioritization as recommended by 
the management review. Elements of the new structure include the 
Surveillance Integrated Requirements Working Group (requirements 
group) and the Surveillance Enterprise Steering Committee (steering 
committee). Established in July 2011, the requirements group resolves 
mismatches between surveillance testing requirements and financial, 
human, and material resources. Specifically, this group examines 
surveillance testing requirements and assesses the impact of 
uncompleted tests. Established in May 2011, the steering committee is 
the highest-level organization in NNSA solely responsible for 
surveillance; the steering committee approves surveillance testing 
requirements and will resolve disputes between the national 
laboratories and the production plants that are not resolved by the 
requirements group. 

* Management of the requirements process through a centralized 
database called the Quality Evaluation Requirements Tracking System. 
In line with the review's recommendation regarding critical 
communication and information pathways, NNSA will require each entity 
in the Core Surveillance process to use this system to input, access, 
or manage surveillance data. For example, within this system, the 
laboratories will issue surveillance testing requirements, and the 
plants will track progress and document completion of tests. NNSA will 
use the data in this system as a basis for the formal performance 
measures the agency uses to hold the national laboratories and 
production plants accountable for the execution of surveillance 
activities. 

* Codification of surveillance governance and processes. Codification 
supports the review's recommendation to implement a disciplined and 
integrated management process, with clear roles and responsibilities. 
NNSA is codifying surveillance governance and processes in section 5 
of the Requirements Management Integration (RMI) manual.[Footnote 29] 
When completed, this manual will include the charters for key entities 
in the newly established surveillance governance structure and clear 
delineation of roles and responsibilities, according to NNSA 
officials. The manual will also include at least 12 guidance documents 
to serve as project management tools. For example, one such document 
codifies the process for investigating anomalies identified through 
surveillance activities; another addresses the process for adjusting 
surveillance schedules or plans. The guidance documents are all 
currently in draft, with completion expected by the end of September 
2012, according to NNSA surveillance program planning documents. The 
2010 management review cited the critical need for clear roles and 
responsibilities for all individuals and committees throughout the 
surveillance enterprise; it found that the number of committees with 
undefined or poorly defined roles and responsibilities, combined with 
inadequate documentation, clearly contributed to NNSA's past 
difficulties in modernizing the surveillance program. 

* Better Integration of Core and Enhanced Surveillance. As of August 
2011, NNSA charged the managers of the Core Surveillance Program and 
the Enhanced Surveillance Campaign with defining integration points 
between them. NNSA also began developing an RMI guidance document 
detailing how the Enhanced Surveillance Campaign should develop new 
diagnostic tools. The 2010 review found that NNSA lacked a clearly 
defined interface between the Core Surveillance Program and Enhanced 
Surveillance Campaign and that the lack of a documented process for 
promoting integration, among other things, has resulted in the 
underutilization of Enhanced Surveillance Campaign capabilities in the 
Core Surveillance Program's testing activities. In June 2011, the 
acting senior advisor told us that integration between Core and 
Enhanced Surveillance is central to the surveillance program's future 
and that increased integration presents a management challenge. Two of 
the surveillance program's objectives are to detect precursors of 
aging weapon components sufficiently early for corrective action in 
existing weapons and to ensure any defects are not repeated in life 
extension programs. According to NNSA officials, these objectives 
depend on the continued development of Enhanced Surveillance Campaign 
technologies that are then used to improve the number and scope of the 
Core Surveillance Program's component and material tests. 

National laboratory and DOD officials we spoke with generally viewed 
NNSA's current and planned actions to improve the surveillance program 
as positive developments. However, these actions are not guided by a 
formal corrective action plan. According to an OMB circular that 
defines management's responsibility for internal control in federal 
agencies, federal managers are to develop a corrective action plan to 
address weaknesses found in program operations, as identified through 
management reviews, inspector general and GAO reports, program 
evaluations, and financial statement audits.[Footnote 30] Corrective 
action plans are to include specific dates, assigned responsibilities, 
and metrics to measure progress to resolve the findings of audits and 
reviews. The circular also states that agencies should periodically 
assess and report on the progress of those plans. Furthermore, under 
the Standards for Internal Control in the Federal Government, federal 
managers are to take steps to ensure that the findings of audits and 
other reviews are promptly resolved by completing, within established 
time frames, all actions that correct or otherwise resolve the matters 
brought to management's attention.[Footnote 31] A corrective action 
plan would provide a framework for such time frames, as well as a 
mechanism for holding management accountable for meeting the time 
frames. According to the acting senior advisor, NNSA did not address 
many of the findings and recommendations in its three previous 
surveillance program management reviews primarily because the agency 
did not have a specific approach for implementation. This statement 
echoes the 2010 draft management review finding that the prior 
reviews' recommendations were not implemented because, among other 
reasons, NNSA did not have a well-defined, documented process for 
executing the surveillance program. In May 2011, more than 6 months 
after NNSA issued its draft October 2010 management review, the acting 
senior advisor directed the steering committee to establish a working 
group to develop a plan to implement the review's recommendations, but 
both the scope and time frame of this plan remain uncertain. In the 
interim, NNSA officials have requested reports on individual actions 
taken to implement the review's recommendations but not on the 
agencywide effort to implement these recommendations. Without such a 
plan, it is unclear how NNSA will (1) ensure that the draft review's 
recommendations are fully implemented and (2) demonstrate to key 
stakeholders, such as Congress and DOD, that NNSA is committed to 
improving the surveillance program. 

Conclusions: 

It is critical that U.S. nuclear capability continues to reassure our 
allies and deter potential adversaries. With most weapons currently in 
the stockpile having been produced over 20 years ago and being 
sustained beyond their original design lifetimes, it is a testament to 
NNSA, the national laboratories, and the production plants that DOD 
officials were confident that nuclear weapon limitations do not 
currently reduce the effectiveness of the nation's strategic 
deterrent. However, several factors raise concerns with the 
limitations and NNSA's management of them. First, some limitations 
require mitigation actions, which can impose logistical burdens, 
increased security risks, and war planning restrictions on the Air 
Force, Navy, and STRATCOM. DOD officials said they would have less 
flexibility in mitigating limitations in the future should the 
stockpile's size be reduced as future arms control agreements are 
pursued. Second, NNSA guidance on limitations does not always clearly 
communicate to DOD the potential impacts that limitations have on 
nuclear weapon operations, maintenance, and war planning and does not 
include all identified limitations; it is uncertain if the risks 
associated with limitations are comprehensively identified and 
analyzed. Third, NNSA's current list of nuclear weapon limitations may 
not reflect the most up-to-date information, and the joint DOD and 
NNSA military requirements review may not contain enough specificity 
to ensure a relevant and reliable count of limitations. 

The stockpile surveillance program provides critical data that informs 
stockpile decisions. A smaller, aging stockpile calls for increasingly 
complex and time-sensitive data. NNSA's multiple actions taken in 
response to recommendations in its draft 2010 surveillance program 
management review demonstrate the agency's commitment to improving the 
program. NNSA is planning to fully address the findings and implement 
the recommendations contained in its draft review. However, it is 
unclear how or if NNSA will do so because the agency has not developed 
a comprehensive corrective action plan in accordance with OMB Circular 
No. A-123 that details actions that agency personnel must take to 
implement the recommendations with specific dates, assigned 
responsibilities, and metrics to measure progress of this 
implementation. Completion of such a plan would provide the agency 
with a reasonable basis for ensuring that recommendations are fully 
implemented. Without such a plan, NNSA is in danger of not 
implementing many of the draft review's recommendations, as it failed 
to do in its three previous surveillance program management reviews. 
For example, previous delays in integrating Core and Enhanced 
Surveillance have been attributed, in part, to a lack of a documented 
process. Furthermore, the successful development and completion of a 
comprehensive corrective action plan would demonstrate to key 
congressional and DOD stakeholders NNSA's commitment to improving the 
surveillance program. Without such a plan, it is unclear how NNSA will 
provide itself and key stakeholders with these assurances. 

Recommendations for Executive Action: 

To improve the processes used to test and report on the nation's 
nuclear weapons stockpile, we are making four recommendations to the 
Secretaries of Defense and of Energy and the Administrator of the 
National Nuclear Security Administration, as appropriate: 

* To improve the clarity of information NNSA provides to DOD about 
nuclear weapon limitations, we recommend that the Secretary of Energy 
and the Administrator of the National Nuclear Security Administration, 
in coordination with the Secretary of Defense, (1) expand the guidance 
provided by NNSA to DOD so that it includes each existing limitation 
and (2) assess, and revise as appropriate, the guidance provided by 
NNSA to DOD to ensure it clearly describes the potential impacts that 
each limitation may have on nuclear weapon operations, maintenance, 
and war planning. 

* To improve the reliability and relevance of information associated 
with limitations, we recommend that the Secretary of Energy and the 
Administrator of the National Nuclear Security Administration, in 
coordination with the Secretary of Defense, determine if the findings 
of the joint DOD and NNSA military requirements review can be used to 
eliminate certain limitations. 

* To increase confidence in NNSA's ability to fully address all 
findings and recommendations from its draft surveillance management 
review, we recommend that the Secretary of Energy and the 
Administrator of the National Nuclear Security Administration prepare 
and complete a comprehensive corrective action plan in accordance with 
OMB Circular No. A-123. This plan should identify the detailed actions 
that agency personnel must take to fully implement the recommendations 
in the review and include specific dates, assigned responsibilities, 
and metrics to measure progress of this implementation. This 
corrective action plan should also address how to better integrate 
Core and Enhanced Surveillance. 

Agency Comments and Our Evaluation: 

We provided NNSA and DOD with a draft of this report for their review 
and comment. In its written comments, NNSA said that GAO did a 
commendable job in reviewing a highly complex and technical area. NNSA 
agreed with two of the four recommendations and "agreed in principle" 
with the other two recommendations. NNSA also outlined the actions 
that it plans to take to address all four of the report's 
recommendations. The complete text of NNSA's comments is presented in 
appendix I. NNSA also provided technical clarifications, which we 
incorporated into the report as appropriate. 

For two of the recommendations, NNSA stated that the Assistant Deputy 
Administrator for Stockpile Management will oversee the development 
and execution of a corrective action plan for the nuclear stockpile 
surveillance program and ensure that the findings of the joint DOD and 
NNSA military requirements review be appropriately implemented. NNSA 
agreed in principle with the other two recommendations aimed at 
clarifying the information NNSA provides to DOD on nuclear weapon 
limitations. NNSA stated that it agrees with the desired outcome of 
these two recommendations, but NNSA concluded that a key procedural 
weakness in the process used to report on weapon limitations is the 
absence of a document that formally communicates DOD's position on 
limitations. NNSA said that it will ask the Nuclear Weapons Council to 
require that military service lead project officers provide NNSA with 
a consolidated DOD response each time a MAR is issued, and that this 
response could include any concerns with nuclear weapon limitations. 
We agree with NNSA that the management of nuclear weapon limitations 
requires active participation from both NNSA and DOD through the 
Nuclear Weapons Council. If NNSA and DOD follow through with these 
planned actions, we believe that the agencies will be responsive to 
our recommendations. 

In its written comments, DOD agreed with all four of the report's 
recommendations and said that the process by which nuclear weapon 
limitations are managed needs to be addressed. DOD said that it will 
coordinate with NNSA, through the Nuclear Weapons Council, to 
implement our recommendations. The complete text of DOD's comments is 
presented in appendix II. 

We are sending copies of this report to the Secretary of Defense, the 
Secretary of Energy, the Administrator of NNSA, the appropriate 
congressional committees, and other interested parties. The report 
also is available at no charge on the GAO website at [hyperlink, 
http://www.gao.gov]. 

If you or your staff have any questions about this report, please 
contact me at (202) 512-3841 or aloisee@gao.gov. Contact points for 
our Offices of Congressional Relations and Public Affairs may be found 
on the last page of this report. GAO staff who made major 
contributions to this report are listed in appendix III. 

Signed by: 

Gene Aloise: 
Director, Natural Resources and Environment: 

List of Requesters: 

The Honorable John S. McCain:
Ranking Member:
Committee on Armed Services:
United States Senate: 

The Honorable Jeff Sessions:
Ranking Member:
Subcommittee on Strategic Forces:
Committee on Armed Services:
United States Senate: 

The Honorable Michael R. Turner:
Chairman:
Subcommittee on Strategic Forces:
Committee on Armed Services:
House of Representatives: 

The Honorable Jon Kyl:
United States Senate:
The Honorable David Vitter:
United States Senate: 

[End of section] 

Appendix I: Comments from the National Nuclear Security Administration: 

Department of Energy: 
Nuclear Security Administration: 
Washington, DC 20585: 

January 20, 2011: 

Mr. Gene Aloise: 
Director: 
Natural Resources and Environment: 
Government Accountability Office: 
Washington, DC 20548: 

Dear Mr. Aloise: 

The National Nuclear Security Administration (NNSA) appreciates the 
opportunity to review the Government Accountability Office's (GAO) 
draft report, GAO-12-188, NNSA Needs to Improve Guidance on Weapon 
Limitations and Planning for its Stockpile Surveillance Program. 

In general, NNSA believes the GAO did a commendable job in reviewing 
this highly complex and technical area, and we agree with the 
underlying principle that it is undesirable to any extent for the 
Department of Defense (DoD) staff to either be uncertain as to the 
documented acceptability of any weapon limitation or unaware of NNSA's 
plans and activities to alleviate those which have been jointly 
determined as unacceptable. Overall, we agree with two of the four 
recommendations in the report, and agree with the desired outcome of 
the two remaining recommendations directed at "expanding guidance" 
from NNSA to DoD related to limitations and impacts of each. In 
general, we believe existing documents provided by NNSA partially 
fulfill the role suggested by GAO for the recommended guidance, and 
that additional action should be requested of DoD to formally 
communicate a consolidated response to limitations identified by NNSA 
each time a new MAR is issued. 

I have enclosed a summary of our specific planned actions to address 
the four recommendations noted in the report. In addition, while the 
auditors have done a thorough job, I have also included general and 
technical comments to further clarify certain salient points in the 
report and/or improve the factual accuracy in selected areas. 

If you have any questions related to this response, please contact 
Dean Childs, Director, Office of Management Controls and Assurance, at 
301-903-1341. 

Sincerely, 

Signed by: 

[Illegible] for: 
Kenneth W. Powers: 
Associate Administrator for Management and Budget: 

Enclosure: 

[End of letter] 

National Nuclear Security Administration Comments on GAO Draft Report
"NNSA Needs to Improve Guidance on Weapon Limitations and Planning for 
its stockpile Surveillance Program" GAO-12-188: 

Initial Response to Report Recommendations: 

Recommendation 1: 

"To increase the confidence in NNSA's ability to fully address all 
findings and recommendations from its draft surveillance management 
review, we recommend that the Secretary of Energy and the 
Administrator of the AMA prepare and complete a comprehensive 
corrective action plan that, in accordance with OMB Circular A-123, 
identifies the detailed actions that agency personnel must take to 
fully implement the recommendations in the review, and that specific 
dates, assigned responsibilities, and metrics to measure progress of 
this implementation. This corrective action plan should also address 
how to better integrate Core and Enhanced Surveillance. 

Management Response: Agree. 

NNSA appreciates the report's recognition of the recent improvements 
NNSA has undertaken in the restructuring and resourcing of the weapon 
surveillance enterprise. We concur with your finding that this effort 
will be further enhanced by the development and execution of an action 
plan to ensure these efforts stay on track through completion. The 
Assistant Deputy Administrator for Stockpile Management will oversee 
this implementation. 

Recommendation 2: 

"To improve the reliability and relevance of information associated 
with [weapon] limitations, we recommend that the Secretary of Energy 
and the Administrator of the NNSA, in coordination with the Secretary 
of Defense. determine if the findings of the joint DOD and NNSA 
military requirements review can be used to eliminate certain 
limitations." 

Management Response: Agree. 

NNSA enjoys an excellent relationship with our partners at the 
Department of Defense in developing realistic requirements and the 
weapon stockpile that fulfills them. We continue to take every 
opportunity to engage in refining the military needs of the nuclear 
weapon stockpile, and concur with your finding that the joint DoD --- 
NNSA military requirements review provides another opportunity to 
identify requirements which may be obsolete and hence are 
unnecessarily drawing nuclear enterprise resources away from other 
priorities in our efforts to assess them. The Assistant Deputy 
Administrator for Stockpile Management will directly oversee the 
consideration of the findings of the review and implement the 
recommendations appropriately. 

Recommendation 3 & 4: 

To improve the clarity of information NNSA provides to DoD about 
nuclear weapon limitations, we recommend that the Secretary of Energy 
and the Administrator of the NNSA. in coordination with the Secretary 
of Defense: 

(1) expand the guidance provided by NNSA to DoD so that it includes 
each existing limitation; 

Management Response: Agree in Principle. 

NNSA agrees NNSA should provide guidance to DoD regarding weapons 
limitations. However, several documents already exist that complement 
the MARs in the communication of the technical impacts of weapon 
limitations. Foremost among these are the Annual Assessment
Reports. However DoD similarly receives the biannual Weapon 
Reliability Reports, the annual Technical Basis for Stockpile 
Transformation Planning, and individual Significant Finding
Investigation closeout reports. As such, the MARs should continue to 
contain short and concise statements of what few military requirements 
the weapons do not meet, and allow the assessment of technical impacts 
to be expanded by the other documents better suited and already in use 
for that purpose. No additional actions planned. 

(2) assess, and revise as appropriate, the guidance provided by NNSA 
to DOD to ensure it clearly describes the potential impacts that each 
limitation may have on nuclear weapon operations, maintenance and war 
planning. 

Management Response: Agree in Principle. 

NNSA will continue to support DoD-led analyses to determine the 
operational, logistical, or strategic impacts of weapon limitations. 
However, findings in the report which imply a greater NNSA role in 
conducting or leading these efforts must recognize that the critical 
aspects necessary to determine these impacts include target engagement 
tactics, military service infrastructures, and theater employment 
scenarios. Authoritative direction to analysts on any of these 
inherently-DoD areas of responsibility exceeds NNSA's 
responsibilities. To the maximum ex-tent possible, NNSA and its 
national laboratories will support DoD organizations with the 
technical data and analyses necessary to conduct its operational 
assessments. No additional actions planned. 

General Comments on Recommendations 3 and 4: 

NNSA views as fundamentally sound the process by which assessment 
information is presented to the Department of Defense when a new or 
modified weapon is considered for admission into the stockpile, and 
how the Major Assembly Release (MAR) documents communicate the few 
limitations these weapons have in meeting the military requirements. 

We agree with your report's underlying concern that it is undesirable 
to any extent for the DoD staff to either be uncertain as to the 
documented acceptability of any weapon limitation or unaware of NNSA's 
plans and activities to alleviate those which have been jointly 
determined as unacceptable. 

However, we view that the report's findings can also lead to a 
different, more valid conclusion; not that DOE has failed to 
adequately communicate the limitations, but rather that DoD needs a 
process to develop and communicate a consolidated response. 

The key procedural weakness illustrated by the report's findings is 
the absence of a consistent process by which DoD reciprocates NNSA's 
formal communication of weapon limitations within a MAR with a written 
document back to NN SA on the acceptability of those limitations.
Without documented institutional positions to provide your auditors 
(which if available the auditors would have referenced in the report), 
the interviewees provided professional perspectives which may not have 
been the official positions for their organizations, had they been 
formally staffed. 

DoD and NNSA need the process for documenting the acceptability of a 
limitation to be as robust throughout the life of a weapon as it is 
when a weapon is first. accepted into the stockpile. To this end, we 
will formally request that the Lead Project Officers coordinate every 
MAR with all DoD members on their weapon Project Officers Groups 
(PO(is), and return a consolidated DoD response to all newly 
documented weapon limitations, such as capturing the acknowledgment 
and any concerns in the POG's official minutes signed by the LPO, or 
by a separate memorandum if necessary. We will additionally enjoin the 
Nuclear Weapons Council Standing and Safety Committee to levy this as 
a procedural requirement for all weapon POGs. 

Defense Programs will also take steps to standardize the organization 
of content within the MARs. The Office of Nuclear Weapon Stockpile 
will work with the national laboratories to establish a consistent 
format for the Major Assembly Release to eliminate instances where a 
statement of weapon or component capability is misconstrued to be a 
limitation to a military requirement. We noted this occurred with at 
least two of the 'limitations' cited in your report. 

[End of section] 

Appendix II: Comments from the Department of Defense: 

Assistant to The Secretary Of Defense: 
Nuclear and Chemical and Biological Defense Programs: 
3050 Defense Pentagon: 
Washington, DC 20301-3050: 

January 24, 2012: 

Mr. Gene Aloise: 
Director, Natural Resources and Environment: 
U.S. Government Accountability Office: 
441 G Street, N.W. 
Washington, D.C. 20548: 

Dear Mr. Aloise: 

This is the Department of Defense (DoD) response to the Government 
Accountability Office (GAO) draft report, 12-188, "Nuclear Weapons: 
NNSA Needs to Improve Guidance on Weapon Limitations and Planning for 
Its Stockpile Surveillance Program,” dated December 12, 2011 (GAO Code 
361215). The DoD concurs with all recommendations contained in the 
draft report. 

Enclosed for your consideration is the DoD response to the audit 
findings and recommendations. As a summary, the DoD agrees that the 
process by which Major Assembly Release (MAR) limitations and 
exceptions are granted will need to be addressed. The DoD, through the 
Nuclear Weapons Council (NWC), will coordinate with the National Nuclear
Security Administration for MAR limitations and exceptions to be 
briefed to the NWC, annually. 

The DoD further agrees to support NNSA in reviewing military 
requirements to determine if certain limitations and exceptions can be 
eliminated. Results of this review may be briefed to the NWC.
If you have any questions, please call me at 703-697-3060. My point of 
contact for this action is Mr. David Court, 703-693-4304, 
david.court@osd.mil. 

Sincerely, 

Signed by: 

Steve Henry: 
Deputy Assistant Secretary of Defense (Nuclear Matters): 

Enclosure: As Stated. 

[End of letter] 

GAO Draft Report Dated December 12, 2012: 
GAO-12-188 (GAO Code 361215): 

"Nuclear Weapons: NNSA Needs To Improve Guidance On Weapon Limitations 
And Planning For Its Stockpile Surveillance Program" 

Department Of Defense Comments To The GAO Recommendations: 

Recommendation 1: To improve the clarity of information NNSA provides 
to DoD about nuclear weapon limitations, the GAO recommends that the
Secretary of Energy and the Administrator of the National Nuclear 
Security Administration (NNSA), in coordination with the Secretary of 
Defense, expand the guidance provided by NNSA to DoD so that it 
includes each existing limitation. (See page 21/GAO Draft Report.) 

DoD Response: The DoD concurs with recommendation as written. The DoD, 
through the Nuclear Weapons Council (NWC), will coordinate with the 
NNSA on expanding guidance to ensure that all Military Characteristics 
(MCs) and Stockpile to Target Sequences (STSs) have been reviewed 
thoroughly through the weapon specific Project Officers Group (POG) 
Requirements Sub Group (RSG). Any MAR exception or limitation should 
clearly explain to the mission impact to DoD. 

Recommendation 2: To improve the clarity of information NNSA provides 
to DoD about nuclear weapon limitations, the GAO recommends that the
Secretary of Energy and the Administrator of the National Nuclear 
Security Administration (NNSA), in coordination with the Secretary of 
Defense, assess, and revise as appropriate, the guidance provided by 
NNSA to DoD to ensure it clearly describes the potential impacts that 
each limitation may have on nuclear weapon operations, maintenance, 
and war planning. (See page 22/GAO Draft Report.) 

DoD Response: The DoD concurs with the recommendation as written. The
DoD, through the NWC, will work with the NNSA and the weapon specific 
POGs to ensure that each weapon systems Requirements Sub-Groups have 
reviewed all MCs and STS requirements to address any new MAR 
limitations and exceptions. 

Recommendation 3: To improve the reliability and relevance of 
information associated with limitations; the GAO recommends that the 
Secretary of Energy and the Administrator of the NNSA, in coordination 
with the Secretary of Defense, determine if the findings of the joint 
DoD and NNSA military requirements review can be used to eliminate 
certain limitations. (See page 22/GAO Draft Report.) 

DoD Response: The DoD concurs with the recommendations as written. The
DoD, through the NWC, will support the NNSA and the POGs in conducting 
a review of military requirements to determine if certain limitations 
can be eliminated. 

Recommendation 4: To increase confidence in NNSA's ability to fully 
address all findings and recommendations from its draft surveillance 
management review, the GAO recommends that the Secretary of Energy and 
the Administrator of the NNSA prepare and complete a comprehensive 
corrective action plan that, in accordance with OMB Circular A-123, 
identifies the detailed actions that agency personnel must take to 
fully implement the recommendations in the review, and that specifies 
dates, assigned responsibilities, and metrics to measure progress of 
this implementation. This corrective action plan should also address 
how to better integrate Core and Enhanced Surveillance. (See page 
22/GAO Draft Report) 

DoD Response: The DoD concurs with the recommendation as written and 
looks forward to reviewing NNSA's development plan to ensure it meets 
DoD requirements for surveillance data needs. 

[End of section] 

Appendix III: GAO Contact and Staff Acknowledgments: 

GAO Contact: 

Gene Aloise, (202) 512-3841 or aloisee@gao.gov: 

Staff Acknowledgments: 

In addition to the contact named above, Jonathan Gill, Assistant 
Director; Patrick Bernard; and Alisa Beyninson made key contributions 
to this report. Colin Chambers, Penney Harwell-Caramia, Jon Kucskar, 
Michelle Munn, Kevin O'Neil, Tim Persons, Rebecca Shea, Carol Shulman, 
and Kiki Theodoropoulos provided technical assistance. 

[End of section] 

Footnotes: 

[1] NNSA was created in 1999 under Title 32 of the National Defense 
Authorization Act for Fiscal Year 2000, Pub. L. No. 106-65, § 3201 et 
seq. 

[2] Pub. L. No. 99-661, § 3137 (1986). 

[3] In this report, we use the term weapon to refer to a weapon system. 

[4] For example, a Stockpile-to-Target Sequence may include a 
temperature range of -180 to +155 degrees Fahrenheit and an 
acceleration force of 10G at launch. 

[5] Pub. L. No. 107-314, § 3141 (2002). 

[6] The Secretaries of Energy and of Defense are required to submit 
the laboratory directors' and STRATCOM Commander's annual assessment 
reports unaltered to the President, who forwards them to Congress, 
along with the conclusions the Secretaries have reached about the 
safety, reliability, performance, and military effectiveness of the 
nuclear stockpile. 

[7] Pub. L. No. 103-160, § 3138 (1993). 

[8] According to NNSA officials, the surveillance program started in 
1958. 

[9] JASON is a group of nationally known scientists who advise 
government agencies on defense, energy, and other technical issues. 

[10] H.R. Rep. No. 111-491 (May 21, 2010). NNSA officials told us that 
the agency addressed this reporting requirement on April 15, 2011, by 
including a classified annex in its Fiscal Year 2012 Stockpile 
Stewardship and Management Plan. 

[11] Intercoder reliability (agreement) statistics were generated in 
the coding process, and the two analysts agreed on 90 percent of the 
limitations. Coding differences were resolved through reviewer 
discussion. 

[12] GAO, Nuclear Weapons: Annual Assessment of the Safety, 
Performance, and Reliability of the Nation's Stockpile, [hyperlink, 
http://www.gao.gov/products/GAO-07-243R] (Washington D.C.: Feb. 2, 
2007). 

[13] GAO, Standards for Internal Control in the Federal Government, 
[hyperlink, http://www.gao.gov/products/GAO/AIMD-00-21.3.1] 
(Washington, D.C.: November 1999). 

[14] [hyperlink, http://www.gao.gov/products/GAO/AIMD-00-21.3.1]. 

[15] For our site visits, we selected one of the two national 
laboratories with design responsibility for a weapon's nuclear 
components and the national laboratory with design responsibility for 
nonnuclear components. 

[16] [hyperlink, http://www.gao.gov/products/GAO-07-243R]. 

[17] In 2007, NNSA embarked on a series of fundamental changes to the 
surveillance program that it believes will improve the detection of 
aging defects through increased testing of weapon components and 
materials. NNSA initially expected to complete component and material 
testing pilots by 2012 but now expects completion of these testing 
pilots by 2018. 

[18] NNSA defines campaigns as technically challenging, multiyear, 
multifunctional efforts to develop and maintain the critical 
capabilities needed to continue assessing the safety and reliability 
of the nuclear stockpile without underground testing. 

[19] The Nuclear Posture Review is a legislatively mandated review 
that establishes U.S. nuclear policy, strategy, capabilities and force 
posture for the next 5 to 10 years. 

[20] A 1998 joint DOE-DOD study determined that the probability of 
encountering the abnormal conditions to be extremely unlikely and did 
not recommend any operational changes. 

[21] Officials at one national laboratory told us that these abnormal 
conditions are an extraordinary unlikely event that cannot be assessed 
with existing stockpile stewardship tools and that no mitigation 
activities are planned for these types of events. 

[22] NNSA defines weapon reliability as "the probability of achieving 
the specified yield, at the target, across the Stockpile-to-Target 
Sequence of environments, throughout the weapon's lifetime, assuming 
proper inputs." 

[23] According to the Chairman of the technical advisory group, weapon 
limitations generally do not affect STRATCOM's war planning efforts 
but that, on occasion, the STRATCOM Commander determined that certain 
limitations could affect some aspects of war planning. 

[24] Sandia National Laboratories began issuing the guidance in 2009. 
This document also provides guidance on "environments of concerns," 
which are areas where military requirements are still met but with 
decreased safety or performance margins. 

[25] [hyperlink, http://www.gao.gov/products/GAO/AIMD-00-21.3.1]. 

[26] [hyperlink, http://www.gao.gov/products/GAO/AIMD-00-21.3.1]. 

[27] We included these four limitations in our above analysis of the 
types of weapon limitations because they are listed in each weapon's 
current MAR. 

[28] This official is the Office of Defense Programs' Assistant Deputy 
Administrator for Stockpile Management. 

[29] The RMI will replace NNSA's Development and Production Manual 
(NNSA Order AL-56XB), which currently serves as the authorization 
basis for Directed Stockpile Work activities--including stockpile 
surveillance. 

[30] Office of Management and Budget (OMB) Circular No. A-123, 
Management's Responsibility for Internal Control (Dec. 21, 2004). 

[31] See [hyperlink, http://www.gao.gov/products/GAO/AIMD-00-21.3.1]. 

[End of section] 

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