Management of Change - hdbk11010036

Exhibit 2.1

DOE-HDBK-1101-96

Management of Change

Procedures exist to manage changes to process chemicals, technology, equipment, procedures, and

process facilities. These procedures provide assurance that the PrHA, PSI, and procedures are

updated, if necessary, to reflect the changes. Essential to the success of MOC system is the active

participation by both site and affected subcontractor employees in the review and evaluation process

to determine the impacts of proposed changes.

Incident Investigation

An incident is an event whose occurrence resulted in, or could reasonably resulted in a catastrophic

release of a highly hazardous chemical in the workplace. It is site policy that all incidents will be

investigated as soon as possible, but be initiated no later than 48 hours after the incident. The team

investigating the incident shall consist of at least one person knowledgeable in the process involved;

a contract employee, if a subcontractor was involved; and other cognizant and informed individuals.

Employees are typically involved in incident investigations since their knowledge and skills in

operations or maintenance are necessary for the conduct of the investigation.

When the investigation is completed, a report, containing the contributing factors to the incident and

recommendations for prevention of future occurrences, will be made by posting in work areas,

circulation of reports, discussion in scheduled safety meetings, or as a subject in ad hoc meetings

with employees. Management then addresses, resolves, and implements the report findings and

recommendations. All site and contractor personnel affected by the changes are informed of any

changes and may be involved in their implementation.

Emergency Planning and Response

A formal review process for site-wide procedures exists for soliciting and obtaining employee input

on site emergency response plans. Employees may critique drills and actual incidents to identify

opportunities for performance improvements, and improve both emergency response planning and

responder performance. Communication to employees and subcontractors to promote understanding

of the actions to take during an emergency.