https://ntrs.nasa.gov/search.jsp?R=20160005772 2019-08-31T03:31:11+00:00Z View metadata, citation and similar papers at core.ac.uk brought to you by CORE

provided by NASA Technical Reports Server

Managing a Safe and Successful Multi-User

Taylor Dacko(1), Kirk Ketterer(2), Phillip Meade(3)

(1)NASA , FL, 32899, taylor.m.dacko@.gov (2)NASA Kennedy Space Center, FL 32899, [email protected] (3)NASA, Kennedy Space Center, FL 32899, [email protected]

ABSTRACT NASA KSC S&MA challenges were met with long- term planning and solutions involving cooperation Encouraged by the creation of the Office of with the Spaceport Integration and Services Commercial Space Transportation within the U.S. Directorate. This directorate is responsible for Federal Aviation Administration (FAA) in 1984 and managing active commercial partnerships with the Commercial Space Act of 1998, the National customer advocacy and services management, Aeronautics and Space Administration (NASA) now providing a dedicated and consistent level of support relies on an extensive network of support from to a wide array of commercial operations. This paper commercial companies and organizations. At NASA’s explores these solutions, their relevance to the current Kennedy Space Center (KSC), this collaboration commercial space industry, and the challenges that opens competitive opportunities for launch providers, continue to drive improvement with a focus on areas including repurposing underutilized Shuttle Program of safety management and risk assessment that have resources, constructing new facilities, and utilizing been crucial in KSC’s evolution into a multi-user center services and laboratories. The resulting multi- spaceport. These solutions may be useful to user spaceport fosters diverse activity, though it government entities and private companies looking to engenders risk from hazards associated with various partner with the commercial space industry. spaceflight processing activities. The KSC Safety &

Mission Assurance (S&MA) Directorate, in 1. BACKGROUND coordination with the center’s Spaceport Integration

and Center Planning & Development organizations, The realm of outer space, from low-earth-orbit to has developed a novel approach to protect NASA’s extraterrestrial bodies and beyond, is always viewed workforce, critical assets, and the public from with great potential, and national pursuit of these hazardous, space-related activity associated with endeavors spurs both technical and economic growth. KSC’s multi-user spaceport. In the United States (US), the road to promote a

commercial space industry was shaped by national For NASA KSC S&MA, the transformation to a multi- policy as well as the high risk of the activity. The user spaceport required implementing methods to National Aeronautics and Space Act of 1958, and foster safe and successful commercial activity while subsequent creation of the National Aeronautics and resolving challenges involving: Space Administration (NASA), declared that this

civilian agency will exercise control of aeronautical • Retirement of the program and space activities, but could enter into cooperative • Co-location of multiple NASA programs agreements with other entities to conduct its work [1]. • Relationships between the NASA programs The US Space Program historically was a joint • Complex relationships between NASA programs and undertaking of the federal government and private commercial partner operations in exclusive-use industry, but this relationship principally existed facilities through the use of commercial contractors for • Complex relationships between NASA programs and federally managed programs. An increased presence commercial partner operations in shared-use of commercially produced vehicles and satellites facilities through NASA’s first few decades led to renewed

interest in enabling commercial space enterprise. The Commercial Space Launch Act of 1984 recognized the personal property capacity, but a large amount of contributions of private industry, and declared that the legacy procedures and processes to maintain. The United States should encourage private sector center, and S&MA sought to consolidate the legacy launches [2]. The Act directed NASA and the United documentation from the . States to promote entrepreneurial activity in space, and S&MA as an organization originated within the facilitate the use of government-developed technology program and engineering directorates, reporting to encourage the private sector. This act created the directly to program management and providing safety Office of Commercial Space Transportation within the engineering services to the center. NASA reassessed Federal Aviation Administration (FAA), and this model after the tragedies of Space Shuttle subsequent NASA Authorization Acts saw similar Challenger, and Space Shuttle Columbia. The Rogers language incorporated to promote private sector Commission Report, investigating the Challenger launches. accident, and the Columbia Accident Investigation Board noted that independent authority did not exist to 1.1 Kennedy Space Center manage technical requirements that addressed hazards The Kennedy Space Center (KSC), located on Merritt [4, 5]. NASA’s Office of Safety and Mission Island, FL, serves as NASA’s primary launch center Assurance realigned to provide independent Technical for its spaceflight programs. Containing over 140,000 Authority to each center’s safety organization. This acres of land, KSC has the capabilities to support Technical Authority allows the KSC S&MA transportation via land, air, rail, sea, and space. The organization to perform independent assessment of location of KSC on the Eastern Seaboard allows for NASA activity, and manage programmatic and multiple launch capabilities, including horizontal and institutional risks for the hazards of a government- vertical, human-rated and unmanned launch vehicles. managed spaceport. The KSC organizational structure is composed of The Space Shuttle program remained the largest multiple directorates, which provide planning and NASA program on KSC for several decades, up until implementation services for ground operations and the final launch of STS-135 in July 2011. The spaceflight programs. These programs manage and presence of purely commercial work at KSC had been share a unique infrastructure of processing facilities, historically small, in comparison to the sizeable launch pads, testing facilities, and laboratories. KSC NASA contractor workforce and amount of center assets are utilized by multiple NASA programs and resources and infrastructure. External partnerships, contractors, and mostly recently, commercial partners. both domestic and international, have increased in the The KSC Institution supports these programs by last three decades. In 1998, NASA introduced the providing and managing the essential functions of the Launch Services Program to procure center. Among these organizations, the Spaceport services from commercial providers. Although these Integration and Services directorate integrates and providers launched federal payloads with NASA manages center services and customer support to oversight, the launch provider managed a larger spaceport users. KSC’s Safety & Mission Assurance portion of risk, with NASA safety and quality (S&MA) Directorate sustains and strengthens the participating in the reviews. The International Space success of KSC’s organizational structure, serving as Station program brought international partners and an independent and value-added partner ensuring the payloads to KSC’s Space Station Processing Facility, mission success of programs while protecting the where S&MA provided safety oversight for both civil safety and health of the public, program team servant, contractor, and international partner members, and those assets that the US entrusts to workforces. Throughout all of these efforts, NASA NASA [3]. retained the primary responsibility for operations and From concept development, to production, to processing activities. KSC also increased partnerships operation and retirement, the lifecycle of many with academic research, prominently in the center’s programs existed at KSC. The last major program Space Life Sciences Laboratory. NASA had dedicated lifecycle to reach retirement, the Space Shuttle the bulk of the center’s facilities, services, and program, left KSC with not only excess real and workforce to the successful completion of the Space Shuttle program’s mission. requirements included explosives safety, pressure vessels, lifting devices and equipment, lightning 1.2 Multi-User Spaceport safety, personal protective equipment, and other The transition and retirement of the Space Shuttle occupational safety policies (industrial health and fire program freed up a number of assets at KSC protection, while referenced in the NPR, are previously utilized by the Shuttle processing and maintained under separate documents at the center launch flows. NASA’s current manned exploration level). This document provides a framework for vehicle, the , will be processed NASA centers to detail specific requirements for their and launched from KSC. KSC determined that the center. At KSC, these further requirements are facilities and services required for current and future addressed via the KSC Procedural Requirements NASA programs left many existing assets (KNPR) 8715.3 document. This KNPR addresses the underutilized or mothballed. Maintaining these governing requirements and demonstrates how KSC facilities and services at their previous capacity would implements the NASA Safety program and NASA result in excess cost to the government. A strategic Safety standards at KSC [9]. The document applies to goal in NASA’s 2007 Strategic Plan was to, all entities, including civil servants, contractors, and “encourage the pursuit of appropriate partnerships visitors, that operate at KSC. with the emerging commercial space sector.” [6] A S&MA developed the KNPR as a catch-all to safety solution, therefore, was to partner with non-NASA programs and practices on the center. KSC S&MA entities, including federal, state, commercial and was concerned that these NASA requirements could academic organizations, to make use of these assets. be burdensome to companies looking to conduct The NASA Authorization Act of 2010 identified KSC business at KSC. KSC previously developed S&MA as a multi-user launch complex, for both government requirements to accommodate large-scale federal and commercial programs [7]. NASA sought programs. Industrial safety requirements in several commercial partners through both open solicitation for areas exceeded those specified by the US NASA partnerships, and by public announcements of Occupational Safety & Health Administration available facilities. NASA made certain facilities (OSHA), and other standards such as the Safety available for exclusive-use including the Launch Standard for Explosives are supplemental to existing Complex 39A, the Orbiter Processing Facilities, federal requirements. Many commercial companies Shuttle Landing Facility, Hypergolic Maintenance interested in partnerships maintain existing safety & Facility, and others, and also proposed sharing space health programs. KSC did not intend to supplant these within active NASA facilities, including the Vehicle existing safety programs and introduce strain in Assembly Building, Launch Control Center and complying with a new set of requirements. S&MA laboratories. needed to understand how to bring these safety & 2. REQUIREMENTS DEVELOPMENT health programs under the umbrella of KSC’s existing safety culture. Multiple safety and health programs This concept for a space center with multiple users would need to operate in harmony, with NASA’s required a thorough review of existing requirements to safety program acting as the final authority if required. determine how commercial launch activity would be NASA sought to fully understand and define an incorporated. Within S&MA, this started with general acceptable level of risk from commercial activity to institutional safety requirements. The basis for the NASA personnel and programs. The S&MA NASA Safety programs, at an agency level, is defined organization formulated two questions to guide in the NASA Procedural Requirements (NPR) development of a solution to this problem. First, what document NPR 8715.3 NASA General Safety are the minimum necessary requirements to develop Program Requirements. This document implements a an acceptable risk profile for commercial activity? comprehensive safety program that defines Secondly, what facets of the safety program must be institutional, program, system, operational, training, universally standard on center? and discipline-specific safety programs [8]. Referenced NASA standards and technical 2.1 Evolving Rationale assessments of quantitative and qualitative safety risks to people, property, or equipment, and include To develop a framework for a minimum set of NASA recommendations to either reduce the risks or accept requirements, the KSC S&MA organization looked them.” [8] This is flowed down to the KNPR 8715.3 externally to find rationale. If general industry in the assessment section, under Chapter 4: operated within the boundaries of the center, then KSC Operational Requirements. Chapter 4 requires that would have to understand general industry. A key organizations on KSC establish a process to review facet of how OSHA interprets fault among multiple and accept risks, perform an assessment to evaluate parties in the same location is by its Multiple hazards associated with operations, and establish Employer Citation Policy [10]. In the event of an controls for the hazards [9]. This applies to NASA as accident that involves multiple organizations, OSHA the sole employer identifying, assessing, and distinguishes these employers into four categories: controlling its own risks. In assessing a third party, creating, controlling, correcting, and exposing and without the full complement of NASA employers. The creating employer introduces the requirements, the government would have to be source of the hazard, the controlling employer judicious in how it collected information through an manages the hazard, the correcting employer mitigates agreement. The solution was to pare down the the hazard, and the exposing employer has employees requirements of KNPR 8715.3 to the minimum safety that could be harmed by the hazard. This is useful in standards necessary to regulate activity on center, determining responsibility in an incident, however the while bolstering the capabilities of the operational citation policy only engages once the accident has assessment that identifies hazard controls. occurred. It is prudent for a worksite manager to ensure hazards are appropriately controlled in order to 2.2 Operational Assessment prevent such a mishap from occurring. This The core of this new multi-use safety policy is categorization of employers still provided a useful NASA’s operational assessment, derived from the framework to understand how NASA wanted to original Chapter 4 in KNPR 8715.3. NASA’s ability position itself as a spaceport manager. Considerations to control and manage hazards is only as strong as its included how NASA or partners introduced hazards to ability to have information available for assessment of the center, how hazards are controlled and mitigated, the existing hazards. As a baseline, NASA maintains and how respective employees might be exposed to the final authority to mitigate a hazard, should partner- those hazards. To address the question of minimum managed controls not be sufficient to reduce the risk necessary requirements, S&MA considered NASA to to KSC personnel or property. At the same time, be an exposing employer. According to the OSHA NASA wants partners to keep their safety programs policy, in the event of a mishap an employer can be and requirements intact, and acknowledges different cited if it, “knew of the hazardous condition or failed approaches in safety. A commercial partner already to exercise reasonable diligence to discover the must comply with all federal, state and local condition.” [10] KSC requirements on agreements requirements, including OSHA and other incorporated with commercial partners would reflect due diligence standards, by operating in the United States. NASA is by S&MA to understand local hazards, and through not responsible for enforcing a commercial company’s coordination with a partner, work to control them. compliance to OSHA and other laws as they pertain to Hazard communication between NASA, partners, the the company’s own employees. Rather than levy the public, and other participants of the multi-user full slate of KSC requirements on a partner, a partner spaceport is a strong component of KSC’s S&MA could demonstrate that their safety programs represent policy. Communication and coordination alone does an equivalent level of safety to NASA requirements not satisfy the principles of NPR 8715.3 with regards that either exceed federal laws or target specific to risk evaluation and acceptance. Safety policy must aerospace hazards. This equivalence would be withstand the rigors of hazards specific to aerospace, assessed against the risk to KSC personnel and activity including launch and reentry activities. The NPR governed by NASA. The more partner documentation states that NASA will, “ensure the conduct of and data NASA could review, the better NASA could understand gaps between partner and NASA safety 3.1 The Safety Requirement Volumes requirements. A complete review of a partner’s Once NASA S&MA understood the hazards posed by business and company documentation would require a partner’s operations, it was necessary to ensure those significant time and resources on behalf of both operations were compatible amongst existing center parties, and might impose an undue burden on programs. The concept of operations document companies wishing to conduct operations. NASA includes information on all locations utilized by the would have to be judicious in its selection of material partner at KSC. The locations made available for to review, while ensuring appropriate breadth to commercial use fell into two categories: facilities adequately assess risk. whose operation, maintenance, and usage are fully The modification of the operational assessment began transferred to a partner; and shared areas within with specifying particular documents that NASA existing NASA-controlled facilities. At facilities required prior to a partner initiating operations. The operated and maintained by a partner, designated first of these is a partner’s concept of operations, exclusive-use, NASA would have flexibility to allow which defines the full extent, at a high-level, of all partner safety programs to manage the facility, proposed activity. The partner has discretion on what provided NASA had full awareness of these policies form this concept of operations takes, and could and deemed them compatible with existing facility originate from an existing document or as a new policies. Facilities designated for exclusive-use also product. Acknowledging partner recommendations, contained NASA systems that fed through or NASA retains the authority to ask for further originated within those facilities, traces of the former information or depth for a full assessment. Along with Shuttle program facility architecture. These facilities a concept of operations, partners would include a would require routine access from KSC personnel for description of all hazards associated with those maintenance or inspection, and KSC S&MA needed operations, and the corresponding controls or oversight of safety controls at these sites. Within a mitigations for those hazards. This is meant to be NASA-controlled facility or shared-use, NASA encapsulating language that included activity covering maintains existing security, safety, and scheduling launch processing and ground operations. General procedures to be complied with by all occupants, hazards include occupational hazards to personnel, including partners. Assessing each agreement and pressurized systems, hazardous chemicals, ordnance, each facility to tailor the KNPR 8715.3 would be a critical lifting, and others to be identified by the laborious process, as each facility had unique partner. The partner would also report all hazardous attributes and infrastructure designed to support flight chemicals so that KSC could catalogue existing hardware processing. S&MA decided to take the chemicals on center and ensure compliance with original KNPR and split it into three volumes: the NASA’s Safety Standard for Explosives [11]. To existing document relabeled Volume 1 for civil prevent cataloguing insignificant quantities, chemicals servants and contractors, a new Volume 2 for partners identified as hazardous by the OSHA General Industry within shared-use or NASA managed facilities, and Hazard Communication standard served to Volume 3 for partners within exclusive-use facilities. encapsulate the information NASA sought [12]. With These individual volumes could be placed within an this information as a basis, NASA could begin to craft agreement, and accommodate a majority of safety a complete story of the proposed activity and the provisions and concerns, with additional tailoring as hazards brought on KSC property. Further needed to accommodate the specific needs of a requirements would address specific highly hazardous partnership. activity, including high-pressure operations, ordnance, 3. SURVEILLANCE AND VERIFICATION and range operations, but these would be tailored from the existing NASA standards. Any coordination on The information gathered from the operational this information would need to begin well in advance assessment of Volumes 2 and 3 provides the of operations, to ensure no delays in NASA receiving foundation of KSC’s risk assessment of partners, but the relevant information. NASA must perform its own due diligence to ensure the information is accurate and complete. NASA develops a surveillance plan for each agreement to 4. SPACEPORT INTEGRATION assess the partner’s compliance to S&MA The usefulness of surveillance relies on close requirements in the agreement. These agreement coordination with NASA partnership management, requirements largely come from Volumes 2 or 3, since which lies within two key center organizations. these documents are intended to exist on a majority of S&MA maintains relationships with KSC managers agreements. The plans document which requirements and stakeholders of partnerships for awareness of any are targeted, and how often KSC S&MA performs concerns with regards to safety requirements and surveillance. S&MA decided that to reduce the burden policies. To understand how these relationships are on partners and manage the resources of KSC S&MA, maintained, it is important to describe how KSC the surveillance frequency would only be performed realigned its structure to better support the multi-user on a monthly, quarterly, or annual basis. The spaceport concept. The Center Planning and frequency is based on current KSC construction Development directorate leads the development of surveillance practices, and S&MA constantly partnership agreements at KSC, and thus is reassesses the frequency of evaluation. Whether a responsible for early partner coordination, contractor or partner has a satisfactory record of negotiations, and ensuring the development of an compliance or not, the evaluator may increase or executable and enforceable agreement which includes decrease the surveillance frequency. all relevant safety requirements. The management of Surveillance of KSC S&MA partnership requirements the multi-user spaceport, and the liaisons to partner falls into two general types: documentation reviews, operations fall under the responsibility of the and site visits. Documentation reviews occur early in Spaceport Integration and Services Directorate. the partnership process, and initially reference the The Spaceport Integration and Services directorate is documents requested in the operational assessment. responsible for the overall planning and assimilation At a minimum this includes a review of the concept of of Kennedy Space Center processing activities and the operations, hazard and chemical lists, and a copy of execution of center services across NASA projects and the partner’s safety & health plan (or program), but programs, other government agencies, and may also include operational or design documentation commercial partners. These functions are integrated to and risk analysis. These reviews provide both NASA create consistently safe, innovative, responsive, and and the partner with a baseline of activities associated cost-effective solutions, driving the success of all with ground and flight operational schedules, safety spaceport customers. The primary goal of the policies and surveillance activity over the life of the directorate is to ensure that the institutional needs of agreement. It also provides sufficient lead time should all spaceport customers, including NASA programs a particular activity require additional controls or and commercial partners, are met. This is done by coordination with NASA. Generally, these reviews providing a consolidated operations and scheduling are conducted once, at the inception of the partnership, function for the center which includes developing and but will be subsequently reviewed as updates are maintaining a top-level operations master schedule available. These are particularly critical for flight that integrates commercial and government entities operating at KSC to ensure awareness and safety analyses developed for commercial launches, deconfliction of hazardous and other operations that since NASA may perform a review in addition to those have potential impact across the customer base. required by range regulators. The second type, site visits, are the best opportunities to verify that the The directorate also provides customer liaisons to information in the documentation is current and customers of the KSC spaceport for the purposes of adequate. Site visits are precoordinated with the identifying, coordinating, deconflicting, scheduling, partner on a non-interference basis, and surveillance is and managing KSC spaceport services. These only performed on requirements identified in the customer liaisons interface directly with partners on a agreement or associated KNPR 8715.3 Volume. Stop- daily basis to develop and communicate requirements, work authority, a critical item in KSC’s safety culture identify creative solutions to issues, and integrate between the various users and stakeholders of the that allows personnel to call a halt to immediate unsafe spaceport (including S&MA). These liaisons also activity, is always explicitly clear for any activity. manage and implement the process for partners to procure services from KSC, facilitate approval for any FAA-licensed launches, safety reviews could be customer-proposed modifications, and coordinate conducted by the 45th Space-Wing or an FAA- customers’ requests with KSC implementing approved entity. This creates more options for organizations to provide a viable support plan to the commercial providers, but moves away from the customer. traditional NASA model for safety review and Through close partnership with Spaceport Integration concurrence. and Services, S&MA is able to maintain a good The flight safety analysis required in the application understanding of the nature of operations occurring at for an FAA launch license is reviewed by the FAA. KSC, the level of interaction between spaceport users With the FAA maintaining the licensing authority, and their operations, and the types of issues being NASA does not have mandated approval of a launch, faced by the customers. This partnership is critical to helping both organizations be successful and in as the FAA ensures protection of the public. As the ensuring that the spaceport enables the safe and manager of the spaceport where this launch activity successful operations of all government and would occur, though, NASA still holds a fundamental commercial activity. responsibility for protecting personnel and property. Using the previous risk-based approach from the 4.1 KSC Technical Integration Operational Assessment in the KNPR Volumes, In addition to working with stakeholders from other NASA will request and review a minimum set of data directorates at KSC for agreement development and from the flight safety analysis for assurance that risk is implementation, S&MA also retains institutional and minimized. If the risk to NASA facilities exceeds programmatic safety, quality, and reliability experts criteria established in the NPR 8715.5A Range Flight within its organization. During the early stages of Safety Program, NASA will work with the launch agreement development, the subject matter experts provider to better quantify or control the risk [14]. (SMEs) are consulted for specific requirements on Likewise, processing and ground safety operations activities that are expected to be highly sensitive or will be conducted according to the shared or highly hazardous, including: program schedules, exclusive-use facility requirements in KNPR 8715.3 explosive siting, lifting device, pressure vessel and Volumes 2 and 3, respectively. The ability to review range safety priorities. During agreement data, request information, and implement controls implementation, NASA KSC SMEs are available for through these document Volumes allows any risk- interpretations of technical safety standards and based safety concerns, regardless of origin, to be program safety priorities. They also assist in the covered by the KNPR requirements. Even in development of targeted surveillance activity for their situations where NASA does not have immediate disciplines. approval authority, NASA must manage the risk to its spaceport. Through coordination and levying prudent 5.0 COMMERCIAL LAUNCH PROVIDERS requirements, NASA will fully understand launch hazards and ensure the risk is acceptable to the center. The authority of KSC safety requirements also KSC stakeholders and S&MA will work with required reevaluation for commercial launches commercial launch providers to identify controls and licensed by the FAA. For NASA-managed or modifications that will allow them to successfully procured launches, safety analysis is performed under execute an FAA-licensed launch. existing cooperative agreements with its neighbor, the Air Force’s 45th Space Wing. The Webb-McNamara 6.0 CONCLUSION Agreement, established in 1963 to minimize the duplication of responsibilities from both NASA and The multi-user spaceport concept invites new Air Force launch operations, drove this cooperation perspectives, novel engineering, and cutting-edge [13]. However, Webb-McNamara did not account for technologies to the KSC. The success of commercial purely commercial launches, and the review and partnerships, and NASA missions, hinges on licensing of launch providers by the FAA therefore cooperation and shared awareness. This awareness is creates another regulatory entity. A review in 2013 by the core of both KSC’s Spaceport Integration and the NASA Executive Council determined that for Services policies and S&MA safety policies that govern the risks and challenges inherent to the multi- user concept. Strong and suitable policies allow KSC 9. KNPR 8715.3 Rev. J-1 KSC Safety Procedural to support a wide variety of partnerships without any Requirements, June 28, 2012, NASA compromise to NASA KSC’s safety culture 10. Occupational Safety and Health Administration The center accepts the new risks associated with (OSHA) Instruction, Multi-Employer Citation Policy, commercial launch activity, and has adapted its CPL 02-00-124, Dec. 12, 1999, US Department of structure, and requirements, to better promote these Labor partnerships. In enabling the multi-user spaceport, KSC also addresses its mission as levied in the 11. NASA-STD 8719.12 (change 2) Safety Standard NASA’s Space Act to foster an environment for for Explosives, Propellants, and Pyrotechnics, commercial space access. As this access to space will December 12, 2011, NASA always offer great rewards at great risk, it is the 12. OSHA Regulations (Standards – 29 CFR S&MA organization’s continued mission to provide a 1910.1200) Hazard Communication, May 25, 2012, framework that allows these goals to be safely US Department of Labor attained. 13. KCA-1645, Rev. Basic Agreement between The

Department of Defense and The National Aeronautics 7.0 REFERENCES & Space Administration Regarding Management of The Atlantic Missile Range of DoD and The Merritt 1. National Aeronautics and Space Act of 1958, Pub. Island Launch Area of NASA, Jan. 17, 1963, Florida L. No. 85-568, 72 Stat. 426-438 (Jul. 29, 1958), NASA Space Development Council Library History Program Office 14. NPR 8715.5A (change 2) Range Flight Safety 2. Commercial Space Launch Act of 1998 (Previously Program, Sept. 12, 2012, NASA Commercial Space Launch act of 1984), Title II – P.L. 105-303, Office of Commercial Space Transportation Legislation & Policies

3. KDP-B-1041 Rev. G, John F. Kennedy Space Center Business Operating and Agreement for Safety and Mission Assurance Directorate, Nov. 12, 2015, NASA

4. Report of the Presidential Commission on the Space Shuttle Challenger Accident (Rogers Commission Report), June 6, 1986, Washington DC, NASA History Program Office

5. Columbia Accident Investigation Board Report, August 2003, NASA History Program Office

6. NASAFY 2007 Performance Highlights, Feb. 1, 2008, NASA

7. NASA Authorization Act of 2010, Pub. L. No. 111- 267, 124 State. 2805 (Oct. 11, 2010), NASA.GOV

8. NPR 8715.3C (change 9) NASA General Safety Program Requirements, Feb. 08, 2013, NASA