**\[DNFSB LETTERHEAD\]**

May 14, 2004

The Honorable Spencer Abraham

Secretary of Energy

1000 Independence Avenue, SW

Washington, DC 20585-1000

Dear Secretary Abraham:

The Defense Nuclear Facilities Safety Board (Board) continues to view
the Facility Representative (FR) Program as one of the Department of
Energy\'s most effective and efficient approaches for assuring the
safety of the full spectrum of hazardous activities. The Board\'s staff
conducted reviews at the Pantex Site Office (PXSO), Sandia Site Office
(SSO), and Los Alamos Site Office (LASO) to evaluate the training and
staffing of FRs.

Observations by the Board's staff revealed that the FRs at these
National Nuclear Security Administration (NNSA) sites are being trained
on the facility-level safety requirements; however, they are not being
adequately trained to understand all hazards that could impact safety
controls for activities being conducted within their assigned
facilities. This lack of activity-specific training limits the FRs'
ability to recognize and identify safety issues associated with the
conduct of these activities. For example, the Board's staff discovered
during the W78 Readiness Assessment that the PXSO FRs were not required
to have any weapon-specific training on the hazards and associated
controls for the W78. It was explained that one factor limiting the
ability to expand FR qualification and continuing training requirements
is the limited number of FRs as compared with the number of nuclear
weapons operations, facilities, and site-wide safety bases.

The number of FRs at PXSO has decreased from nine to six. The level of
staffing of FRs at the NNSA sites is of particular concern to the Board.
As a result, the FRs face significant challenges to their ability to
monitor nuclear weapon activities and perform their other assigned
duties, such as Duty Officer and member of Readiness Assessment teams.
SSO and LASO have not met their FR staffing needs for the past 4 years,
raising the question of how NNSA can be an effective, demanding customer
for its two largest national laboratories. PXSO and LASO have requested
two to three additional FR billets, but even these may not be sufficient
to meet their needs.

The FR training and staffing deficiencies noted above may affect NNSA's
ability to improve and maintain the safety of the hazardous activities
conducted at the NNSA sites.

Therefore, pursuant to 42 U.S.C. § 2286b(d), the Board requests a report
within 60 days of receipt of this letter that reviews the extent of
these issues at all NNSA sites and outlines the measures that will be
taken to address these deficiencies. The enclosed report prepared by the
Board\'s staff is forwarded for your information and use in initiating
this review.

Sincerely,

***John T. Conway***

***Chairman***

c: The Honorable Kyle E. McSlarrow

The Honorable Linton Brooks

The Honorable David K. Garman

The Honorable Jessie Hill Roberson

Mr. Mark B. Whitaker, Jr.

Enclosure

**DEFENSE NUCLEAR FACILITIES SAFETY BOARD**

**Staff Issue Report**

April 27, 2004

**MEMORANDUM FOR:** J. K. Fortenberry, Technical Director

**COPIES:** Board Members

**FROM:** J. DeLoach

**SUBJECT:** Review of Facility Representative Training and Staffing at
Three National Nuclear Security Administration Sites

This report documents observations resulting from a review of Facility
Representative (FR) training and staffing at the Pantex Site Office
(PXSO), the Sandia Site Office (SSO), and the Los Alamos Site Office
(LASO). This review was conducted by a member of the staff of the
Defense Nuclear Facilities Safety Board (Board) J. DeLoach during March
22-24, 2004. The Board\'s staff was not able to review the FR program at
the Kansas City Site Office (KCSO) as it has been disestablished. As
part of each review, the staff also walked down several defense nuclear
facilities at each of the sites with the cognizant FR.

**Overview.** The three National Nuclear Security Administration (NNSA)
sites are not staffed with a sufficient number of FRs to perform their
facility oversight responsibilities and participate in their additional
assignments (e.g., Duty Officer, member of Readiness Assessment teams,
training). SSO and LASO have also been underreporting their FR staffing
needs for the past 4 years. Of note, the guidance on FR staffing
analysis in DOE-STD-1063-2000, *Facility Representatives*, does not
adequately account for all of the hazardous facilities for which the
Department of Energy (DOE) and NNSA have oversight responsibility, and
does not capture all of the FR work demands. The FR continuing training
programs were unstructured, informal, and generally weak in execution.
As of the time of this review, training on specific activities within a
facility (e.g., weapons-specific hazards and associated controls at PXSO
or hazardous research activities at LASO) was not required. Detailed
observations are presented below.

**FR Capacity for Growth.** Because of the demonstrated value and
success of the FRs, DOE and NNSA continue to invest heavily in the FR
program. FRs have been recognized by senior DOE/NNSA managers not only
for their extensive systems knowledge and field skills, but also for
their managerial potential. Personnel with FR experience are often
sought for demanding management positions involving operations and
safety. The *DOE Facility Representative Program Performance Indicators
Quarterly Report* of March 16, 2004, reports an overall attrition rate
in 2003 of 20 percent (40 of 204 FRs). As described in the report, only
6 of the 40 FRs had left DOE, while 34 FRS had remained within the DOE
complex through lateral transfer to another position at their site or
other DOE/NNSA organization (26), transfer to another site to be an FR
(5), or promotion to a higher grade (3).

**FR Training.** DOE Order 5480.19, *Conduct of Operations Requirements
for DOE Facilities*, and DOE Manual 231.1-2, *Occurrence Reporting and
Processing of Operations Information*, specifically assign
responsibility to the FR "for monitoring the performance of the facility
and its operations". At the NNSA sites, it appears that FRs are trained
and qualified primarily on the facility functions; but receive little or
no training on the specific hazards and associated controls of the
operations or activities performed within the facility. This lack of
activity-specific training limits the FRs' ability to recognize and
identify safety issues associated with the conduct of the nuclear
weapons-specific or research-specific activities in their respective
facilities. The NNSA sites have relied to a limited extent on their FR
continuing training programs to provide some training in this area.
However, the continuing training programs at the three NNSA sites
reviewed were unstructured, informal, and generally weak in execution.
FR attendance at key continuing training courses (e.g., the course on
significant changes to the Occurrence Reporting and Processing System in
2003) was not accurately tracked or enforced at any of the three sites.

During the W78 Readiness Assessment conducted in January 2004 at the
Pantex Plant, the Board's staff discovered that the cognizant FR had not
received and was not required to have any weapons-specific training that
would provide an understanding of the unique weapon-related hazards and
associated controls for the upcoming weapon operation. As a result, PXSO
modified its FR continuing training instruction to require FRs to read
the weapon-specific Hazard Analysis Report and Technical Safety
Requirements; observe tooling training; and, if funding is available,
attend the weapons training at Los Alamos National Laboratory (LANL).
This is a good first step, but implementation will be a challenge
because of the limited number of FRs at PXSO. These added training
requirements will also challenge the FRs' ability to perform their
primary functions. Conversely, the press of their duties will hinder
their ability to read and digest weapons-specific safety documentation
in a self-study mode. Additionally, PXSO acknowledged that limited
funding will hinder FR attendance at the LANL training. Of note, this
training is applicable only to LANL-designed weapon systems. Similar
training on Lawrence Livermore National Laboratory's weapon systems
apparently does not exist.

Furthermore, there is no linkage or plan to determine which FR needs
which training. Also, managers are relying on their FRs to identify the
right course and find the time to take it.

**FR Staffing at PXSO, SSO, and LASO.** PXSO has 6 FRs since the
transfer of 1 FR to LASO. In last year's Managed Staffing Plan, NNSA
claimed that 6 FRs were sufficient at the Pantex Plant, justifying this
statement primarily by proposing changes in oversight coverage of
hazardous activities. Since 1999, NNSA's staffing analyses, using the
guidance in DOE-STD-1063-2000, *Facility Representatives*, have
consistently shown a need for 14.5 FRs at PXSO. Their normal
responsibilities include monitoring nuclear weapons activities in 214
nuclear facilities (bays, cells, buildings, and nuclear material storage
magazines) or observing other industrial activities in 150 moderate- to
low-hazard facilities under the BWXT Pantex contract.

The PXSO FRs will also participate in eight readiness reviews in 2004
(duration of 2-4 weeks each for one or two FRs), are scheduled to
conduct 12 site assessments (duration of 1 week each for every FR) this
year, and will serve regularly in rotating assignment as Duty Officer.
The FRs will also observe maintenance activities during the swing shift
on a monthly basis, devote time to training and requalification (five
FRs are due to requalify in 2005), and use several weeks of leave for
vacation and medical reasons. Given these responsibilities, cumulative
time demands, and overall workloads, it is clear that PXSO does not have
a sufficient number of FRs. PXSO recently sent a request to the NNSA
Administrator for three additional FR positions that, if approved, would
increase PXSO's total to nine. However, even this increase may not be
enough to satisfy the current and future workload of the FRs. This
shortage will continue to impact the ability of FRs to spend the
majority of their time in their assigned facilities, observing and
assessing activities to ensure their safe operation.

SSO is responsible for more than 800 facilities, approximately 400 of
which are classified as hazardous facilities. These facilities are
located in five states (New Mexico, Texas, Nevada, California, and
Hawaii), where a wide variety of hazardous operations, mostly
non-nuclear, are performed under the Sandia National Laboratories (SNL)
contract (valued at \$2.02 billion for fiscal year 2004). Among the
hazardous facilities are five nuclear facilities in Technical Area-V
(two Hazard Category 2 research reactors, two Hazard Category 3 hot cell
facilities, and one Hazard Category 3 irradiation facility) and another
four Hazard Category 3 nuclear material storage facilities at Manzano.

SSO currently has 8 FRs, 5 of whom are qualified. One qualified FR is
assigned to the nuclear facilities, while another is in the process of
qualifying, with a scheduled completion date of March 2005. One
qualified FR is charged with monitoring the SNL facilities and
activities of approximately 1,000 contractor personnel in Livermore,
California, but he also serves as an SSO site manager for these remote
SNL facilities. The FR staffing analyses recorded in the DOE *Facility
Representative Program Performance Indicators Quarterly Reports* for the
past 3 years have reported a need for 12 FRs at SSO. It appears that SSO
has been underreporting its FR staffing needs since calendar year 2000.
Earlier FR staffing analyses from 1997 and 1999 showed that SSO needed
approximately 21-22 FRs to carry out required oversight
responsibilities.

LASO has 16 authorized FRs positions, of which 13 are filled. Of these
13, 10 FRs are fully qualified, and 2 others are previously qualified
FRs from other sites. LASO has vacancy announcements posted for 3 FR
positions, and has also submitted a request to the NNSA Administrator
for 2 more FR positions. In the past, LASO has reported a need for 19
FRs, but a staffing analysis from 2001 suggests a more sophisticated
approach to determining staffing needs that incorporates realistic
workload activities and takes into account historical turnover rates of
qualified FRs. The 2001 analysis showed that 24 FR positions were needed
to maintain coverage of LASO hazardous facilities, crediting 19
qualified FRs while allowing time for other FR candidates to qualify
(qualification time for an FR candidate is usually 9-18 months,
depending on the experience level of the individual). With the turnover
of a qualified FR occurring roughly every 3-4 years as a result of
lateral transfers, promotions, or departures, there is a measurable
impact on the availability of qualified FRs at LASO. This detailed
analysis methodology could be applied as well at other NNSA sites.

The LASO staffing analysis will need to be reperformed because of an
increase in the number of LASO facilities identified as nuclear during
efforts to develop the new or revised Documented Safety Analyses
required by 10 Code of Federal Regulations (CFR) 830, *Nuclear Safety
Rule*. Since last reported in the Board's letter of October 10, 2001,
LASO has identified 17 Hazard Category 2 nuclear facilities (an increase
of 5), 9 Hazard Category 3 nuclear facilities (an increase of 6), and 41
radiological facilities. (The 11 additional facilities are inactive
environmental facilities.) With an additional 350 moderate- to
low-hazard facilities under LASO's oversight, the FRs are continually
challenged to find time to observe the multitude of activities tasked
under the Los Alamos contract (valued at \$1.98 billion for fiscal year
2004). For example, it was reported that Technical Area-18, the Los
Alamos Critical Experiments Facility, had no FR coverage since December
2003.

**Staffing Analysis Guidance in DOE-STD-1063-2000.** The guidance for
determining the coverage and staffing requirements for FRs at a site set
forth in DOE-STD-1063-2000 does not adequately account for all of the
hazardous facilities in which DOE/NNSA have oversight responsibility.
The guidance addresses Hazard Category 1, 2, and 3 nuclear facilities,
but does not address nuclear facilities below Hazard Category 3 (i.e.,
radiological facilities). Additionally, the guidance does not clearly
capture other hazardous non-nuclear facilities under DOE/NNSA purview,
such as those facilities handling high explosives, chemicals, or
biological agents. DOE directives (i.e., DOE Order 5480.19 and DOE
Manual 231.1-2) require specific FR actions at all DOE facilities where
hazardous or industrial operations are conducted. Therefore, sufficient
FR staffing levels are needed to ensure the safe operation of these
hazardous non-nuclear facilities, especially if they are collocated with
defense nuclear facilities and could impact nuclear operations or
consume necessary resources needed for adequate coverage of a site's
defense nuclear facilities. Finally, the standard fails to consider all
of the responsibilities, time demands, workload, and turnover rates
affecting all FRs, as discussed above. Misapplication of the staffing
analysis guidance in DOE-STD-1063-2000 has contributed, among other
things, to allowing KCSO to discontinue its FR program and PXSO to
drastically reduce coverage of its non-nuclear hazardous facilities.

Follow-up discussions with the FR Program Manager indicate that
revisions to the guidance to address the issues raised above will be
considered during the upcoming update to DOE-STD-1063-2000. The Board's
staff further notes that a similarly rigorous approach is also needed in
the staffing analyses used to determine other federal technical staffing
needs at each of the sites within the defense nuclear complex. The
Board's staff has discussed with the Federal Technical Capabilities
Panel the need to upgrade its technical staffing analysis methodology to
meet this higher level of rigor.