**SEVENTEENTH ANNUAL REPORT**

**TO CONGRESS**

**DEFENSE NUCLEAR FACILITIES**

**SAFETY BOARD**

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**FEBRUARY 2007**

**\[DNFSB LETTERHEAD\]**

February 28, 2007

To the Congress of the United States:

The Defense Nuclear Facilities Safety Board is pleased to submit to
Congress its Seventeenth Annual Report. The Board is an independent
executive branch agency responsible for providing advice and
recommendations to the Secretary of Energy, and to the President if
necessary, regarding public health and safety issues at the Department
of Energy's defense nuclear facilities.

As required by statute, the Board\'s report summarizes activities during
calendar year 2006, assesses improvements in the safety of defense
nuclear facilities, and identifies remaining health and safety problems.

Respectfully submitted,

***A. J. Eggenberger***

***Chairman***

***John E. Mansfield***

***Member***

***Joseph F. Bader***

***Member***

***Larry W. Brown***

***Member***

***Peter S. Winokur***

***Member***

**PREFACE**

Congress created the Defense Nuclear Facilities Safety Board (Board) as
an independent agency within the Executive Branch (42 U.S.C. § 2286, *et
seq*.) to identify the nature and consequences of potential threats to
public health and safety at the Department of Energy's (DOE's) defense
nuclear facilities, to elevate such issues to the highest levels of
authority, and to inform the public.

The Board is required to review and evaluate the content and
implementation of health and safety standards, including DOE's orders,
rules, and other safety requirements, practices, and events relating to
system design, construction, operation, and decommissioning of DOE\'s
defense nuclear facilities. The Board makes recommendations to the
Secretary of Energy that the Board believes are necessary to ensure
adequate protection of public health and safety. The Board is also
empowered to conduct investigations, issue subpoenas, hold public
hearings, and establish reporting requirements.

The Board is required by law to submit an annual report to the
Committees on Armed Services and Appropriations of the Senate and to the
Speaker of the House of Representatives. This report is to include all
recommendations made by the Board during the preceding year, and an
assessment of: (1) the improvements in the safety of DOE\'s defense
nuclear facilities during the period covered by the report; (2) the
improvements in the safety of DOE\'S defense nuclear facilities
resulting from actions taken by the Board or taken on the basis of the
activities of the Board; and (3) the outstanding safety problems, if
any, of DOE\'s defense nuclear facilities.

On September 29, 2006, House Conference Report 109-702 on the National
Defense Authorization Act for Fiscal Year 2007 (H.R. 5122) was approved
by both houses of Congress. Section 3201 of this report directs the
Board to provide to the congressional defense committees quarterly
reports to identify and report the status of significant unresolved
issues. The first of these reports was submitted by the Board to
Congress on February 15, 2007.

The Board is currently evaluating 25 defense nuclear facility design
activities with a total project cost of about \$20 billion, which
includes \$12.2 billion for the Hanford Waste Treatment Plant. There are
outstanding safety issues associated with many defense nuclear projects
that need to be resolved early during the design phase. The Board and
DOE are working to arrive at an agreed-upon path forward for resolving
these outstanding issues at an early stage in the process.

**Table of Contents**

**Summary of Accomplishments in 2006** 7

**Outstanding Safety Problems of Defense Nuclear Facilities** 14

**Section 1: Introduction** 19

1.1 Background 19

1.2 Oversight Strategy 19

1.3 Strategic Plan 20

**Section 2: Nuclear Weapons Operations** 23

2.1 Safe Conduct of Stockpile Management 23

> 2.1.1 Pantex Plant 23
>
> 2.1.2 Y-12 National Security Complex 26
>
> 2.1.3 Savannah River Site Tritium Operations 28
>
> 2.1.4 Nuclear Material Packaging 28

2.2 Safe Conduct of Stockpile Stewardship 29

> 2.2.1 Los Alamos National Laboratory 29
>
> 2.2.2 Lawrence Livermore National Laboratory 30
>
> 2.2.3 Nevada Test Site 31
>
> 2.2.4 Sandia National Laboratories 33
>
> 2.2.5 Research and Development for Explosives Safety 33

**Section 3: Nuclear Materials Processing and Stabilization** 35

3.1 Stabilization and Storage of Remnant Materials 35

> 3.1.1 Complex-Wide 35
>
> 3.1.2 Plutonium 35
>
> 3.1.3 Uranium 36
>
> 3.1.4 Neptunium 36

3.2 Stabilization of Spent Nuclear Fuel 37

> 3.2.1 Hanford Site 37
>
> 3.2.2 National Spent Nuclear Fuel Program 37

3.3 Waste Management 38

> 3.3.1 High-level 38
>
> 3.3.2 Low-Level Waste and Transuranic Waste 39

3.4 Facility Deactivation and 41

> 3.4.1 Overview 41
>
> 3.4.2 Fernald Closure Project 41
>
> 3.4.3 Miamisburg Closure Project 41
>
> 3.4.4 Savannah River Site 42
>
> 3.4.5 Hanford Site 42
>
> 3.4.6 Idaho Cleanup Project 42

**Section 4: Nuclear Facilities Design and Infrastructure** 45

4.1 Introduction 45

4.2 Hanford Site 45

4.3 Savannah River Site 47

4.4 Y-12 National Security Complex 48

4.5 Los Alamos National Laboratory 49

4.6 Pantex Plant 49

4.7 Idaho Cleanup Project 50

4.8 Nevada Test Site 50

4.9 Seismic Hazard Analysis 50

**Section 5: Nuclear Safety Programs and Analysis** 53

5.1 Federal Oversight 53

> 5.1.1 Overview 53
>
> 5.1.2 Recommendations 95-2 and 2004-1 53
>
> 5.1.3 DOE Oversight Policy and Order 54
>
> 5.1.4 Vital Safety Systems 55
>
> 5.1.5 Activity-Level Work Planning 55
>
> 5.1.6 Small Business Contracting 55

5.2 Health and Safety Directives 55

> 5.2.1 Improvement of Directives 55
>
> 5.2.2 NNSA Policy Letters 56
>
> 5.2.3 Natural Phenomena Hazards 56
>
> 5.2.4 Worker Safety Rulemaking 56
>
> 5.2.5 Hazard Categorization 57
>
> 5.2.6 Scope of the Directives System 57

5.3 Safety Programs 57

> 5.3.1 Administrative Controls 57
>
> 5.3.2 Active Confinement Systems 58
>
> 5.3.3 Quality Assurance 58
>
> 5.3.4 Software Quality Assurance 59
>
> 5.3.5 Risk Assessment 59
>
> 5.3.6 Criticality Safety 59
>
> 5.3.7 Readiness Reviews 60

5.4 Technical Competence 61

> 5.4.1 Federal 61
>
> 5.4.2 Criticality Safety Engineers 61
>
> 5.4.3 Federal Facility Representatives 62

**Section 6: Public Outreach and Agency Administration** 63

6.1 Public Hearings 63

6.2 Responding to Public Requests 63

6.3 Electronic Access 63

6.4 Inquiries Into Health and Safety Issues 63

6.5 Site Representative Activities 63

6.6 Human Resources 64

6.7 Information Technology and Security 64

6.8 Dispute Resolution Programs 65

6.9 Financial Management 65

**Appendices**

A. Recommendations Cited 67

B. Reporting Requirements 69

C. Correspondence 71

**Summary of Accomplishments in 2006**

The nuclear weapons program of the Department of Energy (DOE), which
includes nuclear weapons operations conducted by the National Nuclear
Security Administration (NNSA), is a complex and hazardous enterprise.
Missions include maintenance of the national nuclear arsenal,
dismantlement of surplus weapons, stabilization and storage of surplus
nuclear materials, disposition and disposal of hazardous waste, and
cleanup of surplus facilities and sites. Some of these missions are
carried out with aging facilities while others demand the construction
of new facilities. The constant vigilance of the Defense Nuclear
Facilities Safety Board (Board) is required to ensure that all of these
activities are carried out by DOE in a manner that protects the public,
workers, and the environment.

During this past year, actions by the Board resulted in numerous health
and safety improvements that are summarized briefly below and in more
depth in the main body of the report. These improvements are described
in accordance with the Board\'s four strategic areas of concentration:

-   Nuclear Weapons Operations;

-   Nuclear Materials Processing and Stabilization;

-   Nuclear Facilities Design and Infrastructure; and

-   Nuclear Safety Programs and Analysis.

**Nuclear Weapons Operations**

The Board\'s strategic performance goal for this area is to ensure that
DOE operations directly supporting the nuclear stockpile and defense
nuclear research are conducted in a manner that provides adequate
protection of the health and safety of the workers and the public. The
Board\'s safety oversight activities in this area focus on assembly and
disassembly of weapons; processing and storage of uranium, plutonium,
and tritium; and research, development, manufacturing, and testing.

As a result of the Board\'s efforts during 2006, DOE has taken actions
to upgrade the safety of these activities. These actions include
improving safety systems and controls in aging facilities, achieving
safe packaging of nuclear weapons materials, improving the formality of
nuclear explosive and nuclear processing operations, enhancing the
quality of engineered safety systems, and correcting deficiencies in the
safety bases for new and ongoing activities.

Specific examples of safety improvements in weapons operations made by
DOE in consequence of the Board\'s work are given below.
Cross-references are provided to sections in the body of this report
where further details can be found.

Multiple Sites:

-   DOE is implementing improved requirements for development,
    evaluation, and documentation of nuclear weapon response to external
    stimuli. (Recommendation 98-2; Board letter dated December 14,
    2005)(Sec. 2.1.1)

-   DOE is revising two principal deliverables of its implementation
    plan for Recommendation 2005-1: (1) the repackaging prioritization
    methodology, and (2) the nuclear material packaging manual.
    (Recommendation 2005-1; Board letters dated April 24 and May 1,
    2006)(Sec. 2.1.4)

Pantex Plant (Sec. 2.1.1):

-   As a part of the implementation plan for Recommendation 98-2, DOE
    implemented Seamless Safety for the 21st Century processes for
    weapons programs with insensitive main charge high explosives (the
    W87, B61, and B83 programs). (Recommendation 98-2)

-   DOE completed the safe dismantlement of all W56 war reserve units,
    including certain units that required the development of new tooling
    and procedures. (Recommendation 98-2; Board letter dated July 20,
    2004)

-   DOE is taking a more comprehensive approach toward evaluating
    multi-unit operations. (staff-to-staff meeting, April 2006)

-   DOE completed a three-year effort to implement more than 200
    Technical Safety Requirements. (Recommendation 98-2)

-   DOE identified actions to improve the nuclear explosive safety
    process in response to the Top-Down Review advocated by the Board.
    (staff-to-staff meeting, June 2005)

Y-12 National Security Complex (Sec. 2.1.2):

-   DOE is performing maintenance-related structural fixes in the 9212
    Complex and plans to increase maintenance funding and pursue other
    facility infrastructure improvements to reduce material-at-risk in
    this facility. (Board letter dated April 20, 2005)

-   DOE upgraded the classification of key fire protection systems in
    the 9212 Complex to safety-class. (Board letters dated May 13,2002
    and February 28, 2006)

-   DOE developed a plan to improve conduct of operations. (Site
    Representative Weekly Reports)

-   DOE is improving the Uranium Holdup Survey Program. (Site
    Representative Weekly Reports)

Los Alamos National Laboratory (Sec. 2.2.1):

-   DOE took actions to ensure the continuity of the laboratory\'s
    institutional corrective actions programs as the laboratory
    transitioned to a new prime contractor. (Public Hearing, March 22,
    2006)

-   DOE is examining deficiencies in confinement ventilation at the
    Plutonium Facility. (Recommendation 2004-2; Board letter dated May
    31, 2005)

-   DOE developed plans to address deficiencies in fire protection.
    (Board letters dated March 31, 2003 and May 31, 2005)

-   DOE eliminated a single point of failure vulnerability in the
    high-voltage transmission lines that provide off-site power to the
    laboratory. (Board letters dated May 5, 1995 and September 22, 1999)

Lawrence Livermore National Laboratory (Sec. 2.2.2):

-   DOE was able to resume normal operations in the Plutonium Facility
    after ensuring that safety-related findings by the Board and DOE\'S
    Office of Independent Oversight had been investigated and procedures
    revised as needed for safe operations. (Board letters dated November
    3, 2004 and March 8, 2005)

-   DOE developed a revised documented safety analysis for the Plutonium
    Facility that represents a significant improvement over previous
    versions of the safety basis for this facility. (Board letter dated
    May 10, 2006)

-   DOE developed procedures and processes to identify and record the
    configuration of vital safety systems and to begin the process of
    maintaining a configuration management program for these systems.
    (Board letter dated November 3, 2004)

Nevada Test Site (Sec. 2.2.3):

-   DOE is performing rigorous reviews of the safety bases for
    subcritical experiments, the Criticality Experiments Facility
    Project, and defense nuclear facilities. (Board letters dated March
    27, 2006 and September 22, 2006)

-   DOE continued to make improvements in the facilities and processes
    necessary to dispose of a damaged nuclear weapon. (Board letter
    dated June 19, 2006)

-   DOE is assessing vital safety systems and safety management programs
    at the Device Assembly Facility. (Board letter dated November 28,
    2005)

-   DOE is mapping cracks and water leaks, fixing water leaks, and
    completing key seismic-related analyses at the Device Assembly
    Facility. (Board letters dated March 18, 2005 and August 16, 2006)

Sandia National Laboratories (Sec. 2.2.4):

-   DOE has continued to correct deficiencies in safety analyses and to
    remedy significant shortfalls in the site\'s integrated safety
    management system. (Board letters dated September 27, 2004 and
    October 8, 2004)

**Nuclear Materials Processing and Stabilization**

This area of work includes oversight of DOE\'s efforts to stabilize
remnant materials from past nuclear facility operations, packaging and
storage of those materials, and final disposition in approved waste
repositories. The Board also monitored DOE\'s efforts to decontaminate
and decommission retired nuclear facilities. Materials included in
DOE\'s stabilization efforts are liquid high-level radioactive wastes,
spent nuclear fuel, inactive radioactive actinide materials (which
include uranium and plutonium), low-level wastes, and transuranic
wastes.

Some of the Board\'s reviews in this area focused on specific issues at
individual facilities, while others involved safety topics with broad
implications for multiple defense nuclear facilities. Specific examples
of safety improvements made by DOE in response to the Board\'s actions
are given below. Cross-references are provided to sections in the body
of this report where further details can be found.

Complex-wide Safety Issues:

-   DOE acknowledged safety issues associated with the processing of
    transuranic waste and drafted a new standard designed to achieve
    consistency and enhanced safety in handling of transuranic waste
    across the complex. (Transuranic Waste Authorization Basis Workshop,
    March 2006; Board letter dated January 29, 2007)(Sec. 3.3.2)

-   DOE established a testing program and a new expert panel to study
    corrosion mechanisms in tanks that store liquid high-level wastes.
    This currently impacts primarily the Hanford Waste Storage Tanks.
    (Board letters dated January 18, 2005 and June 1, 2005)(Sec. 3.3.1)

-   DOE conducted analyses and identified new safety controls for
    hydrogen deflagrations in piping and vessels that contain high-level
    wastes at the Hanford and Savannah River Sites. (Board letters dated
    November 4, 2002 and October 17, 2005)(Sec. 3.3.1)

Fernald Closure Project:

-   DOE safely completed final site closure at the Fernald Site in Ohio.
    DOE\'s Office of Environmental Management transferred responsibility
    for the site to the Office of Legacy Management. (Board letters
    dated August 7, 2003 and February 2, 2005)(Sec. 3.4.2)

Hanford Site:

-   DOE directed that transuranic waste drums found to contain hydrogen
    gas be vented until the hydrogen dissipates to below 5 percent by
    volume, instead of 15 percent, which was far greater than the lower
    flammability limit. (staff-to-staff meeting, March 2006)(Sec. 3.3.2)

-   DOE postponed excavation of a burial ground containing spent nuclear
    fuel and other radioactive material. DOE plans to improve work
    planning and criticality safety prior to conducting the work. (Site
    Representative Weekly Reports)(Sec. 3.3.2)

Savannah River Site:

-   DOE removed combustible materials from the K-Area Material Storage
    facility, improving the fire protection posture there. (Annual
    Reports to Congress on Plutonium Storage at Savannah River Site,
    2004, 2005, 2006)(Sec. 3.1.2)

-   DOE finished the stabilization of pre-existing neptunium solutions,
    marking the completion of all Recommendation 94-1 and 2000-1
    milestones at the Savannah River Site. (Recommendations 94-1 and
    2000-l)(Sec. 3.1.1 and 3.1.4)

**Nuclear Facilities Design and Infrastructure**

The Board\'s strategic performance goal for this area is to ensure that
new defense nuclear facilities and major modifications to existing
facilities are designed and constructed in a manner providing adequate
protection of the health and safety of workers and the public. In the
past few years, there has been a substantial increase in the number of
design and construction projects under the Board\'s jurisdiction. DOE
has undertaken design and construction projects with a projected total
cost of about \$20 billion. The Board continues to devote extensive
resources to ensure that designs for defense nuclear facilities
incorporate multiple layers of safety controls commensurate with the
hazards.

DOE is not consistently addressing safety issues early in the design
process. Moreover, in an increasing number of new projects, DOE planned
to make use of closely-coupled \"design build\" techniques for
large-scale facilities, including some that will require hazardous
processes that lack definition. This approach entails considerable risk
when combined with DOE\'s shortage of personnel qualified to adequately
manage such projects. To highlight these problems and to gain further
information, the Board began a series of public hearings in December
2005 on incorporating safety into design and construction. The series
continued through 2006, and the Board is preparing for a third public
hearing to be held in the first quarter of 2007. This latest hearing
will focus on early issue identification, improved communications
between the Board and DOE, and timely resolution of safety issues early
in the design effort.

Specific examples of safety improvements in design and infrastructure
accomplished as a result of the Board\'s work are given below.
Cross-references are provided to sections in the body of this report
where further details can be found.

Hanford Site (Sec. 4.2):

-   DOE continued working to correct potential safety flaws in the
    design of the Waste Treatment Plant. Progress was-made in coating of
    structural steel for fire resistance and the development of design
    bases for mitigation systems used to prevent hydrogen deflagrations
    and detonations. DOE also has undertaken a seismic borehole project.
    The Board expects that ground motion modeling using data due to this
    drilling program will effectively validate the seismic design ground
    motion. DOE also developed new structural design criteria to address
    structural design issues raised by the Board. (Board letters dated
    October 17, 2005 and September 7, 2006)

-   DOE has improved the design for confinement of radioactive materials
    and worker protection for the Demonstration Bulk Vitrification
    Project. (Board letter dated September 7, 2005)

-   DOE is developing a revised safety basis for the Sludge Treatment
    Sub-project of the K-Basin Closure Project. When this work is
    finished in early 2007, the Board can complete its review of the
    project\'s design. (Board letter dated January 5, 2006)

Idaho National Laboratory (Sec. 4.7):

-   DOE directed the Integrated Waste Treatment Unit project to use a
    more conservative and commonly-used computer code for estimating
    radiological consequences for co-located workers and the public from
    postulated accidents. Further, the project conducted a review of key
    safety analysis inputs and subsequently changed them for many of the
    postulated accidents. These changes resulted in a more technically
    defensible safety design basis. (Board letter dated January 24,
    2007)

Los Alamos National Laboratory (Sec. 4.5):

-   DOE decided to classify the fire suppression system and the active
    confinement ventilation system for the Chemistry and Metallurgy
    Research Replacement Project facility as safety class and safety
    significant, respectively. This will be the first DOE facility to be
    designed and constructed with a safety-class fire protection system.
    If properly implemented, this action should result in acceptable
    safety controls for this facility. (staff-to-staff meetings; Site
    Representative Weekly Reports)

Nevada Test Site (Sec. 4.8):

-   DOE is performing a new structural and seismic analysis, plans to
    address water leaks, and is preparing a new safety analysis for the
    Critical Experiments Facility. However, the facility structure still
    has numerous cracks that are considered abnormal for a nuclear
    facility. The Board is considering further action on this subject.
    (Board letter dated March 18, 2005)

Savannah River Site (Sec. 4.3):

-   DOE undertook an extensive geotechnical site characterization
    program at the Salt Waste Processing Facility site, involving
    drilling and sampling of subsurface data, laboratory analysis of
    samples, and geotechnical analyses. Completion of the geotechnical
    engineering work at the Salt Waste Processing facility, including
    comprehensive DOE and peer reviews, will be critical to
    demonstrating that the design is adequate to withstand seismic
    hazards. Significant improvements in the structural analysis
    methodologies are also being implemented. (Board letters dated
    August 27, 2004 and January 10, 2007)

-   DOE successfully and safely started up the Tritium Extraction
    Facility. (Board letter dated December 19, 2002)

-   DOE corrected weaknesses in the hazards analysis for the 3013
    Container Surveillance and Storage Capability Project. (Board letter
    dated January 29, 2007)

Y-12 National Security Complex (Sec. 4.4):

-   DOE assigned additional personnel to monitor construction activities
    at the Highly Enriched Uranium Materials Facility and initiated
    other corrective actions in response to the Board\'s observations.
    (Site Representative Weekly Reports)

**Nuclear Safety Programs and Analysis**

The Board\'s strategic performance goal for this area is to ensure that
DOE develops, maintains, and implements regulations, contract
requirements, guidance, and safety programs that ensure adequate
protection of the health and safety of workers and the public. The
Board\'s oversight activities in this area focus on generally applicable
safety standards and on issues affecting a variety of defense nuclear
facilities.

As a result of the Board\'s efforts during 2006, DOE has taken actions
to strengthen the technical competence of its contractors and federal
employees, to establish and implement safety standards, and to improve
the quality of engineered safety systems. DOE has also taken measures to
enhance the effectiveness of oversight and integrated safety management.

Specific examples of improvements in nuclear safety programs and
analysis made in consequence of the Board\'s work are given below.
Cross-references are provided to sections in the body of this report
where further details can be found.

-   DOE strengthened its directives for oversight of complex,
    high-hazard nuclear operations and made progress implementing the
    new requirements in the complex. (Recommendation 2004- l)(Sec.
    5.1.2, 5.1.3)

-   DOE developed a new integrated safety management manual to clarify
    its expectations concerning implementation of integrated safety
    management by DOE personnel.

-   (Recommendation 2004- l)(Sec. 5.1.2)

-   DOE developed and implemented a process and criteria for delegating
    authorities to field personnel for fulfilling assigned safety
    responsibilities. (Recommendation 2004-1)(Sec. 5.1.2)

-   DOE developed and executed a Senior Technical Safety Manager Course.
    (Recommendation 2004- l)(Sec. 5.1.2, 5.4.1)

-   DOE developed a directive on \"operating experience\" and provided
    direction and a schedule for implementation. (Recommendation 2004-
    l)(Sec. 5.1.2)

-   DOE established two Central Technical Authorities with associated
    support staff that centralize technical expertise and operational
    awareness to assure adequate and proper implementation of nuclear
    safety requirements. (Recommendation 2004-1 )(Sec. 5.1.2)

-   DOE strengthened the oversight of nuclear criticality safety through
    more effective reviews by the Criticality Safety Support Group.
    (Recommendation 97-2)(Sec. 5.3.6)

-   DOE restructured and strengthened the Corporate Technical Intern
    Program. (Recommendation 2004-l)(Sec. 5.4.1)

-   DOE developed and issued a Ventilation System Evaluation Guidance
    document that identifies a set of design and performance attributes
    that ventilation systems are being evaluated against for
    identification of potential upgrades. (Recommendation 2004-2)(Sec.
    5.3.2)

**Outstanding Safety Problems of Defense Nuclear Facilities**

**Integration of Safety in the Design of New Defense Nuclear
Facilities**

The Board believes that improvement in the incorporation of safety in
design of new defense nuclear facilities is necessary. Therefore, the
Board began a series of public hearings, one in December 2005 and a
second in July 2006, concerning the integration of safety in design.
During the initial public hearing, the Board focused on the adequacy of
DOE\'s existing directives related to the design of new facilities. As a
result of the Board\'s first public hearing, DOE acknowledged that
safety was not being integrated consistently into the early stages of
the design of new defense nuclear facilities. DOE is revising its
relevant directives. These directives are expected to mandate an
appropriate set of requirements designed to better integrate safety into
the design of new defense nuclear facilities at the earliest stages of
project management.

During the second public hearing, the Board further explored integration
of safety in design and the progress being made in implementing DOE\'s
safety in design initiatives. DOE has made some progress in revising its
directives. The Order was recently revised to reflect senior DOE
management\'s objective of early integration of safety into the design
process. In particular, DOE Order 413.3A, *Program and Project
Management for the Acquisition of Capital Assets*, requires that safety
design reports be prepared at the conceptual design and preliminary
design stages, in addition to the preliminary documented safety analysis
prepared at the final design stage. These reports are envisioned to
contain an evaluation of the safety aspects of the design. The Order
delineates the need to charter an Integrated Project Team led by the
Federal Project Director at the conceptual design stage and further
clarifies the safety role of DOE\'s Central Technical Authority, Chief
of Defense Nuclear Safety, and Chief of Nuclear Safety. These are
positive changes that will enhance safety in design.

The Board is being proactive with DOE in promoting the timeliness of
issue resolution.

The Board\'s staff has met with DOE headquarters personnel, federal
project personnel, and contractor personnel to discuss several key
projects, including the Uranium Processing Facility at the Y-12 National
Security Complex and the Integrated Waste Treatment Unit at Idaho
National Laboratory. These meetings have been aimed at developing a
mutual understanding of the safety requirements for these new facilities
and establishing common expectations for early design maturity and early
identification of safety issues and their resolution.

Finally, the Board has scheduled a third public hearing for March 2007.
This hearing will be devoted to early issue identification,
communication of Board issues to DOE, issue management, and timely issue
closure or resolution.

**Reinvigorating Integrated Safety Management**

In 1995, the Board issued Recommendation 95-2, urging DOE to integrate
work planning and safety planning more effectively. The methodology that
evolved from this recommendation and from DOE\'s implementation plan is
termed integrated safety management. Integrated safety management is a
structured, comprehensive, common-sense approach to performing work
safely. Through integrated safety management, the Board has encouraged
DOE to identify and implement measures to protect the public, workers,
and the environment from nuclear, chemical, and physical hazards. The
identification of hazards and development of protective measures should
be integrated.

In 2001, DOE achieved a major goal in its commitment to integrated
safety management by verifying through comprehensive assessments that
the basic elements of integrated safety management had been implemented
at defense nuclear facilities. This was a commendable achievement. Over
the next three years, however, implementation faltered. In
Recommendation 2004-1, the Board identified the need to reinvigorate
integrated safety management through technical and operational
excellence based on nuclear safety standards subjected to rigorous
oversight. DOE\'s implementation plan of June 2005, and its subsequent
revision in October 2006, contained three major thrusts, one of which
directly addresses integrated safety management.

In 2006 the Board closed Recommendation 95-2 after determining that the
Recommendation 2004-1 implementation plan and the recently-issued
Integrated Safety Management System Manual contain the actions necessary
to reinvigorate the program. While progress has been made in 2006,
overseeing the execution of DOE\'s implementation plan will continue to
be a major focus of the Board\'s work in 2007.

**Reliable Operation of Safety Systems**

The Board remains committed to ensuring that DOE properly maintains
safety systems at defense nuclear facilities. Many defense nuclear
facilities were constructed decades ago.

Especially in light of the aging of these facilities, protective
features must be maintained in a serviceable and effective condition.
For new facilities, on the other hand, the Board focuses its attention
on ensuring that safety systems are correctly identified, designed, and
constructed.

Unfortunately, the Board continues to identify weaknesses in programs
critical to continued reliable operation of safety systems: maintenance,
testing, surveillance, quality assurance, detection and removal of
counterfeit parts, configuration management, training, conduct of
operations, and confinement strategies. DOE is working to make
improvements in many of these areas in response to related
recommendations from the Board, such as Recommendations 2000-2, 2002-1,
2004-1, and 2004-2. However, as DOE continues to extend the life of
aging facilities, and budgets tighten, there is constant pressure to
reduce the number of safety systems, to provide less effective
maintenance, or to defer necessary infrastructure improvements.

A typical example of this issue exists at the 9212 Complex at Y-12
National Security Complex. This collection of structures, built between
1947 and 1958, has numerous seismic deficiencies, including missing
bolts, missing or structurally inadequate braces, and inadequate beam
supports. The Board highlighted these issues in letters dated April and
November 2005. DOE\'s response indicated that the main long term action
necessary to support safe operation is to construct the planned Uranium
Processing Facility, which will be designed to efficiently meet modern
safety and security requirements. However, DOE has not fully defined the
remedies required to keep the 9212 Complex operational prior to
completion of the Uranium Processing Facility. The Board will continue
to stress to DOE the importance of ensuring the long-term reliability of
vital safety systems and the infrastructure needed to maintain them.

**Safe Retrieval, Handling, and Stabilization of Nuclear Materials**

The Board continues to provide close oversight of DOE\'s efforts to
safely retrieve, treat, and dispose of high-level wastes, spent fuel
sludges, inactive actinides, and transuranic wastes. Many of these
activities present significant programmatic and safety challenges to
DOE. For example, the project to retrieve radioactive sludges from the
K-Basins at the Hanford Site has experienced many delays and cost
overruns during the past decade. DOE has isolated some sludge in
suitable containers to prevent release to the environment but faces new
challenges in safely treating the sludge in a timely fashion.

At both the Hanford Site and the Savannah River Site, DOE is responsible
for the safe storage of tens of millions of gallons of high-level waste
tanks that have exceeded their original design lives. While DOE has
taken action to prolong the lives of the tanks, high waste levels in the
tanks continue to make transfer and treatment operations difficult.
Potential waste leaks and mistransfers threaten the safety of workers
and the environment. The Board works with DOE to ensure that it
continues to focus on the highest priority safety issues.

Many of DOE\'s facilities around the nation store large quantities of
transuranic wastes in drums, a significant portion of which are buried
under soil and in poor condition. The drums pose safety hazards,
including contamination, high radiation, and potential explosions from
the generation of hydrogen gas and volatile organic compounds. The Board
has urged DOE to improve the consistency and rigor of the safety
controls for these hazards. (Board letters dated January 5, 2006,
January 17, 2006, January 18, 2007 and January 29, 2007) Improved safety
becomes more important as DOE begins to retrieve and treat
remote-handled transuranic wastes that generate very high radiation
fields and must be handled by remote-controlled equipment. DOE is
planning to ship remote-handled wastes from the Idaho Cleanup Project to
the Waste Isolation Pilot Plant in 2007.

In 2006, the Board reviewed two principal deliverables of DOE\'s
implementation plan for Recommendation 2005-1: (1) nuclear material
packaging requirements and (2) a repackaging prioritization methodology.
The Board found that fundamental errors in analyses and narrowing of
scope had substantially precluded the intended benefits of both
documents. The Board identified these errors in analysis and reasoning
in letters dated April 24, 2006 and May 1, 2006. DOE\'s responses,
provided in letters dated June 8, 2006 and July 21, 2006, were not
satisfactory to the Board. Discussions between the Board and DOE
resulted in a DOE letter dated July 27, 2006, rescinding several of its
responses. Further discussions between the Board and DOE have resulted
in substantial progress toward resolving the Board\'s concerns. DOE
subsequently revised its implementation plan for Recommendation 2005-1
in a letter dated November 22, 2006, to reflect the delays in completing
these two principal deliverables. The Board will continue to hold DOE to
commitments it made to improve nuclear material packaging for protection
of workers.

**Deactivation and Decommissioning Operations**

DOE continues to deactivate, decontaminate, and decommission many
facilities at sites such as the Idaho Cleanup Project, Hanford Site,
Savannah River Site, Oak Ridge National Laboratory, and the Miamisburg
Closure Project. In the past, the Board has noted that operating
contractors lack the expertise to plan and conduct deactivation and
decommissioning work. (Examples include the Board\'s letters dated
February 11, 2005 and February 14, 2005.) In these cases, DOE must bring
in managers and workers who are familiar with the unique hazards of
these activities and who understand the continually changing nature of a
facility undergoing decommissioning. Specialists are needed in nuclear
criticality safety, fire protection, contamination control, and remote
measurement of nuclear materials in piping, vessels, and systems. The
Board will continue to provide close oversight of these projects.

**1. Introduction**

**1.1 Background**

The Defense Nuclear Facilities Safety Board is an independent federal
agency established by Congress in 1989. Simply stated, the Board\'s
mandate under the Atomic Energy Act is safety oversight of nuclear
weapons facilities managed by the Department of Energy. The nuclear
weapons program remains a complex and hazardous operation. DOE must
maintain in readiness a nuclear arsenal, dismantle surplus weapons,
dispose of excess radioactive materials, maintain aging facilities,
clean up surplus facilities, and construct new, complex, one-of-a-kind,
high-hazard facilities for many purposes. All of these functions must be
carried out in a manner that protects the public, workers, and
environment.

Congress established the Board as an independent agency to provide sound
technical safety oversight of DOE\'s defense nuclear weapons facilities
and operations. For that reason, the Board is composed of respected
experts in the field of nuclear safety. The Board has, in turn,
assembled a permanent staff with broad experience and competence in all
major aspects of safety.

The Board has established site offices at six high-priority defense
nuclear sites: Pantex Plant in Texas, Los Alamos National Laboratory in
New Mexico, Y-12 National Security Complex in Tennessee, Savannah River
Site in South Carolina, Hanford Site in the State of Washington, and
Lawrence Livermore National Laboratory in California. The site offices
provide the Board with a continuous presence at these locations. At
other locations, the Board maintains safety oversight by means of
regular onsite reviews by members of its technical staff.

During the Board\'s 17 years of operation, its priorities have evolved
with changes in the nuclear weapons program. The Board uses its
Strategic Plan, required by the Government Performance and Results Act,
to ensure that its limited resources remain focused on the most
significant health and safety challenges and keep pace with shifts in
those challenges from year to year. The Board\'s health and safety
oversight activities are closely tied to goals and objectives embodied
in this plan.

This Annual Report summarizes the Board\'s work during calendar year
2006. Sections 2, 3, 4, and 5 describe progress in the four major areas
of the Board\'s operations: Nuclear Weapons Operations, Nuclear
Materials Processing and Stabilization, Nuclear Facilities Design and
Infrastructure, and Nuclear Safety Programs and Analysis. Section 6
explains the Board\'s interactions with the public and reports on
administrative matters. Appendix A lists all recommendations cited in
this report, Appendix B lists all reporting requirements imposed on DOE
in 2006, and Appendix C contains a full list of the Board\'s 2006
correspondence.

**1.2 Oversight Strategy**

Maintaining an effective safety oversight program that fulfills the
broad mandates of the Board\'s enabling legislation requires continuing
reassessment of health and safety conditions throughout DOE\'s defense
nuclear complex. The Board concentrates its resources on the most
hazardous operations and complex safety issues, guided by its Strategic
Plan and the following principles.

-   **Oversight Role** - As an oversight but not a regulatory agency,
    the Board uses a variety of statutory powers to ensure adequate
    protection of the public and worker health and safety. While the
    Board is empowered to identify current and potential safety problems
    and to recommend solutions, DOE remains responsible for taking
    actions based on the Board\'s insights.

-   **Risk-Based Oversight** - The Board\'s safety oversight activities
    are prioritized predominantly on the basis of risk to the public and
    workers, types and quantities of nuclear and hazardous material at
    hand, and hazards of the operations involved.

-   **Technical Competence** - The Board has endeavored since its
    inception to ensure that DOE obtains and maintains the high level of
    technical expertise essential to the management of nuclear
    activities.

-   **Line Management** - Primary responsibility for safety resides in
    DOE and contractor management. Safety oversight can reinforce but
    not substitute for the commitment of line management and workers to
    safe work planning and performance.

-   **Clear Expectations** - Effective safety management demands that
    safety expectations be clearly defined and tailored to specific
    hazards. Work instructions that are clear, succinct, and relevant to
    the work are more likely to be embraced by workers.

-   **Effective Transition Planning** - The Board\'s safety oversight of
    defense nuclear facilities is coordinated with other federal
    agencies and with state governments to ensure a smooth transition
    from deactivation and decommissioning to environmental regulation.

The Board is provided by statute with a number of tools to carry out its
mission. Among these are recommendations (typically broad and
comprehensive in nature), reporting requirements (focused on specific
safety issues), and public hearings (used to obtain information from
DOE, other expert sources, and the public at large). Since 1989 when the
Board began operations, it has issued 48 formal recommendations,
comprising 221 individual sub-recommendations. In that same period of
time, the Board has issued 184 reporting requirement letters and held 94
public hearings.

3.  **Strategic Plan**

The Board organizes its safety work by merging the broad health and
safety mandate of its statute with the requirements of the Government
Performance and Results Act. The Board\'s Strategic Plan identifies the
serious hazards of handling nuclear weapons and weapons materials, and
disposing of aging and surplus facilities. These hazards include:

-   Tons of radioactive and toxic materials throughout the defense
    nuclear complex, some stored in an unstable state.

-   Aging facilities that require ever-increasing maintenance and
    surveillance to assure safety.

-   The potential for accidental releases caused by inadequate safety
    controls, human errors, equipment malfunctions, chemical reactions,
    building fires, detonations, and criticality events.

-   Natural phenomena such as wildfires, earthquakes, extreme winds,
    floods, and lightning.

Given these hazards, safety can be assured by the adoption of a
conservative engineering philosophy that hinges on reliable systems and
multiple layers of protection. This concept is called \"defense in
depth,\" and it has been a precept of nuclear safety in the United
States for many decades. Defense in depth is especially important with
respect to the handling of high explosives in proximity to radioactive
material.

The Board\'s Strategic Plan sets forth four general goals:

-   *Nuclear Weapons Operations*: Operations that directly support the
    nuclear stockpile and defense nuclear research are conducted by DOE
    in a manner that ensures adequate protection of the health and
    safety of workers and the public.

-   *Nuclear Materials Processing and Stabilization*: Processing,
    stabilizing, and disposing of hazardous nuclear materials are
    performed by DOE in a manner that ensures adequate protection of the
    health and safety of workers and the public.

-   *Nuclear Facilities Design and Infrastructure*: New defense nuclear
    facilities and major modifications to existing facilities are
    designed and constructed by DOE in a manner that ensures adequate
    protection of the health and safety of workers and the public.

-   *Nuclear Safety Programs and Analysis*: Regulations, requirements,
    guidance, and safety management programs adequate to protect public
    health and safety, including workers, are developed and implemented
    by DOE.

**2. Nuclear Weapons Operations**

**2.1 Safe Conduct of Stockpile Management**

Stockpile management refers to the industrial aspects of maintaining the
nation\'s nuclear weapons stockpile. Examples of the Board\'s activities
to improve health and safety in stockpile management are discussed in
the following subsections.

**2.1.1** **Pantex Plant**

The Pantex Plant, located near Amarillo, Texas, serves a central role in
stockpile management. Operations at the site include assembly,
disassembly, dismantlement, and surveillance of weapons, as well as
interim storage of special nuclear material removed from retired
weapons. In 2006, the Board sought health and safety improvements in
weapons operations, requirements for the evaluation of weapons response
to external stimuli, implementation of the special tooling program, and
implementation of multi-unit operations.

**Nuclear Explosive Safety.** In response to a commitment made to the
Board in 2005, DOE conducted a comprehensive \"Top-Down Review\" of its
nuclear explosive safety directives to determine if existing
requirements are being implemented effectively, and to propose
improvements to the requirements for ensuring the safety of nuclear
explosive operations. On November 2, 2006, the Assistant Deputy
Administrator for Military Application and Stockpile Operations issued a
corrective action plan to implement 11 of the 20 recommendations from
the Top-Down Review. The Board is conducting its own review of the
nuclear explosive safety process and has identified a number of
additional issues to be addressed in 2007.

**W88 Cell Operations.** During 2006, Los Alamos National Laboratory
requested that the W88 program take steps to restart cell operations to
perform disassembly and inspection on a limited number of units to
support a high priority, safety-related significant finding
investigation. In order to meet this request in a timely manner, the
Pantex Plant contractor requested a temporary exemption from the
documented safety analysis requirements of 10 CFR (Code of Federal
Regulations) Part 830, *Nuclear Safety Management*, subpart B. In a
letter dated August 9, 2006, the Board requested that the Deputy
Administrator for Defense Programs consider compensatory measures for
the proposed disassembly and inspection operations. In addition, the
Board requested justification for proposed rebuild operations and any
additional operations performed beyond the three units identified by Los
Alamos, and that NA-10 consider the impact of the proposed operations on
the timely implementation of a Seamless Safety for the 21st Century
process for W88 cell operations. The Deputy Administrator provided the
requested information to the Board and issued a temporary exemption
limited to the disassembly and inspection and rebuild of three specific
units. Direct observation of sensitive operations by laboratory experts
was instituted as an additional safety measure.

To ensure a safe approach to restart of W88 cell operations, the Board
observed the limited scope nuclear explosive safety study, DOE\'S
readiness assessment, and disassembly of the first W88 unit, which was
in process at the end of 2006. The Board is continuing to press DOE to
develop a firm schedule for implementing an SS-21 process for W88
operations.

**Recommendation 98-2.** NNSA management continued to provide the Board
with regular briefings on the status of commitments in the
implementation plan for Recommendation 98-2. DOE completed the
commitment to implement an SS-21 process for a weapons program with
insensitive main charge explosives by implementing such a process for
the B61, B83, and W87 programs in 2006.

In May 2006, DOE issued a revision to *Hazard Analysis Reports for
Nuclear Explosive Operations* (DOE-STD-3016), which was intended in part
to close the commitment in the implementation plan for Recommendation
98-2 to provide further guidance on expectations for the development and
documentation of weapons response information. In a letter dated August
16, 2006, the Board provided comments to DOE on the revision to the
standard. DOE briefed the Board on its responses to the Board\'s
comments and described its planned approach to ensuring that hazard
analysis reports and weapons response information were adequate.
However, follow-up reviews by the Board found that there was still no
clear plan for implementing improved processes for developing and
documenting weapons response information. Therefore, in a letter dated
December 15, 2006, the Board requested that the Final Assessment Report
required by the implementation plan for Recommendation 98-2 include an
explicit description of DOE\'s plans and criteria for review and
approval of the design agencies\' processes for expert elicitation,
expert judgment, and peer review as required by DOE-STD-3016.

**Cell Gap Analysis.** The Board evaluated calculations of leakage
through gaps in cells.

These calculations were performed to better understand the consequences
of potential accidents at the Pantex Plant. Based on these calculations,
leakage through cell gaps does not appear to be an issue for accident
scenarios involving single-unit operations. However, there is still a
concern that accident consequences for multi-unit operations involving
certain systems in certain facilities could challenge the evaluation
guidelines. DOE will perform additional analyses to provide assurance
that the evaluation guidelines will not be challenged for multi-unit
operations.

**Electrostatic Discharge.** The Board evaluated efforts by DOE and the
weapons design

agencies to characterize potential electrostatic discharge effects and
the response of sensitive components to them. Progress has been made in
defining the environments and the associated hazards; however, the Board
has identified the need for additional clarification with respect to
furniture (e.g., tooling and equipment), capacitive coupling between the
insulting objects and other nearby charged objects, the assumption of
electrical isolation of tools within the established standoff boundary,
and resonance conditions and effects.

**Special Tooling Program.** In a letter dated December 15, 2004, the
Board expressed concern that continuing weaknesses in the Special
Tooling Program could have an adverse impact on the safety of nuclear
explosive operations that rely on specially designed tools to eliminate
or minimize hazards. In response, DOE conducted a comprehensive,
independent review of tooling program deficiencies and committed to
implementing corrective actions. The Board reviewed the program in March
2006 and determined that the safety and efficiency of nuclear explosive
operations had been enhanced.

**Seamless Safety for the 21st Century.** In 2006, the Board evaluated
the start-up of the Seamless Safety processes for the W87 and B61
Disassembly & Inspection and Rebuild Programs and the B83 Disassembly &
Inspection Program. The enhanced processes utilize upgraded procedures,
redesigned tooling, and fewer handling and lifting steps. These
improvements make the operations significantly safer and more efficient
than their predecessors.

**Safety of Dismantlement Operations.** The Board evaluated process
development and execution of the W56 dismantlement campaign at Pantex.
The Board urged DOE to ensure that laboratory expertise, both active and
retired, was applied to resolve technical challenges that arose to help
ensure the safe and successful completion of the dismantlement campaign.
Dismantlement of all W56 war reserve units was safely completed in June
2006.

The Board continued to evaluate DOE\'s plans to dismantle an older
weapons system not protected by modern safety controls. The Board
expressed concern to DOE regarding proposed disassembly activities at
non-DOE facilities that did not have adequate safety programs and
systems. DOE no longer plans to use such facilities; dismantlement
operations are now planned for Pantex facilities.

**Conduct of Operations.** In response to a Board letter issued in May
2005 identifying deficiencies in the conduct of nuclear explosive
operations at Pantex, DOE initiated efforts to address the cause of the
deficiencies and to develop both near- and long-term plans to improve
the conduct of operations. After a follow-up review, the Board issued a
letter to DOE in March 2006, re-emphasizing the importance of a
consistently high degree of formality in the conduct of nuclear
explosive operations, and favorably noting the extensive involvement of
senior contractor management in developing and implementing improvements
in conduct of operations at Pantex. As proposed improvements are
implemented and the process matures, the Board expects to see continued
improvement in this area. The Board is continuing to evaluate
improvements in the formality of work through daily operational
oversight provided by its site representatives.

**Multi-Unit Operations.** The Board is evaluating the safety
implications of the implementation of multi-unit nuclear explosive
operations at Pantex, which are being pursued in support of increasing
throughput. In response to the Board\'s observations, Pantex is taking a
more comprehensive approach to evaluating the implementation of
multi-unit operations, including analyzing human factors considerations.
In addition, the Board has urged Pantex to become more closely involved
with studies being performed by the design agencies that will aid in
evaluating the increase in risk associated with performing multi-unit
operations.

**Technical Safety Requirement Implementation.** In October 2006, the
contractor at Pantex completed the implementation of more than 200
Technical Safety Requirements.

Continued engagement by the Board during this three-year effort resulted
in the implementation of some new controls and improved the overall
quality of the safety basis documents. DOE has so far verified
implementation of 138 of these controls. The Board will continue to
monitor implementation of Technical Safety Requirements.

**2.1.2 Y-12 National Security Complex**

Y-12 National Security Complex is a manufacturing facility located in
Oak Ridge, Tennessee. Stockpile management activities at Y-12 include
production, maintenance, refurbishment, dismantlement, evaluation, and
storage of certain components of nuclear weapons. Production activities
include manufacture or re-manufacture of unique nuclear weapons
components. The Board\'s most recent efforts to improve safety at Y-12
concentrated on highly enriched uranium processing, conduct of
operations, fire protection, and the safety of several new or modified
processing capabilities.

**9212 Complex Seismic Deficiencies.** The 9212 Complex at Y-12 is a
collection of structures built between 1947 and 1958 for processing
highly enriched uranium. While updating the complex\'s safety basis in
2004, DOE noted numerous seismic deficiencies, including missing bolts,
missing or structurally inadequate braces, inadequate beam supports, and
designs that are deficient when measured by current design requirements
for nuclear facilities. In addition to the facility structure, internal
systems are subject to seismic failure, including tall glass columns and
sight glasses, can restraints, storage racks, and storage tanks.

In response to Board letters issued in April and November 2005, DOE
agreed to perform maintenance-related fixes and other practical facility
modifications to the 9212 Complex and to perform a review to identify
other actions needed to support safe operations. DOE provided the
results of this review to the Board in November 2006. The reviewers
concluded that the most practical approach to improving the safety
posture of the 9212 Complex is to reduce the inventory of nuclear
materials in the facility. DOE plans to increase maintenance funding and
pursue other facility infrastructure improvements while working to
accomplish that inventory reduction.

DOE\'s response also indicated that the main long term action necessary
to support safe processing of highly enriched uranium at Y-12 is to
construct the planned Uranium Processing Facility, which will be
designed to efficiently meet modern safety and security requirements. By
year\'s end, however, DOE had not defined the point at which more
aggressive remedies would be required to keep the 9212 Complex
operational, should this facility be delayed, and what those remedies
would entail. The Board is continuing discussions with DOE on this
matter.

**9212 Complex Safety Analysis.** The Board reviewed a draft version of
the documented safety analysis for the 9212 Complex, the final Y-12
facility to implement a safety basis in accordance with 10 CFR Part 830.
The Board noted weaknesses associated with the calculation of off-site
consequences that resulted in improper classification of safety systems,
including certain fire protection systems. The Board communicated these
issues to DOE in a letter in February 2006. In response, DOE upgraded
the classification of key fire protection systems to safety-class.
Discussions continue with DOE on the safety analysis methodology for
Y-12 facilities.

**Conduct of Operations.** The Board had noted overall improvement in
the proper conduct and formality of nuclear operations at Y-12 during
recent years. However, following several operational errors and events
at this facility, the Board urged DOE to consider special action to
achieve consistent, disciplined operations in Y-12 nuclear facilities.
Examples included failure to adhere to criticality safety requirements,
an inadvertent hazardous gas release, and conduct of a nuclear operation
without proper authorization. DOE evaluated the concerns and concluded
that the events were generally caused by lack of adherence to procedures
or nonconservative decisions by operations personnel upon encountering
an unanticipated condition. DOE developed a plan in December 2006 that
outlines actions to address these causes. With proper implementation,
the plan should improve conduct of operations at Y-12.

**Uranium Holdup Survey Program.** The Y-12 Uranium Holdup Survey
Program is used to monitor accumulations of enriched uranium in process
systems to protect against an inadvertent criticality. DOE developed a
corrective action plan to address issues identified by both DOE\'s and
the Board\'s assessment in 2005 and for operational events in 2006 where
the program failed to identify fissile material accumulations. During
2006, DOE made progress on equipment upgrades and in improving the
formality in identifying and responding to high accumulations of
enriched uranium. DOE also implemented a new approach to evaluate
uranium holdup using design features, periodic cleanout, and routine
hold-up monitoring in combination for all uranium process operations
that rely on the holdup program.

**Criticality Safety.** In April, the Uranium Holdup Survey Program
indicated a large holdup in a filter in a system providing vacuum to
uranium casting furnaces. Initial criticality safety assessments
concluded that lack of moderation was the only remaining contingency
precluding a criticality accident. Subsequently, a moderator (oil) was
observed to have leaked from the filter housing. This represented a
serious safety concern. The Board provided input regarding assay
procedures, criticality calculations, and the approach to filter
cleanout for DOE\'s consideration in developing a recovery plan. The
Board\'s input resulted in a more demonstrably safe recovery operation.

**Fire Protection.** In response to Board correspondence in 2002, DOE
developed a ten-year comprehensive improvement plan for fire protection
at Y-12. Significant improvements were subsequently made in many facets
of fire protection, such as maintenance of systems, analysis of fire
hazards, and inspection of fire barriers. Progress stalled in 2006 due
to a cut in funding for the project. The Board queried DOE on plans for
completing the project. DOE committed to provide a revised plan in early
2007.

**Quality Assurance.** Because of quality assurance problems found
during construction of the Highly Enriched Uranium Materials Facility,
and other site-wide quality assurance problems identified in early 2006,
DOE developed a site-wide corrective action plan. The Board reviewed the
plan and provided specific comments. Based on this feedback, DOE
chartered a local steering group to review the effectiveness of
completed corrective actions, and the contractor provided
corporate-level resources to conduct a review of corrective action
progress.

**Conduct of Engineering.** In 2005, Y-12 personnel discovered that the
design of a new vessel installed for blending enriched uranium materials
would not preclude a criticality accident in a water intrusion scenario.
A design change was necessary to correct this deficiency. Subsequently,
the Board found that a planned Y-12 investigation of this engineering
deficiency had not been completed. In response to an inquiry by the
Board, Y-12 completed the investigation and developed corrective
actions. The Board found that the corrective actions did not fully
address the lack of an appropriate design review of the new
installation. At year\'s end, Y-12 was evaluating its engineering
protocols regarding performance of design reviews for the installation
of new process equipment and systems.

3.  **Savannah River Site Tritium Operations**

**Tritium Extraction Facility.** The Tritium Extraction Facility will be
used to extract tritium from target rods irradiated in commercial light
water reactors. The extracted tritium will be used to replenish tritium
reserves for the nation\'s nuclear weapons stockpile. During 2006, the
Board reviewed startup preparations, observed readiness reviews
conducted by the contractor and by DOE, and as the year ended, monitored
the startup of nuclear operations. During the readiness reviews, the
contractor demonstrated the ability to safely perform extraction
evolutions, but did not demonstrate the ability to routinely conduct
these evolutions without frequent work interruptions or compensatory
actions to address equipment reliability issues. Frequent problems were
encountered with the ventilation system, the Tritium Rod Preparation
Module, various cranes, several electronic procedures, and the Tritium
Air Monitoring System. While these problems were handled correctly, the
Board encouraged the Savannah River Site to take full advantage of site
programs for System Health Reports and performance monitoring, because
repeated equipment problems can lead to complacency (i.e., deficient
conditions become viewed as normal) and other conduct of operations
problems.

4.  **Nuclear Material Packaging**

**Recommendation 2005-1.** The Board issued Recommendation 2005-1 to
provide more reliable protection for workers from the hazards associated
with storage and handling of nuclear materials. The recommendation
stated, and DOE accepted, the fundamental principle that this would be
achieved by issuing a requirement that \"nuclear material packaging meet
technically justified criteria for safe storage and handling.\" In 2006,
the Board reviewed two principal deliverables of DOE\'S implementation
plan for Recommendation 2005-1: (1) a methodology for assigning
priorities to repackaging operations, and (2) a manual for these
operations.

The methodology was issued by DOE on March 31, 2006. In a letter dated
April 24, 2006, the Board pointed out errors in analysis and reasoning.
DOE\'s response, provided in a letter dated July 21, 2006, was not
satisfactory to the Board and was partially rescinded by DOE in a letter
dated July 27, 2006, pending further discussions between DOE and the
Board. DOE subsequently revised its implementation plan for
Recommendation 2005-1 in a letter dated November 22, 2006, noting that
the methodology was being further evaluated based on comments from the
Board and would be revised and reissued, if warranted, by February 28,
2007.

In its implementation plan, DOE committed to issuing packaging
requirements for \"materials that are stored outside of an approved
engineered contamination confinement barrier, such as a glovebox or
packages meeting DOE-STD-3013 and/or DOE-STD-3028.\" These requirements
are to be issued as a new DOE Nuclear Material Packaging Manual, a draft
version of which was sent to Board for comment on March 31, 2006. In a
letter to DOE dated May 1, 2006, the Board identified deficiencies that
would undermine the safety benefits of the manual if not appropriately
resolved, such as wording that would allow the sites to exclude many
hazardous nuclear materials from the scope of the manual without
ensuring that adequately engineered protection would be provided for
workers. DOE\'s response, provided in a letter dated June 8, 2006, was
not satisfactory to the Board. Further discussions between the Board and
DOE have resulted in substantial progress toward resolving the Board\'s
comments on the draft packaging manual. DOE\'s revised implementation
plan for Recommendation 2005-1 commits to submitting the packaging and
storage requirements document into DOE\'s Directives System by February
28, 2007. The Board will continue to ensure that DOE meets its
commitment to improve nuclear material packaging for protection of its
workers.

1.  **Safe Conduct of Stockpile Stewardship**

*Stockpile stewardship* refers to activities carried out in the absence
of underground nuclear weapons testing to ensure confidence in the
safety, security, and reliability of nuclear weapons in the nation\'s
stockpile. Stockpile stewardship includes using past nuclear test data
in combination with future non-weapons test data and aggressive
application of computer modeling, experimental facilities, and
simulations. Safety aspects of activities at the major sites engaged in
stockpile stewardship are discussed in the following subsections.

1.  **Los Alamos National Laboratory**

Los Alamos National Laboratory, located in New Mexico, is the DOE
weapons laboratory with the largest number of defense nuclear facilities
and weapons-related activities. In 2006, a new contracting structure was
put in place for management of the laboratory. The Board focused its
attention on institutional corrective actions, federal oversight, active
confinement ventilation, nuclear criticality safety, fire protection,
and transuranic waste operations.

**Institutional Corrective Actions.** The Board spent considerable
effort, including holding a public hearing on March 22, 2006, reviewing
DOE\'s institutional corrective action programs and heightening
awareness of the need to maintain these programs through contract
transition. Corrective actions focus on key areas including safety,
quality assurance, software quality assurance, conduct of engineering,
safety bases, conduct of operations, environmental risk management, and
training. The Board has urged DOE to adequately fund corrective action
plans.

**Federal Oversight.** On October 1, 2006, DOE began a two-year pilot of
a new federal oversight model at the Los Alamos Site Office. The pilot
increases the federal presence in nuclear and high hazard facilities and
relies on the contractor\'s assurance systems to monitor less hazardous
operations. The Board objected to the concept of the pilot and raised
specific concerns including the lack of compensatory measures in
oversight for the period of time it takes for the contractor\'s
assurance system to reach full effectiveness and maturity; the absence
of federal oversight of radiological facilities under the pilot; and
significant weaknesses in the technical capability of the federal
workforce.

**Confinement Ventilation at the Plutonium Facility.** The current
safety basis for the Plutonium Facility relies on a passive confinement
strategy that does not credit active confinement ventilation for
protecting the public from postulated accidents. In response to issues
raised by the Board, a comprehensive set of airflow calculations was
performed to estimate potential releases under accident conditions. The
analysis demonstrated that the passive confinement strategy was
inadequate, and the laboratory developed preliminary compensatory
measures and alternatives for the confinement strategy. Under the
implementation plan for the Board\'s Recommendation 2004-2, confinement
ventilation at this facility is now being assessed on a high priority
basis with an accelerated schedule. The Board will continue to review
and provide feedback to DOE.

**Fire Protection.** On May 15, 2006, the Board received DOE\'s response
to issues previously identified by the Board regarding the need to
define a multi-year strategy for timely resolution of all fire
protection deficiencies and achievement of site-wide improvements.
Issues requiring resolution included incomplete documentation and delays
in the completion of inspections, tests, and maintenance; untimely
implementation of fire hazard analysis recommendations; no formal plan
to address the Baseline Needs Assessment for fire and emergency
services; no long-term contract for fire and emergency services with Los
Alamos County; and fire alarm systems in several defense nuclear
facilities still requiring upgrades. DOE is currently updating the
strategy to reflect additional scope and funding adjustments. Overall,
the Board has succeeded in increasing management attention to the fire
protection problems, but these problems will take additional analysis,
time, and attention to fully resolve.

**Transuranic Waste Operations.** The Board has been closely following
efforts to safely dispose of the laboratory\'s large inventory of
transuranic waste, which is packaged in drums and other containers
within several hundred meters of the site boundary. Some of the highest
consequence accidents postulated at the laboratory involve this
transuranic waste inventory. The Board has urged DOE to expeditiously
develop a viable disposition pathway for this waste.

**Support of Nuclear Weapons Operations at Pantex.** In August 2006, the
Board assessed the laboratory\'s protocols for support of operations at
the Pantex Plant. With respect to elements of the Board\'s
Recommendation 2002-2, the Board found a lack of succession planning for
weapons system experts. The Board also observed a lack of progress
toward developing a formalized expert elicitation (or expert judgment)
process for review of weapons response information, which in part led to
the Board\'s December 15, 2006, letter to DOE requesting its plans for
the review and approval of these essential design agency processes.

**Power Grid Infrastructure Upgrade Project.** In reports dated May 5,
1995, December 5, 1996 and September 22, 1999, the Board noted that a
single-point failure vulnerability existed in the high-voltage
transmission lines that provide off-site power to the laboratory. A
failure at this single point, where aerial transmission lines from each
of the independent feeds crossed, could have isolated the laboratory
from off-site power for an extended time until repairs could be
performed. In response, DOE initiated a project to eliminate this
single-point failure vulnerability by providing an independent power
feed to the existing Western Tech Area substation. Construction of the
independent power feed was completed in 2006, and overall project
completion is scheduled for spring 2007.

2.  **Lawrence Livermore National Laboratory**

Lawrence Livermore National Laboratory, located 45 miles southeast of
San Francisco, California, is a nuclear weapons research and development
laboratory. It provides technical expertise to support stockpile
stewardship and management, including consulting on the surveillance and
dismantlement of nuclear weapons. Most defense nuclear activities are
conducted in the Superblock complex, which includes the Plutonium
Facility and the Tritium Facility. During 2006, the Board conducted
reviews of resumption of operations in the Plutonium Facility,
configuration management of vital safety systems at the Superblock
facilities, criticality safety, fire protection, and conduct of
operations.

**Resumption of Plutonium Facility Operations.** In January 2005, DOE\'s
Office of Independent Oversight and Performance Assurance issued a
report identifying serious deficiencies in the administrative control
programs mandated by the Technical Safety Requirements for the Plutonium
Facility (including the configuration management program), as well as
deficiencies in the supporting analyses for safety systems. Because of
these findings, the laboratory suspended programmatic operations in the
Plutonium Facility. The Board issued a letter to DOE on March 8, 2005,
cautioning against resuming operations until the assessment report\'s
findings had been adequately studied and requesting a report on planned
corrective actions. On October 11, 2005, DOE authorized the resumption
of limited operations in the Plutonium Facility using a process for
achieving and verifying readiness found generally acceptable by the
Board. In April 2006, the Board observed the laboratory\'s readiness
assessment to remove the remaining compensatory measures and return to
normal operations, and determined that operations could safely resume.
On May 23, 2006, DOE authorized the laboratory to resume normal
operations.

**Configuration Management.** In a November 2004 letter, the Board
identified the apparent lack of configuration management of vital safety
systems at Lawrence Livermore facilities. DOE responded on January 4,
2005, agreeing that prompt action needed to be taken to review the
configuration and condition of all vital safety systems in defense
nuclear facilities at the laboratory. During 2005, DOE completed
evaluations of the application of configuration management for the vital
safety systems at Lawrence Livermore defense nuclear facilities and
developed plans to establish the needed configuration management
program. During 2006, the laboratory established procedures and
processes to maintain an interim configuration management system. The
Board reviewed this system and found it to be reasonably adequate to
support operations while a more durable institutionalized program is
developed and implemented.

**Criticality Safety.** In response to the Board\'s Recommendation 97-2,
DOE established an interim capability at the laboratory in 2006 for
hands-on criticality safety training that meets DOE- STD-1135-99,
*Guidance for Nuclear Criticality Safety Engineer Training and
Qualification*. Training classes previously held at Los Alamos National
Laboratory had been halted pending the establishment of a suitable
location. Lawrence Livermore conducted the first hands-on training class
in September 2006.

3.  **Nevada Test Site**

The Nevada Test Site is located in southern Nevada, about 75 miles
northwest of Las Vegas. Stockpile activities at the Test Site include
test readiness preparations, planning for the disposition of damaged
nuclear weapons, and subcritical experiments. Underground testing of
nuclear weapons is no longer being conducted; however, the site is
maintained in a state of readiness should national security requirements
demand the resumption of underground testing. The Board seeks to ensure
that if testing is resumed, it will be done safely. During 2006, the
Board focused its attention on the Device Assembly Facility, test
readiness posture, capability to dispose of a damaged nuclear weapon,
subcritical experiments, and conduct of transuranic waste operations.

**Device Assembly Facility.** The Device Assembly Facility is a key
structure at the Nevada Test Site, intended to house diverse operations
including nuclear explosive operations and criticality experiments. In
2004, the Board requested that DOE assess the Device Assembly
Facility\'s safety systems and management programs. DOE attempted to
respond by using the site office\'s assessment program, but this was
ineffective in delivering a comprehensive assessment. The Board wrote to
DOE again on November 28, 2005, requesting that more aggressive action
be taken with respect to the assessment of the safety systems and
management programs needed to ensure that the Device Assembly Facility
is ready for planned increases in the scope of work. In response, DOE
developed assessment plans for each vital safety system and safety
management program and began assessments in 2006. Assessments and
corrective actions will continue in 2007.

The Board evaluated the physical condition of the Device Assembly
Facility and found extensive rainwater leakage and extensive cracking in
the facility\'s walls and floors. The Board advised DOE in a letter
dated March 18, 2005, that an immediate and thorough evaluation was
needed. DOE has taken suitable remediation actions, but the Board is
still concerned that the extensive cracking might have been the result
of poor construction practices that adversely affected the concrete\'s
in situ strength. The Board has advised DOE that it would be prudent to
evaluate the in situ concrete compressive strength using non-destructive
investigation techniques, assess the potential for long-term rebar
corrosion, and assure confinement and leak tightness of the bays and
cells. However, DOE has declined to perform in situ testing of the
concrete. The Board is considering further action on this subject.

**Damaged Weapons.** The Board has consistently highlighted to DOE the
need to develop the programs and infrastructure necessary to safely
dispose of a damaged nuclear weapon or improvised nuclear device. G
Tunnel at Nevada Test Site is the location DOE has selected for these
activities. In a March 28, 2005 letter to DOE, the Board noted the slow
progress in defining and executing an action plan for addressing known
problems with G Tunnel. The Board subsequently determined that DOE no
longer had a clear plan for meeting this programmatic need. In a June
19, 2006 letter to DOE, the Board requested that DOE explain the
required state of facility readiness and its plans for safety
improvements, because it did not appear the mission and hazards had
changed. DOE responded with a new statement of policy for the
disposition mission at the Test Site, including a new scope of
operations at G Tunnel. In follow-up discussions, DOE stated that a
revised safety analysis is being developed that will identify safety
controls and upgrades appropriate for the new scope of operations. The
Board expects the new analysis to be available for review in 2007.

**Subcritical Experiments.** The Board reviewed preparations for
subcritical experiments at the Test Site and identified inadequate
nuclear safety management programs. DOE made improvements for the
UNICORN experiment in 2006 in areas such as safety basis reviews,
implementation of controls, and readiness reviews. As a result, UNICORN
had a more complete documented safety analysis and thorough verification
of readiness. The Board has stressed to DOE that it is essential to
carry the improved practices and formality forward for future
subcritical experiments and as part of maintaining nuclear test
readiness.

**Safety Basis Reviews.** The Board continued to review the safety bases
for nuclear facilities and activities, including the Device Assembly
Facility, Criticality Experiments Facility Project, Ula Complex,
Radioactive Waste Management Complex, G Tunnel, subcritical experiments,
and onsite transportation. Although the safety bases are improving
substantially, in 2006 the Board identified deficiencies in submitted
documented safety analyses and technical safety requirements,
classification of a facility, and in a Transportation Safety Document.
Several iterations of DOE review and document revision are needed to
develop and implement adequate safety bases.

**Lightning Protection and Electrical Systems.** In 2003 and 2005, the
Board noted deficiencies in lightning protection and in electrical
systems. In the past three years, DOE has made gradual improvements. In
2006, a site-wide directive for the lightning protection program was
completed, as well as lightning protection studies. As a result, the
Test Site now has a technical basis to identify appropriate controls for
lightning protection for hazardous operations and has implemented a
site-wide lightning protection program and controls. Remaining
electrical safety issues include oil-insulated transformers at the
Device Assembly Facility, an antiquated ventilation system in G Tunnel,
and the need to demonstrate the adequacy of the Faraday cage in the
operations alcove in G Tunnel.

4.  **Sandia National Laboratories**

Sandia National Laboratories are located in Albuquerque, New Mexico, and
Livermore, California. Major defense nuclear facilities at Sandia, most
of which are located in Technical Area V at the New Mexico site, include
the Annular Core Research Reactor, Auxiliary Hot Cell Facility, Gamma
Irradiation Facility, and Sandia Pulsed Reactor Facility. In September
2004, the Board issued a letter questioning the adequacy of safety bases
at Sandia. Subsequently, the Board issued a letter asking for a schedule
of actions to be taken to ensure that integrated safety management is
fully implemented at Sandia. Follow-up reviews performed by the Board
during 2006 found that DOE has continued to make progress toward
completing the corrective actions for the identified deficiencies.

5.  **Research and Development for Explosives Safety**

The Board reviewed research and development on high explosives and
weapon detonator safety for Pantex Plant operations, as conducted at
both Los Alamos and Lawrence Livermore National Laboratories. The
laboratories are testing detonators for electrostatic discharge hazards
and reviewing the safety of operations with certain detonators at
Pantex. One very positive outcome has been the installation of special
static dissipative flooring in certain Pantex Plant facilities as an
engineered safety control to mitigate electrostatic discharge concerns
for a weapons system. The Board also reviewed work at Los Alamos and
Lawrence Livermore to determine the effects of aging on weapon
explosives. Low-velocity impact and mechanical strength testing are
being used to model and predict the properties of aged explosives. The
Board observed from these data that a certain aged explosive was safe
for planned operations.

DOE briefed the Board on the Enhanced Surveillance Campaign in December
2006. This campaign has funded significant research and development on
the effects of aging on numerous stockpile components with safety
implications. Recent accomplishments include research and development
support for stockpile transformation and infrastructure, significant
finding investigations, annual assessments of weapons systems, and new
diagnostics for stockpile surveillance.

**3.** **Nuclear Materials Processing and Stabilization**

**3.1 Stabilization and Storage of Remnant Materials**

1.  **Complex-Wide Program**

**Nuclear Material Stabilization.** The Board provided significant
oversight of DOE efforts to improve the safety posture of remnant
nuclear materials throughout the DOE complex. HB-Line operators at the
Savannah River Site stabilized the final quantities of neptunium
solutions included in the scope of Recommendation 2000-1. This activity
marks the completion of all commitments under this recommendation at the
Savannah River Site. However, the Board continues to monitor the safety
of unstabilized materials still in storage at the Hanford Site and the
Los Alamos National Laboratory. Details of these activities are provided
in later sections of this report.

**Nuclear Material Consolidation, Storage, and Disposition.** For
several years, DOE has attempted to develop a coordinated plan for the
consolidation and disposition of nuclear materials that are excess to
national security needs. Some activities have proceeded on an individual
basis, but an integrated, complex-wide plan does not yet exist. In March
2005, the Secretary of Energy chartered the Nuclear Material Disposition
and Consolidation Coordination Committee to develop such a plan. This
committee continues to assemble parts of the plan, but progress has been
slow. The Board meets regularly with the chairman of the committee and
provides feedback on potential safety issues.

This year, the committee approved an implementation plan for the
consolidation of plutonium-239 materials from several DOE sites to one
location. However, the plan is considered predecisional until DOE
submits its fiscal year 2008 budget request to Congress. If implemented,
this plan will represent a significant step forward in material
consolidation. The plutonium-239 plan is the first of eight plans to be
approved. The second plan, addressing the consolidation and disposition
of uranium-233 materials, is in draft form. The other plans, addressing
the consolidation of plutonium-238 and removal of excess materials from
specific DOE sites remain at the conceptual planning stage.

2.  **Plutonium**

**Plutonium Stabilization, Los Alamos National Laboratory.** Operators
at the Los Alamos National Laboratory are stabilizing or repackaging
excess nuclear materials stored in thousands of containers on site. The
laboratory continues to make progress in risk reduction by repackaging
materials into more robust containers and intends to chemically
stabilize these materials at a later date when aqueous chemistry
capability is fully restored. The materials include metals, residues,
and oxides of both weapons grade and non-weapons grade plutonium. Many
of these items are stored in containers not suitable for long-term
storage, and therefore, continue to warrant stabilization or repackaging
on a priority basis. The Board continues to closely monitor the storage
conditions and stabilization efforts at the Los Alamos National
Laboratory.

**Adequacy of Plutonium Storage at the Savannah River Site.** In 2006
the Board issued its third annual report to Congress on plutonium
storage at DOE\'s Savannah River Site. DOE completed all but one of the
actions required to improve storage conditions at the site, including
removing combustible materials to improve the fire protection posture.
The unfinished task (suggested by the Board) is to upgrade the fire
protection system in the K-Area Materials Storage Facility. While DOE
has planned to complete this activity, it is unclear whether funding
will be available to do the work in fiscal year 2007.

3.  **Uranium**

**Oak Ridge National Laboratory.** The Board began its design review of
the rebaselined Uranium-233 Downblendig and Disposition Project in
Building 3019 at Oak Ridge National Laboratory. Following direction from
Congress, DOE will continue the primary mission of downblending the
material for disposition but will no longer extract thorium-229 for
medical use. Current plans call for most of the downblended material to
be disposed of at the Waste Isolation Pilot Plant as remote-handled
transuranic waste, with the remainder going to the Nevada Test Site. The
project design is about 90 percent complete. Building 3019 equipment
removal and facility modifications required prior to project
construction will not begin until Critical Decision-3A approval. The
Board reviewed the revised preliminary documented safety analysis to
support Critical Decision-2/3A and advised DOE of deficiencies in fire
protection controls, ventilation and confinement, and administrative
controls. The Board will provide oversight to ensure that adequate
safety controls are provided for this project.

4.  **Neptunium**

**Oxide Production and Storage.** The Board assessed the adequacy of the
actions taken by DOE to develop controls to ensure the purity of
neptunium oxide at the HB-Line facility at the Savannah River Site.
Subsequent to the Board\'s inquiries, analysis of archived samples
revealed higher moisture content than anticipated. The presence of
elevated levels of moisture or other contaminants could lead to
container pressurization, as well as concerns over flammability and
corrosion during storage. The suspect containers were restabilized, and
additional process controls and verification sampling have been
implemented. The Board found that the enhanced process controls,
moisture sampling, and periodic impurity analysis provide adequate
assurance of product quality for parameters that could impact safe
storage. DOE plans to store the neptunium oxide at the Idaho National
Laboratory and use it as feed to support the production of plutonium-238
for use in radioisotope power systems.

**Safe Storage at the Idaho National Laboratory.** The Board continues
to monitor the storage of neptunium at the Materials and Fuels Complex
at the Idaho National Laboratory. The Board reviewed the neptunium
storage plans and provided feedback to DOE regarding the adequacy of the
storage plans. As a result, DOE developed a new surveillance and
maintenance plan for this activity. DOE also continues the preparation
of a Final Environmental Impact Statement for the consolidation of
plutonium-238 activities from across the complex to the Idaho National
Laboratory.

**3.2 Stabilization of Spent Nuclear Fuel**

1.  **Hanford Site**

Nearly 50 cubic meters of radioactive sludge, including the corrosion
products of spent nuclear fuel, still reside in the K-East and K-West
Basins at the Hanford Site. This sludge is the only material at Hanford
that remains to be stabilized under the Recommendation 2000-1 program.
The project warrants some urgency because the K-Basins are degrading and
the K-East Basin is known to have leaked to the underlying soil. At the
Board\'s insistence, DOE developed a new implementation plan for
Recommendation 2000-1 based on a formal risk assessment process and more
realistic assumptions. DOE issued the new implementation plan on
November 28, 2005. DOE completed the consolidation of bulk sludge, the
first milestone in the revised plan, on schedule. DOE also prepared and
completed a rigorous readiness review process for the startup of the
system to transfer sludge between the basins. While DOE demonstrated
adequate procedures and operations, several equipment problems hampered
operations after start-up. Many of these problems required design
changes and equipment modifications, and this is an area the Board
intends to follow closely.

The development of the system to treat sludge and package it for
disposal has not had similar success. DOE authorized procurement at the
contractor\'s discretion. The Board found that the incorporation of
safety into design was behind schedule and posed an increasing risk to
the project. DOE conducted an independent review of this situation and
rescinded the contractor\'s procurement authority. DOE also considered a
proposal to accelerate the closure of the Hanford K-Area by transferring
sludge to the T Plant at Hanford for storage and treatment. The Board
concluded that the proposal represented a change in the project baseline
without a supporting conceptual design or preliminary hazards analysis.
DOE reached a similar conclusion and determined that the lack of this
information posed risks that did not justify the change in approach. The
Board plans to continue its close oversight of this project.

2.  **National Spent Nuclear Fuel Program**

The Board monitored DOE\'s efforts to plan for spent fuel packaging and
storage. DOE plans to ship aluminum plate fuel from the Idaho Cleanup
Project to the Savannah River Site for reprocessing in H-Canyon
beginning in 2010. DOE plans to ship its stainless steel and Zircaloy
clad fuel from the Savannah River Site to the Idaho Cleanup Project for
packaging and storage pending shipment to the geological repository for
disposal. These decisions were proposed at a national program strategy
meeting in July 2006 followed by an Energy Systems Acquisition Advisory
Board meeting, which approved the decision. The decision will require an
amendment to the Record of Decision removing melt-and-dilute as the
preferred method of handling aluminum plate fuel. The need for a
packaging and shipping facility at Idaho was acknowledged. Two
alternatives being considered are a dry storage option previously
designed under a privatization contract and licensed by the Nuclear
Regulatory Commission, and a direct packaging option proposed by the
current contractor at the Idaho Cleanup Project. An independent cost
evaluation team will evaluate the options and report by spring 2007. DOE
plans to ship spent fuel from the Fast Flux Test Facility at Hanford to
the Idaho Cleanup Project in 2007. The Board reviewed the safety of
spent fuel storage at the Idaho Cleanup Project and found the facilities
and systems adequate to protect worker and public safety.

**3.3** **Waste Management**

1.  **High-Level Waste**

**Hanford Tank Farms**

**Tank Integrity.** The high-level waste storage tanks at both the
Hanford and Savannah River Sites contain millions of gallons of
radioactive waste that DOE plans to vitrify and put into long term
storage. Current forecasts are for continued use of these tanks for
storage of the radioactive waste until about 2040. Corrosion controls
are in place to extend the lives of these tanks, and in general, these
controls are working reasonably well. However, over the years, there
have been anomalous occurrences of pitting, crevice corrosion, and
cracking in the tank walls. These occurrences have caused the Board to
encourage DOE to conduct fundamental studies to better understand the
ongoing corrosion mechanisms and improve corrosion controls to provide
greater assurance that the tanks will not develop leaks during their
service lives. DOE has responded positively. Activities in 2006
regarding tank chemistry and corrosion are noted below.

The Board questioned DOE\'s plans to change chemistry controls used to
mitigate corrosion in tanks at Hanford. DOE responded by establishing a
corrosion testing program to determine optimum waste chemistry limits
for maintaining tank integrity. The first phase of this program studied
the effect of pH on corrosion. The results showed the pH could as be as
low as pH 10 without significantly increasing corrosion. To confirm the
laboratory results, a corrosion probe has been installed in double-shell
tank AN-107 to continuously monitor in-tank corrosion.

In response to the Board\'s letter of June 1, 2005, citing unusual
corrosion observations in the vapor space of waste storage tanks at both
the Hanford and Savannah River Sites, an expert panel workshop was held
at Hanford. The expert panel identified several mechanisms by which
corrosive species could concentrate on tank walls. A series of
laboratory experiments to evaluate these mechanisms will be conducted
during 2007.

**Savannah River Site**

**High-Level Waste Management.** The Board continued to monitor the
high-level waste system at the Savannah River Site. DOE is faced with
many challenges while balancing the priorities of safe storage of
high-level waste, retrieval and treatment of the waste, and support for
facilities that depend on the waste system to remain operational. The
Board reviewed DOE\'s three-pronged strategy to remove and process the
low-activity portion of wastes in the high-level waste system. The first
step includes operation of the Deliquification, Dissolution, and
Adjustment process, a small-scale waste treatment capability that
removes low-activity liquid waste from the tanks, thereby allowing
greater flexibility in many aspects of tank farm operations. Steps two
and three include the design, construction, and testing of the Actinide
Removal Process and the Modular Caustic Side Solvent Extraction Unit
(pilot-scale waste processing facilities), which will operate until the
Salt Waste Processing Facility comes on line.

DOE completed the construction of the pilot-scale waste processing
facilities. Low-level radioactive waste operations are expected to
commence in fiscal year 2008. The Board also reviewed the safety of the
design of the Salt Waste Processing Facility. Based on delays in
permitting and regulatory activities, the step one process has been
delayed but is expected to start up soon. DOE plans to update and
reissue its high-level waste planning documents (i.e., Disposition
Processing Plan and System Plan) to reflect these delays, and the Board
plans to review these documents.

Several of the original problems that led the Board to issue
Recommendation 2001-1 continue to affect the Savannah River Site. These
problems include limited tank space in high-level waste tanks, delays in
waste processing, mixed evaporator performance, and the fact that one of
the former In-Tank Precipitation tanks (Tank 48) has remained out of
service for eight years after the suspension of a failed precipitation
process.

The Board believes that substantial progress must be made in 2007 or the
lack of tank space will begin to jeopardize important operations such as
those at the H Canyon and the Defense Waste Processing Facility. The
Board continues to provide oversight of these high-level waste systems.

**Hydrogen Gas in Process Systems.** Last year, the Board began
reviewing the risks of hydrogen accumulation in the piping and equipment
at the Defense Waste Processing Facility. The concern was that a
hydrogen explosion could rupture the equipment and the resulting
fragments could damage nearby safety equipment. After significant
discussion between the Board and the Savannah River Site on the
analyses, the Savannah River Site developed an acceptable path forward:
(1) pipes that could fail without fragmenting would have their design
credited; (2) seal pots that could fail with fragmenting would be
reinforced with a carbon/epoxy composite wrap (approved for high
pressure piping repairs); (3) components in personnel corridors would be
upgraded, reinforced, contained, isolated, or removed; and (4) a safety
management program would be implemented to ensure proper safeguards
during maintenance.

**Idaho Cleanup Project**

**High-Level Waste Tank Closure.** During 2006, the Board completed its
review of DOE\'s cleaning of high-level waste tanks and found the level
of cleanliness adequate to protect the public and the environment. Seven
of eleven 300,000 gallon tanks and four 30,000 gallon tanks were cleaned
and found acceptable for closure by the State of Idaho. Concurrently,
the Nuclear Regulatory Commission issued its decision that the residual
waste in the tanks was incidental to reprocessing and concurred in
DOE\'s decision under Section 3116 of the National Defense Authorization
Act of 2005 that the tanks could be closed in place with cement grout.
DOE grouted and closed three of the smaller tanks before the end of the
year. The Board plans to observe future tank closure operations at
Idaho.

2.  **Low-Level Waste and Transuranic Waste**

Advanced Mixed Waste Treatment Project. DOE\'s largest effort to
retrieve transuranic waste at the Idaho Cleanup Project takes place at
the Advanced Mixed Waste Treatment Project, and the Board continues to
provide close oversight of the activities there. As of December 2006,
DOE has successfully shipped more than 14,000 cubic meters of
transuranic waste to the Waste Isolation Pilot Plant. However, many
thousands of cubic meters of waste remain to be packaged and shipped.
The Board remains concerned about the safety of the workers there, who
could be at risk from potential deflagrations and fires in transuranic
waste drums. The Board discussed these concerns with DOE, and site
managers began to take action to improve the safety controls associated
with handling transuranic waste drums. The Board expects to review these
corrective actions in 2007.

**Accelerated Retrieval Project.** DOE operates a second activity to
retrieve transuranic wastes buried at the Idaho Cleanup Project. This
smaller operation, run by a different site contractor, is called the
Accelerated Retrieval Project. The Board monitored DOE\'s performance at
the Accelerated Retrieval Project following a drum fire there in
November 2005 which caused an interruption in retrieval of transuranic
waste drums until May 2006. Site personnel made several equipment and
procedural changes to improve worker and public safety. However,
following resumption of retrieval activities, site personnel noted that
one corner of the structure covering the waste trench had settled into
the ground. The corner settled far enough to cause concern for the
structural integrity of the facility. DOE took corrective action to
stabilize the foundation of the structure, but additional settling may
occur. Additional Board review is needed to assess the structural
stability of this facility.

**Oak Ridge National Laboratory Tank W-1A.** Tank W-1A collected
radioactive wastes from analytical facilities at Oak Ridge National
Laboratory between 1951 and 1986. Leakage from a pipe supplying this
underground tank caused soil and groundwater contamination around the
tank. Due to the high projected radiation levels, the Board carefully
examined work planning for a campaign to retrieve contaminated soils for
sampling and characterization in support of eventual removal and
disposal. In a January 2006 letter to DOE, the Board identified
weaknesses in various aspects of the integrated safety management
program for the sampling effort. In response, DOE took corrective
actions including practicing the sampling process prior to startup and
employing improved radiological soil handling equipment and improved
radiological controls to minimize worker exposure. DOE safely completed
the Tank W-1A soil sampling effort in the summer of 2006. Future efforts
to complete all soil removal around Tank W-1A will require additional
Board oversight.

**National Transuranic Waste Program.** DOE stores large quantities of
transuranic waste on concrete pads and in soil-covered trenches at many
sites, and is actively retrieving this waste for shipment to the Waste
Isolation Pilot Plant for disposal. Noting that significant differences
exist in the safety requirements governing such work at the various
sites, the Board encouraged DOE\'s initiative to develop a draft
standard for the safe retrieval and characterization of transuranic
waste at these sites. The Board reviewed a draft of the standard and
will continue to interact with DOE to ensure that a consistent and
enhanced approach to safety is taken during transuranic waste retrieval,
characterization, and shipping operations.

**Waste Isolation Pilot Plant.** The Waste Isolation Pilot Plant in New
Mexico is a geologic repository utilized for the disposal of defense
transuranic wastes. During 2006, the site received and deposited more
than 1,100 shipments of transuranic waste with a total volume in excess
of 10,000 cubic meters. Throughout 2006, the Board verified that these
operations were conducted safely. In late 2006, the Board reviewed
preparations for remote-handled (high activity) transuranic waste
operations, including observation of a DOE operational readiness review.
As DOE makes final preparations for and begins receipt of the
remote-handled transuranic waste in 2007, the Board plans to provide
direct oversight.

**Soil Remediation at Hanford.** The Board reviewed DOE\'s safety
documentation and work planning process for the 118-K burial ground at
Hanford. DOE plans to exhume wastes from the burial ground, repackage
the waste, and dispose of it in modem waste facilities. The Board found
(1) confusing nuclear criticality safety controls and (2) safety
documentation that did not comply with guidance from DOE. The Board
provided this feedback to DOE, which resulted in DOE making the
necessary changes to address these issues.

**Transuranic Waste Drum Handling at Hanford.** The Board reviewed
hydrogen controls for vented transuranic waste drums at Hanford and
found the controls to be nonconservative. DOE was using a control level
of 15 percent hydrogen, while the safe and commonly accepted control
level is 4 percent (the lower flammability limit for hydrogen). After
this concern was communicated, DOE reduced the control level for
hydrogen concentration in vented drums to 5 percent. This action
represented a significant improvement in worker safety for these
operations.

**3.4** **Facility Deactivation and Decommissioning**

1.  **Overview**

DOE\'s Office of Environmental Management continues to pursue
accelerated deactivation and decommissioning at some defense nuclear
facilities, while other such work has been delayed due to funding
shortfalls. DOE completed closure activities at the Fernald Closure
Project and made significant progress in the cleanup of the Miamisburg
Closure Project (formerly called the Mound Site). The Board observed
much of the ongoing deactivation and decommissioning work and found that
weaknesses exist in the areas of nuclear criticality safety, fire
prevention, and conduct of operations. Although DOE has taken corrective
actions to strengthen these programs, additional improvement is needed.
Lessons learned from completed work are not always implemented at new
closure sites. A positive observation is that a number of personnel
trained in deactivation and decommissioning have moved from existing and
closed sites to sites with new work, bringing with them valuable
experience and lessons learned. The Board has encouraged DOE to maintain
the experienced deactivation and decommissioning work force within the
defense nuclear complex.

2.  **Fernald Closure Project**

The Board reviewed and provided comments to DOE on the safety of final
decommissioning and closure project work at the Fernald Closure Project.
In response, DOE made changes to improve safety during the demolition of
the silos waste treatment facilities and during placement of low-level
wastes in the on-site disposal cells. DOE completed all site closure
work in fiscal year 2006. DOE transferred responsibility for continued
site stewardship from the Office of Environmental Management to the
Office of Legacy Management.

3.  **Miamisburg Closure Project**

The Board reviewed the safety of closure activities at the Miamisburg
Closure Project, including the demolition of former production buildings
and removal of contaminated soil from site landfills. No significant
safety issues were identified. Site closure work is complete, except for
the removal of contaminated soil from one landfill and the rail car
loading area. The Board plans to follow the deactivation and
decommissioning activities on site through completion, expected in
fiscal year 2007. Ownership of the site will be transferred to the
Miamisburg Mound Community Improvement Corporation for commercial use
after all site cleanup work is complete.

4.  **Savannah River Site**

The Board reviewed DOE\'s efforts to conduct deactivation and
decommissioning work at the Savannah River Site and concluded that the
program is reasonably well run. DOE completed deactivation and
decommissioning in the T and D Areas and the Naval Nuclear Fuel complex.
The F-Canyon and FB-Line have been de-inventoried and placed in a cold,
dark, and dry status. The remaining decommissioning work is scheduled to
be completed by 2025.

**3.4.5 Hanford Site**

The Board conducted several reviews of deactivation and decommissioning
projects at the Hanford Site. DOE is engaged in a number of such
activities at Hanford including demolition of buildings in the 300 Area
(former Pacific Northwest National Laboratory facilities),
decontamination at the Plutonium Finishing Plant, extensive soil and
groundwater remediation, and planning for deactivation and
decommissioning of the K-Basins and the large \"canyon\" facilities on
site.

Due to the redirection of funding to higher risk projects, the Plutonium
Finishing Plant has been put into a reduced deactivation and
decommissioning mode. DOE plans to continue deactivation and
decommissioning work during fiscal years 2007 and 2008 at about
one-fourth the previous level. All plant operating and vital safety
systems will continue to be operated during this reduced work period.
DOE plans to resume this work at higher levels in fiscal year 2010 with
a target of demolishing the facility to \"slab-on-grade\" by fiscal year
2016. The Board\'s reviews found that idle areas of the plant have been
placed in safe condition. Life extension studies of plant systems are in
progress to determine upgrades that might be necessary to keep the
systems operating until fiscal year 2016. The Board\'s reviews of these
life extension studies indicate that the vital safety systems should be
adequately maintained.

The Board had noted high numbers of nuclear criticality safety
nonconforrnances, including violations of mass and spacing controls,
that were occurring during operations. DOE made significant progress in
reducing these nonconformances from approximately five per month 18
months ago to a current rate of approximately one per month. The
techniques for achieving this improvement were innovative and will
provide valuable lessons learned for other facilities with fissile
material holdup.

5.  **Idaho Cleanup Project**

The Board reviewed the deactivation and decommissioning activities at
the Idaho Cleanup Project and found an aggressive program to remove
surplus facilities. The level of staffing was judged optimum for this
work. It consisted of a combination of experienced workers from other
sites, such as the Rocky Flats Environmental Technology Site, and
experienced personnel from Idaho. The Board found the work to be
conducted in a manner that was protective of the workers, the public,
and the environment. The most hazardous facility is the former Idaho
Chemical Processing Plant, which was used to process spent nuclear fuel
from the on-site test reactors and from the U.S. Navy until 1992. DOE
initiated characterization and planning for deactivation and
decommissioning of the Idaho Chemical Processing Plant in fiscal year
2006. The Board plans to closely monitor this high risk deactivation and
decommissioning activity.

**4. Nuclear Facilities Design and Infrastructure**

1.  **Introduction**

The Board\'s strategic performance goal for this area is to ensure that
new defense nuclear facilities and major modifications to existing
facilities are designed and constructed in a manner providing adequate
protection of the health and safety of the workers and the public. There
has been a substantial increase in the number of design and construction
projects under the Board\'s jurisdiction. DOE has undertaken design and
construction projects with a projected total cost of about \$20 billion.
The Board continues to expend extensive resources to ensure that designs
for defense nuclear facilities incorporate multiple layers of safety
controls commensurate with the hazards presented.

The Board is required by statute to review the design and construction
of defense nuclear facilities, which must be designed and constructed in
a manner that will support safe and efficient operations for 20 to 50
years. This demands an exacting design process, guided by integrated
safety management principles, that will ensure appropriate safety
controls are identified early in the design. The Board expects the
design and construction process for defense nuclear facilities to
demonstrate clear and deliberate use of integrated safety management
principles, core functions, and manuals of practice.

The Board began a series of public hearings in 2005, continuing through
2006, concerning the integration of safety in design. As a result of
these public hearings, DOE has established new expectations for
identifying and resolving safety issues earlier in the design process,
revised the existing DOE Order for project management, and is developing
more detailed guidance for project management. Further, DOE is
developing a new standard to implement a more rigorous approach to
safety-in-design. The Board is preparing for a third public hearing on
integration of safety into design that will consider early issue
identification, communication between the Board and DOE, and timely
resolution of issues.

House Conference Report 109-702, issued September 29, 2006, directed the
Board and DOE to continue discussion on the timely identification and
resolution of technical differences over design standards and other
issues at DOE\'s nuclear facilities. The Board is required to provide
quarterly reports to the Congressional defense committees to identify
and report the status of significant unresolved issues.

2.  **Hanford Site**

**Waste Treatment Plant.** The Waste Treatment Plant is a multi-facility
complex designed to treat Hanford\'s high-level radioactive liquid
wastes. It consists of three primary nuclear facilities known as
Pretreatment, Low-Activity Waste, and High-Level Waste, as well as an
Analytical Laboratory. The Pretreatment facility receives high-level
waste from Hanford\'s tank farms and separates it into high and low
activity streams. The low-activity portion will be transferred to the
Low-Activity Waste facility, where it is mixed with glass-forming
materials and converted to a stable borosilicate glass, or
\"vitrified.\" The glass canisters from the Low-Activity Waste facility
are subsequently placed in an onsite, near-surface disposal facility.
The high-activity waste stream is transferred from the Pretreatment
facility to the High-Level Waste facility, where it is also vitrified.
After vitrification, high-level waste glass logs are temporarily stored
at the Hanford site in the Canister Storage Building pending shipment to
DOE\'s high-level waste repository.

Construction progress varies among the facilities. Currently,
construction of the Low-Activity Waste facility is furthest along. Work
on the Pretreatment and High-Level Waste facilities has been temporarily
halted by DOE to address budget issues. In the meantime, the Board has
continued its review of the design and construction of
important-to-safety structures, systems, and components. During 2006,
the Board\'s activities primarily consisted of considering the
resolution of previously identified issues.

*Structural Design*. In response to a finding by the Board that seismic
requirements were not sufficiently conservative, DOE determined that
these requirements had been underestimated by about 40 percent. DOE is
now evaluating the effect of this increase on the design of the
structure and equipment and, using state-of-the-art techniques, is
developing new data to resolve some uncertainty in the modeling used to
predict the seismic hazard. DOE has undertaken a seismic borehole
project under the direction of the Pacific Northwest National
Laboratory. Three deep boreholes and one deep corehole have been drilled
adjacent to the construction site. Once all of the subsurface data is
collected, confirmatory ground motion calculations will be performed.
Pacific Northwest National Laboratory is expected to form a peer review
panel that will review the subsurface data and recommend how these data
should be used to estimate earthquake ground motion. In a September 6,
2006 letter to DOE, the Board reiterated its belief that the updated
ground motion criteria provide a reasonably conservative basis for
validating the design. This conclusion was based on an analysis (using a
conservative selection of soil and rock properties) that addressed
recognized uncertainties in subsurface material properties. The Board
anticipates that ground motion modeling using data from the drilling
program will validate the seismic design ground motion. The Board raised
several issues specifically regarding the structural design: inadequate
modeling, no clear seismic load transfer capability in the structure,
and an inadequate finite element analysis. DOE developed new structural
design criteria that addressed the issues raised by the Board.

*Fire Protection*. The Board objected to DOE\'s decision not to apply
fire resistant coatings to structural steel. DOE changed course and is
now committed to a fireproofing strategy complying with the building
code and other DOE requirements. DOE has prepared structural design
criteria for implementing this strategy across the project and is
completing calculations to determine which steel members must be coated.
The Board is also reviewing DOE\'s effort to repair weather damage to
coatings, and the validation of the fire rating of coatings applied by a
method not meeting code requirements.

*Hydrogen Gas Hazards*. DOE significantly underestimated the impact of
hydrogen hazards on pipes and small process vessels and components. At
the urging of the Board, DOE has continued to evaluate design solutions
to address the issue and re-evaluated and issued new design criteria to
ensure the design remains fully protective of the public\'s health and
safety.

**Demonstration Bulk Vitrification Project.** The Demonstration Bulk
Vitrification Project is a research and development project intended to
demonstrate the suitability of bulk vitrification for disposing of
low-activity waste from the Hanford Tank Farms. In a letter to DOE dated
September 7, 2005, the Board pointed out weaknesses in the design for
confinement of materials and worker protection. DOE subsequently
conducted an independent review and further analyses of hazards, leading
to improvements in the design.

**K-Basin Closure Project Sludge Treatment.** Sludge treatment is a
sub-project in the overall K-Basin Closure Project. The Sludge Treatment
Project is a major modification to two operating facilities that will
provide capability to treat waste sludge from corroded spent fuel and
package it for disposal. The project is approaching what would be
Critical Decision-3 (Start of Construction). The Board has identified
portions of the preliminary documented safety analysis that are based on
the conceptual and preliminary design instead of the final design. A
revised analysis based on the final design is expected to be delivered
in early 2007. At that point, the Board can complete its review of the
adequacy of the design.

**Interim Secure Storage Facility.** The Interim Secure Storage Facility
was a new project at Hanford to store the site\'s inventory of plutonium
until 2035. The Board questioned DOE\'s application of project
management requirements to the project. DOE\'s project team subsequently
developed a critical decision package for approval which, upon further
review, revealed that the mission need was not justified. DOE eventually
terminated the project in favor of consolidation of plutonium storage
off-site.

3.  **Savannah River Site**

**Plutonium Storage.** The 3013 Container Surveillance and Storage
Capability project is a major modification to a Hazard Category 2
facility within the K-Area Complex. This project will provide
examination, stabilization, and packaging capabilities for
plutonium-bearing materials stored in 3013 containers. It will also
provide rack storage for approximately 1900 containers. The Board
reviewed the preliminary design of the facility, focusing on the
preliminary hazards analysis, proposed safety systems, and criticality
safety strategy. The Board identified weaknesses in the hazards
analysis, which the contractor agreed to address. Based on the Board\'s
Recommendation 2004-2, the contractor discovered that the preliminary
facility design did not protect safety-related filters from excessive
soot loading during fire events. The design and functional
classification of the ventilation and fire protection systems were
subsequently modified, though DOE has not yet approved the new design.
The Board also encouraged DOE to ensure that its decision regarding
exclusion of criticality accident alarms in the facility takes into
account the revised design requirements found in DOE Order 420.lB,
*Facility Safety*.

**K-Area Interim Surveillance Project.** The K-Area Interim Surveillance
project will provide the capability to conduct non-destructive and
destructive surveillance of 3013 containers in the Building 105-K slug
vault until the 3013 Container Surveillance and Storage Capability
facility becomes operational (in about 2010). The Board reviewed the
final design of this facility, focusing on the ventilation and fire
protection systems, and found it acceptable. The Board identified
several deficiencies in the documented safety analysis and nuclear
criticality safety evaluation; the contractor corrected these in later
revisions. The Board also identified a potential threat to the
safety-significant ventilation system from an old non-seismically
qualified ventilation duct in Building 105-K. DOE removed the duct.

**Salt Waste Processing Facility.** The Board continued its review of
the Salt Waste Processing Facility\'s design and processes. The Board
had previously identified weaknesses in the performance categorization
and potential seismic interactions of various portions of the facility.
As a result, DOE directed its contractor to design a more robust
structure, which will provide the confinement required by the DOE safety
basis. This facility is of particular concern to the Board because of
observed technical shortcomings in the design process. The geotechnical
requirements have not been finalized, the as-designed structure\'s
ability to transfer imposed loads is not well defined, the structural
analysis to date is incorrect and less than adequate, and the structural
models developed to advance the design may not be valid. DOE is taking
action to address these issues with the Board\'s assistance to minimize
impacts on the Savannah River Site\'s high-level waste program.

**Pit Disassembly and Conversion Facility.** In 2006, the Board
continued to review safety aspects of the design of the Pit Disassembly
and Conversion Facility. The Board reviewed the surface settlement
profiles at the building foundation due to the presence of soft zones
unique to the Savannah River Site. Based on this review, the Board found
that, although the final predicted surface settlement is deemed
adequate, the methods used to analyze surface settlement need to be
improved. The Board will address this concern with the Savannah River
Site separately. The Board also suggested several improvements in the
electrical design. The Board observed that the design rating of the
diesel generator may not be adequate to handle the necessary startup
loads following a loss of offsite power.

**Tritium Extraction Facility.** The Tritium Extraction Facility will be
used to extract tritium from target rods irradiated in commercial light
water reactors. The extracted tritium is used to replenish tritium
reserves for the nation\'s nuclear weapons stockpile. DOE successfully
started up this facility in 2006.

4.  **Y-12 National Security Complex**

**Highly Enriched Uranium Materials Facility.** The Highly Enriched
Uranium Materials Facility will replace several aging storage
facilities. The new facility will reduce the site footprint of uranium
storage, thus simplifying safeguards and security measures. The design
of this facility is essentially complete. DOE began construction in
early 2005, with completion now projected in 2008. In late 2005, the
Board noted that quality assurance and control practices for placement
of concrete were deficient. In response, DOE assigned personnel to
monitor construction and initiated other corrective actions. In January
and February 2006, however, shortly after DOE initiated corrective
actions, DOE\'s contractors identified numerous construction errors in
concrete placement. DOE then shut down construction activities and
initiated short-term compensatory actions including a review by outside
construction experts. Subsequently, DOE developed and implemented
long-term corrective actions to address the quality assurance and
control deficiencies.

**Uranium Processing Facility.** The Uranium Processing Facility is a
new project intended to replace a number of aging facilities that
process enriched uranium. In 2006, the project\'s completion schedule
was in doubt due to funding reductions. DOE\'s review and approval of
Critical Decision-1 authorizing preliminary design is being delayed
until project management problems at the Highly Enriched Uranium
Materials Facility are sufficiently resolved. The Board has raised
concerns with the development of the preliminary hazard analysis and
selection of a conservative set of safety-related controls. The Board
has also questioned the level of detail developed for the conceptual
design of the safety systems and the risks this may pose for the
project.

5.  **Los Alamos National Laboratory**

**Chemistry and Metallurgy Research Facility Replacement Project.** The
Board continued its review of the Chemistry and Metallurgy Research
Replacement Project facility design. To expedite the schedule, DOE is
planning to use a design-build approach for the final design and
construction of this facility. DOE proposes to combine Critical
Decision-2 (Approval of Performance Baseline) and Critical Decision-3
(Start of Construction). For this strategy to be successful, the
preliminary design package needs to be more developed than would
typically be expected. This approach will also require a completed
preliminary documented safety analysis with a DOE safety evaluation
report. The Board has stressed that for this plan to be successful,
aggressive oversight will be required by federal and contractor
personnel experienced in the management and oversight of large, complex
projects. There are many safety-related issues and concerns with this
project that remain to be resolved. The Board will continue its efforts
to achieve resolution in a timely manner.

**Pit Manufacturing, Technical Area-55.** Upgrades are currently
underway to improve the pit manufacturing capability at Technical
Area-55. Overall, the objective of these efforts is to install
manufacturing equipment necessary to produce increased numbers of pits
and establish the capability to manufacture legacy pit types or a
Reliable Replacement Warhead. The Board has found that this activity is
not being managed as a formal project with design milestones in
accordance with DOE Order 413.3A, *Program and Project Management for
the Acquisition of Capital Assets*. Rather, modifications to the pit
manufacturing facilities and equipment are ongoing and funded on an
annual basis. The Board is currently evaluating whether the lack of
adherence to DOE Order 413.3A is adversely affecting safety integration
within the design.

6.  **Pantex Plant**

**Component Evaluation Facility.** The Component Evaluation Facility is
a new project at Pantex intended to provide additional capability for
qualifying, certifying, and inspecting assembled weapons and components.
This project is presently on hold while NNSA is revisiting the Program
Requirements Document and Mission Need to ensure compatibility with the
Reliable Replacement Warhead and the Complex 2030 vision. This facility
was scheduled to be operational in 2012.

**Special Nuclear Material Component Requalification Facility.** The
Board has continued its review of the Special Nuclear Material Component
Requalification Facility. The project team has completed construction
and system testing and is currently resolving Operational Readiness
Review findings from the recently completed contractor review. The
critical path for this project is controlled by the Laser Gas Sampling
System, which is not required immediately for stockpile work and is
expected to lag production startup. The Board conducted reviews of the
ventilation and fire protection systems and of safety basis
documentation. The Board noted that though the facility is equipped with
an active ventilation system, this system is not credited in the safety
analysis. This issue will be evaluated in connection with Recommendation
2004-2.

7.  **Idaho Cleanup Project**

**Integrated Waste Treatment Unit.** The Integrated Waste Treatment Unit
will convert approximately 900,000 gallons of acidic sodium-bearing tank
waste at the Idaho National Laboratory to a dry carbonate product for
disposal at the Waste Isolation Pilot Plant. The Board reviewed major
aspects of the project\'s organization, preliminary design, and safety
basis development. Primary areas of focus included process design and
confinement strategy, safety strategy as detailed in the preliminary
documented safety analysis, and pilot plant testing. In response to the
Board\'s concerns, DOE will use a more conservative and commonly used
computer code to estimate radiological consequences of postulated
accidents for co-located workers and the public. Further, DOE conducted
a review of key safety analysis inputs and subsequently changed these
inputs for many of the postulated accidents. The Board is continuing to
review major aspects of the design as they are developed, including the
distributed control system, waste characterization and radionuclide
inventory controls, geotechnical engineering work supporting the design
of Performance Category 3 structures, and additional pilot plant
testing.

8.  **Nevada Test Site**

**Criticality Experiments Facility.** The Criticality Experiments
Facility is a major modification of the Device Assembly Facility. This
modification will permit transfer of criticality machines and fuel from
Technical Area-18 at Los Alamos to the Nevada Test Site. Design is about
90 percent complete on modifications to the rooms within the Device
Assembly Facility that are needed for this project. The Board reviewed
the preliminary documented safety analysis and developed a significant
number of comments and concerns. Many of these concerns were shared by
DOE\'s Safety Basis Review Team. DOE now plans to perform a new
structural and seismic analysis, address water leaks, and prepare a new
safety analysis. However, as noted in Section 2, the Device Assembly
Facility structure has numerous cracks that are considered abnormal for
a nuclear facility.

9.  **Seismic Hazard Analysis**

The Board is reviewing a number of DOE studies and reports on seismic
ground motion.

DOE Order 420.1B, *Facility Safety*, requires that a review of natural
phenomena hazards assessments be conducted at least every 10 years, and
that this review include recommendations to DOE for updating the
existing natural phenomena hazard assessments based on significant
changes that have occurred in methods or data. As a result of this
requirement, a number of DOE sites are updating their probabilistic
seismic hazard analyses. These analyses will be used to establish the
site-specific design basis earthquake ground motion. During the past 10
years, the practice for establishing earthquake ground motions has
advanced, particularly with respect to understanding the impact of local
site conditions on ground motions. Local site conditions can have a
significant impact on either amplifying or reducing ground motions
depending on the geologic stratigraphy and related material properties
of the site.

Probabilistic seismic hazard updates are underway at the Savannah River
Site, Los Alamos National Laboratory, and the Nevada Test Site. These
updates were undertaken to incorporate the most recent data regarding
seismic sources, including the Charleston, South Carolina source at
Savannah River Site and the Pajarito Fault source in New Mexico. Studies
to better understand the impact of local site conditions are also
underway at the Hanford Site (Waste Treatment Plant) and at the Idaho
National Laboratory (Integrated Waste Treatment Unit). Given that the
state of practice is evolving, one key concern of the Board is that DOE
perform an adequate review, including independent peer review, of both
the site specific acquisition of data and the subsequent analysis. This
will ensure that design basis earthquake ground motions are based on
accurate scientific knowledge. The Board will continue its review of
this ongoing work during 2007.

**5. Nuclear Safety Programs and Analysis**

**5.1 Federal Oversight**

1.  **Overview**

To meet its statutory health and safety mandate, the Board must
continuously assess DOE\'s ability to achieve adequate oversight of
contractor work. Oversight, in this context, includes Federal
line-management assessment of contractors, contractor self-assessment,
and independent assessment of both Federal and contractor work. For much
of the work conducted in the defense nuclear complex, DOE relies upon
contractors to perform inherently risky activities in government-owned
facilities. These activities are nevertheless governed by nuclear safety
requirements promulgated by the government. Thus, DOE fills three
simultaneous roles: owner, customer, and regulator. Preventing conflict
among these roles requires a complex oversight system strained by
competing demands that must be reconciled to ensure that the overall
mission is achieved safely.

2.  **Recommendations 95-2 and 2004-1**

The Board continued driving DOE to improve its oversight of complex,
high-hazard nuclear operations. One important aspect of that oversight
is integrated safety management, a concept that evolved from
Recommendation 95-2 and is being further developed and implemented in
response to Recommendation 2004-1. The basic tenets of this approach
provide the framework for safely performing all of the diverse hazardous
activities in the defense nuclear complex. Integrated safety management
provides for a single safety management program rather than multiple,
unintegrated programs (e.g., quality assurance and environmental
management). Nuclear safety is an important but not exclusive target,
because nonradioactive hazardous materials and operations can also
present significant risk. Integrated safety management builds upon
standards of safe practice for nuclear, chemical, and other hazardous
operations to ensure protection of the public, workers, and the
environment. In 2006, the Board issued a technical report, *Integrated
Safety Management: The Foundation for an Effective Safety Culture*
(DNFSB/TECH-36). This report documents a detailed examination of the
current status and effectiveness of integrated safety management systems
at the seven NNSA weapons sites, summarizes failures and good practices,
and proposes changes to enhance the effectiveness of these systems.

DOE completed the following actions in 2006:

-   designated a chair for the Integrated Safety Management Council;

-   established two Central Technical Authorities with associated
    technical support staff;

-   issued a new DOE policy and order on DOE oversight;

-   implemented a nuclear safety research function;

-   strengthened the technical qualification program for Federal safety
    assurance personnel;

-   implemented a formal safety delegation and assignment process; and

-   took steps to improve the implementation of the \"feedback and
    improvement\" function, including issuance of a new DOE Order
    describing the Operating Experience Program.

DOE also performed a review of Recommendation 2004-1 implementation plan
commitments. Based on the results of the reviews and experience with
implementation to date, DOE developed a revision to the plan that the
Board found acceptable. The Board also took this opportunity to close
Recommendation 95-2. The Board concluded that the Recommendation 2004-1
plan and the recently-issued DOE Manual 450.4-1, *Integrated Safety
Management System Manual*, contained the actions necessary to
reinvigorate integrated safety management.

1.  **DOE Oversight Policy and Order**

In accordance with the implementation plan for Recommendation 2004-1,
DOE issued a new policy and order (Order 226.1, *Implementation of
Department of Energy Oversight Policy*) on federal oversight, bringing
together for the first time specific guidance and detailed requirements
for federal oversight of safety, security, and business operations. In
development is an oversight guide providing more detailed guidelines and
lines of inquiry. These steps are intended to ensure a more uniform
process for oversight of DOE\'s activities.

The order was scheduled to be implemented by DOE and its contractors by
September 2006. In early 2006, the Board\'s reviews showed that most
sites needed to fill a substantial gap to fully implement these safety
requirements by the required date. In March 2006, the Board provided to
DOE the results of a detailed review of the technical assessment, safety
system oversight, and management walkthrough programs at the Savannah
River Operations Office. The Board\'s report noted a substantial gap
between current performance and the requirements of Order 226.1, and
expressed concern with the limited actions taken at that time to
implement the new order.

In response to the Board\'s March 2006 letter, DOE assigned a lead at
Savannah River for implementing the new requirements, conducted a formal
gap analysis, and developed an implementation plan. In addition, DOE
developed a new Integrated Performance Assurance Manual and plans to
conduct structured and comprehensive assessments of the contractor\'s
performance starting in 2007. While significant improvements were made
in 2006, progress was hindered by a number of DOE staffing deficiencies.
The Board is also concerned that the decision to increase the number of
contractors at Savannah River and the increased use of small business
contracts in the future will make the situation even more challenging.

The Board\'s March 2006 letter also requested that DOE provide its
implementation plans for the new directives across the complex and
encouraged DOE to take aggressive steps to implement the 226 series of
directives. These steps could include assigning a lead for implementing
the new requirements, performing a formal gap analysis, and developing
an implementation plan. Without these, or similar positive steps, the
Board had little confidence that the programs would be implemented
within the one-year requirement. DOE provided plans to the Board for
implementing the directives in June 2006, and more detailed
implementation plans in September 2006. At the end of 2006, however,
implementation of the new directives was still not complete. The Board
will continue to follow implementation and effectiveness of the federal
oversight programs in 2007.

2.  **Vital Safety Systems**

In response to Recommendation 2000-2, DOE has taken steps to ensure the
operability of vital safety systems. During 2006, at the request of the
Board, DOE reported its progress. Based on a detailed review of the
information provided, the Board has concluded that two sites, Lawrence
Livermore National Laboratory and the Los Alamos National Laboratory,
have not fully implemented a program to verify configuration management
of vital safety systems.

3.  **Activity-Level Work Planning**

The Board has continuously emphasized the importance of ensuring that
hazards are identified and controlled, work is performed in a careful
manner in accordance with the safety controls, and that DOE uses
appropriate feedback mechanisms to ensure continuous improvement at the
individual activity level. In its implementation plan for Recommendation
2004-1, DOE acknowledged the need to strengthen this area and committed
to enhanced focus on work planning and work control at the field office
level. In 2006, the Board continued to provide technical oversight of
activity-level work planning within the DOE complex. Reviews of three
activities at the Hanford site and one at Oak Ridge National Laboratory
were conducted. At both of these sites, DOE had made significant
improvements, but it is too early to tell if these changes have been
fully captured in institutional policies and procedures.

4.  **Small Business Contracting**

Section 6022(c) of Public Law 109-13 mandated that the Administrator of
the Small Business Administration, Chief Counsel for Advocacy of the
Small Business Administration, Chairman of the Defense Nuclear
Facilities Safety Board, Secretary of Energy, and Administrator of NNSA
jointly conduct a study on means to promote opportunities for small
business participation in DOE\'S contracting system. While the study
covered contracting for all DOE facilities, the Board limited its
involvement to contracts at defense nuclear facilities.

The Board provided its input to DOE for the report on September 2, 2005
and DOE issued the final report on June 27, 2006. The Board noted that
in exercising its safety oversight responsibilities, it has no
preference on the size of contractors managing defense nuclear
facilities or activities. The Board expects defense nuclear work to be
conducted safely. Hence, regardless of the size of the contractor, work
should be conducted under the same contractual requirements, with the
same degree of formality, and with the same level of safety oversight by
DOE and the Board. The Board noted that substantially increasing the
number of prime contractors increases the number of DOE staff necessary
to discharge non-delegable safety functions. DOE is already short of
trained staff.

**5.2 Health and Safety Directives**

1.  **Improvement of Directives**

In 2006, as part of its ongoing review of new and revised DOE
directives, the Board evaluated and provided constructive critiques of
38 directives dealing with nuclear design criteria, maintenance
management, worker protection, emergency management, and project
management. At year\'s end, the Board\'s staff was working to resolve
safety issues on 23 directives. Work was completed on these directives:

-   DOE Order 151.1X, *Comprehensive Emergency Management System*

-   DOE Order 251.lX, *Directives Program*

-   DOE Order 413.3A, *Program and Project Management for the
    Acquisition of Capital Assets*

-   DOE Order 420.lB, *Facility Safety*

-   DOE Guide 424.1-lA, *Implementation Guide for Use in Addressing
    Unreviewed Safety*

-   *Question Requirements*

-   DOE Order 452.lC, *Nuclear Explosive and Weapon Surety Program*

-   DOE Order 452.2C, *Safety of Nuclear Explosive Operations*

-   DOE Standard 1104, *Review and Approval of Nuclear Facility Safety
    Basis Docume*nts

-   DOE Manual 450.5-1, *Integrated Safety Management Manual*

    1.  **NNSA Policy Letters**

On several occasions the Board expressed concern over a new family of
directives called \"policy letters\" that had no standing in DOE\'s
directives system. In response, NNSA agreed to suspend applying these
documents to defense nuclear facilities until a satisfactory directives
system architecture was developed. Changing course, NNSA decided to
eliminate the policy letter system entirely and replace it with a new
directives system. In 2006, NNSA presented to the Board its plans for
new directives to be issued in 2007.

2.  **Natural Phenomena Hazards**

In an August 27, 2004 letter to DOE, the Board requested improved
technical criteria for systems, structures, and components relied upon
to confine radioactive materials threatened by natural phenomena. In
2005, DOE provided a revision to DOE Guide 420.1-2, *Guide for the
Mitigation of Natural Phenomena Hazards for DOE Nuclear Facilities and
Non-nuclear Facilities*. The Board provided comments on this revision,
suggesting that DOE consider adopting the consensus standard American
National Standards Institute/American Nuclear Society Standard
2.26-2004, *Categorization of Nuclear Facility Structures, Systems, and
Components for Seismic Design*, rather than revising the guide. DOE has
elected to adopt this national consensus standard by providing guidance
for its implementation in a new standard, DOE-STD-1189, *Integration of
Safety into the Design Process.*

3.  **Worker Safety Rulemaking**

On December 8, 2003, DOE published in the *Federal Register* a proposed
rule on worker protection, 10 CFR Part 85 1, *Worker Safety and Health*.
This action was required under the Bob Stump National Defense
Authorization Act, Public Law 107-314, which directed DOE to promulgate
regulations on worker safety and health, rather than rely exclusively on
a contractual approach. On January 26, 2005, DOE published a revised
proposed rule for public comment. The Board\'s comments on this rule
stressed tightening the proposed exemption criteria, strengthening the
tailoring process, and complying with the oversight themes of
Recommendation 2004-1. DOE modified the proposed rule considerably based
on input from the Board, and published the final rule on February 9,
2006. The Board also provided oversight of DOE\'s development of DOE
Guide 440.1-8, *Implementation Guide for Use with 10 CFR Part 851*,
*Worker Safety and Health Program*, which was issued in January 2007.
The rule\'s full implementation is required by May 2007.

4.  **Hazard Categorization**

In a letter dated June 26, 2006, the Board requested that DOE review and
address issues associated with the implementation of DOE-STD-1027-92,
*Hazard Categorization and Accident Analysis Techniques for Compliance
with DOE Order 5480.23, Nuclear Safety Analysis Reports, Change Notice
1*. The letter described specific problems observed throughout the
complex, including inappropriate exclusion of sealed sources from
facility inventories, the interaction between hazard categorization and
criticality safety, and poorly defined technical bases for threshold
values. Improper application of the standard can result in
non-conservative facility hazard categorization and a reduced set of
safety requirements and controls. DOE responded on October 25, 2006,
with a letter committing to the establishment of a working group to
address these and other weaknesses in the standard and develop a path
forward for resolution, which will be available by March 2007.

5.  **Scope of the Directives System**

In response to previous input from the Board, DOE offered changes to DOE
Policy 251.1, *Directives Program Policy*, DOE Order 251.1X, *DOE
Directives Program*, and DOE Manual 251.1-lX, *Directives Program
Manual*. The Board\'s oversight resulted in a significantly improved
series of directives that provide the framework for the development of
all other safety directives. The directives in the 251 series were
published in August 2006.

**5.3 Safety Programs**

1.  **Administrative Controls**

Contractors at defense nuclear facilities are required by DOE\'s
principal nuclear safety rule (codified in 10 CFR Part 830) to submit
documented safety analyses and controls for approval. To meet this
requirement, many contractors have developed new safety analyses and,
perhaps more importantly, new safety controls. In many cases, the choice
of these new safety controls was limited because the installed equipment
had been built years or even decades ago. This led some contractors to
reclassify existing equipment as safety-related and to rely on
safety-related administrative controls rather than engineered features.
In Recommendation 2002-3, the Board advised DOE to improve its guidance
for the use of administrative controls at defense nuclear facilities.

Responding to the recommendation, DOE developed and implemented a plan
to improve the reliability and effectiveness of administrative controls
that serve important safety functions. As a key step in the
implementation plan, DOE developed and issued a new standard, *Specific
Administrative Controls* (DOE-STD-1186), and in 2006, completed the
commitments outlined in the implementation plan for Recommendation
2002-3. Of particular note, DOE revised the safe harbor methodology
associated with the performance of safety analyses (DOE-STD-3009,
*Preparation Guide for U.S. Department of Energy Nonreactor Nuclear
Facility Documented Safety Analyses*) to reflect the requirements
associated with specific administrative controls. The Board intends to
conduct independent verification reviews to assess the effectiveness of
implementation.

2.  **Active Confinement Systems**

The Board issued Recommendation 2004-2 to ensure that a reliable and
effective control would be available to mitigate the consequences of
potential accidents at defense nuclear facilities that rely on
confinement ventilation systems. DOE has now screened all Hazard
Category 2 and 3 defense nuclear facilities against criteria designed to
identify those with the potential for benefitting from the intent of the
recommendation. DOE also completed another major milestone in February
2006, developing and issuing its Ventilation System Evaluation Guidance
document. This document identifies a set of design and performance
attributes that ventilation systems should be evaluated against for
identification of potential upgrades. Several pilot facilities have been
identified by DOE to which these attributes will be applied, in order to
identify potential improvements, before the guidance document is applied
to the rest of Hazard Category 2 and 3 facilities that were identified
earlier in the year. The evaluation process will be completed over the
next two years, resulting in significant improvement in the safety
posture of defense nuclear facilities across the complex.

In 2006, DOE submitted a revised implementation plan to reflect delays
that have occurred. The Board objected to these changes in an August
2006 letter, noting that DOE had removed the Central Technical Authority
from the review and concurrence process and eliminated the Central
Technical Authority\'s responsibility for ensuring technical adequacy.
The Board also objected to the removal of the Program Secretarial
Officer from the review and approval process for exceptions, giving that
authority over to the site manager. Over the Board\'s objections, DOE
elected to follow the revised implementation plan. The Board has been
informed that the Office of Environmental Management and the National
Nuclear Security Administration have provided guidance to explain the
coordination and level of reviews expected by these program offices for
ventilation system evaluations, including review and oversight by the
Central Technical Authorities and subsidiary offices. The Board is
evaluating DOE\'s implementation plan and will closely follow the
implementation of the recommendation in 2007.

3.  **Quality Assurance**

During 2006, the Board continued to urge DOE to improve the
implementation of quality assurance programs. In accordance with its
Quality Assurance Improvement Plan, DOE is reviewing quality assurance
processes at its various sites and developing corrective actions where
needed. The Quality Assurance Working Group (under the auspices of the
Energy Facility Contractors Group) continues to assist DOE in making
these improvements. The actions taken as part of NNSA\'s \"Quality
Assurance Roadmap to Excellence\" also continue to have a positive
effect. The Board also provided representation at the biannual meeting
of the American Society of Mechanical Engineers\' committee devoted to
NQA- 1, *Quality Assurance Program Requirements for Nuclear Facilities*.

4.  **Software Quality Assurance**

The safe design and operation of many defense nuclear facilities is
assured, in part, by analysis and operational support provided by
computer software. In January 2002, the Board issued Recommendation
2002-1 to force significant changes in DOE\'s policies and practices
regarding software design, implementation, testing, configuration
management, and training of personnel in order to address longstanding
safety deficiencies in these areas. During 2006, the newly revised DOE
Order 414.1C, *Quality Assurance*, that contained new software quality
assurance requirements, was added to NNSA contracts. At this point, DOE
has completed all but one action in the implementation plan. DOE
performed a gap analysis on its toolbox of codes to determine the
actions needed to bring them into compliance with software quality
assurance qualification criteria. However, the funding to upgrade codes
based on the gap analysis results has not been available. DOE will brief
the Board on its plan for correcting this deficiency in 2007.

5.  **Risk Assessment Methodologies**

Previously, the Board conducted a comprehensive assessment of DOE\'s
policies, programs, processes, and procedures with respect to the use of
quantitative risk assessment and related methodologies. This review
found that DOE widely employed quantitative risk assessment but without
adequate controls over quality and applicability. This in turn causes
risk management plans, risk mitigative actions, and residual risk
identification to be inadequate. DOE responded by offering to develop a
policy governing the use of risk assessment methodologies at defense
nuclear facilities.

In a letter to DOE dated November 23, 2005, the Board found deficiencies
in the policy as written and objected to the slow pace of its
development. As a result of the Board\'s observations and concerns, DOE
has chartered a working group comprising representatives from the major
program offices, field elements, national laboratories, and major
contractors to guide the efforts in this area. This group has developed
a draft policy, along with draft implementation guidance, which is
scheduled to be released for general comment in early 2007. The Board
will continue to oversee DOE\'s progress in developing an effective
policy and useful implementing guidance to govern the use of risk
assessment methodologies at DOE facilities.

6.  **Criticality Safety**

The Board continued to monitor DOE\'s progress in improving nuclear
criticality safety programs. The Board reviewed a DOE report entitled
*Status of the Department of Energy Nuclear Criticality Safety Program
for Calendar Year 2005* (February 8, 2006), and in a letter dated June
28, 2006, noted favorably the positive influence of the Criticality
Safety Support Group, the improved stability of funding for the
criticality program, and the increased frequency \'of reviews under the
Criticality Safety Monitoring Program. However, the Board was concerned
about several items that are fundamental to the health of DOE\'S nuclear
criticality safety program and requested that DOE provide an estimate of
when critical experiments would be started at Nevada Test Site and a
status report on staffing and training. In October 2006, DOE responded
to the Board that critical experiment operations at Nevada Test Site are
planned to resume in late 2009, and the experimenters will undergo
requalification in accordance with a training plan to be finalized in
2007. DOE also identified sites that require additional criticality
safety resources to provide effective oversight and has taken action to
acquire and qualify these resources. Finally, a number of engineer
training courses devoted to criticality matters were held at Lawrence
Livermore National Laboratory this past summer, after a nearly two-year
hiatus throughout the complex.

The Board has also closely followed efforts by Los Alamos National
Laboratory to correct program deficiencies identified during an October
2005 review. A review in early August found that progress in completing
the corrective actions had stalled. Subsequently, the Board issued a
letter on September 22, 2006, asking DOE what compensatory measures
would be put in place until the laboratory\'s program deficiencies could
be corrected. DOE responded in a letter dated November 2, 2006, stating
that it has increased oversight of the laboratory\'s program and
assigned a full-time individual to oversight. A limited review of
compensatory measures taken for current operations determined that there
were no immediate criticality safety concerns. DOE will meet
periodically with contractor management to monitor progress on
corrective actions. The Board will continue to monitor progress and
oversight effectiveness.

At Lawrence Livermore\'s Plutonium Facility, a review by the Board
identified two noncompliances with requirements of American National
Standards Institute/American Nuclear Society Standard 8.19,
*Administrative Practices for Nuclear Criticality Safety*. The Board
described these noncompliances to DOE in a letter dated October 11,
2006. On November 22, 2006, DOE directed the laboratory to take action;
improvements in the laboratory\'s criticality safety program have now
been made.

7.  **Readiness Reviews**

In a September 14, 2005 letter to DOE, the Board highlighted some
instances of reduced rigor in the selection of readiness review
processes for defense nuclear facilities. Such reduced rigor affects the
application of design requirements and preparation of safety documents.
One cause for this situation appeared to be inconsistent interpretation
and implementation of rules and orders that apply to new Hazard Category
1, 2, and 3 nuclear facilities and major modifications to existing
nuclear facilities. In the cases noted by the Board, DOE used
nonconservative interpretations that could lead to less vigorous
readiness reviews and omission of required reviews of design and safety
documentation. As a result, DOE conducted a focused review at two sites
and found inconsistent interpretation and application of these nuclear
safety definitions. DOE will brief the Board before these definitions
are revised in the DOE directive.

The Board had also identified several problems with the planning and
conduct of startup readiness reviews at the Savannah River Site in late
2005. As a result, the Board provided extensive oversight of the 17
contractor and DOE readiness reviews that were conducted at the Savannah
River Site during 2006 to ensure the subsequent corrective actions were
producing the desired effect. In general, a significant improvement was
observed. That being said, the Board disagreed with a contractor
decision in a particular case in which a readiness review commenced
before the supporting authorization basis had been approved. The Board
also identified other problems with specific readiness reviews: frequent
equipment reliability issues, lack of prerequisites in a plan of action,
disclosure of an emergency drill scenario ahead of time, and reviewer
actions that could bias their review. Feedback from the Board on these
issues allowed corrective actions to be taken to ensure they remained
isolated cases.

Similarly, the Board identified weaknesses with the Idaho process for
determining readiness to begin venting of remote-handled transuranic
waste drums. DOE-Idaho gave approval to perform a readiness assessment
for a new Hazard Category 2 activity instead of a more rigorous
operational readiness review as required by DOE Order 425.lC, *Startup
and Restart of Nuclear Facilities*, without receiving an exemption from
DOE headquarters. DOE\'s Office of Environmental Management issued a
memorandum to all of its sites providing clear expectations for
implementing the requirements of the order.

**5.4 Technical Competence**

1.  **Federal**

In accordance with the implementation plan for Recommendation 2004-1,
DOE prepared a corrective action plan in August 2005 to address federal
technical competency issues. The action plan focused on several major
areas including: (1) conducting a functional workforce analysis as a
basis for meeting the needs of DOE\'s missions for the next five years;
(2) establishing a voluntary corporate accreditation process for the
Technical Qualification Program based on the Institute of Nuclear Power
Operation model; (3) reestablishing the corporate Technical Leadership
Development Program to hire and develop new engineers; and (4)
strengthening the qualification program for Senior Technical Safety
Managers. DOE plans to revise its Federal Technical Capability Manual to
incorporate changes in federal technical capability expectations
developed as part of the implementation plan. DOE will also conduct a
follow-on line management review of the effectiveness of their
corrective action plan.

DOE achieved several successes in pursuing the corrective action plan.
In May 2006, DOE conducted the initial accreditation review of the
Technical Qualification Program at the site office for the Y-12 National
Security Complex. The Y-12 Site Office had a solid program and served as
a good benchmark for this accreditation process. DOE budgeted \$2
million for fiscal year 2008 to reestablish the Corporate Technical
Intern Program, which would fund ten interns. DOE developed and executed
a Senior Technical Safety Manager overview course in Albuquerque in
February 2006 for qualified managers in the process of requalification
and for new manager candidates to assess gaps in their knowledge level.
DOE will use lessons learned from this course to improve its next
scheduled course. DOE is also strengthening its qualification criteria
with mandatory performance activities through a significant revision to
DOE-STD-1075, *Senior Technical Safety Manager Functional Area
Qualification Standard*. DOE expects to issue this standard later in
2007.

2.  **Criticality Safety Engineers**

In 2006, the Board assessed the nuclear criticality training and
staffing at several DOE site offices in the area of nuclear criticality
safety oversight. The Board found that several DOE site offices continue
to be either understaffed or not staffed at all in the area of
oversight. Some of the problems with contractor programs can be traced
to ineffective oversight by DOE site offices. By October 2006, DOE was
actively seeking to fill criticality safety positions at the Nevada Site
Office, Los Alamos Site Office, and Savannah River Operations Office. In
the meantime, technical support in the criticality safety area is being
provided to these sites through DOE\'s Albuquerque Service Center. At
the Los Alamos Site Office, a general engineer has also been assigned as
a full-time criticality safety engineer. He is required to complete
qualification as an expert by April 2008, but DOE is exploring
mechanisms to accelerate his qualification progress.

3.  **Federal Facility Representatives**

The Board conducted on-site reviews of the staffing levels and training
of DOE\'s facility representatives at the Pantex, Sandia, and Los Alamos
Site Offices. The Board found that both staffing and training were
inadequate in all three offices. DOE agreed and took steps to improve
its activity-specific hazard training and to develop a more rigorous
means of establishing a minimum staffing level at each office. However,
DOE continues to experience difficulty maintaining the desired number of
qualified facility representatives at too many sites.

**6. Public Outreach and Agency Administration**

**6.1 Public Hearings**

During 2006, the Board conducted two public hearings. The Board held its
first public hearing in March at Los Alamos, New Mexico, at which it
received testimony from DOE and its operating contractors for Los Alamos
National Laboratory. The Board\'s interest was focused on improvements
in safety management at the laboratory\'s defense nuclear facilities.
The second public hearing, held in July in Washington, D.C., was the
second in a series regarding DOE\'s incorporation of safety into design
and construction projects. This hearing explored actions taken by DOE to
further improve incorporation of safety early in the design process.

2.  **Responding to Public Requests**

The Board answered numerous public requests for documents and
information and responded to eight requests filed under the Freedom of
Information Act. The average response time for requests was 5.6 working
days, as compared with the statutory requirement of 20 working days. The
Board\'s website (www.dnfsb.gov) contains a complete list of requests
processed since 2001.

3.  **Electronic Access**

The Board posts essential, publicly-releasable documents on its website
in a timely manner in a format suitable for downloading. The Board also
mails paper copies of certain documents (annual reports, technical
reports, public hearing notices, and others) to a list of nearly four
hundred addressees.

4.  **Inquiries into Health and Safety Issues**

The Board often receives information regarding potential health and
safety hazards from private citizens or from employees at defense
nuclear facilities. The Board treats these matters with the utmost
seriousness by assigning members of its legal and technical staff's to
investigate or inquire further. These inquiries, which may involve
interviews, review of documents, and site visits, are continued until
the Board is able to reach a technical judgment on the issues raised. If
the Board finds that a health or safety hazard exists, it takes prompt
action to inform DOE and closely monitors DOE\'s corrective actions.
When the Board receives information on matters outside its jurisdiction,
such as alleged criminal activities or unlawful personnel practices, it
refers the information to the appropriate federal agency for action.
During 2006, the Board directed inquiries into health and safety issues
at Hanford, Idaho, Los Alamos, and Pantex. These inquiries led to safety
improvements in the conduct of work at the respective sites.

5.  **Site Representative Activities**

The Board enhances its onsite health and safety oversight of defense
nuclear facilities by assigning experienced technical staff members to
full-time duty in the field. There are two site representatives at the
Pantex Plant near Amarillo, Texas; two at the Hanford Site near
Richland, Washington; two at the Savannah River Site near Aiken, South
Carolina; two at the Y-12 National Security Complex in Oak Ridge,
Tennessee; two at Los Alamos National Laboratory in New Mexico; and one
at Lawrence Livermore National Laboratory in Livermore, California. Site
representatives conduct first-hand assessments of nuclear safety
management to identify health and safety concerns promptly. They meet
regularly with the public, union members, Congressional staff members,
and public officials from federal, state, and local agencies. The Board
receives weekly reports and regular briefings from its site
representatives in person and maintains continuous contact with them
using all available communication media.

6.  **Human Resources**

In the second half of 2006, the Board instituted an aggressive hiring
initiative to replace retiring and otherwise departing technical staff.
In addition, the Senate confirmed nominees for the two vacant Board
member positions. As a result, the Board increased its personnel
strength to 89 (including Board members) with four more technical staff
members scheduled to arrive in early January 2007.

The Board has assembled a professional staff of exceptional technical
capability. Staff members\' expertise covers all major aspects of
nuclear safety: nuclear, mechanical, electrical, chemical, fire
protection, and structural engineering, as well as physics and
metallurgy. Most mid- to senior-level technical staff members possess
practical nuclear experience gained from duty in the United States Navy
nuclear propulsion program, the nuclear weapons field, or the civilian
nuclear reactor industry. Both the Board and its staff include
individuals experienced in environmental impact assessments and
regulatory processes. Four of the Board\'s attorneys have technical
degrees, and one is also a licensed professional engineer. The Board
expects its engineers and scientists to maintain the highest level of
technical knowledge, encouraging them to improve their skills
continually through academic study. Ninety-five percent of the Board\'s
technical staff holds advanced science and engineering degrees, with 17
percent at the doctoral level.

Junior technical staff members continue to be recruited through the
Board\'s professional development program. Entry-level employees
recruited into this 3-year program receive graduate education and
intensive on-the-job training guided by experienced technical mentors.
Currently, there is one entry-level employee in this program. The Board
will continue its vigorous recruitment program to attract the brightest
engineering students from colleges and universities across the country.

7.  **Information Technology and Security**

The Board has continued to strengthen internal controls and ensure that
it is in compliance with the requirements of the Federal Information
Security Management Act as well as other security guidance. The Board is
implementing the processes called for by Homeland Security Presidential
Directive 12 and has begun issuing cards compliant with this directive.

The Board has continued to increase its use of advanced information
technology.

Desktop hardware, software, and network servers provided to the staff
are continually upgraded to ensure that the latest tools are available.
In 2006, the Board continued to improve its information technology
infrastructure to allow the adoption of emerging technologies, such as
the conversion to IPv6 and the use of credentials for logical access
compliant with Homeland Security Presidential Directive 12. The Board
also continued to develop more robust technology capabilities at its
alternative facility. These capabilities will allow the Board to
continue to operate effectively in the event of an emergency or flu
epidemic. The Board\'s internet website is continuously updated to
ensure that public documents are available for viewing and downloading.
Access to documents has been improved by the installation of a better
search engine.

8.  **Dispute Resolution Programs**

The Board, like other federal agencies, is required by the
Administrative Dispute Resolution Act of 1996 to provide an alternative
dispute resolution program for use in resolving appropriate disputes.
The Board maintains such a program, making use of cooperative agreements
with other agencies to resolve workplace and contracts disputes
economically.

9.  **Financial Management**

The Board received its first unqualified audit opinion on its financial
statements and made progress in resolving other issues associated with
its annual independent audit. This represents a significant milestone in
the Board\'s efforts to fully comply with financial management laws and
practices.

**Appendix A: Recommendation Cited**

  ------------ ----------------- -------------------------------------------
  **Number**   **Date**          **Title**

  94-1         May 26, 1994      Improved Schedule for Remediation in the
                                 Defense Nuclear Facilities Complex

  95-2         October 11, 1995  Safety Management

  97-2         May 19, 1997      Continuation of Criticality Safety at
                                 Defense Nuclear Facilities in the
                                 Department of Energy

  98-2         September 30,     Safety Management at the Pantex Plant
               1998              

  2000-1       January 14, 2000  Prioritization for Stabilizing Nuclear
                                 Materials

  2000-2       March 8, 2000     Configuration Management, Vital Safety
                                 Systems

  2001-1       March 23, 2001    High-Level Waste Management at the Savannah
                                 River Site

  2002-1       September 23,     Quality Assurance for Safety-Related
               2002              Software

  2002-2       October 3, 2002   Weapons Laboratory Support of the Defense
                                 Nuclear Complex

  2002-3       December 11, 2002 Requirements for the Design,
                                 Implementation, and Maintenance of
                                 Administrative Controls

  2004-1       May 21, 2004      Oversight of Complex, High-Hazard Nuclear
                                 Operations

  2004-2       December 7, 2004  Active Confinement Systems

  2005-1       March 10, 2005    Nuclear Material Packaging
  ------------ ----------------- -------------------------------------------

**Appendix B: 2006 Reporting Requirements**

  ------------ -------------------------------- -------------- ------------
  **Date**     **Site or Topic**                **Response**   **Due**

  January 5    K-Basins at Hanford              Briefing       90 days

  January 17   Work Planning at Oak Ridge       Briefing       \--

  March 3      DOE Oversight Policies           Report         90 days

  March 27     Criticality Experiments          Report         60 days

  March 27     Vital Safety Systems             Report         60 days

  April 24     Rec. 2005-1 Repackaging          Report         30 days
               Methodology                                     

  May 1        Comments on DOE Manual 441.1     Report         30 days

  June 19      NNSA plans for G-Tunnel          Report         60 days

  June 26      DOE Standard 1027                Report         120 days

  June 28      Nuclear Criticality Safety       Report         90 days

  August 15    DOE Order 226.1                  Report         30 days

  September 22 Critical Experiments Facility    Report         \--

  September 22 Criticality Safety at Los Alamos Report         45 days
  ------------ -------------------------------- -------------- ------------

**Appendix C: Correspondence in 2006**

**Hanford Site**

September 7 letter to the Assistant Secretary for Environmental
Management on structural issues in the Waste Treatment and
Immobilization Plant.

April 24 letter to the Assistant Secretary for Environmental Management
on review of the implementation of activity-level work control by Fluor
Hanford, Inc.

January 5 letter to the Secretary of Energy imposing a 90-day reporting
requirement on sludge stabilization and packaging at the K-Basins.

**Lawrence Livermore National Laboratory**

October 11 letter to the Administrator, NNSA, regarding the Board\'s
review of the nuclear criticality safety program.

May 10 letter to the Administrator, NNSA, on the development of the
authorization basis documentation for the Plutonium Facility.

**Los Alamos National Laboratory**

September 22 letter to the Secretary of Energy imposing a 45-day
reporting requirement on the site\'s nuclear criticality safety program.

**Nevada Test Site**

September 22 letter to the Administrator, NNSA, imposing a reporting
requirement, the report to be submitted when the Critical Decision-3
package is submitted, describing how previously identified
safety-related issues are being addressed at the Critical Experiments
Facility.

August 16 letter to the Deputy Administrator for Defense Programs, NNSA,
on building leaks and structural cracks in the Device Assembly Facility.

June 19 letter to the Administrator, NNSA, imposing a 60-day reporting
requirement to describe plans for staging, assessing, and disposing of a
damaged nuclear weapon or improvised nuclear device at the G-Tunnel.

March 27 letter of the Administrator, NNSA, imposing a 60-day reporting
requirement on the issues pertaining to the Critical Experiments
Facility.

**Pantex Plant**

December 15 letter to the Deputy Administrator for Defense Programs,
NNSA, requesting a completion date for the Final Assessment Report on
the implementation plan for Recommendation 98-2.

August 9 letter to the Deputy Administrator for Defense Programs, NNSA,
on the restart of W88 cell operations.

March 27 letter to the Administrator, NNSA, on formal conduct of
operations.

**Savannah River Site**

September 26 letter to the Administrator, NNSA, on surface settlement
profiles for the Pit Disassembly and Conversion Facility.

July 12 letter to Secretary of Energy forwarding a copy of the Board\'s
Third Annual Report to Congress on Plutonium Storage at DOE\'s Savannah
River Site.

March 3 letter to the Secretary of Energy imposing a 90-day reporting
requirement on the plans for implementing DOE Policy 226.1 and DOE Order
226.1.

**Oak Ridge National Laboratory, Y-12 National Security Complex**

February 28 letter to the Administrator, NNSA, on the documented safety
analysis for the 9212 Complex at Y-12.

January 17 letter to the Assistant Secretary for Environmental
Management imposing a reporting requirement for a briefing on the steps
planned to ensure worker protection during Tank W-1A soil
characterization.

**Other Correspondence**

November 21 letter to the Secretary of Energy accepting the revised
implementation plan for Recommendation 2004-1 and closing Recommendation
95-2.

August 21 letter to the Deputy Secretary of Energy on observations from
the Board\'s second public hearing on the integration of safety into
design.

August 16 letter to the Administrator, NNSA, on the resolution of issues
regarding DOE-STD-3016-2006.

August 15 letter to the Secretary of Energy imposing a 30-day reporting
requirement to provide the previously requested plans for implementing
the safety requirements in DOE Order 226.1.

August 15 letter to the Secretary of Energy requesting revision and
re-submission of the implementation plan for Recommendation 2004-2.

June 28 letter to the Deputy Secretary of Energy imposing a 90-day
reporting requirement regarding DOE\'s nuclear criticality safety
program.

June 26 letter to the Secretary of Energy on the reorganization of
DOE\'s Office of Environment, Safety and Health.

June 26 letter to the Acting Assistant Secretary for Environment, Safety
and Health imposing a 120-day reporting requirement to address issues
associated with DOE-STD-1027-92.

May 1 letter to the Acting Assistant Secretary for Environment, Safety
and Health establishing a 30-day reporting requirement to respond to the
Board\'s comments on Draft DOE Manual 441.1, *Nuclear Material Packaging
Manual*.

April 24 letter to the Secretary of Energy imposing a 30-day reporting
requirement to address comments on the Draft Repackaging Prioritization
Methodology for Recommendation 2005-1.

March 27 letter to the Secretary of Energy imposing a 60-day reporting
requirement on vital safety systems.

January 20 letter to Secretary of Energy transmitting DNFSB/TECH-36,
*Integrated Safety Management: The Foundation for an Effective Safety
Culture*.