THIRTEENTH ANNUAL REPORT

TO CONGRESS

DEFENSE NUCLEAR FACILITIES

SAFETY BOARD

FEBRUARY 2003

ii

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)

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 must consider the

technical and economic feasibility of implementing the recommended measures. The Secretary may

accept in whole or in part or reject the recommendations. If the Secretary rejects a recommendation in

whole or in part for any reason, the Board does not withdraw or modify the recommendation, and the

Secretary maintains the rejection, the Secretary must publish his or her decision and reasoning in the

Federal Register and must formally notify both Houses of Congress. The Secretary must report to the

President and Congress if implementation of a recommendation is impracticable because of budgetary

considerations. Should the Board determine that an imminent or severe threat to public health or safety

exists, the Board must transmit its recommendation to the President, and the Secretaries of Energy and

Defense.

The Board may conduct investigations, issue subpoenas, hold public hearings, gather

information, conduct studies, establish reporting requirements for DOE, and take other actions in

furtherance of its oversight of health and safety at defense nuclear facilities.

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 defense nuclear facilities during the period covered by the

report; (2) the improvements in the safety of DOE 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 defense nuclear facilities.
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EXECUTIVE SUMMARY

The nuclear weapons program of the Department of Energy (DOE), including the National Nuclear

Security Administration (NNSA), is a complex and hazardous operation. Missions include maintenance of

the national nuclear arsenal; dismantlement of surplus weapons; stabilization, storage, disposition, and

disposal of surplus nuclear materials and toxic and contaminated waste; and cleanup of surplus facilities and

sites. Some of these missions are carried out with aging facilities; 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. 

These improvements are described in this Annual Report along the lines of the Board’s three strategic areas

of concentration:

! Safe management and stewardship of the nation’s nuclear stockpile and nuclear weapons

components;

! Safe disposition of the hazardous remnants of nuclear weapons production; and

! Complex-wide health and safety issues.

The most significant health and safety improvements during 2002 are summarized below.

SAFE MANAGEMENT AND STEWARDSHIP OF THE NATION’S NUCLEAR WEAPONS

STOCKPILE AND NUCLEAR WEAPONS COMPONENTS

! In response to the Board’s Recommendation 99-1, during 2002 NNSA met a safety goal of

repackaging an average of 200 pits per month into robust containers with inert internal

environments, reaching a total of more than 6,000 pits repackaged by the end of the year.

! The Board’s efforts to improve the lightning protection posture at the Pantex Plant reached a

milestone in 2002 when Sandia National Laboratories (SNL) completed low-voltage testing of

all selected nuclear facilities under the project plan for lightning protection.

! Responding to deficiencies identified by the Board, NNSA directed the Pantex Plant contractor

to revise the Unreviewed Safety Question (USQ) process to fulfill the requirements of 10 CFR

§ 830.203.

! Based on observations of a contractor operational readiness review (ORR) for the wet

chemistry process at the Y-12 National Security Complex (Y-12), the Board found that
1

 See Appendix A for the full text of the recommendation.

vi

preparations in the areas of operating procedures, conduct of operations, and training were

inadequate. The ORR was suspended pending corrective actions.

! In response to the Board’s oversight, DOE’s Y-12 site contractor moved non-nuclear material

out of inadequate facilities, razed one facility, prepared another facility for transfer, reduced the

material inventory in Building 9206, and developed disposition pathways for several unique

items.

! The Board issued Recommendation 2002-2, Weapons Laboratory Support of the Defense

Nuclear Complex urging the Secretary of Energy for safety reasons to reemphasize the priority

of the nuclear weapons program at the nuclear weapons laboratories, and to ensure that clear

lines of communication are maintained between the laboratories and the complex.1

! The Board identified significant deficiencies in the safety basis and controls associated with the

Plutonium-238 Scrap Recovery Line at the Los Alamos National Laboratory (LANL). The

weapons laboratory contractor performed a new process hazards analysis, and proposed new,

more robust controls to NNSA.

! The Board identified numerous physical deficiencies with the lightning protection system at the

Weapons Engineering Tritium Facility at LANL. The laboratory corrected the deficiencies and

imposed administrative controls to minimize the possibility of future deficiencies.

! As a result of Recommendation 2000-2, LANL found institutional and facility-level deficiencies

in the inspection, testing, and maintenance of fire protection systems. Subsequently, LANL

developed and is now executing a corrective action plan.

! At the urging of the Board, DOE’s contractor for the Lawrence Livermore National Laboratory

(LLNL) has developed a set of compensatory measures and design modifications to address

deficiencies associated with the emergency power system for Building 332, and to foster an

enhanced understanding of vulnerabilities in emergency power systems.

! The Board found that deactivation planning for LLNL’s Heavy Element Facility was piecemeal

rather than systematic and integrated. In response to the Board’s letter dated March 11, 2002,

LLNL corrected the poor planning, leading to improvements in safety and efficiency.

! The Board identified serious deficiencies in the Nevada Test Site’s (NTS) readiness to safely

conduct underground nuclear weapons tests. NNSA is preparing a safety basis, improving the

state of readiness of facilities and equipment, and developing a readiness review process

compliant with NNSA requirements.
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! The Board informed NNSA that safety controls had not been implemented adequately at NTS

waste facilities. NNSA subsequently added nuclear facility requirements to the contract with its

primary contractor and initiated a complete revision of the documented safety analysis of all waste

activities at NTS.

SAFE DISPOSITION OF THE HAZARDOUS REMNANTS OF NUCLEAR 

WEAPONS PRODUCTION

! The Board pressed DOE to complete the stabilization of remaining nuclear materials posing the

highest risk. The following activities were carried out in continuing response to the Board’s

recommendations:

– At the Rocky Flats Environmental Technology Site (RFETS), all plutonium- bearing residues

(more than 100 metric tons) were packaged into stable configurations; all plutonium-bearing

solutions were eliminated; and more than 60 percent of the plutonium metal and oxide material

was stabilized and packaged into robust sealed containers.

– At the Hanford Spent Nuclear Fuel Project, a major milestone was reached with the removal,

stabilization, and packaging of the first containers of deteriorating spent nuclear fuel from the

K-East Basin.

– At the Hanford Plutonium Finishing Plant, stabilization of plutonium-impregnated polystyrene

cubes was begun; all plutonium solutions were disposed or converted to stable solids; thermal

stabilization of plutonium alloys was completed; and all plutonium-bearing ash and sand, slag,

and crucible residues were packaged for disposal at the Waste Isolation Pilot Plant (WIPP).

– At the Savannah River Site (SRS), disposition of plutonium-bearing residues and dissolution

of damaged and deteriorating targets and spent nuclear fuel continued; stabilization and

disposition of plutonium solutions began.

– At LANL, processing of plutonium residues and oxide items continued; higher- risk materials

and organic solutions were eliminated.

! The Board issued DNFSB/TECH-32, Savannah River Site Canyon Utilization, emphasizing

the role of the F-Canyon facility in safely stabilizing nuclear materials. DOE continued to pursue

deactivation of F-Canyon, leading the Board to issue additional correspondence suggesting that

DOE identify clear and achievable disposition paths for materials present in F-Canyon and define

how future disposition requirements for fissile materials could be met without F-Canyon before

proceeding with deactivation. Full response by DOE is still awaited.

! The Board identified safety deficiencies in the practices at RFETS and Hanford for measuring

moisture and other volatile materials remaining in stabilized plutonium oxides. To correct the
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deficiencies, DOE changed its measurement techniques and strengthened its understanding of

moisture measurement.

! The Board identified safety deficiencies in the processes for stabilizing impure plutonium oxide

materials at RFETS and plutonium-impregnated polystyrene cubes at Hanford, resulting in

process modifications to improve health and safety.

! The Board advised DOE to correct promptly the known deficiencies in the confinement ventilation

system for the H-Canyon facility at SRS, with the result that DOE is making the needed repairs.

! The Board issued a letter identifying weaknesses in DOE’s disposition program for uranium-233-

bearing sodium fluoride traps stored at the Oak Ridge National Laboratory (ORNL); in response,

DOE committed to timely decisions and corrective actions.

! In response to a letter from the Board identifying vulnerabilities associated with the large quantity

of depleted uranium stored at SRS, DOE started to dispose of the material housed in the worst

storage conditions and to evaluate the best way to dispose of the remaining materials by fiscal

year 2006.

! The Board’s evaluations of the Hanford Spent Nuclear Fuel Project resulted in several key

improvements, including enhanced safety of the equipment used for transferring spent fuel from the

Hanford K-East Basin; improved contamination controls for the transfer casks; and an improved

mechanical sealing process for storage canisters and the commitment to expedite closure welding

of these canisters.

! In response to the Board’s oversight, DOE modified the in-service inspection program at SRS to

require ultrasonic inspection of all double-shell high-level waste tanks instead of just a subset, and

to inspect the tanks at greatest risk of corrosion early in the program.

! In response to a letter from the Board regarding the draft documented safety analysis for highlevel waste facilities at SRS, the SRS contractor performed additional sensitivity calculations and

added specific administrative controls in the Technical Safety Requirements to protect key input

values and assumptions used in the accident analyses.

! Following continued urging by the Board to reduce the hazards in Building 9206 at the Y-12

National Security Complex (Y-12), pyrophoric material was stabilized.
2

 See Appendix A for the full text of the recommendation.

3

 Also found in Appendix A.

ix

COMPLEX-WIDE HEALTH AND SAFETY ISSUES

Accomplishments affecting multiple sites:

! In response to Recommendation 2000-2, DOE completed detailed reviews of vital safety systems

that identified equipment degradation, as well as program weaknesses (such as control of

drawings), that needed improvement. DOE has taken positive steps to ensure that the condition

of vital safety systems is understood and controlled.

! The Board has urged DOE to integrate hazard and safety analyses more effectively. In response,

DOE has developed a draft handbook—Integration of Multiple Hazard Analysis

Requirements and Activities.

! The Board continued to seek improvements in DOE’s quality assurance program in 2002. At the

Board’s urging, DOE issued a Quality Assurance Improvement Plan to strengthen the

implementation of existing quality requirements for safety-related components and systems.

! The Board issued Recommendation 2002-1, Quality Assurance for Safety-Related Software,

to strengthen requirements and guidance on engineering practices for safety-related software.2

! The Board issued Recommendation 2002-3, Requirements for the Design, Implementation,

and Maintenance of Administrative Controls. This recommendation charges DOE to

promulgate a set of requirements for safety-class and safety-significant administrative controls; to

establish appropriate expectations for the design, implementation, and maintenance of these

important safety controls; and to ensure that all existing administrative controls are evaluated

against these new requirements and upgraded as necessary.3

! The Board has continued its efforts to ensure the availability of a criticality safety infrastructure to

support nuclear operations (see Recommendation 97-2, Criticality Safety). One significant

DOE accomplishment in response to the Board was the establishment of a stable funding source

for future criticality safety programs.

Accomplishments at Specific Sites:

! The Board identified deficiencies in the Integrated Safety Management (ISM) System of the Oak

Ridge environmental management contractor. In response, DOE and the contractor completed

more than 150 actions to strengthen the ISM System, including adding 25 DOE health and safety

orders to the contract, conducting training in safety basis fundamentals for key personnel, and

hiring additional technical staff.
x

! The Board found weaknesses in a Hanford contractor’s feedback and improvement

program. Following implementation of corrective actions, DOE performed a focused review

of the ISM system of the Office of River Protection (ORP) and the contractor, and found

that significant improvement had occurred.

! Inspections of dry pipe fire protection systems at Hanford, conducted in response to the

Board’s Recommendation 2000-2, found significant quantities of debris obstructing fire

protection systems within the Central Waste Complex. The systems have been cleaned.The

Board found a number of weaknesses related to work control, outage planning, and

equipment reliability related to the Spent Nuclear Fuel Project at Hanford. As a result of the

Board’s review, DOE and its contractor made changes that have improved project reliability

and equipment availability.

! In response to the Board’s observations on the maintenance program at Y-12, the site

implemented a comprehensive maintenance improvement plan that has resulted in measurable

improvement in the site’s maintenance program and equipment availability.

! The Board found that the design of the Tritium Extraction Facility (TEF) at SRS would not

adequately protect workers from a tritium release in an earthquake. DOE responded by

adding a seismic monitor and alarm system to the design.

! When out-of-specification concrete was placed for the Hanford Waste Treatment Plant

(WTP) Low-Activity Waste basemat, the Board questioned the effect of the deficiency on

the structural integrity of the building under all design loading conditions. In response, WTP

developed a systematic approach to investigating and correcting the areas of weak concrete.

! The Board determined that the proposed structural configuration for the Highly Enriched

Uranium Materials Facility at Y-12 would not safely resist seismic forces and that the design

might not ensure a criticality-safe configuration of the uranium storage cans after an

earthquake. In response, DOE strengthened the structure and reconfigured the storage

design. 

OUTSTANDING SAFETY PROBLEMS OF DEFENSE NUCLEAR FACILITIES

! Ensuring that safety information developed at the national laboratories is adequately

communicated to DOE’s defense nuclear complex. Recommendation 98-2, Safety

Management at the Pantex Plant, urged DOE to improve the tooling and procedures used

to work on nuclear explosives by means of an engineering process known as Seamless

Safety for the 21st Century (SS-21). In 2002, the Board continued to urge DOE to expedite

the full implementation of SS-21 for all weapon systems to improve health and safety. 

Although DOE has made progress, technical and resource issues continue to impede SS-21

implementation. These issues are often the result of poor communication between the
4

 See Appendix A for the full text of the recommendation.

xi

national laboratories and the complex. To address this support issue complex-wide and to

maintain progress in the implementation of Recommendation 98-2, the Board issued

Recommendation 2002-2, Weapons Laboratory Support of the Defense Nuclear

Complex. This recommendation outlined a number of actions DOE should take to ensure

that information on weapons safety is developed by the national laboratories in a timely

fashion and is promptly and effectively disseminated to the complex.4

! Ensuring safety in the design and construction of new defense nuclear facilities. The

Board’s enabling statute requires that it review the design and construction of new defense

nuclear facilities to ensure that adequate health and safety requirements are identified and

implemented, and that it make timely recommendations to the Secretary of Energy on any

needed public health and safety improvements. 

DOE is committed to numerous new design and construction projects during the next decade

to provide support for the nuclear weapons stockpile for the nation’s defense, and to resolve

the remaining health and safety issues that are the historical legacy of weapons production. 

For example, tritium extraction for stockpile use, conduct of nuclear experimentation, and

preservation of the strategic pit inventory will require the Board to oversee the health and

safety of new defense nuclear operations. New defense nuclear facilities currently in the

design and construction phases that support these missions include the Highly Enriched

Uranium Materials Facility at Y-12, TEF at SRS, and WTP at Hanford. 

These facilities must be designed and constructed in a manner that will support safe and

efficient operations for 20 to 50 years. This in turn requires a robust design process to

ensure that appropriate health and safety controls are identified and properly implemented

early in the process. ISM provides the framework for this process. DOE continues to

struggle with incorporating ISM principles into the design process. The Board’s expectation

is that the design and construction phases of defense nuclear facilities will demonstrate clear

and deliberate implementation of the principles and core functions of ISM, codified in

manuals of practice and implemented on design and construction projects.

! Stabilizing and confining nuclear materials and waste stored in degrading conditions. 

In response to the Board’s oversight, DOE is pursuing stabilization and disposition of the

hazardous remnants of nuclear weapons production. Substantial progress is being made

toward characterizing, stabilizing, and dispositioning many high-hazard nuclear materials, and

several associated new facilities are in either design, construction, or initial operation. 

However, DOE is encountering difficulty in maintaining its momentum in all areas of this

important risk reduction effort. The Board will continue to urge DOE to maintain, and in

some areas accelerate, these risk reduction activities. During 2002, DOE suspended

operations at the F-Canyon facility at SRS, a significant resource for the stabilization of

nuclear materials. The Board has strongly urged DOE to establish well-defined disposition
5

 See Appendix A for the full text of the recommendation.

6

 Also found in Appendix A.

xii

paths for materials that might have gone to F-Canyon, and will continue to review DOE’s

efforts in this area.

! Ensuring that health and safety controls established to prevent or mitigate the

hazards of activities at defense nuclear facilities are designed, implemented, and

maintained to be effective and reliable. Most facilities of interest to the Board were

constructed many years ago and are deteriorating as they age. The Board’s

Recommendation 2000-2, Configuration Management, Vital Safety Systems, addressed

the degrading condition of safety systems, calling upon DOE to assess the condition of vital

safety systems, designate technically competent system engineers, codify this program in the

DOE directives system, and ensure that DOE possesses the requisite technical expertise to

monitor and oversee these systems. 

In 2002, DOE completed initial assessments of vital safety systems in high-priority defense

nuclear facilities, and began more in-depth assessments of specific systems and programs

(e.g., control of drawings and configuration management) that the initial assessment identified

as problematic. These detailed assessments have continued to identify significant weaknesses

in the operability of a number of vital safety systems across the complex (examples include

the confinement ventilation system in Technical Area-48 at LANL and the fire suppression

system in the Central Waste Complex at Hanford). With the basic assessments nearing

completion, the Board has begun to place greater emphasis on the broader aspects of vital

safety system operability. At the Board’s urging, DOE issued a Quality Assurance

Improvement Plan to strengthen the implementation of quality assurance for the design,

procurement, construction, operation, and maintenance of vital safety systems. The Board

issued Recommendation 2002-1, Quality Assurance for Safety-Related Software, to

strengthen engineering practices for safety-related software.5

The Board has also challenged the reliability and design of systems reclassified as safetyrelated systems during development of the authorization basis of a facility. Several sites are

now developing backfit policies to formally evaluate reclassified systems against current

design criteria. Finally, the Board observed that, in many applications, DOE and its

contractors rely on technically inadequate operator actions or administrative programs to

reduce anticipated consequences of potential accidents. For this reason, the Board issued

Recommendation 2002-3, Requirements for the Design, Implementation, and

Maintenance of Administrative Controls.

6

! Maintaining the direction and momentum of the ISM program. In 1995, the Board

issued Recommendation 95-2, Safety Management, urging DOE to integrate work planning

and safety planning more effectively. The methodology that evolved from this
xiii

recommendation and from DOE’s Implementation Plan is termed Integrated Safety

Management. The term “integrated” is used to indicate that all aspects of safety, work

planning, and performance are integrated into a single process under the responsibility of line

management. ISM is a structured, comprehensive, common-sense approach to performing

work safely. Through ISM, the Board has encouraged DOE to identify and implement

measures to protect the public, workers, and the environment from a wide range of hazards: 

nuclear, chemical, and physical. The identification of hazards and development of protective

measures should be carried out in an integrated way. In 2002, DOE and the Board focused

on raising the technical expertise of DOE as a means to foster ISM growth. (This is a

congressional mandate to the Board—see S. Rep. No. 232, 100th Cong., 1st Sess., 10

(1987)—as well as a specific deliverable under Recommendation 2000-2, Configuration

Management, Vital Safety Systems). The Board evaluated and found wanting DOE’s

efforts to institutionalize the use of system engineers and federal subject matter experts for

vital safety systems. Qualification and training programs were deficient, and requirements for

many vital technical personnel, both system engineers and federal subject matter experts,

were unfulfilled. These issues remained open at the end of 2002.

HUMAN CAPITAL MANAGEMENT

The ability of the Board to fulfill its mission to ensure the health and safety of workers and the

public depends heavily on attracting and retaining top-caliber technical staff. The Board has been

successful in creating a work environment that emphasizes excellence as the standard for staff

performance, and rewards staff members accordingly. The pay banding and pay for performance

programs developed and implemented by the Board have proven to be effective in hiring technical talent,

holding employees accountable for their performance, and rewarding outstanding performance on the

job. 

The Board’s enabling legislation grants authority for excepted service hiring and classification. 

During fiscal year (FY) 2002, the Board operated at 63 percent of its statutory employment ceiling of

150 Full Time Equivalents due to fiscal constraints. Within these constraints, however, the Board used

excepted service authority, along with recruitment and relocation bonuses, student loan repayments, and

retention allowances. In consequence, the Board has been successful in competing for scientific and

technical staff in a competitive employment market. The recruitment and retention of scientific and

technical staff with outstanding qualifications continues to be critical to the successful accomplishment of

the Board’s mission. 

The Board expects its engineers and scientist to maintain the highest level of technical knowledge

to meet the wide range of health and safety challenges it faces. As of the end of FY 2002, 87 percent of

the staff held advanced degrees, 29 percent of which were at the Ph.D. level. To meet expected staffing

needs, the Board continued its recruitment of senior, experienced technical staff by traditional methods. 

To attract younger staff members, the Board relies on its Professional Development Program (PDP), a 3-

year program that brings entry-level technical talent into professional positions within the Board. Through
xiv

a technical mentor, individuals are provided a series of individually tailored developmental assignments,

formal academic schooling, and a 1-year hands-on field assignment. This is a highly competitive program

to attract the next generation of scientific and technical talent to federal service.

In summary, the Board’s ability to accomplish its health and safety mission successfully begins

with a determined, focused, and well-executed human capital program. This program uses all available

tools to attract and retain the people necessary to accomplish the job that Congress has asked the Board

to do.
xv

TABLE OF CONTENTS

Section Page

1. INTRODUCTION ...................................................... 1-1

1.1 Background ...................................................... 1-1

1.2 Heath and Safety Oversight Strategy .................................... 1-2

1.3 Goals and Objectives of the Board’s Strategic Plan ........................ 1-3

2. SAFE MANAGEMENT AND STEWARDSHIP OF NUCLEAR WEAPONS 

STOCKPILE AND COMPONENTS ........................................ 2-1

2.1 Safe Conduct of Stockpile Management ................................. 2-1

2.1.1 Pantex Plant ................................................ 2-1

2.1.2 Y-12 National Security Complex ................................ 2-3

2.1.3 Tritium Production ........................................... 2-4

2.2 Safe Conduct of Stockpile Stewardship ................................. 2-4

2.2.1 Recommendation 2002-2, Weapons Laboratory Support 

of the Defense Nuclear Complex . . . ............................. 2-4

2.2.2 Los Alamos National Laboratory ................................ 2-5

2.2.3 Lawrence Livermore National Laboratory ......................... 2-7

2.2.4 Nevada Test Site ............................................ 2-8

2.2.5 Sandia National Laboratories ................................... 2-9

3. SAFE DISPOSITION OF HAZARDOUS REMNANTS OF WEAPONS 

PRODUCTION ........................................................ 3-1

3.1 Stabilization and Storage of Remnant Materials ............................ 3-1

3.1.1 Complex-Wide Program ...................................... 3-1

3.1.2 Plutonium .................................................. 3-2

3.1.3 Uranium ................................................... 3-4

3.1.4 Special Isotopes ............................................. 3-5

3.1.5. Inactive NNSA Nuclear Materials ............................... 3-5

3.2 Stabilization of Spent Nuclear Fuel ..................................... 3-6

3.2.1 Hanford Spent Nuclear Fuel Project .............................. 3-6

3.2.2 Savannah River Site .......................................... 3-7
xvi

TABLE OF CONTENTS (Continued)

Section Page

3.3 Waste Management ................................................ 3-7

3.3.1 High-Level Waste ........................................... 3-7

3.3.2 Low-Level and Transuranic Waste ............................... 3-9

3.4 Facility Deactivation and Decommissioning .............................. 3-10

3.4.1 Safe Practices for Deactivation and Decommissioning ................ 3-10

3.4.2 Y-12 National Security Complex ............................... 3-10

3.4.3 Rocky Flats Environmental Technology Site ....................... 3-11

3.4.4 Fernald Closure Project ...................................... 3-11

3.4.5 Mound Closure Project ...................................... 3-12

4. COMPLEX-WIDE HEALTH AND SAFETY ISSUES .......................... 4-1

4.1 Implementation of Integrated Safety Management .......................... 4-1

4.1.1 Overview .................................................. 4-1

4.1.2 ISM Annual Update Process ................................... 4-1

4.1.3 Reliability and Configuration Management of Vital Safety

Systems ................................................... 4-2

4.1.4 Site-Specific ISM Reviews and Improvements ...................... 4-2

4.2 Health and Safety Directives .......................................... 4-3

4.2.1 Improvement of Directives ..................................... 4-3

4.2.2 Implementation of Directives .................................... 4-4

4.2.3 Recommendation 2002-3, Requirements for the Design, 

Implementation, and Maintenance of Administrative

Controls ................................................... 4-7

4.3 Technical Competence .............................................. 4-7

4.3.1 Competence of DOE and Contractor Personnel ..................... 4-7

4.3.2 System Engineers and Federal Subject Matter Experts ................ 4-8

4.4 Nuclear Facility Design Reviews ....................................... 4-9
xvii

TABLE OF CONTENTS (Concluded)

5. INFORMING THE PUBLIC .............................................. 5-1

5.1 Public Meetings. ................................................... 5-1

5.2 Responding to Public Requests ........................................ 5-1

5.3 Electronic Access .................................................. 5-1

5.4 Inquiries into Health and Safety Issues .................................. 5-1

5.5 Site Representative Activities ......................................... 5-2

Appendices

A. RECOMMENDATIONS. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . A-1

B. REPORTING REQUIREMENTS. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . B-1

C. CORRESPONDENCE. . . . . . . . . . . . . . . . . . .. . . . . . . . . .. . . . . . . . . . . . . . . . . . . . . C-1

D. ADMINISTRATIVE ACTIVITIES. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . D-1

E. HUMAN RESOURCES. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . E-1

F. LIST OF ABBREVIATIONS AND ACRONYMS. . . . . . . . . . . . . . . . . . . . . . . . . . . . F-1
1-1

1. INTRODUCTION

1.1 BACKGROUND

The Defense Nuclear Facilities Safety Board (Board) is an independent federal agency

established by Congress in1989. Simply stated, the Board’s mandate under the Atomic Energy Act is

safety oversight of the civilian nuclear weapons facilities managed by the Department of Energy (DOE). 

The nuclear weapons program remains a complex and hazardous operation. DOE must maintain in

readiness a nuclear arsenal, maintain aging facilities, dismantle surplus weapons, dispose of excess

radioactive materials, clean up surplus facilities, and construct new facilities for many purposes. All of

these functions must be carried out in a manner that protects the public, workers, and the environment. 

Congress expects the Board to be an independent, expert agency capable of understanding the

complexity of nuclear weapons facilities and operations. For that reason, Members of the Board are

required by statute to be experts in the field of nuclear safety. The Board has, in turn, assembled a

permanent staff with broad nuclear industry experience and competence in all major aspects of nuclear

safety: nuclear, mechanical, electrical, chemical, and structural engineering, as well as physics and

metallurgy. Currently, 87 percent of the Board’s technical staff hold advanced degrees, of which 29

percent are at the Ph.D. level. 

The Board has established site offices at six high-priority defense nuclear sites: Pantex Plant in

Texas, Los Alamos National Laboratory (LANL) in New Mexico, the Y-12 National Security Complex

(Y-12) in Tennessee, Savannah River Site (SRS) in South Carolina, the Hanford Reservation in

Washington State, and the Rocky Flats Environmental Restoration Site (RFETS) in Colorado. These

site offices provide the Board with capability for continuous on-site oversight. 

During the Board’s 13 years of operation, its priorities have evolved with changes in the nuclear

weapons program. The Board uses its Strategic Plan under the Government Performance and Results

Act (GPRA) to ensure that its limited resources remain focused on the most significant health and safety

challenges, and to keep pace with shifts in those challenges from year to year. The Board’s health and

safety activities are closely tied to goals and objectives embodied in this plan.

This Annual Report summarizes the Board’s work during calendar year 2002. Sections 2, 3,

and 4 describe progress in the three major areas of the Board’s operations: safe management and

stewardship of nuclear weapons, safe disposition of hazardous nuclear materials and facilities, and

complex-wide health and safety issues. Section 5 addresses the Board’s interactions with the public. 

Appendices A through F provide additional material: the text of the Board’s recommendations

(Appendix A), a list of reports requested from DOE (Appendix B), a list of the Board’s letters

(Appendix C), a summary of administrative activities (Appendix D), a description of the Board’s human

resources activities (Appendix E), and a list of abbreviations and acronyms used in this report (Appendix

F).
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1.2 HEALTH AND SAFETY OVERSIGHT STRATEGY

Maintaining an effective safety oversight program that fulfills the broad mandates of the Board’s

enabling legislation requires a constant reassessment of health and safety conditions throughout DOE’s

defense nuclear complex. The Board continues to focus its attention on the most hazardous DOE

operations and complex-wide health and safety issues, consistent with its strategic plan and the health and

safety oversight philosophy described below.

On the basis of 13 years of operating experience, the Board has established the following guiding

principles for maximizing the effective use of its resources:

! The primary responsibility for ensuring protection of the health and safety of the public and

workers rests with DOE’s line managers, extending in an unbroken chain from the Secretary

of Energy to the workers on the floor.

! As an external action-forcing agency, the Board influences the actions of DOE’s line

management to the extent necessary to achieve its objectives of improved health and safety.

! Effective safety management demands that safety expectations be clearly defined and tailored

to specific hazards at all levels—site, facility, and activity.

! Technical expertise is required to define, and ensure compliance with, controls commensurate

with the identified hazards.

! Health and safety oversight activities are prioritized largely on the basis of risks to the public

and workers. Key indicators are the types and quantities of nuclear material at risk and the

process and setting of the operations involved.

! With regard to final cleanup, demolition, and environmental restoration activities, the Board’s

health and safety oversight activities will be carried out in full cooperation with individual

states and other agencies such as the Environmental Protection Agency, in compliance with

the Atomic Energy Act of 1954, as amended, and federal environmental laws.

The Board is provided by statute with a number of action-forcing mechanisms to elicit a DOE

response to safety problems. Among these mechanisms are recommendations, typically broad and

comprehensive in nature; reporting requirements, most often sharply focused on specific safety issues;

and public hearings, used to obtain information from DOE, other expert sources, and the public at large

on important health and safety issues. 

Since 1989 when the Board began operations, 45 formal recommendations, comprising 210

individual sub-recommendations, have been transmitted to the Secretary of Energy. Eighty-nine reporting

requirement letters have been sent to DOE requesting specific information on actions that DOE agrees to

take to resolve the identified health and safety deficiencies. It is informative, in retrospect, to look at the
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topics the Board has asked DOE to target for safety improvements. The 45 recommendations and 89

reporting requirement letters fall into the broad categories of human resources (11), safety standards

(10), design and construction (13), decommissioning (12), safety management (35), and operational

safety (55). A review of these actions shows that in the early years, the Board focused on ensuring that

safety standards and DOE’s technical competence were adequate, while at the same time trying to

ensure that operational safety issues were dealt with expeditiously. Once adequate safety standards were

in place, the Board focused more explicitly on DOE’s safety management activities, on continuing

improvement in conduct of operations, and on ensuring the integration of safety principles into design,

construction, and decommissioning activities. 

The Board’s recommendation authority has been used most fruitfully for gaining DOE response

to broad, cross-cutting matters that affect much of the defense nuclear complex. Examples of complexwide issues include stabilization and remediation of hazardous materials, technical qualifications, criticality

safety, and configuration management of vital safety systems. In view of the typical breadth and

complexity of the issues addressed by a recommendation, the time required for DOE to develop an

implementation plan and carry it to completion is measured in years. 

In contrast, a mandatory reporting requirement has been an effective tool in compelling DOE to

respond in a more expeditious manner to important safety issues. Comparison of the Board’s use of

these two methods shows a marked shift beginning in 1994 toward much greater reliance on reporting

requirements. Prior to 1995, the Board had issued 31 recommendations and 17 reporting requirement

letters. For the 7-year period from 1995 through 2002, the Board issued 14 recommendations and 72

reporting requirement letters. In 2002 alone, the Board sent 22 reporting requirement letters to DOE. 

Using both recommendations and reporting requirements, the Board has been able to enhance

markedly DOE’s integrated safety management program. The health and safety of the public and

workers, and protection of the environment, have been improved as a result of the actions taken by DOE

in response to the combined 299 sub-recommendations and reporting requirement letters.

1.3 GOALS AND OBJECTIVES OF THE BOARD’S STRATEGIC PLAN 

The Board organizes its safety work by merging the broad health and safety mandate of its

statute with the requirements of GPRA. The Board’s Strategic Plan identifies the serious hazards

associated with the handling of nuclear weapons, weapon materials, and cleanup of aging and surplus

facilities. These hazards include the following:

! Tons of fissionable material, in various forms, housed in 50-year-old buildings and structures;

! Thousands of nuclear weapons being dismantled, inspected, or modified;

! Tons of plutonium, including components from dismantled nuclear weapons;
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! The nation’s strategic inventory of tritium gas, including thousands of individual tritium

containers removed from nuclear weapons;

! Thousands of tons of deteriorating spent nuclear fuel in water-filled storage basins; and

! More than 100 million gallons of high-level radioactive waste awaiting treatment.

The Board’s Strategic Plan sets forth its statutory mission, divided logically along the lines established by

three general goals:

! Safe stewardship of the nuclear weapons stockpile and nuclear weapons

components—Nuclear weapons stockpile support and defense nuclear research activities

continue to be planned and executed safely at DOE’s defense nuclear facilities under the

National Nuclear Security Administration ( NNSA).

! Safe disposition of the hazardous remnants of weapons production—Hazardous

remnants of nuclear weapons production are appropriately characterized, stabilized, and

stored, and legacy facilities are decommissioned in a manner that protects workers and the

public.

! Complex-wide health and safety issues—Integrated Safety Management continues to

evolve through feedback and improvement and is implemented in all life-cycle

phases—design and construction, startup, operation, and decommissioning.
7

 The terms “disassembly” and “dismantlement” are not synonymous. Disassembly refers to the activities

associated with taking apart a weapon for purposes of inspecting or testing its components, while dismantlement is a

permanent action to render the weapon no longer usable.

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2. SAFE MANAGEMENT AND STEWARDSHIP OF NUCLEAR WEAPONS

STOCKPILE AND COMPONENTS

2.1 SAFE CONDUCT OF STOCKPILE MANAGEMENT

Stockpile management is the term used to describe the industrial aspects of maintaining the

National Nuclear Security Administration’s nuclear weapons stockpile and complex. 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 the assembly, disassembly, dismantlement, and surveillance of nuclear

weapons,7 as well as interim storage of plutonium removed from retired weapons. In 2002, the Board

sought health and safety improvements in weapons operations, fire protection, lightning protection,

laboratory support, and storage of special nuclear materials. The Board’s pursuit of operational safety

improvements at Pantex involved three related areas: development of adequate safety bases, reengineering of nuclear explosive processes consistent with the Board’s Recommendation 98-2, and

operators’ procedural compliance.

NNSA and its contractors have been working to develop site safety bases compliant with 10

CFR Part 830 by the April 2003 deadline. A key element of the system to protect and maintain these

safety bases is the site’s Unreviewed Safety Question (USQ) program. Responding to deficiencies

pointed out by the Board, NNSA directed the Pantex Plant contractor to revise the USQ process to

ensure compliance with the requirements of 10 CFR Part 830.

The Board has closely monitored safety basis development at the Pantex Plant to ensure that

hazards are being accurately identified and controls properly classified. In November 2002, the Board

noted deficiencies in the classification and reliability of worker safety controls identified in the hazard

analysis. To correct these deficiencies, NNSA has agreed to impose alternative controls to protect

workers from potential exposures to tritium. Likewise, in a staff report enclosed with an August 2002

letter, the Board challenged the reliability of existing systems reclassified as safety-class or safetysignificant. The Board observed that insufficient effort had been made to verify or validate the design

adequacy of reclassified systems. In response, the Pantex Plant contractor and the Office of Amarillo

Site Operations are developing a policy to evaluate reclassified systems against current design criteria. 

Where appropriate from a cost-benefit perspective, these backfit evaluations will lead to improvements in

the reliability of existing safety systems.
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In a letter dated March 25, 2002, the Board emphasized the importance of aggressively

addressing inadequate procedural compliance at the Pantex Plant. In response, the Pantex contractor

executed an action plan designed to decrease the frequency and significance of events attributed to lack

of compliance with procedures. Key corrective actions remain to be completed in 2003, including a

procedure upgrade project and implementation of a fully automated material movement system. 

Observations by the Board’s staff and NNSA personnel indicate significant improvement in safety for

handling of several weapons programs.

The Board continued to emphasize the need for improved tooling and procedures for work on

nuclear explosives by urging DOE to complete the engineering process called Seamless Safety for the

21st Century (SS-21). In December 2002, the Board accepted NNSA’s proposed revision to the

Implementation Plan for Recommendation 98-2. NNSA has started the SS-21 process for four

additional enduring stockpile programs. The wisdom of moving rapidly ahead with SS-21 was illustrated

when, in an attempt to perform disassembly and inspection of several W62 warheads, an unexpected

bond separation occurred. This event could have been averted had the SS-21 process been fully

implemented for this operation. The Board’s oversight of NNSA resulted in a more careful and thorough

accident analysis by the contractor to ensure safe disassembly of these units. All future units will be

disassembled using new SS-21 tooling.

During the last several years, the Board, NNSA, and the Pantex contractor have noted

deficiencies at Pantex in the implementation of fire protection controls in the authorization basis, existing

fire detection and suppression systems, and the response capability of the Pantex Fire Department. In

2002, NNSA and its contractor undertook to correct many of these deficiencies. The Board also

provided additional guidance and insights to further improve fire protection at Pantex in a report

forwarded to NNSA in September 2002.

The Board’s efforts to improve lightning protection at the Pantex Plant reached a milestone in

2002 when Sandia National Laboratories (SNL) completed low-voltage testing of all selected nuclear

facilities as part of the Pantex Plant’s Project Plan for Lightning Protection Authorization Basis Post-Start

Implementation. Information from this testing is critical for validating the conservatism of voltage

estimates that are used to derive safety controls. The evaluation of these critical data will continue into

2003. An August 2002 letter from the Board urged the timely completion of these evaluations to verify

the efficacy of lightning protection controls.

The Board continued to press NNSA to make safety improvements in the packaging and storage

of special nuclear materials at Pantex. During 2002, NNSA sustained its goal of repackaging an average

of 200 pits per month into robust containers with inert internal environments. The Pantex Plant

contractor reduced by half the existing surveillance backlog. In a May 2002 letter, the Board outlined

the remaining health and safety issues associated with the packaging of pits. (See Recommendation 99-

1, Safe Storage of Fissionable Material called “Pits”.)
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2.1.2 Y-12 National Security Complex 

Y-12 is a manufacturing facility located in Oak Ridge, Tennessee. Stockpile management activities

at Y-12 include the production, maintenance, refurbishment, dismantlement, evaluation, and storage of

certain components of nuclear weapons. Production activities include the manufacture or re-manufacture

of unique nuclear weapon components required by the nation’s long-term defense capabilities. The

Board’s most recent efforts to improve safety at Y-12 were concentrated in the areas of preparations for

processing of highly enriched uranium, criticality safety, maintenance, nuclear material storage, and fire

protection/combustible loading.

In several letters to DOE, the Board highlighted health and safety deficiencies in the management

of readiness preparations at Y-12. Based on observations of a contractor operational readiness review

(ORR) for the wet chemistry process in Building 9212, the Board found that preparations in the areas of

operating procedures, conduct of operations, and training were inadequate. The ORR was suspended. 

The inability to complete this contractor ORR indicated that the corrective actions taken by the contractor

in response to previous letters from the Board on this topic had not been effective. The Board continues to

impress upon NNSA that satisfactory preparations prior to the restart of hazardous activities are

imperative to ensure the health and safety of workers and the public.

The Board has continued intense oversight of criticality safety practices at Y-12. During 2002,

criticality safety violations in Building 9212 gave the Board cause for concern, pointing to a general neglect

of some criticality controls in the storage and handling of fissile material. In November, the Board

emphasized the need to correct deficiencies in the criticality safety program at Y-12, as well as the

associated formality of operations program. The Board urged NNSA to standardize storage conditions,

requirements, postings, and containers to further operators’ understanding of and compliance with the

essentials of criticality safety. In previous correspondence, the Board had urged Y-12 to reduce

maintenance backload, establish reliable maintenance schedules, track and reduce equipment unavailability,

track maintenance history, and identify maintenance for vital safety equipment. In 2002, Y-12 made some

progress in most of these areas, but further efforts are required to demonstrate that the maintenance

program has reached nuclear quality and effectiveness.

The Board has expressed significant concern with regard to deteriorating nuclear storage facilities

and material disposition activities at Y-12. In 2002, NNSA reduced specific risks in these areas. 

Particularly noteworthy were actions taken to move non-nuclear material out of inadequate facilities, raze

one of these inadequate facilities, and prepare another facility for imminent transfer to the Infrastructure

Reduction organization. The Y-12 contractor made substantial progress in reducing the inventory of highly

enriched uranium in Building 9206, as well as in developing disposition pathways for unique items currently

stored in the warehouse. The Y-12 contractor also began to integrate long-range facility planning with

overall storage planning, which will result in a significant upgrade in the future safety posture of the site. 

This year, the Board also reviewed NNSA’s plans to build a new long-term storage facility at Y12 for highly enriched uranium, a material critical to the nation’s security posture. Many issues were
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identified in the areas of siting, safety analysis, and disposition and containerization of legacy material. 

Some issues have been resolved, and others require more action by NNSA and its contractor. (For more

details, see Section 4.4.)

Based on the high risk of fire and the grave potential consequences of fire in the wet chemistry area

of Building 9212 (B-l Wing), the Board suggested that NNSA consider installation of a fixed fire

suppression system to protect the structure and its workers. NNSA has decided to reexamine the process

to be used for fire prevention and remediation and to seek alternatives that would reduce fire hazards. In

the interim, the contractor has proposed upgrades to the fire protection program to support resumption of

operations in this area. These upgrades will include installation of full sprinkler coverage for the long term if

the activities in the B-1 Wing are to continue. The Board also found that combustible loading control and

general housekeeping in Building 9204-4 were deficient. In response, facility management removed

hundreds of cubic meters of combustible waste. Recent walkdowns of the facility revealed measurable

improvement, significantly lowering the likelihood of a building-wide fire.

2.1.3 Tritium Production 

Tritium, a radioactive isotope of hydrogen, has a relatively short half-life (12.3 years) and must be

replaced periodically. The tritium facilities at SRS, located near Aiken, South Carolina, play a vital role in

stockpile management: ensuring the nation’s capability to replenish certain weapon components with

tritium gas and to process and store the gas. In 2002, the Board devoted time and resources to reviewing

the design and construction of the Tritium Extraction Facility (TEF) at SRS, currently under construction. 

This facility will be used to extract tritium from target rods irradiated in commercial light water reactors. 

The Board reviewed the application of integrated safety management (ISM) to the TEF design to ensure

that hazards had been identified and appropriate controls developed. Based on the Board’s latest review,

TEF operations can be conducted while providing adequate protection of workers, the public, and the

environment. (For more information, see Section 4.4.)

2.2 SAFE CONDUCT OF STOCKPILE STEWARDSHIP 

Stockpile stewardship is the term used by NNSA to refer to activities, in the absence of

underground nuclear weapons testing, carried out to ensure confidence in the safety, security, and reliability

of nuclear weapons in the stockpile. Stockpile stewardship includes using past nuclear test data in

combination with future non-weapon 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.

2.2.1 Recommendation 2002-2, Weapons Laboratory Support of the Defense Nuclear Complex

Safe operations in the nuclear weapons complex depend directly upon the technical abilities of the

highly skilled scientists and engineers at the nuclear weapons laboratories. These personnel apply their

unique expertise to address the health and safety of operations throughout the complex. The information
8

 See Appendix A for the full text of the recommendation.

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generated at the laboratories is of little use, however, unless it is disseminated effectively to the relevant

operations in the complex. Thus, clear lines of communication are vital to ensure that issues raised

anywhere in the complex are properly routed to the laboratories for resolution, that timely answers are

developed, and that information generated at the laboratories is transmitted successfully for use throughout

the complex. 

While NNSA has taken some actions to ensure that there is a steady supply of qualified scientists

and engineers and that clear lines of communication are maintained, the Board believes additional attention

is needed to assure health and safety. In Recommendation 2002-2, the Board recommended that the

Secretary of Energy reemphasize the priority of the nuclear weapons program at the nuclear weapons

laboratories. The Board recommended that each nuclear weapon system in the stockpile have a senior,

technically competent expert serving as the single point of contact responsible for that system at the

cognizant laboratory. 

This single point of contact should have the ability to ensure that emergent health and safety issues

are tracked, prioritized, and resolved in a timely manner. Technical qualifications should be of the highest

caliber, and a commensurate qualification and development program should be established to ensure the

availability of personnel to fill these positions. The Board recommended that NNSA, as the integrator of

the activities in the defense nuclear complex, also establish a point of contact within its laboratory site

offices to ensure that requests for laboratory support are being met in a timely fashion and to resolve

resource conflicts.8

2.2.2 Los Alamos National Laboratory 

Los Alamos National Laboratory, located in New Mexico, is the NNSA weapons laboratory with

the largest number of defense nuclear facilities and weapon-related activities. Site personnel are heavily

involved in ongoing research and development on means for certifying the safety and reliability of nuclear

weapons in the absence of nuclear testing. At present, LANL is the planned location of NNSA’s limitedscale manufacturing capability for replacement pits for existing nuclear weapons. In 2002, the Board

focused its attention on the effort to start up the Plutonium-238 (238Pu) Scrap Recovery Line, development

of adequate documented safety analyses for selected facilities, quality assurance, lightning protection,

construction of the new emergency operations center, fire protection, and formality of operations.

LANL is completing construction of a new aqueous processing line for recovery of scrap 238Pu. 

This new recovery line will be the only source of purified 238Pu for at least the next decade. The Board

found significant deficiencies in the safety basis and the proposed implementation of safety controls

associated with the line. LANL personnel have been working with the Board to develop a more rigorous

safety basis. A new process hazards analysis has been performed, and new, more robust controls have

been proposed to NNSA. The revised safety basis documentation is currently under review by contractor

management prior to submission to NNSA for approval.
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LANL’s development of documented safety analyses complying with the requirements of 10 CFR

Part 830 has led to the identification of new safety-class and safety-significant structures, systems, and

components (SSCs), as well as the reclassification of some existing SSCs. However, LANL has not

demonstrated that systems reclassified as safety-class or safety-significant equipment are designed

adequately. The Board was briefed by NNSA personnel on this issue in November 2002, and expects

that in 2003 LANL will remedy the situation with the Board’s oversight.

For new projects at LANL, the Board has observed a need for early identification of candidate

safety-related SSCs to preserve design flexibility as the coupled design and safety processes mature. This

need is especially great with respect to the 238Pu Scrap Recovery Line and the DynEx Project. The Board

also found deficiencies in the Safety Analysis Report developed by LANL for the Weapons Engineering

Tritium Facility, and suggested ways to improve tritium containment. In response, NNSA has limited the

amount of material approved for use in facility operations, and has demanded improvements in the tritium

containment strategy.

In 2002, the Board continued to urge NNSA and the LANL contractor to improve the quality

assurance program across the site. Institutional plans were still in development, and the Board found that

several LANL divisions and projects for which quality programs needed to be in place sooner were

proceeding with their own programs independent of the institutional effort. These disparate efforts were at

cross-purposes in several cases. As a result of the Board’s intervention, NNSA is now coordinating the

improvement of quality assurance programs at LANL.

In August, the Board noted that, although the lightning protection system at the Weapons

Engineering Tritium Facility had been designated as safety-class (important for the protection of the

public), a rooftop review had identified numerous physical deficiencies in system components. The LANL

contractor took immediate action to correct these deficiencies, and changed its safety controls to minimize

the possibility of recurrence. The Board also found deficiencies in LANL’s lightning warning and detection

systems, and is closely monitoring improvements being made in these systems.

LANL is constructing a new Emergency Operations Center (EOC), located such that the

prevailing winds would carry plumes from most postulated accidents away from the EOC. The location,

however, is in the deformation zone associated with a seismically active fault. The initial design considered

the new EOC in isolation, rather than as part of a system of EOCs that would include an older EOC and a

mobile command center under consideration. The Board suggested that LANL adopt a systems approach

to address the possible lack of functionality of the new EOC under severe seismic conditions. Moreover,

the Board suggested that LANL consider the new EOC to be part of a system of EOCs that includes an

older EOC and a mobile command center. NNSA and LANL have taken this approach and expect

procurement of a mobile command center to be completed by September 2003. The new EOC is

expected to be completed by then.

In January 2002, LANL experienced an uncontrolled energetic reaction in a non-nuclear

laboratory, due in part to a lack of disciplined operations. An investigation by LANL personnel identified

weaknesses in safe work practices as a cause. At LANL, documented safe work practices are the
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mechanism for incorporating ISM into program work for both nuclear and non-nuclear facilities. The

Board has concluded that the lessons learned from this event may have laboratory-wide implications on

work control, formality of operations, and safe work practices; LANL is currently evaluating these

implications, and has committed to improving formality of operations in facility and program work. 

As a result of the Board’s Recommendation 2000-2, NNSA and LANL assessed fire protection

and alarm systems in several nuclear facilities at LANL. In May 2002, these assessments led LANL to

determine that institutional and facility-level issues exist with regard to inspection, testing, and maintenance

of fire protection systems. LANL has developed and is executing a corrective action plan. The Board has

also questioned the hydraulic adequacy of the fire suppression system at the Plutonium Facility known as

Technical Area-55 (TA-55). NNSA and LANL plan to address this potential safety issue as part of the

improved TA-55 Documented Safety Analysis, to be completed in 2003.

2.2.3 Lawrence Livermore National Laboratory 

Lawrence Livermore National Laboratory (LLNL), 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 consultation on the surveillance and

dismantlement of LLNL-developed nuclear weapons. Most defense nuclear activities are conducted in the

Superblock complex, which includes the Building 332 Plutonium Facility and the Tritium Facility. 

During 2002, the Board increased the scope and frequency of its health and safety reviews at

LLNL. On September 26, 2002, the Board held a public hearing in Livermore, California. The Board

focused its efforts on LLNL’s support for Pantex Operations (see Section 2.2.1 above), the safety-class

emergency power system (EPS) in the Plutonium Facility (Building 332), the deactivation of the Heavy

Element Facility (Building 251), and the Decontamination and Waste Treatment Facility (DWTF) complex. 

The Board found deficiencies in the EPS of Building 332 that threatened the reliability and efficacy

of power-dependent hazard controls. In response, the LLNL contractor developed a set of compensatory

measures and design modifications to address the identified deficiencies and foster an enhanced

understanding of EPS vulnerabilities. EPS reliability has been enhanced, and should meet commercial

standards upon completion of the corrective actions currently in progress.

The Board reviewed LLNL’s plans for the deactivation of the Heavy Element Facility (Building

251). In addition to the decontamination and removal of 48 gloveboxes and contaminated systems, this

effort involves the removal of nearly 300 items of radioactive material, some posing a significant risk of

external radiation exposure to workers and the release of contamination in the building. The project is

being pursued on an accelerated schedule to achieve near-term risk reduction and avoid costly safety basis

upgrades. The Board found that planning for the project was being approached piecemeal, rather than in a

systematic and integrated manner. In a March 2002 letter, the Board stated that the use of comprehensive

planning methods, such as those contained in DOE Order 430.1A, Life Cycle Asset Management, was

warranted. The use of an integrated and systematic planning approach results in safety and efficiency

improvements by better identifying hazards and necessary controls, improving the sequencing of tasks, and
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identifying repetitive tasks that could be standardized. The LLNL contractor has now adopted this

approach.

LLNL intends to centralize transuranic (TRU) waste processing and storage operations within the

DWTF area. Building 696R is a new facility within the DWTF complex that will be used to store much of

the TRU waste presently stored in a tent and in Building 332. Operations in Building 696R began in

October 2002. Moving TRU waste from less desirable storage locations to Building 696R will reduce the

health and safety risks. Ultimately, however, the Board believes that the only way to truly reduce the risk

associated with storing TRU waste at LLNL is to ship the waste to an approved disposal site. The Board

is currently evaluating health and safety issues affecting the transfer of TRU waste from LLNL. 

2.2.4 Nevada Test Site 

The Nevada Test Site (NTS) is located in southern Nevada, about 75 miles northwest of Las

Vegas. Stockpile activities at NTS include test readiness preparations, disposition of damaged nuclear

weapons, and subcritical experiments. Underground testing of nuclear weapons is no longer being

conducted at NTS. However, NTS 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 would be done safely. During 2002, the Board focused its attention on NTS’s test readiness

posture, capability to dispose of a damaged nuclear weapon, subcritical experiments, and TRU waste

operations.

During its 2002 review of NTS’s current test readiness posture, the Board found weaknesses that

could affect NNSA’s ability to conduct safely an underground nuclear weapons test. The number of

personnel uniquely qualified to plan and conduct underground nuclear weapons tests was shrinking. There

was no formal safety basis for an underground nuclear weapons test, nor was there a rigorous process to

assess the safety of such a test. Subsequently, NNSA developed a plan to prepare a safety basis, address

the loss of uniquely qualified personnel, improve the state of readiness of facilities and equipment, and

develop a readiness review process compliant with NNSA requirements for nuclear and nuclear explosive

operations.

The Board continued to highlight the need to develop the programs and infrastructure necessary at

NTS to safely dispose of a damaged nuclear weapon or improvised nuclear device. During 2002, the

Board reviewed infrastructure improvements, procedures, and exercises designed to train personnel and

develop standards of practice. NNSA continued to make physical improvements to G-Tunnel, and

conducted an extensive exercise to practice the full scope of disposition activities at NTS and identify

further issues to be addressed. The Board pointed out that there was still no safety basis for these nuclear

explosive and nuclear operations, and that the work planning, review and approval processes and the

conduct of operations were not sufficiently rigorous for nuclear explosive and nuclear operations. To

improve this disposition capability in 2003, NNSA plans to develop a safety basis, address organizational

issues, improve the condition of G-Tunnel, and conduct several training activities.
9

 Hazard categories are defined in Appendix A to 10 CFR Part 830. A Hazard Category 3 facility is one where the

hazard is of “only local [sic] significant consequences.”

2-9

After reviewing the Joint Actinide Shock Physics Experimental Research subcritical experiments at

NTS, the Board concluded that the quantity of nuclear material in the targets would exceed the threshold

values for a Hazard Category 3 nuclear facility.9 However, NTS personnel had not developed safety

controls appropriate for this level of hazard. As a result of a July 2001 letter from the Board, a visit by the

Board to NTS in April 2002, and numerous other communications, the contractor designed controls

adequate for the safety of this operation. NNSA is now assessing and improving the adequacy of the

controls and configuration management prior to the start of the next series of experiments. The Board has

found that NNSA’s assessment process is adequately rigorous.

NNSA conducts Hazard Category 2 storage and Hazard Category 3 examination and

repackaging of TRU waste at NTS. In a March 2002 letter, the Board informed NNSA that controls

from the Safety Analysis Report and Technical Safety Requirements had not been incorporated adequately

into facility operating and surveillance procedures. Further, the Board has found that NTS’s support

programs (such as maintenance, training, and qualification) are not adequate to support Hazard Category 3

nuclear facility operations. As a result, NNSA has added nuclear facility requirements to the contract with

its primary contractor, improved the capability of the Nevada Operations Office to manage and assess

nuclear facility operations at NTS, initiated a complete revision of the documented safety analysis of all

waste activities at NTS, and encouraged the primary contractor to improve its capability to manage and

operate nuclear facilities.

2.2.5 Sandia National Laboratories 

SNL, which manages research and development installations at several DOE sites, including

Albuquerque, New Mexico, and Livermore, California, has significant responsibility for the conduct of

engineering research on nuclear weapon systems and components. SNL’s major defense nuclear facilities,

most of which are located in TA-V at the New Mexico site, include the Annular Core Research Reactor,

the Hot Cell Facility, the Gamma Irradiation Facility, and the Sandia Pulse Reactor Facility. 

In 2001, the Board had reviewed preliminary plans for the Sandia Underground Reactor Facility

project and found health and safety deficiencies in the protection of workers exposed to radiological and

industrial hazards. Some of these problems stemmed from the below-ground location of the facility. 

NNSA committed to correct the deficiencies before approving the preliminary safety analysis. On

November 12, 2002, however, NNSA canceled the project.
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3. SAFE DISPOSITION OF HAZARDOUS REMNANTS OF WEAPONS PRODUCTION

3.1 STABILIZATION AND STORAGE OF REMNANT MATERIALS

3.1.1 Complex-Wide Program

In Recommendations 94-1, 96-1, 97-1, 2000-1, and 2001-1, the Board urged DOE to assess

and take action on legacy nuclear materials remaining in defense nuclear facilities. Implementation of

these recommendations has resulted in significant risk reduction. A large portion of the plutonium

solutions and residues, special isotopes, and irradiated fuel and targets has been stabilized and placed

into safe storage. In a major step forward, DOE began removing deteriorating spent nuclear fuel from

the K-East Basin at Hanford after many years of preparation. However, significant hazards remain,

some key stabilization activities have been delayed, and technical and programmatic difficulties threaten

to cause further delays in risk reduction. The Board has continued to encourage DOE to promptly

stabilize the materials and place them in a safe configuration for storage pending programmatic use or

disposition.

The Board believes that DOE has established reasonable disposition paths and plans for most

of the materials addressed by the Board’s recommendations. However, the disposition of some

materials remains problematic. For example, the schedule for addressing legacy plutonium materials at

LANL continues to be delayed beyond the time the Board considers acceptable. Many of these items

have not been opened for inspection for an extended period—more than 20 years in some cases. 

Likewise, the plan for stabilizing neptunium solutions at SRS is still uncertain.

The Board has begun to evaluate other materials in addition to those addressed by its existing

recommendations that may require timely stabilization and disposition to prevent new hazards from

developing. The Board has determined that NNSA is managing a substantial inventory of nuclear

materials without identified programmatic uses. To avoid problems such as those prompting the

issuance of the Board’s previous recommendations, DOE must undertake a comprehensive evaluation

of this inventory; stabilize materials and improve storage conditions; and improve life-cycle planning.

In addition to pressing for progress in reducing the risk posed by legacy nuclear materials, the

Board has continued to assess the safety and adequacy of stabilization activities. In 2002, the Board

conducted assessments of stabilization and disposition at LANL, Hanford, SRS, and RFETS. The

Board evaluated the implementation of health and safety requirements in accordance with applicable

standards (e.g., DOE-STD-3013, Stabilization, Packaging, and Storage of Plutonium-Bearing

Materials), as well as safe startup of certain stabilization activities. The Board has paid particular

attention to DOE’s progress in providing a reliable methodology to verify that plutonium oxides are

adequately stabilized prior to packaging for long-term storage. During the past year, the Board found

inadequacies with stabilization activities and plans at Hanford, RFETS, and LANL. 
3-2

The Board has closely evaluated DOE’s management of SRS’s nuclear chemical separation

facilities, F-Canyon and H-Canyon. These facilities provide unique processing capabilities and have

played a central role in DOE’s nuclear materials stabilization program. In March 2002, the Board

issued DNFSB/TECH-32, Savannah River Site Canyon Utilization, emphasizing the role of the FCanyon facility in safely stabilizing nuclear materials, and suggesting the continued operation of both

canyon facilities to ensure the timely completion of this mission. However, DOE has decided to halt

chemical separation operations in F-Canyon, citing the need for cost savings, and has begun to

deactivate the facility.

As a result of the suspension of F-Canyon operations, all materials that might have been

processed in F-Canyon must now be processed in H-Canyon or disposed of by some other means. In

a letter to DOE dated November 8, 2002, the Board asserted that DOE had not met the statutory

requirements of Section 3137 of the National Defense Authorization Act for Fiscal Year 2001 (Public

Law 106-398). The Board suggested that DOE identify clear and achievable disposition paths for

materials present in F-Canyon and define how future requirements for disposition of fissile materials

could be met without F-Canyon. The Board will continue its efforts to ensure that DOE’s facility

utilization decisions are based upon a sound evaluation of its processing needs.

3.1.2 Plutonium

In response to the Board’s Recommendations 94-1 and 2000-1, DOE committed to stabilize

and package its legacy plutonium materials. During the past year, DOE made significant progress:

! RFETS completed stabilizing all of its plutonium-bearing residues (a significant

accomplishment involving more than 100 metric tons of material); eliminated all 

plutonium-bearing solutions; and packaged more than 60 percent of its plutonium metal and

oxide into robust sealed containers in compliance with DOE-STD-3013.

! Hanford began stabilizing its inventory of plutonium-impregnated polystyrene cubes;

stabilized or disposed of all its plutonium solutions; completed the thermal stabilization of

plutonium alloys; continued packaging plutonium metal and oxide into sealed containers;

and repackaged all ash residues and sand, slag, and crucible residues for disposal at the

Waste Isolation Pilot Plant (WIPP).

! SRS restarted the plutonium oxide processing line in the HB-Line facility, completed the

conversion of existing plutonium solutions to metal in the FB-Line facility, and continued

dissolution of spent nuclear fuel in H-Canyon.

! LANL continued processing more than 300 items of plutonium residues and oxide, and

eliminated several higher-risk material categories (cellulose rags, nitrides, and organic

solutions) after the Board highlighted the risk they posed. Following repeated urging by the

Board, LANL requested and received authorization to discard low-purity

plutonium-bearing materials as waste, instead of processing them to recover the plutonium. 
3-3

Establishing the capability to stabilize and package plutonium-bearing materials to meet the

requirements of DOE-STD-3013 is a key element of the implementation of these recommendations. 

RFETS, Hanford, and LLNL have established this capability, and SRS has made significant progress. 

The Board has evaluated initial steps to establish the necessary capabilities at SRS, and questioned

DOE’s plan to allow the contractor to commence stabilization operations next year with no independent

readiness assessment by DOE. The Board raised this issue with DOE, which now plans to perform an

independent readiness assessment of the activity.

As the sites continue to stabilize and package plutonium-bearing materials, the Board evaluates

these activities to ensure that they are safe and effective. The Board identified deficiencies in the

processing at RFETS and Hanford that had complex-wide implications regarding approved methods

for measuring moisture and other volatile substances in stabilized plutonium oxides. Such measurements

are essential to ensure that the stabilization process results in a product that can be kept safely in a

sealed container during long-term storage. The Board pointed out deficiencies in DOE’s technical basis

for authorizing the measurement methods now being used. As a result, DOE has revised the technical

basis and in doing so has greatly enhanced its understanding of moisture measurement methods. 

The Board questioned Hanford’s plans for meeting a requirement of DOE-STD-3013 by

setting aside representative samples of packaged materials as part of a long-term surveillance program

for long-term storage. As a result of actions by the Board, DOE is independently evaluating the

materials at Hanford and has initiated actions to provide guidance for the complex on how to satisfy this

important requirement. Also at Hanford, the Board called into question the safety of the polycube

stabilization process, which was experiencing regular shutdowns because of clogged off-gas filters. 

DOE responded by installing new equipment and modifying the stabilization process until the plugging

can be eliminated.

At SRS, DOE and its contractor resumed the plutonium solution stabilization process in the

HB-Line facility. The Board performed an extensive review of the HB-Line restart in late 2001,

making several suggestions for improving the safety of that operation, and performed follow-up reviews

during 2002. The contractor made improvements in the areas of fire protection and chemical

processes, and strengthened administrative controls for hazards in the facility.

The Board reviewed the SRS H-Canyon ventilation system—a safety system important to the

protection of workers and the public. This system has experienced degradation in the past and has not

been repaired. In a letter to DOE dated June 26, 2002, the Board stressed the need for DOE to take

more aggressive action to correct deficiencies in the ventilation system. DOE is now planning to make

the needed repairs.

The Board reviewed the technical basis for stabilizing impure plutonium oxide materials at

RFETS. The Board concluded that DOE’s technical evaluation was flawed, and that DOE had not

identified adequate controls to prevent a deflagration or explosion in the stabilization furnace. Following

briefings provided to the Board, DOE implemented modifications to the stabilization furnaces and

associated process parameters to ensure that these materials could be safely stabilized.
3-4

The Board has continued to review and evaluate changes to DOE’s long-term plutonium

storage standard, DOE-STD-3013, to ensure that material is safely stabilized and packaged. This past

year, DOE proposed reducing the stabilization temperature for chloride-bearing plutonium oxides at

RFETS. This change was requested by RFETS to reduce the likelihood of corrosion in the process

equipment. The Board noted deficiencies in the technical basis for this change. As a result, DOE

agreed to approve this change only for a subset of purer, better-characterized materials, and to

continue to verify adequate stabilization using the existing requirements of the standard.

3.1.3 Uranium

Highly Enriched Uranium. DOE has entered an agreement with the Tennessee Valley

Authority to supply low-enriched uranium from the DOE complex to make commercial nuclear fuel. 

DOE is readying facilities in the H-Area of SRS to purify highly enriched uranium solution, blend it

down to low enrichment, and ship it to a vendor for fabrication into fuel. The Board conducted several

on-site reviews of this activity and found inadequacies in work processes and criticality safety. DOE is

working to correct these inadequacies. The Board continues to monitor DOE’s efforts to commence

blending and shipping operations in 2003.

Uranium-233. Uranium-233 (233U) is a man-made radioisotope that contains uranium-232

(

232U) as an unavoidable contaminant; products of the decay of 232U are highly radioactive. Most of the

233U not in the form of fabricated fuel materials is stored at Oak Ridge National Laboratory (ORNL). 

In Recommendation 97-1, the Board urged DOE to characterize, stabilize, and ensure safe storage of

its 233U materials expeditiously, because there was significant uncertainty about the safety of storage

conditions. During 2002, DOE made considerable progress in the 233U inspection program at ORNL. 

Forty containers representing about 75 percent of the types of containers stored at ORNL were

successfully inspected. The containers were in good condition, except for one package containing an

unexpected corrosive material. ORNL transferred that container to a hot cell and stabilized and

repackaged its contents.

DOE is also storing sodium fluoride (NaF) traps that contain 233U in the form of uranium

hexafluoride in Building 3019A at ORNL. These containers require remediation because they are

becoming pressurized with fluorine gas produced by radiolysis of the uranium hexafluoride. On

September 23, 2002, the Board issued a letter questioning DOE’s program for dealing with these traps. 

In response to the Board’s letter, DOE agreed to measure the pressure in several NaF traps and to

depressurize them. DOE will use the results of this activity to develop plans for depressurizing the

remaining NaF traps and disposing of the 233U.

Depleted Uranium. More than 22,000 metric tons of depleted uranium is stored at SRS. 

The Board reviewed storage conditions for the material, as well as DOE and contractor guidance for its

packaging, storage, and inspection. The Board also reviewed DOE’s disposition plans for these

materials. In a letter dated March 7, 2002, the Board criticized improper storage conditions,

weaknesses in hazard analyses, inadequate inspection of containers, and an overall lack of a disposition

plan for depleted uranium. The Board noted that most of the depleted uranium had been in storage for
3-5

an extended period and that the storage conditions were worsening with time. In response to the

Board’s letter, DOE and its contractor took short-term corrective actions and committed to the

development of a long-term disposition strategy. DOE intends to dispose immediately of the material

housed in the worst storage conditions, and to conduct a feasibility study to evaluate disposal of the

remaining materials by fiscal year 2006.

3.1.4 Special Isotopes

Several thousand gallons of solution containing americium and curium (Am/Cm) stored in the

SRS F-Canyon is being prepared for disposal in the SRS high-level waste tanks. The Board’s review

of the disposition plan uncovered several weaknesses that DOE is attempting to correct. 

Improvements DOE has agreed to implement include verifying the functionality of safety equipment

prior to the transfer, modifying response times to radiation alarms to minimize potential worker

exposure, implementing additional controls to preclude plugging the F-Canyon waste header through

which the transfer will be made, and performing additional cold runs to demonstrate the viability of the

transfer path.

As part of the Am/Cm disposal discussions, the Board expressed concern over the fate of

Mark 18A targets stored in a spent fuel basin at SRS. These targets contain significant quantities of

irreplaceable isotopes, and the Board has requested that DOE develop a firm path forward for the

storage, processing, and recovery of these materials.

3.1.5 Inactive NNSA Nuclear Materials

The Board reviewed the packaging, storage, and disposition plans for inactive nuclear materials

at LANL and LLNL. The Board found that NNSA has not been managing effectively its growing

backlog of nuclear materials that have no identified programmatic application. Many of these materials

lack adequate physical, chemical, or radiological characterization, and packaging of some items is

inappropriate for extended storage.

The Board believes action is needed to improve the management of NNSA’s inventory of

inactive nuclear materials. In a letter dated May 20, 2002, the Board requested that NNSA examine

the issues and outline measures to be taken to improve the safe management of these materials. 

NNSA’s response of September 24, 2002, was not entirely satisfactory, but did acknowledge that

improvement in the management of nuclear materials is needed and that the issues identified in the

Board’s letter will be addressed. The response identified the strategy by which NNSA will deal further

with these issues, including the recent establishment of an Inactive Actinides Working Group to address

inactive actinide issues. The Board will continue to press for improvements in this area.
3-6

3.2 STABILIZATION OF SPENT NUCLEAR FUEL

3.2.1 Hanford Spent Nuclear Fuel Project

The Board continued to perform comprehensive reviews of the Hanford Spent Nuclear Fuel Project

(SNFP), which is presently retrieving deteriorating spent nuclear fuel from the K-East and K-West Basins,

cleaning and drying the fuel, and packaging it for eventual repository disposal. The Board reviewed ongoing

operations, as well as the design and installation of the remaining equipment needed to accomplish the project.

This year, DOE completed installation of the Fuel Transfer System (FTS) that transfers fuel from the

K-East to the K-West Basin for cleaning and packaging. The Board’s review of this system called into

question the hoisting and rigging methods to be used for the fuel transfer cask. As a result, DOE modified the

design of the equipment to limit the distance a dropped container could fall, and thus reduce the potential for a

release of sludge and water from the cask in the event of a drop. The Board also found weaknesses in the

contamination control strategy for the fuel casks, leading DOE to implement improved controls.

The Board expended considerable effort in ensuring that DOE will adequately achieve and confirm the

readiness of SNFP processes to operate safely. In 2001, operations at T-Plant—from which spent fuel was

to be removed to make room for interim storage of sludge from the K-Basins—failed the DOE ORR, despite

having passed the contractor ORR. The contractor resisted performing another ORR, but the Board

persuaded DOE to require one. The facility failed this ORR as well. After corrective actions were taken to

shore up both the contractor’s readiness determination process and DOE line management’s verification

process, the facility passed both ORRs.

The Board evaluated the implementation of these corrective actions during the contractor’s and

DOE’s ORRs for the K-Basin FTS. Again, the contractor failed to achieve an adequate level of readiness

prior to beginning its ORR; however, DOE’s line management review team appropriately assessed the level of

readiness and ensured that corrective actions were complete prior to initiating the DOE ORR. These

activities culminated in the start of fuel removal from the K-East Basin on November, 26, 2002, a major

accomplishment that has been many years in the making. However, DOE failed to meet the commitments

made in its Implementation Plan for Recommendation 94-1 to begin containerization of sludge in the K-East

Basin in November 2002 and to initiate sludge removal from the basin in December 2002, primarily as a result

of continued deficiencies in project management.

The Board also continued to study the poor equipment performance hindering the removal of fuel

from K-West Basin. The Board found that the major causes of low reliability were inadequate conduct of

operations, maintenance, and engineering evaluation of equipment failures. Efforts by the contractor to deal

with these weaknesses led to substantially improved production rates, recovering several months of

production schedule.

The fuel from the K-Basins is packaged into mechanically sealed multi-canister overpacks (MCOs). 

The MCOs were to be welded shut, but DOE allowed the contractor to delay this operation to apply more

resources to preparations for fuel retrieval and processing. The primary mechanical seals on several MCOs
3-7

failed leak checks immediately following closure, leading the Board to challenge the adequacy of the MCO

sealing process. In a letter dated February 15, 2002, the Board urged DOE to expedite preparations to weld

closure caps on the MCOs as originally planned. As a result, the contractor improved the mechanical sealing

process and is now completing preparations for welding operations.

3.2.2 Savannah River Site

In December 2001, DOE decided to suspend preparations to start up the L-Area Experimental

Facility and cease pursuit of the planned full-scale facility to treat aluminum spent nuclear fuel for disposal. 

Since suspension of this activity, the Board has monitored DOE’s efforts to consolidate spent nuclear fuel at

SRS by transferring all fuel from the Receiving Basin for Offsite Fuel and the K-Reactor Basin to the L-Basin. 

The Board has expressed concern regarding the lack of a clear disposition path for the spent nuclear fuel at

SRS, most recently in a letter to DOE on November 8, 2002, and will continue to press DOE on this matter.

3.3 WASTE MANAGEMENT

3.3.1 High-Level Waste

Tank Integrity. The Board has continued to press DOE to improve programs that protect and

verify the integrity of the high-level waste (HLW) storage tanks at Hanford and SRS, particularly the doubleshell tanks that must continue to provide reliable service for many years to come. Significant improvements in

tank integrity programs have resulted, particularly at Hanford, including improved waste chemistry controls,

addition of corrosion inhibitors to several tanks, development of improved capabilities for tank wall

inspections, and progress toward implementation of more rigorous requirements to ventilate the tank annulus

so as to help prevent corrosion of the primary tank wall. The Board has continued to urge DOE to address

leak-tightness as well as gross structural integrity in its tank integrity program, and to thoroughly evaluate

evidence that tank walls above the waste may be susceptible to corrosion despite the presence of corrosion

inhibitors in the waste. 

As part of its implementation of the Board’s Recommendation 2001-1, DOE revised its in-service

inspection program for the SRS HLW tanks. Based on guidance provided by the Board in a letter dated June

11, 2002, DOE modified the program to require ultrasonic inspection of all the double-shell tanks at SRS,

instead of just a subset, and to inspect tanks early in the program if they are potentially at greater risk of

corrosion. The Board continues to pursue acceleration of DOE’s proposed 9-year schedule for inspecting all

the double-shell tanks.

Accelerated HLW Cleanup at SRS. The Board reviewed the accelerated HLW cleanup

initiative at SRS. As part of this initiative, DOE is exploring approaches to accelerate disposal of saltcake

from the HLW tanks. DOE is pursuing disposal of dissolved saltcake on site as saltstone, with limited or

no processing to remove radionuclides. This approach may increase the radioactivity in the saltstone

beyond current permit limits, but is not expected to present a hazard to the public. However, the existing

Saltstone Production Facility at SRS is not designed for the radiation levels expected from processing
3-8

untreated saltcake, and the Board is closely evaluating the associated hazards for workers. DOE is

presently analyzing the modifications necessary to protect workers from the increased radiological hazard.

The SRS contractor performed a “waste incidental to reprocessing” determination in accordance

with DOE Order 435.1, Radioactive Waste Management, to demonstrate that the dissolved saltcake

represents no greater risk than that posed by traditionally defined low-level waste. In a letter to DOE

dated June 27, 2002, the Board suggested improvements in the methodology and assumptions used in this

analysis. The choice of method is complicated by a pending court case challenging DOE’s determination. 

Recognizing these uncertainties, the Board has encouraged DOE to pursue development and

demonstration of alternative methods of waste treatment, especially for cesium removal.

As a result of the selection of caustic-side solvent extraction (CSSX) as the baseline technology for

salt solution processing and the extensive research performed on benzene generation in the In-Tank

Precipitation (ITP) process, the Board closed Recommendation 96-1, In-Tank Precipitation System at

the Savannah River Site, this year. However, the former ITP precipitation tank still contains significant

quantities of tetraphenylborate from early tests of the ITP process, and CSSX will not be capable of

treating this waste. The Board has stressed the need for DOE to remediate this tank, preferably using a

technology that could also treat wastes from other HLW tanks.

Safety Analysis of SRS Tank Farms. To comply with 10 CFR Part 830, the SRS contractor

prepared a Documented Safety Analysis (DSA) for the HLW tank farms and associated facilities. 

Although the hazard and accident analyses reported in the DSA are the most comprehensive performed to

date for the tank farms, the Board detected several deficiencies and informed DOE of its findings in a letter

dated November 4, 2002. The Board found that, contrary to applicable DOE directives, analyses of

unmitigated consequences had not been performed for several accidents, and certain key input values and

assumptions had not been shown to be conservative. Analyses of unmitigated consequences are needed to

allow the proper selection of safety-class and safety-significant controls to adequately protect members of

the public and site workers. In response, the SRS contractor performed additional sensitivity calculations

and added specific administrative controls in the Technical Safety Requirements to ensure the continued

validity of key input values and assumptions used in the accident analyses. 

Hanford Tank Farms. The Board continued to perform extensive reviews of the health and

safety of ongoing and planned operations at the Hanford HLW tank farms. The Board has also tracked

the development of an upgraded safety basis and preparations to provide feed for the planned Waste

Treatment Plant (WTP).

Saltwell Pumping—The readiness assessment (RA) for starting saltwell pumping at 

Tank U-111 at Hanford was suspended after the Board questioned the preparedness of the RA team

members and the depth and breadth of the review. The RA resumed after these issues had been

addressed.

Common Cause Analysis for Electrical Safety—The Board highlighted several cases in which

work had been performed on energized systems without proper authorization and appropriate controls. 
3-9

Subsequently, DOE’s tank farms contractor performed a common cause analysis for 27 events involving

electrical hazards. As a result of this analysis, the contractor initiated a number of corrective actions and

communicated lessons learned to its workforce.

Transfer Line Failure—In January 2002, HLW being transferred through a temporary

hose-in-hose transfer line leaked from the primary hose into the secondary hose. The Board suggested

that the leak might have been caused by water flushes using operating parameters more severe than those

used during qualification testing. As a result, the contractor changed the test specifications for this type of

hose and performed field proof tests before resuming operations of another existing hose. DOE plans to

inspect the failed hose, as suggested by the Board, to determine its failure mechanism.

Waste Feed Delivery—The Hanford Waste Feed Delivery transfer system will deliver the first

phase of HLW slurries from the tank farms to WTP. The Board reviewed the design of this safety-class

system, and issued letters to DOE in May 2001 and September 2002, identifying flaws in the

characterization of the physical properties of the waste and functional design requirements for the system,

particularly the minimum design pressure rating. DOE performed additional waste characterization and

system modeling, and convened an expert panel in October 2002. The panel assessed the adequacy of

physical property data and the waste transfer analytical model, and provided recommendations for a path

forward. 

Tank Farms Safety Basis—The Board assessed modifications to the existing safety basis for the

HLW tank farms and reviewed a new DSA written to comply with 10 CFR Part 830. The Board

concluded that DOE’s guidance to the contractor imposed an excessively high consequence threshold for

implementing safety-significant controls for worker protection. Following a briefing provided to the Board,

DOE sent a letter to the contractor altering the risk classification criteria in the safety basis document and

the guidelines for selecting controls for the tank farms.

3.3.2 Low-Level and Transuranic Waste

Waste Isolation Pilot Plant. During 2002, the pace of operations at WIPP increased

significantly. More than 900 shipments totaling more than 29,000 drum equivalents of TRU waste were

received and disposed of underground. The Board continued its oversight of these operations to ensure

that they proceeded safely at the dramatically increased rate. To that end, the Board evaluated an August

2002 dry run of newly installed systems and equipment to be used for future disposal of remote-handled

TRU waste at WIPP. The Board found the equipment, systems, and procedures to be satisfactory overall;

however, several areas for improvement were identified.

Idaho National Engineering and Environmental Laboratory. The Board reviewed waste

disposal activities at the Idaho National Engineering and Environmental Laboratory (INEEL) including both

TRU waste characterization and loading of drums in shipping containers for shipment to WIPP. These

reviews focused on the implementation of ISM to improve worker health and safety for these activities,

and contributed to the successful completion of the project to ship the first 3,100 cubic meters of TRU

from INEEL to WIPP.
3-10

The Board reviewed the design and construction of the Advanced Mixed Waste Treatment

Project at INEEL, which will retrieve and process 65,000 cubic meters of TRU waste for shipment to

WIPP. Since the 1970s, the drums stacked five-high have been stored in the TRU Waste Storage Area

Retrieval Facility, on an asphalt pad, beneath an earthen berm, under a recently-erected weather

enclosure. The contractor has been slow to address the potential plutonium inhalation hazard to workers

handling aging and corroded drums that may fail or be damaged during retrieval. Based upon briefings

provided to the Board in December 2002, it appears that the contractor has acknowledged this hazard

and is working to identify appropriate controls.

Melton Valley Transuranic Waste Treatment Project. The Melton Valley Transuranic Waste

Treatment Project at ORNL will process liquid and solid TRU waste and low-level radioactive waste for

off-site disposal. Due to the high activity of substantial portions of the TRU and low-level wastes to be

processed by this facility and the potential hazards for workers, the Board scrutinized the facility design

process and the preparation of the facility’s DSA. In 2002, an acceptable final design for the project was

completed and the facility constructed. The Board will provide health and safety oversight of the startup of

liquid processing in early 2003.

Hanford Central Waste Complex. Assessments conducted at Hanford in response to

Recommendation 2000-2 resulted in the finding that dry pipe fire protection systems had not been

inspected in accordance with National Fire Protection Association standards. These inspections were

subsequently performed and revealed significant quantities of debris obstructing fire protection systems in

the Central Waste Complex. These systems have been cleaned and restored to operability.

3.4 FACILITY DEACTIVATION AND DECOMMISSIONING

3.4.1 Safe Practices for Deactivation and Decommissioning

On March 19, 2002, the Board sent DOE a letter noting recent occurrences during deactivation

and decommissioning that illustrated the health and safety hazards associated with cutting radioactively

contaminated equipment using saws, cutting torches, and other tools. The Board pointed out that

preventable mishaps, such as fires and lacerations, continue to occur despite DOE guidance on how such

work can be performed safely. The Board suggested that a compendium of good practices would assist in

the safe performance of such activities. More specific and detailed information would help support work

planning, preclude duplication of effort, and minimize the repetition of errors.

3.4.2 Y-12 National Security Complex

The Board has persisted in urging DOE to reduce the hazardous materials inventory in Building

9206 at Y-12. These materials represent one of the most serious legacy health and safety issues at this

site. In 2002, stabilization of pyrophoric materials was successfully completed, and the pyrophoric

uranium compounds were processed and shipped out of the facility. Progress also continues to be made in
10 The Board is a party to a Memorandum of Understanding (MOU) that coordinates health and safety oversight at

RFETS. The MOU, titled “Memorandum of Understanding Governing Regulation and Oversight of Department of

Energy Activities in the Rocky Flats Environmental Technology Site Industrial Area,” was executed by the Board,

DOE, the Environmental Protection Agency, and the Colorado Department of Public Health and Environment on

February 15, 1996. It can be viewed on the Board’s website at: http://www.dnfsb.gov/pub_docs/rfets/

mou_19960215_rf.html.

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reducing the inventory of containerized highly enriched uranium solids. The Board will continue to press

DOE to expeditiously pursue risk reduction and deactivation in Building 9206.

3.4.3 Rocky Flats Environmental Technology Site

Facility decommissioning constitutes most of the high-hazard nuclear operations at RFETS.10

Sound activity-level work planning and effective DOE oversight of contractor work planning have

particular importance for the safety of decommissioning at the site. However, the Board’s review of

several occurrences at RFETS revealed deficiencies in activity-level hazard analyses, as well as failures to

identify controls for work being performed. The Board’s review also revealed that DOE had not been

systematically reviewing activity-level work planning by the RFETS contractor. In March 2002, the Board

issued a letter to DOE requesting that corrective actions be taken. In response, DOE committed to

improving activity-level work planning and oversight, including mentoring of work planning teams and

regular assessments of work planning. RFETS has implemented the actions, and the Board is examining

their effectiveness. 

In February 2002, the Board reviewed radiological work practices for decommissioning at

RFETS. In response to the observations provided during this review, RFETS has increased monitoring of

airborne radioactivity, improved requirements and guidance for air flow testing following reconfiguration of

room areas, and improved requirements and guidance for hand protection against cuts and punctures that

could cause injection of radiological material.

Lack of proper safety management and conduct of operations had been evident in occurrences

involving subcontractors’ work at RFETS in 2001. During 2002, the Board evaluated plans for increased

use of subcontractors in decommissioning activities in major defense nuclear facilities at the site. The

Board found that actions being pursued by RFETS did not address the flowdown of health and safety

requirements and work planning/control processes or strengthening of floor-level oversight of

subcontractor work by the principal contractor, Kaiser-Hill. In August 2002, DOE informed the Board of

several actions to be taken to address these issues.

3.4.4 Fernald Closure Project

The Fernald Closure Project has made significant progress in the deactivation and

decommissioning of former uranium processing buildings, and in removal of radioactive waste materials

from the site. In 2002, the Board conducted reviews of the work authorization programs for each of the

seven major closure projects and reviewed the health and safety oversight programs of DOE and its
3-12

primary contractor. The Board found that both DOE and its contractor need to pay closer attention to

worker health and safety and to proper conduct of operations on most site projects, especially those

involving subcontractors.

The Board also reviewed the design and safety analysis work on the Silos project, which involves

removing and treating radioactive waste (stored in three concrete silos for approximately 50 years) and

shipping the material off site. The Board has provided technical comments to DOE on the structure and

content of the safety basis for these activities. The Board also evaluated readiness reviews by DOE and

the contractor for the startup of a new Radon Control System that will remove radon gas from the silos

during waste removal and treatment. These readiness reviews were well-performed and revealed software

problems in the distributed control system.

The Board evaluated additional health and safety problems at this site, including an April 2002

accident in which a worker was pinned between a railcar and a metal platform, and five separate accidents

between February and August 2002 in which workers were exposed to nitrogen dioxide fumes. In light of

this record, the Board continues to press DOE to supervise its contractors more closely at this site. 

3.4.5 Mound Closure Project

The Board reviewed the work control program for decontamination and decommissioning at the

Mound Closure Project, which has been revised to reduce its complexity. The Board found that the

resulting work packages were simple to prepare and execute, but were less detailed and relied heavily on

workers’ familiarity with the facility. The work control procedure applied to all site work except

maintenance, which was performed using a separate maintenance procedure. The Board noted

discrepancies between the work control and maintenance procedures, which the contractor corrected. 

Many of the radiological control procedures have also been revised and streamlined to allow easier

application and reduce the likelihood of errors. 
4-1

4. COMPLEX-WIDE HEALTH AND SAFETY ISSUES

4.1 IMPLEMENTATION OF INTEGRATED SAFETY MANAGEMENT

4.1.1 Overview

ISM is a concept that evolved from the Board’s Recommendation 95-2, Safety Management. 

The basic tenets of ISM provide the framework for safely performing all of the diverse hazardous activities

in the defense nuclear complex.

ISM provides for a single safety management program rather than multiple, unintegrated programs. 

Nuclear safety is an important but not exclusive target of ISM. Nonradioactive hazardous materials and

operations require attention in proportion to the risks they pose to the public, workers, and the

environment. ISM builds upon standards of safe practice for nuclear, chemical, and other hazardous

operations to ensure protection of the public, workers, and the environment.

Since the Board’s initial recommendation, the implementation of ISM has progressed through three

phases: (1) developing necessary guidance documents; (2) establishing the infrastructure for implementing

ISM at individual sites and facilities, including instructing leaders and workers in the application of ISM;

and (3) confirming that ISM Systems are effective and being applied to design and construction, startup,

operation, and decommissioning of DOE’s hazardous facilities. At the end of 1999, the implementation of

ISM was well into the second phase. With the successful completion of ISM System Verification Reviews

at all sites during 2000, the Board’s focus on implementation of ISM shifted to the third phase. 

Throughout 2002, the Board stressed the need to look beyond initial implementation to ensure continued

improvement. In addition to ensuring that ISM was implemented at all DOE sites, the Board focused on

two key initiatives that are critical to the long-term effectiveness of ISM—the ISM annual update process

and the implementation of the Board’s Recommendation 2000-2, Configuration Management, Vital

Safety Systems.

4.1.2 ISM Annual Update Process

The Board continued to oversee the implementation and effectiveness of ISM at defense nuclear

facilities. Noting indications that efforts to continually improve ISM were faltering, the Board requested in

a November 8, 2001, letter that DOE provide information on the schedule for ISM annual reviews, the

review processes being used, and an evaluation of the adequacy of those processes. DOE forwarded the

requested information on January 25, 2002. Analysis of the DOE response showed significant differences

existed among the annual review processes being used to maintain and improve ISM. A May 2002 ISM

Forum also revealed that broad variation in rigor and senior management attention existed with respect to

annual reviews. In an August 8, 2002, letter the Board notified DOE of the results of its analysis and its

concern regarding the variability in the conduct of annual ISM reviews. The Board pointed out that one

outcome of the May ISM Forum—a commitment to conduct a workshop on maintaining and improving

ISM systems—provided an opportunity to resolve some of the problems associated with the annual ISM
4-2

review process; the Board also offered suggestions for the workshop. DOE included all of the Board’s

suggested topics in the workshop agenda. The workshop’s final report provided a series of

recommendations for strengthening the annual ISM update process that will fully address the Board’s

concerns as expressed in earlier letters. If properly implemented, the Board believes these

recommendations will greatly strengthen ISM implementation.

4.1.3 Reliability and Configuration Management of Vital Safety Systems

Unless proper protection is provided, the operation of many of DOE’s defense nuclear facilities

could pose significant hazards to the environment, the public, and workers. Typically the designs of these

facilities include safety systems intended to control the hazards present. The availability, operability, and

conditions specifying operational limits for these systems are included in the written agreements established

by DOE with its contractors as conditions for authorizing the performance of work. Many of the facilities

were constructed decades ago and are undergoing deterioration from aging. For that reason alone, it is

essential that safety systems be maintained. 

In Recommendation 2000-2, Configuration Management, Vital Safety Systems, the Board

urged DOE to ensure the operability of these systems by (1) assessing their reliability and operability; (2)

requiring that contractor personnel responsible for configuration management maintain the design basis and

operating limits; (3) confirming that DOE’s technical staff has the requisite number of qualified subject

matter experts; and (4) inserting necessary legal requirements into DOE directives and contracts. 

In response to the Board’s actions, DOE has taken steps to ensure the operability of vital safety

systems. DOE completed an initial assessment of each of the vital safety systems in high-priority defense

nuclear facilities. Using the findings from this assessment, DOE conducted in-depth reviews of specific

systems and programs (such as control of drawings and configuration management) known to be problemridden. These reviews uncovered significant weaknesses in the operability of several systems, leading to

further evaluation and sometimes to repairs. DOE also revised its directives to include a requirement for

contractors to identify system engineers. The sites have begun staffing these programs and developing the

appropriate qualification and training programs. In addition, DOE issued the first draft of a major revision

to the handbook on ventilation design.

Overall, improvements have been made in ensuring that vital safety systems remain fully operable. 

However, significant work remains to be accomplished by DOE and its contractors.

4.1.4 Site-Specific ISM Reviews and Improvements

In October 2001, the Board issued a letter to DOE that highlighted numerous deficiencies in the

ISM system of the Oak Ridge environmental management contractor, such as inadequate facility hazard

classification, missing DOE health and safety orders in the contract, and improper safety basis

documentation. In response to the Board’s letter, DOE and the contractor conducted a top-to-bottom

review of their ISM programs and prepared a comprehensive corrective action plan. In 2002, DOE and

the contractor completed more than 150 actions to strengthen the ISM system, including inserting 25 DOE
4-3

health and safety orders into the contract, conducting training in safety basis fundamentals for key

personnel, and hiring additional technical staff. The Board believes that DOE and the contractor are

making adequate progress toward rectifying the serious deficiencies in the ISM program.

In the fall of 2001, the Board noted that the feedback and improvement program of a Hanford

contractor was weak and a corrective action plan had not been devised. Given these weaknesses and the

significant changes being made to the ISM system, the Board suggested that DOE complete a focused

ISM System Verification Review for the revised program. In September 2002, at the urging of the Board,

a focused review of the ISM system of the Office of River Protection and the contractor was completed. 

The review team concluded that significant improvement had occurred, that the ISM system is now

structured for continuous improvement, and that it is therefore adequate for safe tank farm operations.

At the end of 2001, the Board commended DOE’s Rocky Flats Field Office (DOE-RFFO) for

continuing to strive toward improving ISM at the site. That office performed a rigorous annual ISM

update review that identified much-needed improvements in activity-level work planning and DOE-RFFO

oversight. Subsequently, the Board observed that DOE-RFFO was making slow progress in undertaking

the corrective actions resulting from the annual ISM update. After an on-site review in late February

2002, the Board requested that DOE report to the Board on actions needed to improve the response to

annual ISM update reviews. DOE has developed suitable corrective actions. As a result of these actions

by the Board, DOE-RFFO has strengthened the activity-level work planning process and oversight by

DOE of activity-level planning. The Board’s efforts also led DOE-RFFO to better implement and track

needed corrective actions as identified in the annual ISM reviews. 

4.2 HEALTH AND SAFETY DIRECTIVES

4.2.1 Improvement of Directives

During 2002, the Board received 28 new or revised drafts of health and safety directives and

associated standards from DOE for review. Highlights of the Board’s reviews follow:

! Assignment of Authorities and Responsibilities. The Board’s comments on a revision to

DOE Manual 411.1C, Safety Management Functions, Responsibilities, and Authorities

Manual, helped clarify the roles of DOE’s safety oversight offices that were either confusing or

deleted entirely from this important directive. Documents subordinate to this directive will have

to be revised to reflect the resulting changes.

! Integration of Hazard Analyses. The Board has urged DOE to integrate hazard and safety

analyses more effectively in light of Recommendation 95-2 and DNFSB/ TECH-16. The

integration of activities supporting the preparation of DSAs, emergency preparedness hazard

assessments, fire hazard analyses, and environmental impact statements would increase

consistency and effectiveness in the development of health and safety controls. 
4-4

In response to the Board’s actions, DOE has developed a draft handbook, Integration of

Multiple Hazard Analysis Requirements and Activities. The Board provided comments on

the handbook in a letter to the Secretary of Energy on November 4, 2002. Development of

this guidance was a commendable effort that has the potential to address many of the Board’s

comments. However, the Board stated in its letter that while the current version may be of

some benefit in performing hazard and safety analyses, a more comprehensive document in the

form of a DOE guide or manual will be appropriate for the future. In its current form, the

handbook lacks the detailed information in certain areas needed to ensure the comprehensive

integration of hazard analyses and resulting controls. 

! Nuclear Air Cleaning Handbook. In response to Recommendation 2000-2, DOE

committed to publishing a revised Nuclear Air Cleaning Handbook by December 2002. A

large number of comments were received by DOE on the April and June 2002 drafts. DOE’s

pace of work on these comments made unachievable a December 2002 publication date. 

Aggressive DOE attention is still needed to support publication by June 2003, the newly

proposed deadline.

4.2.2 Implementation of Directives

A directive only contributes to health and safety if it is rigorously and competently carried out in the

field. In 2002, the Board continued to scrutinize closely the implementation of health and safety directives. 

Examples of the Board’s work include:

! Systematic Review of Orders. DOE initiated an internal review in 2001 to determine

whether the requirements in DOE orders were consistent with its current intent to focus

directives on “what” rather than “how.” Teams were formed to review the orders and to

provide their findings and recommendations to a senior management panel. The senior

management panel reviewed the teams’ reports and forwarded its recommendations to

Program Secretarial Officers and support offices. The Board, in a March 29, 2002, letter to

DOE, provided comments on those recommendations affecting safety-related orders. The

Board cautioned DOE against “actions that would cause DOE's safety assurance program to

be diminished or lead the public to perceive a decreased emphasis on safety in DOE

operations.” The Board also noted that “[T]he core safety practices retained in Rules, Orders,

and Manuals, which have evolved throughout the years in response to lessons learned, should

remain relatively constant and changed only for cause.” Finally, the Board warned DOE to

move slowly in replacing well-established safety practices developed by the national and

international nuclear safety community with general, performance-based safety objectives in

the name of eliminating “needlessly burdensome” requirements. As of the end of 2002, no

significant changes had been made to the orders being reviewed.

! Quality Assurance (QA) Including Software QA. During 2002, the Board continued to

seek improvements in DOE’s QA program. In previous years, the Board had found

weaknesses in DOE’s implementation of existing QA requirements for safety-related
11 See Appendix A for the full text of this recommendation.

4-5

components and systems, as well as weaknesses in requirements and guidance on engineering

practices for safety-related software. At the Board’s urging, DOE issued a Quality

Assurance Improvement Plan to strengthen the implementation of existing quality

requirements for safety-related components and systems. The Board provided technical

comments on this plan in a letter to DOE dated February 22, 2002. On November 22, 2002,

DOE provided the Board with its approved Quality Assurance Improvement Plan. This

plan describes DOE’s actions to improve the implementation of quality assurance in the design,

procurement, construction, operation, and maintenance of vital safety systems. 

On the other hand, despite the Board’s continuing emphasis on software QA, DOE was

unable to develop and execute an acceptable plan to strengthen requirements and guidance on

engineering practices in this area. To remedy this situation, the Board issued Recommendation

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

November 21, 2002, the Secretary accepted this recommendation, and an Implementation

Plan is under development.11

! Safety Basis Assumptions. The development of a comprehensive safety basis and the

identification and selection of an appropriate control set are essential cornerstones of safe

operation at defense nuclear facilities. In 2002, the Board conducted numerous reviews of the

safety bases throughout the DOE complex. The Board reviewed the critical assumptions used

in the development of the safety bases, as well as the control strategies used to prevent and

mitigate accident scenarios of concern. The Board pointed out a number of specific instances

in which faulty assumptions and methodologies had been used in the development of safety

bases. These included analyses that did not always use bounding input assumptions and that

implicitly credited non-qualified plant indications and equipment in the development of the

safety analyses. These deficiencies resulted in situations wherein the safety analyses may not

have accurately bounded the actual hazard conditions for the facilities involved. Specific

examples of such deficiencies were documented by the Board in letters to DOE dated May

13, September 23, and November 4, 2002. DOE and its contractors have implemented a

number of corrective actions to correct the deficiencies.

! Unreviewed Safety Question Procedures. The USQ process is designed to identify

proposed but unanalyzed changes to facilities or procedures that may affect the safety basis for

a defense nuclear facility. Contractors must obtain approval from DOE before implementing a

change determined to constitute a USQ. Since April 10, 2001, contractors have been

required to submit their USQ procedures to DOE for approval and to follow approved USQ

procedures thereafter. This year, the Board reviewed USQ procedures and samples of USQ

documentation obtained from defense nuclear facilities throughout the nuclear weapons

complex. Each procedure had been submitted to local DOE site offices for approval, and

most had been approved prior to the Board’s review. 
4-6

The Board found that the consistency of USQ procedures with written requirements and

DOE expectations varied widely across the complex, even among procedures approved by

DOE. Weaknesses identified by the Board included inadequacies in the safety analyses

supporting USQ determinations. The Board provided technical advice to the cognizant

DOE site offices to assist them in correcting the deficiencies. In consequence, many of the

procedures have since been rewritten or revised. However, the adequate implementation

of the USQ process will continue to require attention, particularly as documented safety

analyses are revised and updated to fulfill the requirements of 10 CFR Part 830.

! Maintenance Programs for Defense Nuclear Facilities. The development and

implementation of an effective equipment maintenance program is a critical element in

ensuring safe and efficient operations at defense nuclear facilities. During 2002, the Board

continued to place high priority on the review and assessment of maintenance programs and

related activities conducted by DOE and its contractors.

In furtherance of this complex-wide initiative, in 2002 the Board conducted on-site reviews

of maintenance programs at the Hanford Spent Nuclear Fuel Project and at Y-12. In

each case, weaknesses in the maintenance program were found and communicated to

DOE. As a result of these reviews, DOE and its contractors at these sites implemented

measures that significantly strengthen this critical safety program. In addition to in-depth

reviews of this kind, the Board’s site representatives regularly assess maintenance activities

at priority sites. 

! Criticality Safety. The Board has continued to urge DOE to establish a stable source of

funding for the development of nuclear criticality experimentation and safety analysis

methods, as defined in the Implementation Plan for the Board’s Recommendation 97-2,

Criticality Safety. In 2002, DOE made good progress toward establishing a stable

funding source when the Secretary determined that the Office of Defense Programs would

fully fund and manage the Nuclear Criticality Safety Program (NCSP) in fiscal year 2003

and beyond. The Board has also encouraged DOE to integrate end-user needs, including

criticality engineer training and qualification, and experimentation, with overall management

of the NCSP. DOE has completed a Five-Year Criticality Safety Program that is

responsive to these needs. 

4.2.3 Recommendation 2002-3, Requirements for the Design, Implementation, and

Maintenance of Administrative Controls

On December 11, 2002, the Board issued Recommendation 2002-3, Requirements for the

Design, Implementation, and Maintenance of Administrative Controls. In this recommendation,

the Board highlighted the fact that the prevention and mitigation of potential accidents inherent in the
12 See Appendix A for the full text of this recommendation.

4-7

mission activities at defense nuclear facilities require DOE and its contractors to identify accident

scenarios and then establish effective and reliable safety controls to address them.12

The Board noted that engineered safety controls are preferred over administrative controls

because, in general, engineered controls are more reliable and effective. In many applications,

however, DOE and its contractors have concluded that discrete operator actions or administrative

programs are required to address consequences of accidents that would otherwise be unacceptable. 

The Board has identified a number of flawed administrative safety controls that are proposed or in use

at various defense nuclear facilities. In many cases, DOE and its contractors have asserted that the

methods used to establish these administrative controls comply with existing DOE directives. 

After further analysis, the Board concluded that the DOE directives system does not contain

requirements adequate to ensure that the design, implementation, and maintenance of important safetyrelated administrative controls will be effective and reliable. As a result, the Board recommended that

DOE promulgate a set of requirements for safety-class and safety-significant administrative controls to

establish appropriate expectations for the design, implementation, and maintenance of these important

safety controls. The Board also recommended that DOE take action to ensure that all existing

administrative controls that serve as safety-class or safety-significant are evaluated against these new

requirements and upgraded as necessary.

4.3 TECHNICAL COMPETENCE

4.3.1 Competence of DOE and Contractor Personnel

During 2002, the Board continued to examine the competence of key health and safety

personnel at defense nuclear facilities. A number of years ago, DOE established a Federal Technical

Capabilities Panel to respond to the Board’s concerns in this area. Several initiatives resulted in

marginal improvements, but not with enough substance to justify optimism that this issue was well in

hand. In May 2002, the Board noted that the NNSA Administrator and the DOE Assistant Secretary

for Environmental Management were enacting major personnel realignments that promised improved

performance on the part of their organizations. Other actions in this area during 2002 included the

following:

! The Board scrutinized the contractor’s ORR for resumption of Wet Chemistry Operations

in Building 9212 at Y-12. Based on observation of demonstrations during the ORR, the

Board found that the preparations in the areas of conduct of operations and training were

inadequate. Therefore, the ORR was suspended so that these deficiencies could be

corrected.
4-8

! The Board continued its efforts to ensure the availability of a criticality safety infrastructure

in support of nuclear operations (see Recommendation 97-2, Criticality Safety). The

Board stressed the need to provide stable funding for future criticality safety program

elements, place dedicated emphasis on maintenance of criticality safety engineering training,

and minimize the gap in criticality services during the relocation of the Los Alamos

Criticality Test Facility.

! The Board reviewed the safety basis, supporting programs, and operational readiness of the

Waste Examination Facility at the Nevada Test Site, a Hazard Category 3 nuclear facility. 

Many administrative support programs, such as the training and qualification program, had

not been adequately developed or implemented to meet the requirements of nuclear

facilities as set forth in 10 CFR Part 830. Training of facility operators and outside

maintenance support personnel to perform surveillance activities or preoperational checks

was inadequate. The Board’s letter of March 7, 2002, transmitted these observations to

DOE for further corrective action.

! The Board found that the Office of River Protection’s (ORP) oversight of the WTP design

process was seriously lacking in level of detail. In a letter to DOE dated December 16,

2002, the Board requested a report on DOE’s plans to strengthen the design review

process for WTP to avert future safety problems.

4.3.2 System Engineers and Federal Subject Matter Experts

Recommendation 2000-2, Configuration Management, Vital Safety Systems, urged DOE to

develop formal requirements for training and qualification of competent subject matter experts in vital

safety systems (system engineers) for both federal and contractor organizations. As part of its response

to this recommendation, in 2001 DOE issued a significant modification to DOE Order 420.1, Facility

Safety, defining responsibilities and training requirements for contractors’ system engineers. DOE also

revised Order 433.1, Maintenance Management Program for DOE Nuclear Facilities, to include

requirements for establishing a system engineer program for the management of vital safety systems. 

During 2002, the Board evaluated DOE’s efforts to institutionalize the use of system engineers

and federal subject matter experts for vital safety systems at defense nuclear facilities throughout the

DOE complex. The Board’s staff conducted reviews of DOE’s implementation of this requirement at

six DOE sites: SRS, ORNL, Pantex, LANL, ORP, and the Richland Operations Office. Staffing of

system engineers and federal subject matter experts varied considerably from site to site; only SRS was

able to satisfy most of the direction prescribed in DOE standards. The Board’s staff found that the

federal programs at the Amarillo Site Office, and the Los Alamos Site Office were understaffed and

lacked adequate definition of roles and responsibilities for subject matter experts. 

During the review at Hanford, the staff noted significant deficiencies in the implementation of

Recommendation 2000-2. Specifically, the qualification and training programs for ORP’s subject

matter experts on vital safety systems lacked the rigor required for these individuals to provide effective
4-9

oversight of the contractors. The system engineering program at Fluor Hanford was weak, with few

requirements for training and qualifying a system engineer. The site has since informed the Board that

corrective actions are being taken to redress these deficiencies. The staff also found weaknesses in this

area at RFETS. For example, the system engineers who were assigned to vital safety systems had not

been required to participate in the work control processes for substantial modification, troubleshooting,

and repair of the systems. This situation has been corrected. 

In a September 2002 letter to DOE, the Board rejected DOE’s list of federal personnel who

are filling positions as subject matter experts in DOE’s field and area offices. Numerous inconsistencies

and gaps were noted in this list, including many vacant positions with no plans to fill them; vacant

positions to be filled from within the current DOE organization for which no candidate had been

identified; and safety system categories listed as non-existent, in conflict with information provided in the

original report of January 2002. DOE is now in the process of resolving these discrepancies and

establishing a plan to fill vital technical positions. The Board will continue to emphasize to DOE the

importance of assigning qualified system engineers and federal subject matter experts to vital safety

systems.

4.4 NUCLEAR FACILITY DESIGN REVIEWS

One of the Board’s statutory responsibilities is review of the design and construction of defense

nuclear facilities to ensure that adequate health and safety requirements are identified and implemented. 

These facilities must be designed and constructed in a manner that will support safe and efficient

operations for 20 to 50 years. This in turn requires a robust design process to ensure that appropriate

health and safety controls are identified and properly implemented early in the process. ISM provides

the framework for this process. The Board’s expectation is that the design and construction phases of

defense nuclear facilities will demonstrate clear and deliberate implementation of ISM principles and

core functions, clearly codified in manuals of practice and implemented on design and construction

projects. The following are examples of the Board’s design review work in 2002:

! Tritium Extraction Facility. TEF, currently under construction at SRS, will be used to

extract tritium from target rods irradiated in commercial light water reactors. The extracted

tritium is to be used to replenish tritium reserves for the nation’s nuclear weapon stockpile. 

The Board reviewed the application of ISM to the TEF design process to ensure that

hazards were identified and appropriate controls developed. There are two major hazards

associated with TEF: uncontrolled release of tritium, a radiological hazard that can also

cause fires or explosions and high gamma radiation from the target rods. In a letter dated

July 19, 2002, the Board challenged the adequacy of design features intended to protect

workers from the potential consequences of an earthquake. DOE’s response of October

17, 2002, stated that a seismic monitor and alarm system would be added to the TEF

design. Overall, the Board was able to resolve 46 potential health and safety issues

associated with the project. These issues and their resolution are documented in DOE’s

November 18, 2002, letter to the Board. 
4-10

! Hanford Waste Treatment Plant (WTP). The Board continues oversight of the design and

safety basis for WTP at Hanford. The Board’s activities focused on two major areas during

2002: adequacy of the structural design, and review of the Preliminary Safety Analysis Report. 

Review of the structural design focused on those elements completed early in the construction

life cycle. This approach was taken to accommodate DOE’s aggressive schedule, whereby

construction is allowed to commence before the overall structural design has been completed. 

In July 2002, the Board reviewed the High-Level Waste (HLW) and Low-Activity Waste

(LAW) basemat designs, and concluded that, although three seismic questions remained,

sufficient margin existed in the design to allow construction to move forward. Subsequently,

two of these three questions were satisfactorily answered. The remaining question is the

spectral response associated with attenuation relationships.

This issue continues to be bounded by the design margins imposed upon the structural design. 

The Board remains interested in the management of these margins, to better understand any

overall health and safety impacts from future changes in margin values. In a December 2002

letter, the Board requested that DOE provide a report describing how structural design

margins will be managed as a function of design uncertainty. The response to this request is

expected in early 2003. The Board also requested that summary structural reports for the

HLW, LAW, and Pretreatment Facilities be prepared so that a full assessment of the structural

design and supporting analysis can be completed. These reports will be used by DOE and the

Board to understand each facility’s structural response to seismic loads, and to detect

important, yet subtle, modeling and computation anomalies that could affect safety. These

reports are expected to be completed during calender year 2003. 

The Board has also been maintaining oversight of WTP construction. When out-ofspecification concrete was placed for the LAW basemat, the Board questioned the effect this

could have on the structural integrity of the building under all design loading conditions. In

response to the Board’s inquiry, WTP developed a systematic approach to investigating and

correcting the areas of weak concrete.

WTP has elected to implement a unique ISM review process to evaluate the design’s

adequacy and to ensure that all health and safety issues have been addressed. The Board

reviewed this process and determined that systematic weaknesses might exist, among them a

failure to identify conditions requiring safety-related controls and poor execution of supporting

calculations. DOE’s contractor had initiated but not yet completed corrective actions to

address these deficiencies. Finally, the Board found that health and safety requirements

delineated in DOE Order 420.1, Facility Safety, and DOE Standard DOE-STD-3009-94,

Change Notice 2, Preparation Guide for U.S. Department of Energy Nonreactor Facility

Safety Analysis Reports, were not being fully met. In this case, the design contractor used

incorrectly DOE’s evaluation guidelines for determining the adequacy of safety systems. The

Board noted this deficiency in a letter to DOE dated November 4, 2002, and requested a

letter report on corrective actions. DOE’s response is expected in early 2003.
4-11

! Highly Enriched Uranium Materials Facility (HEUMF). HEUMF at Y-12 is being

designed to provide long-term consolidated storage. Review of the conceptual design of the

facility disclosed a number of design weaknesses. Although the facility must be capable of

withstanding an earthquake, the Board determined that the proposed structural configuration

would not safely resist seismic forces. Additional strengthening was provided. The Board also

found design deficiencies that could threaten the criticality-safe configuration of uranium

storage cans. As a result, the storage design was reconfigured to render it safe from seismic

forces.

! Pit Disassembly and Conversion Facility (PDCF). The Board reviewed the preliminary

design and the Facility Design Descriptions of PDCF, to be constructed at SRS. The Board’s

review revealed the need for further study of the geological soft zone in the area proposed for

the foundation, and for improvements in the safety and hazard analyses for worker protection. 

The Board has noted several positive features of the PDCF design: a sand filter for building

confinement, 3 to 4 hour fire barriers between major processing areas, two independent

sources of emergency power, and a conservative seismic response spectrum. 
5-1

5. INFORMING THE PUBLIC

The Board keeps the public informed of its work through public meetings, quick responses to

public requests for documents, effective responses to public inquires into health and safety issues, outreach

activities of the Board’s site representatives, and an Internet website.

5.1 PUBLIC MEETINGS

During 2002, the Board conducted a public meeting in Pleasanton, California, near LLNL. This

meeting focused on LLNL’s implementation of Recommendations 2000-2, 94-1, and 2000-1, and the

adequacy of LLNL’s support for nuclear explosive operations at the Pantex Plant.

5.2 RESPONDING TO PUBLIC REQUESTS

The Board responded to numerous public requests for documents and information during 2002. 

The Board also responded to 16 requests filed under the Freedom of Information Act (FOIA). The

average response time was 11 working days, as compared with the statutory requirement of 20 working

days. The Board has posted on its website a complete list of FOIA requests processed since 2000.

5.3 ELECTRONIC ACCESS

The Board redesigned its website (www.dnfsb.gov) in 2002 to keep pace with rapid changes in

Internet technologies, and to meet federal regulations and security requirements. Restructuring the site with

state-of-the-art technology has made it easier to update with limited staff, thus ensuring timely posting of

essential documents. The improved design has made the website more attractive and easier for the public

to use, and has improved the process of recruiting for potential applicants. The redesigned website also

enhances accessibility for individuals with disabilities, and offers convenient and thorough public access to

the Board’s oversight work.

The Board established a priority to comply with the Government Information Security Reform Act

and other federal standards for information security. In furtherance of that objective, the Board subjected

its information security systems to an independent audit. While the audit found no significant weaknesses,

it identified ways to improve the Board’s security policies and procedures. The recommendations from the

audit are now being implemented to ensure that the Board’s information security posture is capable of

countering continual and changing cyber threats.

5.4 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 to investigate or inquire further. These

inquiries, which may involve interviews, review of documents, and site visits, are continued until the Board
5-2

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 2002, the Board directed inquiries into health and safety issues at DOE Headquarters,

Hanford, LANL, Pantex, and Fernald. The Fernald inquiry resulted in improvements to hazard

categorizations used in planning for the safe execution of cleanup. The headquarters inquiry resulted in

increased attention to quality assurance in such areas as design and procurement. Additionally, the inquiry

resulted in improved DOE and DOE contractor activities to prevent the introduction of suspect/counterfeit

items into safety or mission-sensitive applications, and improved programs to respond to emergent

problems concerning suspect/ counterfeit items. However, a recent Board staff review identified an

erosion in DOE activities regarding suspect/counterfeit items and shortcomings in DOE’s response to a

Department of Defense notification of a suspect/counterfeit parts alert. Suspect/counterfeit parts, items,

and equipment continue to be supplied to DOE and constant attention is required to detect, prevent the

installation, and, where installed, to remove potentially discrepant items which could pose a threat to the

health and safety of workers and the general public. The Board continues to devote substantial resources

to assist DOE in implementing effective quality assurance programs and effective controls on

suspect/counterfeit items.

5.5 SITE REPRESENTATIVE ACTIVITIES

The Board enhances its on-site health and safety oversight of defense nuclear facilities by assigning

experienced technical staff members to full-time duty at priority DOE sites: Pantex, Hanford, RFETS,

SRS, Y-12, and LANL. 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 regular briefings from its site representatives in person, and maintains continuous contact

with them using all available media. 
APPENDIX A

RECOMMENDATION 2002-1

RECOMMENDATION 2002-2

RECOMMENDATION 2002-3 







B-1

APPENDIX B

Reporting Requirements

Date of Letter Subject 

 

Response

 Required 

Response

 Due 

December 27 Address secondary confinement system design deficiencies and

primary confinement systems at the Y-12 Highly Enriched Uranium

Materials Facility

Report 90 Days

December 16 Management of structural design margins and plans to

systematically review the Hanford Waste Treatment Plant design

Report 45 Days

November 13 Address criticality safety for operations in Building 9212 and actions

taken to ensure the continued adequacy of the Y-12 criticality safety

program

NNSA 

Report

Contractor

Report

60 Days

60 Days

November 13 DOE actions to ensure that controls, such as continuous air

monitors and radiation alarm monitors, are afforded protection

required by safety-significant designation at the Pantex Plant

Briefing 60 Days

November 4 DOE resolutions of safety and design deficiencies at the Hanford

Waste Treatment Plant

Report 60 Days

September 23 Safe storage of sodium fluoride (NaF) traps stored in Building 3019A

at the Oak Ridge National Laboratory

Briefing 60 days

August 9 Recommendations 94-1 and 2000-1 Implementation Plan, Revision 2,

plans and schedules for stabilizing nuclear material at LANL

Briefing

IP Rev.

 Date

30 Days 

No Time 

Specified

August 1 Design agency designation of a single integrated point of contact

for each weapon system

Briefing 30 Days

July 19 Describe the seismic-detection and alarm system test program for the

Savannah River Tritium Extraction Facility and identify the safety

design feature to be incorporated in the event the aforementioned

system proves impractical or ineffective

Report 60 Days

July 17 Outline specific actions DOE will take to implement

recommendations of the DOE Commission on Fire Safety and

Preparedness

Report 60 Days

July 12 Address issues concerning verification of plutonium oxide

stabilization

Report 60 Days

June 27 Summarize DOE’s plan for further development of alternative

technologies for removal of cesium from salt wastes at SRS

Report 60 Days
B-2

 Date of Letter Subject Response

 Required 

 Response

 Due 

May 20 Measures taken to improve the safe management of inactive nuclear

materials at sites managed by NNSA

Report 120 Days

May 13 Fire protection issues for Building 9212, B-1 Wing, at the Y-12

National Security Complex

Report 60 Days

April 23 Identified deficiencies in new Plutonium-238 Scrap Recovery Line at

the Los Alamos National Laboratory

Report 60 Days

April 19 Emergency power system at the Lawrence Livermore National

Laboratory’s Plutonium Facility (Building 332)

Briefing 30 Days

March 29 Recommendations on the high-level waste operations at the

Savannah River Site

Report 60 Days

March 21 Issues raised in DNFSB/TECH-32 on the Savannah River Site

canyon utilization

Report 60 Days

March 7 Issues on depleted uranium storage at the Savannah River Site Report 120 Days

March 7 Preliminary design of the Sandia National Laboratories Underground

Reactor Facility

Report 60 Days

February 22 Design requirements and guidance and status of quality assurance

improvement at the Los Alamos National Laboratory

Report 60 Days

February 15 Hanford’s Multi-Canister Overpack (MCO) in relation to

Recommendation 94-1

Report 60 Days
C-1

APPENDIX C

CORRESPONDENCE

The Board’s 2002 letters are organized below in two ways, first by strategic plan area and second

by site or facility. Some letters pertain to more than one strategic plan area or site; in these cases, the letter

is listed only once.

I. STRATEGIC AREA LISTS

Strategic Area of Planning I: Complex-wide Issues

January 28 letter to the Deputy Secretary of Energy concerning the Nuclear Air Cleaning

Handbook.

January 31 letter to Secretary Abraham responding to DOE’s letter proposing closure of

Recommendation 98-1.

February 15 letter to the Assistant Secretary for Environmental Management regarding MultiCanister Overpack in relation to Recommendation 94-1.

February 22 letter to the Deputy Secretary of Energy on the Quality Assurance Improvement Plan.

March 19 letter to the Assistant Secretary of Energy for Environmental Management forwarding a

staff issue report on feedback from deactivation and decommissioning activities.

March 22 letter to the Assistant Secretary for Environmental Management in reference to

Recommendation 2001-1.

March 29 letter to the Assistant Secretary for Environmental Management on the expertise of

industry groups.

March 29 letter to Secretary Abraham on the order review in progress.

April 19 letter to the Under Secretary for Nuclear Security on the calendar year 2002 master

schedule of external NNSA assessments.

May 20 letter to the Deputy Administrator for Defense Programs forwarding a staff issue report on

the review of inactive nuclear materials management at DOE nuclear weapons laboratories. 

June 7 letter to Secretary Abraham commending the Facility Representative Program and the

selection of Mr. Brian Harkins as the 2001 Facility Representative of the Year.
C-2

July 11 letter to the Deputy Administrator of Naval Reactors concerning receipt of the

NNSA/Naval Reactors report on radiological waste disposal and environmental monitoring,

occupational safety and health, and occupational radiation exposure.

July 12 letter to the Assistant Secretary for Environmental Management with an enclosed issue

report regarding the approved guidelines for verifying thermal stabilization of plutonium oxide. 

July 17 letter to Secretary Abraham on the recommendations of the DOE Commission on Fire

Safety and Preparedness.

August 8 letter to Secretary Abraham on the Integrated Safety Management annual review

process.

August 9 letter to Secretary Abraham on DOE’s Implementation Plan for Recommendations 94-1

and 2001-1.

August 9 letter to the Honorable Baron P. Hill on the Waste Pits Remedial Action Project.

September 18 letter to Secretary Abraham on Recommendation 2000-2 actions.

September 23 letter to Secretary Abraham on Recommendation 2002-1.

September 23 letter to Secretary Abraham on safety and hazard analysis methodology at DOE

defense nuclear facilities.

October 3 letter to Secretary Abraham forwarding Recommendation 2002-2.

November 4 letter to Secretary Abraham on Integrated Safety Management.

November 15 letter to the Assistant Secretary for Environmental Management requesting a briefing

on the vapor-space corrosion program.

November 22 letter to Secretary Abraham approving DOE’s request for an extension to respond

to Recommendation 2002-2.

December 11 letter to Secretary Abraham forwarding Recommendation 2002-3.

December 19 letter to the Deputy Administrator for Defense Programs regarding the Tritium

Extraction Facility at SRS.

December 31 letter to the Deputy Administrator for Defense Programs regarding DOE’s

September 20 response to the Board’s May 20 letter on inactive actinide materials.
C-3

Strategic Area of Planning II: Safe Management and Stewardship of Nuclear Weapons

Stockpile and Components

January 15 letter to the Acting Deputy Administrator for Defense Programs enclosing a staff issue

report on verification of hazard assessment at LLNL.

January 18 letter to the Under Secretary of Energy, Science, and Environment on environmental

management activities of DOE’s Oak Ridge Operations Office.

February 22 letter to the Deputy Administrator for Defense Programs forwarding a report on

design requirements and guidance and status of quality assurance improvements at LANL. 

March 7 letter to the Deputy Administrator for Defense Programs forwarding a staff issue report

on the safety basis and readiness of the Waste Examination Facility at the Nevada Test Site.

March 7 letter to the Deputy Administrator for Defense Programs enclosing a staff issue report on

the preliminary design of the Sandia Underground Reactor Facility.

March 11 letter to the Deputy Administrator for Defense Programs enclosing a staff report on the

deactivation of LLNL’s heavy element facility.

March 25 letter to the Deputy Administrator for Defense Programs on compliance with procedures

at Pantex.

March 25 letter to the Deputy Administrator for Defense Programs forwarding three staff issue

reports on the Highly Enriched Uranium Materials Facility at Y-12.

March 25 letter to the Deputy Administrator for Defense Programs enclosing a staff issue report on

the disposition of various radioactive and hazardous materials stored at Y-12.

April 19 letter to the Deputy Administrator for Defense Programs enclosing a staff issue report on

the emergency power system at LLNL’s Plutonium Facility (Building 332).

April 23 letter to the Under Secretary for Nuclear Security and Administration forwarding a staff

report on the new 238Pu Scrap Recovery Line at LANL. 

May 8 letter to Secretary Abraham on DOE’s Implementation Plan for Recommendation 99-1.

May 13 letter to the Deputy Administrator for Defense Programs enclosing a staff issue report on

fire protection for B-1 Wing of Building 9212 at Y-12.
C-4

July 30 letter to the Under Secretary of Energy, Science, and Environment on the proposal for

obtaining medical isotopes from the uranium-233 stored at Oak Ridge National Laboratory, and

the shutdown of the Building 3019 complex.

August 1 letter to the Acting Administrator of NNSA concerning actions being taken to ensure

support of safety initiatives at the Pantex Plant.

August 6 letter to the Deputy Administrator for Defense Programs forwarding a staff report on the

status of lightning protection and electrical systems at Pantex.

August 6 letter to the Deputy Administrator for Defense Programs forwarding a staff report on

lightning protections systems at LANL.

September 23 letter to the Assistant Secretary of Environmental Management forwarding a staff

report on safe storage of sodium fluoride traps at ORNL.

September 23 letter to the Acting Administrator of NNSA forwarding a staff report on fire

protection at Pantex.

October 3 letter to the Deputy Administrator for Defense Programs forwarding a staff report on

conduct of operations and training preparations for a contractor’s operational readiness review at

Y-12.

November 13 letter to the Deputy Administrator for Defense Programs establishing a 60-day

reporting requirement for addressing criticality safety at Y-12.

November 13 letter to the Deputy Administrator for Defense Programs establishing a 60-day

reporting requirement on controls to protect against significant exposure to radiological hazards at

Pantex.

November 15 letter to the Deputy Administrator for Defense Programs regarding the need to

restart disassembly and inspection operations for the W84 Program.

December 19 letter to Secretary Abraham regarding the implementation of Seamless Safety for the

21st Century at the Pantex Plant.

December 27 letter to the Deputy Administrator for Defense Programs establishing a 90-day

reporting requirement on the Highly Enriched Uranium Materials Facility at Y-12.

December 31 letter to the Deputy Administrator for Defense Programs on the Highly Enriched

Uranium Materials Facility at Y-12.
C-5

Strategic Area of Planning III: Safe Disposition of Hazardous Remnants of Weapons Production

February 5 letter to the Assistant Secretary for Environmental Management forwarding a staff issue

report on electrical and instrumentation and control systems at Hanford’s Plutonium Finishing Plant.

February 15 letter to the Assistant Secretary for Environmental Management on Recommendation

94-1.

March 4 letter to the Assistant Secretary for Environmental Management on high-level waste salt

processing capability at SRS.

March 19 letter to the Assistant Secretary for Environmental Management enclosing a staff issue

report on activity-level work planning and feedback and improvement at RFETS.

March 21 letter to Secretary Abraham forwarding DNFSB/TECH-32, Savannah River Site

Canyon Utilization.

March 29 letter to Secretary Abraham formally closing Recommendation 96-1, and requesting a

report on DOE’s approach for treatment and disposition of the waste in Tank 48 at SRS.

March 29 letter to Secretary Abraham on Recommendation 2001-1.

May 22 letter to Secretary Abraham on Recommendation 94-1.

June 5 letter to the Assistant Secretary for Environmental Management forwarding a staff issue

report reviewing maintenance at the Hanford Spent Nuclear Fuel Project.

June 11 letter to the Assistant Secretary for Environmental Management forwarding a staff issue

report on Recommendation 94-1/2000-1 stabilization activities at the Hanford Plutonium Finishing

Plant.

June 11 letter to the Assistant Secretary for Environmental Management on Recommendation

2001-1.

June 26 letter to the Assistant Secretary for Environmental Management enclosing a staff issue

report on the H-Canyon ventilation system at SRS.

June 27 letter to the Assistant Secretary for Environmental Management requesting a summary of

DOE’s plan for further development of alternative technologies for the removal of cesium from salt

wastes at SRS.
C-6

July 30 letter to the Assistant Secretary for Environmental Management on the seismic design of the

Pretreatment, Low-Activity Waste, and High-Level Waste Facilities of the Hanford Waste

Treatment Plant.

September 9 letter to the Assistant Secretary for Environmental Management on the Waste Feed

Delivery Transfer System at Hanford.

November 4 letter to the Assistant Secretary for Environmental Management forwarding a staff

issue report on safety and design basis activities at the Hanford Waste Treatment Plant.

November 4 letter to the Assistant Secretary for Environmental Management enclosing a staff issue

report on documented safety analysis for the concentration, storage, and transfer facilities at SRS.

November 8 letter to Secretary Abraham on F-Canyon at SRS.

November 14 letter to the Assistant Secretary for Environmental Management forwarding staff

observations on the Hanford High Level Waste Building “Load Path Report.”

December 13 letter to Congressman Porter on the hazard categorization of the Waste Pits

Remedial Action Project at Fernald.

December 16 letter to the Assistant Secretary for Environmental Management forwarding a staff

issue report on the status of the Implementation Plan for Recommendation 2000-2. 

December 16 letter to Secretary Abraham establishing a 45-day reporting requirement regarding

safety issues at the Hanford Waste Treatment Plant project.

II. SITE/FACILITY LIST

Fernald Closure Site

December 13 letter to Congressman Porter on the hazard categorization of the Waste Pits

Remedial Action Project.

Hanford Site

February 5 letter to the Assistant Secretary for Environmental Management forwarding a staff issue

report on electrical and instrumentation/control systems at the Plutonium Finishing Plant.

February 15 letter to the Assistant Secretary for Environmental Management on Recommendation

94-1.
C-7

June 5 letter to the Assistant Secretary for Environmental Management forwarding a staff issue

report reviewing maintenance at the Spent Nuclear Fuel Project.

June 11 letter to the Assistant Secretary for Environmental Management forwarding a staff issue

report on Recommendation 94-1/2000-1 stabilization activities at the Plutonium Finishing Plant.

July 30 letter to the Assistant Secretary for Environmental Management on the seismic design of the

Pretreatment, Low-Activity Waste, and High-Level Waste Facilities of the Waste Treatment Plant.

September 9 letter to the Assistant Secretary for Environmental Management on the waste feed

delivery transfer system.

November 4 letter to the Assistant Secretary for Environmental Management forwarding a staff

issue report on safety and design basis activities at the Waste Treatment Plant.

November 14 letter to the Assistant Secretary for Environmental Management forwarding staff

observations on the High Level Waste Building’s “Load Path Report.”

December 16 letter to the Assistant Secretary for Environmental Management forwarding a staff

issue report on the status of the Implementation Plan for Recommendation 2000-2.

December 16 letter to Secretary Abraham establishing a 45-day reporting requirement on safety

issues at the Waste Treatment Plant.

Los Alamos National Laboratory 

February 22 letter to the Deputy Administrator for Defense Programs forwarding a report on

design requirements and guidance and the status of quality assurance improvements.

April 23 letter to the Under Secretary for Nuclear Security and Administration of NNSA

forwarding a report on the new 238Pu Scrap Recovery Line.

August 6 letter to the Deputy Administrator for Defense Programs forwarding a staff report on a

review of lightning protection systems.

Lawrence Livermore National Laboratory

January 15 letter to the Acting Deputy Administrator for Defense Programs enclosing a staff issue

report on verification of hazard assessments.

March 11 letter to the Deputy Administrator for Defense Programs enclosing a staff report on the

deactivation of LLNL’s heavy element facility.
C-8

April 19 letter to the Deputy Administrator for Defense Programs enclosing a staff issue report on

the emergency power system at the Plutonium Facility, Building 332.

Nevada Test Site

March 7 letter to the Deputy Administrator for Defense Programs forwarding a staff issue report on

the safety basis and readiness of the Waste Examination Facility.

Oak Ridge/Y-12

January 18 letter to the Under Secretary of Energy, Science, and Environment concerning the

environmental management activities of the Oak Ridge Operations Office.

March 25 letter to the Deputy Administrator for Defense Programs forwarding three staff issue

reports on the Highly Enriched Uranium Materials Facility at Y-12.

March 25 letter to the Deputy Administrator for Defense Programs enclosing a staff issue report on

the disposition of various radioactive and hazardous materials stored at Y-12.

May 13 letter to the Deputy Administrator for Defense Programs enclosing a staff issue report on fire

protection for the B-1 Wing of Building 9212 at Y-12.

July 30 letter to the Under Secretary of Energy, Science, and Environment on obtaining medical

isotopes from the uranium-233 stored at ORNL, and the shutdown of the Building 3019 complex.

September 23 letter to the Assistant Secretary of Environmental Management forwarding a staff

report on safe storage of sodium fluoride traps at ORNL.

October 3 letter to the Deputy Administrator for Defense Programs forwarding a staff report on

conduct of operations and training preparations for a contractor’s operational readiness review at Y12.

November 13 letter to the Deputy Administrator for Defense Programs establishing a 60-day

reporting requirement on criticality safety at Y-12.

December 27 letter to the Deputy Administrator for Defense Programs establishing a 90-day

reporting requirement on the Highly Enriched Uranium Materials Facility at Y-12.

December 31 letter to the Deputy Administrator for Defense Programs regarding the Highly

Enriched Uranium Materials Facility at Y-12.

Pantex Plant

March 25 letter to the Deputy Administrator for Defense Programs on compliance with procedures.
C-9

May 8 letter to Secretary Abraham on DOE’s Implementation Plan for Recommendation 99-1.

August 1 letter to the Acting Administrator of NNSA concerning support for the implementation of

safety initiatives.

August 6 letter to the Deputy Administrator for Defense Programs forwarding a staff report on the

status of lightning protection and electrical systems.

September 23 letter to the Acting Administrator of NNSA forwarding a staff report on fire

protection.

November 13 letter to the Deputy Administrator for Defense Programs establishing a 60-day

reporting requirement on ensuring controls to protect against significant exposure to radiological

hazards.

November 15 letter to the Deputy Administrator for Defense Programs regarding the need to restart

disassembly and inspection operations for the W84 Program.

December 19 letter to Secretary Abraham regarding the implementation of Seamless Safety for the

21st Century.

Rocky Flats Environmental Technology Site

March 19 letter to the Assistant Secretary for Environmental Management enclosing a staff issue

report on activity-level work planning and feedback and improvement.

May 22 letter to Secretary Abraham on Recommendation 94-1.

Sandia National Laboratories

March 7 letter to the Deputy Administrator for Defense Programs enclosing a staff issue report on

the preliminary design of the Underground Reactor Facility.

Savannah River Site

March 4 letter to the Assistant Secretary for Environmental Management on high-level waste salt

processing capability.

March 7 letter to the Assistant Secretary for Environmental Management on the issues outlined in the

forwarded staff issue report on depleted uranium storage.

March 21 letter to Secretary Abraham forwarding DNFSB/TECH-32, Savannah River Site

Canyon Utilization.
C-10

March 29 letter to Secretary Abraham formally closing Recommendation 96-1, and requesting a

report on DOE’s approach for treatment and disposition of the waste in Tank 48.

March 29 letter to Secretary Abraham on Recommendation 2001-1.

June 11 letter to the Assistant Secretary for Environmental Management on Recommendation 2001-

1.

June 26 letter to the Assistant Secretary for Environmental Management enclosing a staff issue report

on the H-Canyon ventilation system.

June 27 letter to the Assistant Secretary for Environmental Management requesting a summary of

DOE’s plan for further development of alternative technologies for the removal of cesium from salt

wastes.

July 19 letter to the Deputy Administrator for Defense Programs concerning the Tritium Extraction

Facility.

November 4 letter to the Assistant Secretary for Environmental Management enclosing a staff issue

report on documented safety analysis for concentration, storage, and transfer facilities.

November 8 letter to Secretary Abraham on F-Canyon.

December 19 letter to the Deputy Administrator for Defense Programs regarding the Tritium

Extraction Facility.
D-1

APPENDIX D

ADMINISTRATIVE ACTIVITIES

INFORMATION TECHNOLOGY AND SECURITY

The Board has continued to make improvements to the information technology (IT) resources

provided to its staff. Desktop hardware and software are continually upgraded to ensure that the Board has

the latest tools available. 

Improvements in IT resources have also allowed the Board to provide expanded services to the

public. The Board’s public website has been completely redesigned. The new format makes it easier for the

public and other interested parties to locate documents. An expanded career opportunities section has been

added so that the website can become one of the Board’s primary recruiting tools. The redesigned website

is also compliant with Section 508 of the Rehabilitation Act, making it possible for visually impaired persons

to navigate the site. 

The Board has also placed a heightened emphasis on IT security. Even before the terrorist attacks

of September 11, the Board was evaluating IT security. Based on the results of an in-depth analysis of the

existing IT security program, the Board has initiated numerous upgrades. These include updating the

Board’s existing perimeter defenses; enhancing and centralizing the Board’s anti-virus capability; improving

and integrating the Board’s incident handling capability with those of other federal agencies, such as the

Federal Computer Incident Response Center and the National Infrastructure Protection Center; and

evaluating the use of two-factor authentication devices to provide stronger user authentication. 

STAFF

As of December 31, 2002, the Board employed 95 full-time staff in addition to the three Board

Members. The Board continued its aggressive recruitment program to attract the brightest engineering

students from colleges and universities across the country, as well as experienced engineering professionals. 

This year, technical recruiters visited 10 campuses and 10 career fairs, and the Board continued its

recruitment outreach program through the National Society of Black Engineers and Mexican-American

Engineers and Scientists.

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. During

2000, the Board established such a program, making innovative use of cooperative agreements with other

agencies to resolve disputes economically.
13

 National Defense Authorization Act for Fiscal Year 1991, Conference Report, H.R. Conf. Rep. No. 923, 101st Cong.

2

nd Sess. 767 (1990).

E-1

APPENDIX E

HUMAN RESOURCES

As clearly recognized by the Congress when evaluating the Board, the ability to effectively carry out

an independent technical oversight program throughout the DOE weapons complex depends upon the

technical capability of the Board Members and staff:

The conferees believe that the DNFSB is a unique Federal agency, in that its mission [is] to

oversee the activities of another federal department whose work is highly technical and

potentially dangerous, and that to properly carry out its mission, not only the DNFSB

members but also its limited staff must be technically competent in all major phases of nuclear

safety.13

Simply stated, the Board’s ability to fulfill its safety mission rests heavily on attracting and retaining

top-caliber technical staff. The Board has been successful in creating a work environment that emphasizes

excellence as the standard for staff performance, and rewards its staff accordingly. The pay banding and

pay for performance programs developed and implemented by the Board have proven to be effective in

hiring technical talent, holding employees accountable for their performance, and rewarding outstanding

performance on the job. 

The Board’s success in accomplishing these goals has been recognized by independent audits

conducted by the Office of Personnel Management (OPM) and the Institute of Public Administration. For

example, OPM completed an extensive survey and review of the Board’s human resources management

programs in August 2000 and reported the following:

[The Board’s] employees believe that supervisors communicate job expectations, that

performance appraisals are fair, and that awards are based on performance. High

performance is continually recognized, both monetarily and non-monetarily. Employees

recognize the award-achievement connection. [This] indicates how much the Board differs

from the rest of the Government in terms of performance management. 

The Board’s enabling legislation grants authority for excepted service hiring and classification. Using this

authority, along with recruitment and relocation bonuses, student loan repayments, and retention allowances,

the Board has been successful in competing for scientific and technical staff in a competitive employment

market.

The challenges involved in recruiting and retaining a high-quality, diverse workforce can be grouped

into two categories: (1) competition from the private sector, and (2) fiscal constraints. Competition for top

engineering professionals is intense. Even with the special hiring and pay authorities granted to the Board,

private industry can easily promise higher salaries and benefits. The Board has also found that the federal
E-2

downsizing campaigns of the 1990s, coupled with the perception that the federal bureaucracy stifles

creativity and fails to encourage and reward outstanding work, have damaged its recruiting campaigns. 

Recruitment and retention of recent college engineering graduates, especially women and minorities, is

difficult in the current job market, and will become even more challenging with the renewed activity in the

commercial nuclear industry. 

Despite these problems, 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, 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 a licensed professional

engineer. 

 Seven technical staff members are located at priority DOE sites. There is one site representative at

the Pantex Plant near Amarillo, Texas; two at Hanford near Richland, Washington; two at SRS near Aiken,

South Carolina; and one each at RFETS near Boulder, Colorado, and LANL in New Mexico.

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. Currently, 87

percent of the staff hold advanced degrees, 29 percent of which are at the Ph.D. level. Younger technical

staff members have been recruited through the Board’s professional development program. Entry-level

employees recruited into this 3-year program receive graduate-school education and intensive on-the-job

training guided by experienced technical mentors. Currently, there are 11 entry-level employees in this

program. Three completed their master’s degrees in the summer of 2002 and are in their third-year field

assignment. By the summer of 2003, 3 more of these individuals should be awarded a master’s degree in an

engineering discipline. The Board’s professional development program remains extremely useful in attracting

and retaining high-quality entry-level engineers and preparing them for challenging assignments in their fields.
F-1

APPENDIX F

LIST OF ABBREVIATIONS AND ACRONYMS

Am/Cm Americium/Curium

Board Defense Nuclear Facilities Safety

Board

CSSX Caustic-side Solvent Extraction

CFR Code of Federal Regulations

DOE Department of Energy

DNFSB Defense Nuclear Facilities Safety

Board

DSA Documented Safety Analysis

DWTF Decontamination and Waste Treatment

Facility 

EOC Emergency Operations Center

EPS Emergency Power System

FOIA Freedom of Information Act

FTS Fuel Transfer System

FY Fiscal Year

GPRA Government Performance and Results

Act

Hanford Hanford Reservation

HEUMF Highly Enriched Uranium Materials

Facility 

HLW High-level Waste

INEEL Idaho National Engineering and

Environmental Laboratory

ISM Integrated Safety Management

IT Information Technology

ITP In-Tank Precipitation Facility

LANL Los Alamos National Laboratory

LAW Low Activity waste

LLNL Lawrence Livermore National

Laboratory

MCOs Multi-Canister Overpacks

MOU Memorandum of Understanding

NaF Sodium Fluoride

NCSP Nuclear Criticality Safety Program 

NNSA National Nuclear Security

Administration

NTS Nevada Test Site

OPM Office of Personnel Management

ORNL Oak Ridge National Laboratory

ORP Office of River Protection

ORR Operational Readiness Review

Pantex Pantex Plant

PDCF Pit Disassembly and Conversion Facility 

PDP Professional Development Program 

QA Quality Assurance

RA Readiness Assessment

RFETS Rocky Flats Environmental

Technology Site

RFFO Rocky Flats Field Office

SNFP Spent Nuclear Fuel Project

SNL Sandia National Laboratories

SRS Savannah River Site

SS-21 Seamless Safety for the 21st Century

SSCs Structure, systems and components

TA Technical Area

TEF Tritium Extraction Facility

TRU Transuranic

USQ Unreviewed Safety Question

WIPP Waste Isolation Pilot Plant

WTP Waste Treatment Plant

Y-12 Y-12 National Security Complex

232U Uranium-232

233U Uranium-233

238Pu Plutonium-238