TENTH ANNUAL REPORT

TO CONGRESS

DEFENSE NUCLEAR FACILITIES

SAFETY BOARD

FEBRUARY 2000

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PREFACE

The Atomic Energy Act of 1954 as amended (Section 316) requires the Defense Nuclear

Facilities Safety Board (Board) to submit to the Committees on Armed Services and on

Appropriations of the Senate and to the Speaker of the House of Representatives a written report

each year concerning its activities. In addition to setting forth all recommendations made by the

Board during the preceding year, the Annual Report is required to include an assessment of:

(A) the improvements in the safety of Department of Energy defense nuclear facilities

during the period covered by the report;

(B) the improvements in the safety of Department of Energy defense nuclear facilities

resulting from actions taken by the Board or taken on the basis of the activities of the

Board; and

(C) the outstanding safety problems, if any, of Department of Energy defense nuclear

facilities.
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EXECUTIVE SUMMARY

During this past year, the Defense Nuclear Facilities Safety Board (Board) has seen

significant progress by the Department of Energy (DOE) in upgrading its safety management

program. The cumulative effects of the Board’s initiatives and DOE’s positive responses have

been increasingly evident at defense nuclear facilities.

In keeping with the Government Performance and Results Act (GPRA) and its enabling

statute, the Board has established safety goals as a focus for all safety oversight activities and

strategic planning. The Board’s three strategic areas of concentration are as follows:

! Complex-wide health and safety issues,

! Management and stewardship of the nation’s nuclear stockpile and nuclear weapons

components, and

! Hazardous remnants of weapons production.

DOE’s prime defense mission during 1999 continued to be stewardship of the nation’s

nuclear arsenal. DOE also continued its ongoing work to decontaminate and decommission

nuclear facilities no longer needed. The Board gave priority attention to DOE’s safety

management of these major activities, as well as the need to stabilize hazardous materials

remaining from previous operations. The following sections summarize the Board’s principal

actions in each of these areas during 1999.

COMPLEX-WIDE HEALTH AND SAFETY ISSUES

! Significant progress was made in implementing systems based on the concept of

Integrated Safety Management (ISM). The requisite framework for ISM has been

established and its successful application verified at most major sites in the defense

nuclear complex. Roles and responsibilities have been clarified, guidance has been

updated, and programs to measure effectiveness and establish accountability for the

federal workforce and site contractors are maturing. Most sites have in place at least

the basic elements of an acceptable ISM System. More work remains to be done to

embed the functions and principles of ISM deeply into the planning and execution of

work at all levels of an organization, thereby achieving the goal of enhanced safety for

the public, workers, and the environment. Secretary of Energy Bill Richardson has

tasked the complex with implementation of the ISM concept at all DOE facilities by

September 2000—a commendable goal.

! The key objective of ISM is to improve the safety of operations at defense nuclear

facilities. This is done by linking work planning more closely with safety planning and

by clearly establishing controls necessary to protect the public, workers, and the

environment in performing hazardous tasks. The Board has continued to stress the
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importance of developing Authorization Agreements that define specific safety

controls for high-hazard defense nuclear facilities. More than 100 facilities or major

activities are now operating within the bounds of Authorization Agreements. This

accomplishment by DOE is a notable outcome of the ISM effort and a substantive

measure of the concept’s successful implementation. 

! The Board has focused considerable attention on DOE’s progress in implementing

ISM through an effective program of obtaining feedback from operating experience

and applying that feedback to improve the safety of ongoing and future work at

DOE’s facilities and sites. As a result of the Board’s actions, DOE has clarified its

roles and responsibilities for feedback and improvement, established formal processes

for addressing and tracking safety issues, and improved programs to profit from

lessons learned.

! DOE’s efforts to upgrade safety management in 1999 included enhanced enforcement

of nuclear safety requirements. As part of this effort, DOE revived earlier attempts to

issue some of its safety requirements through rulemaking, hence bringing them under

the enforcement provisions of the Price-Anderson Amendments Act. These same

requirements are now established as contract terms and conditions, and form a

fundamental component of requirements associated with ISM. The Board has

counseled DOE to ensure that the rulemaking complements—not jeopardizes—the

comprehensive ISM upgrade program under way, and that regulatory enforcement of

any new nuclear safety requirements is integrated with contract enforcement programs

recently published in Department of Energy Acquisition Regulations. Integrating the

rule into ISM may be difficult to accomplish. The Board has reviewed the draft rule,

preamble, and associated guides. The Board’s staff has provided DOE with suggested

language in several areas, including nuclear explosive safety and facility deactivation

activities.

! Staff reviews and the Board’s interactions with DOE have resulted in DOE’s

consolidating, integrating, and updating health and safety directives for the protection

of workers and the public. For example, DOE revised or developed 18 directives in

support of the amended rule, 10 CFR Part 835, Occupational Radiation Protection, or

as a result of periodic review and update. The Board reviewed and commented on

these directives. As a result of improvements derived through these reviews and

repeated interaction with DOE, guidance in support of this important safety

management function was clarified and strengthened to provide more effective tools

for the protection of workers.

! In June 1993, the Board issued Recommendation 93-3, Improving DOE Technical

Capability in Defense Nuclear Facilities Programs. In its implementation of this

recommendation, DOE has developed and instituted a standardized technical

qualification program for approximately 1,800 federal employees, identified 251 

senior technical safety management positions, and pursued and been granted an

excepted service hiring authority for an additional 200 positions (in addition to the 200

positions allowed under the DOE Reorganization Act). Although federal staffing 
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of DOE offices has generally been decreasing, some offices have identified critical

staffing needs, conducted nationwide searches, and successfully hired technically

outstanding employees in areas important to safety at defense nuclear facilities. DOE

has made significant strides in improving the technical competence of federal

employees in areas important to safety at defense nuclear facilities, and has taken

notable steps toward institutionalizing the Federal Technical Capability Program. 

Having determined that the objectives of its recommendation had been met, the Board

closed Recommendation 93-3 in November 1999.

! The Board continues to devote attention to certain developments affecting the future

viability of DOE’s programs for prevention of criticality accidents. These

developments follow recent DOE studies that raise security questions as to limiting 

the use of the criticality facility at the Los Alamos National Laboratory. The Board

will maintain the position that no steps in remediation of this situation should weaken

the program of training the criticality engineers needed to prevent criticality accidents

in DOE’s facilities.

! Confinement ventilation systems are important safety features of DOE facilities in

which hazardous materials are handled in dispersible form. High-efficiency particulate

air (HEPA) filters are critical elements of such systems. Because HEPA filters are the

final physical barrier to the release of material to the atmosphere, they serve a vital

function in protecting the public, workers, and the environment. In May 1999, the

Board issued DNFSB/TECH-23, HEPA Filters Used in the Department of Energy’s

Hazardous Facilities, addressing a number of potentially significant weaknesses in the

maintenance and operation of confinement ventilation systems, particularly in the

procurement, application, and use of HEPA filters. In its forwarding letter, the Board

called on DOE to provide a report addressing the weaknesses identified in

DNFSB/TECH-23. DOE provided a partial response on December 6, 1999, and at

year’s end was developing a supplemental report.

! The Board’s oversight and timely intervention in dealing with suspect/counterfeit items

have been pivotal in re-energizing DOE’s quality assurance program, which is vital to

ensuring public health and safety at DOE’s defense nuclear facilities. Additionally, the

Board’s inquiries into issues raised by a concerned individual regarding temporary

storage of low-level radioactive waste led to more effective control of storage

conditions for low-level radioactive wastes.

MANAGEMENT AND STEWARDSHIP OF THE NATION’S NUCLEAR STOCKPILE

AND NUCLEAR WEAPONS COMPONENTS

! During the past year, the Board and its staff conducted numerous assessments of the

safety of specific nuclear explosive activities at the Pantex Plant. These reviews,

which included the W56 dismantlement, the W87 Life Extension Program, and the

W62 disassembly and inspection program, revealed safety-related issues in areas such

as the adequacy of safety analyses and controls, the flowdown of controls into
viii

operating-level procedures, and the readiness of activities to operate safely. The

Board’s involvement has contributed to DOE’s improvement of the safety of these

operations.

! The Board has recently focused attention on DOE’s rapidly diminishing capability at

defense nuclear facilities to safely perform the work necessary to dispose of damaged

nuclear devices should such a contingency arise. In the past, maintenance of the

facilities and personnel necessary to support this mission depended on the availability

of a technical staff skilled in nuclear test operations. However, the infrastructure of

personnel and facilities required to support nuclear testing operations is quickly

disappearing. The Board counseled DOE to plan alternative means of dealing with

such an emergency should it arise. DOE has agreed to address this need and is

increasing its contingency planning efforts.

! In late 1998, the Board issued Recommendation 98-2, Safety Management at the

Pantex Plant, urging DOE to take fundamental actions to improve the safety of all

weapons-related work at the Pantex Plant. Foremost among the Board’s specific

recommendations was that DOE increase the formality of the processes designed to

ensure the safety of activities at Pantex so that resultant safety improvements will be

expedited and accelerated. DOE accepted Recommendation 98-2 and made specific

commitments to improve safety management at Pantex, including accelerated efforts to

establish weapon-specific safety bases for all ongoing activities at the plant. 

! On the basis of evaluations from its staff, the Board concluded that actions to improve

chemical safety at the Oak Ridge Y-12 Plant were not keeping pace with those at

other defense nuclear sites or with the Secretary of Energy’s published expectations. 

After the Board communicated its concern, DOE stepped up actions to complete a

chemical management program at the Y-12 Plant, including a renewed commitment to

characterize chemical inventories for emergency planning purposes and to dispose of

excess chemicals. As part of its continuing pursuit of this issue, the Board participated

in a DOE workshop focused on upgrading chemical safety throughout the defense

nuclear complex.

! The Board continued to assist DOE in addressing potential lightning hazards to

nuclear explosive operations at Pantex. During 1999, DOE’s lightning protection

project team (which was established in response to the Board’s reporting requirement)

completed a comprehensive investigation and report detailing the threat of lightning to

nuclear explosives at Pantex, analyzing potential controls and mitigating measures, and

summarizing the actions DOE considers necessary to protect nuclear explosive

operations at Pantex from lightning threats. During this same period, DOE upgraded

its lightning protection measures at the plant.

! In early 1999, in response to a suggestion from the Board, DOE developed and

published a standard for conducting and documenting hazard analyses for nuclear

explosive operations. This important directive sets forth DOE’s fundamental

expectations in this area, and provides guidance on how to establish and document a
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safety basis ensuring that hazardous activities involving nuclear explosives can be

completed safely.

! Pit inventories are growing at the Pantex Plant. Poor programmatic direction and

management have led to large expenditures with little corresponding improvement in

the storage conditions of the pits. Because of the safety implications of inadequate pit

storage conditions, the Board issued Recommendation 99-1, Safe Storage of

Fissionable Materials Called “Pits,” on August 11, 1999. The Board recommended

that attention and resources be directed at the expeditious repackaging of pits into

acceptable storage containers. In response to Recommendation 99-1, DOE has

drafted an Implementation Plan that partially addresses the Board’s recommendation. 

The Board’s staff is closely monitoring DOE’s development efforts, and expects to

receive an adequate plan and to see the institution of a repackaging program in 2000.

HAZARDOUS REMNANTS OF WEAPONS PRODUCTION

! After numerous interactions with the Board and its staff, DOE issued a revised plan

and schedule for addressing the many health and safety risks, originally identified by

the Board in Recommendation 94-1, posed by the highest-priority legacy materials

stored throughout the DOE nuclear weapons complex. The Board identified

deficiencies in the new plan and found that site-level planning did not support several

significant commitments. Throughout 1999, the Board engaged DOE on these issues

in an attempt to obtain a clear, concise plan for stabilization of these legacy materials. 

Lack of progress led the Board to issue Recommendation 2000-1, Prioritization for

Stabilizing Nuclear Material, which recommends a prioritization scheme based upon

risk considerations. Even though DOE’s revised 1999 plan did not provide a path

forward for stabilization and safe storage of all legacy materials, progress was made in

reducing the risk of a large quantity of material. DOE has been able to complete the

following risk reduction activities:

– At the Rocky Flats Environmental Technology Site (RFETS), DOE has processed

all plutonium-bearing solutions at the site except for a small amount held up in

Building 771; completed stabilization of all high-risk residues; and stabilized more

than 6 metric tons of salt residues, 9 metric tons of ash residues, 8 metric tons of

combustible residues, and 12 metric tons of dry residues.

– At the Hanford Site, DOE has commenced stabilization of plutonium oxide

material and plutonium-bearing solutions; established a reasonable path forward

for the remaining stabilization activities; and made major progress in the

construction of fuel retrieval and stabilization facilities at the K-Basins.

– At the Savannah River Site (SRS), DOE has completed the packaging of all

plutonium metal items into welded stainless steel cans that will serve as the inner

containers to meet DOE-STD-3013. DOE also completed stabilization of

miscellaneous plutonium metal items, dissolution of plutonium sweepings, and 60
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containers of RFETS sand, slag, and crucible residues. In addition, it has dissolved

the last of the low-irradiated Mark 16/22 spent fuel assemblies, and completed the

laboratory testing and preliminary design of a system for vitrification of highly

radioactive americium-curium solutions.

! In spring 1999, the Board’s continuing review of operational data for DOE defense

nuclear facilities revealed a negative trend in control of work and operations at SRS. 

The Board brought this issue to DOE’s attention in a letter dated June 2, 1999, stating

that a broader look at the underlying causes of this trend and a systematic

understanding of those causes would be required to correct weaknesses in

performance. In response, DOE has undertaken corrective actions to reverse this

trend and ensure a sustained, satisfactory level of performance in this area.

! In 1994 the Board issued Recommendation 94-3, Rocky Flats Plutonium Storage, to

help ensure that the large quantity of plutonium at RFETS would be safely stored. 

The Board recommended that DOE take a systematic approach to evaluating the

suitability of Building 371 for the proposed new mission of storing the site’s entire

plutonium inventory, and prepare a program plan for building upgrades and

improvements consistent with that mission. As a result of the Board’s

recommendation, upgrades to the building’s structure, systems, and components, as

well as the safety basis, were completed during 1999. The Board now considers the

safety management provisions for Building 371 adequate for the building’s current

storage mission, and accordingly has closed Recommendation 94-3.

! As a result of the Board’s Recommendation 97-1, Uranium-233 Storage Safety at

Department of Energy Facilities, DOE took action to reduce safety risks and

uncertainties associated with storage of uranium-233 (U-233) at a number of sites. 

For example, U-233 material at Los Alamos National Laboratory was relocated to a

more suitable area; testing of U-233 fuel pellets at Idaho National Engineering and

Environmental Laboratory was completed to establish safe near-term storage; the first

fire hazards analysis for storage of high-risk U-233 in Oak Ridge National

Laboratory’s Building 3019 was conducted; a large portion of construction activities

within Building 3019 required for characterization of high-risk U-233 was completed;

a draft U-233 storage standard was issued; and a multiyear management and technical

plan for the U-233 safe storage program was issued. These actions should help ensure

safe storage of this material.

! The Board and its staff worked closely with DOE to institutionalize the changes

needed to improve DOE’s radioactive waste management program through issuance

of a comprehensive new directive, DOE Order 430.1, Radioactive Waste

Management. Compliance with this directive should improve DOE’s management of

all radioactive waste types. Issuance of this directive represents the culmination of

several years of effort to implement the Board’s Recommendation 94-2, Low-Level

Waste Disposal. This accomplishment, along with progress by DOE in other aspects

of low-level waste management, allowed the Board to close this recommendation in

December 1999.
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! During 1999, the Board evaluated the safety of two new nuclear facilities at SRS—the

Replacement High-Level Waste Evaporator and the K-Area Materials Storage Facility

(KAMS). The Board and its staff thoroughly reviewed the facilities’ design and

construction, safety systems and controls, operating procedures, operator readiness,

and observed DOE’s Operational Readiness Reviews. The Board concluded that both

facilities should be ready to operate safely once pre-start findings have been resolved,

but also noted several matters that will need to be addressed to ensure continued safe

operations (e.g., the need for a sound container surveillance program at KAMS).

! The Board has continued to press DOE to resolve the health and safety issues arising

from storage of high-level waste in tanks at the Hanford Site. In 1999, the Board

worked closely with DOE to develop a sound strategy for narrowing the remaining

safety-related uncertainties in the characterization of these wastes and for mitigating

problems from possible retention of flammable gas. Because of DOE’s progress on

these characterization issues, the Board’s Recommendation 93-5, Hanford Waste

Tanks Characterization Studies, was closed on November 15, 1999.

! Decommissioning activities are being conducted in several buildings at RFETS. The

Board noted that safety controls for the protection of workers did not provide the

desired level of protection and that there was an overreliance on personal protective

equipment (e.g., respirators) instead of engineered controls to eliminate or mitigate

hazards. Furthermore, when engineered controls (e.g., air movers) were used, they

were not adequately analyzed to ensure that they would have the desired result. As a

consequence of the Board’s attention to this issue, enhanced engineered controls are

now being applied more appropriately by DOE contractors in the demolition of

contaminated equipment at the site. 

! During 1999, the Board evaluated radiation protection in decommissioning of areas at

the Miamisburg Environmental Management Project (MEMP) that are suspected of

being contaminated with tritium compounds. As a result of the staff’s visits and

subsequent information exchanges, the MEMP contractor prepared a corrective action

plan. Work is proceeding to resolve these issues before major decommissioning

involving such tritium compounds begins in early 2000. Because similar technical

issues may also apply to other defense nuclear facilities, the Board suggested that

DOE articulate a technical position on the hazards specific to metal tritides to ensure

that appropriate measures are implemented across the defense nuclear facilities

complex. In response, DOE informed field offices of the issue and developed an

approach that is expected to lead to the promulgation of needed formal requirements

and guidance.

! In a review of the deactivation of the Hanford 233-S Facility, the Board’s staff 

identified a substantial underestimation of the amount of dispersible plutonium

contamination. The contractor has initiated changes to the safety basis for the

cleanup. The Board has requested that DOE describe actions to correct the

programmatic deficiencies that led to the improper hazard identification.
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TABLE OF CONTENTS

Section 

Page

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

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

1.2 Board’s Strategic Planning ....................................... 1-5

2. COMPLEX-WIDE HEALTH AND SAFETY ISSUES ...................... 2-1

2.1 Safety Management Upgrade Program .............................. 2-1

2.2 Integrated Safety Management .................................... 2-1

2.3 Review of Department of Energy Directives ....................... . 2-20

2.4 Raising DOE’s Technical Competence .............................. 2-24

3. MANAGEMENT AND STEWARDSHIP OF THE NATION’S STOCKPILE

 AND NUCLEAR WEAPONS COMPONENTS ........................... 3-1

3.1 Stockpile Management of Nuclear Weapons ......................... 3-2

3.2 Stockpile Stewardship of Nuclear Weapons .......................... 3-14

3.3 Defense Programs-wide Topics ................................... 3-20

4. HAZARDOUS REMNANTS OF WEAPONS PRODUCTION ................ 4-1

4.1 Stabilization of Legacy Materials .................................. 4-2

4.2 Stabilization of Spent Nuclear Fuel .............................. . 4-10

4.3 Storage of Hazardous Materials ................................... 4-13

4.4 Waste Management ............................................ 4-14

4.5 Deactivation and Decommissioning ................................ 4-19

5. ADMINISTRATIVE MATTERS ...................................... 5-1

5.1 Human Resources ............................................. 5-1

5.2 Acquisition and Financial Management ............................. 5-3

5.3 Information Technology and Security .............................. 5-3

5.4 Inquiries into Health and Safety ................................... 5-4

5.5 Public Interaction with the Board .................................. 5-5

Appendices

A. BOARD RECOMMENDATION 99-1 .................................... A-1

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

1. INTRODUCTION

CONTENTS OF THIS SECTION

Section Page

1.1 BACKGROUND ................................................................. 1-1

1.1.1 Board Responsibilities ....................................................... 1-1

1.1.2 Powers of the Board ......................................................... 1-2

1.1.3 Avoidance of Interference with DOE Functions .................................... 1-2

1.1.4 Formal Mode of Communication ............................................... 1-3

1.1.5 Nature of the Board’s Work ................................................... 1-3

1.2 BOARD’S STRATEGIC PLANNING ................................................. 1-5

1.2.1 Board’s Planning Goals ...................................................... 1-5

1.2.2 Board’s Strategic Plan ....................................................... 1-6

1.1 BACKGROUND

In the late 1980s, a number of public health and nuclear safety issues at aging defense

nuclear facilities operated by the Department of Energy (DOE) led Congress to create the fivemember Defense Nuclear Facilities Safety Board (Board). The Board began functioning in late

October 1989 with the swearing in of the Board’s charter members. To help ensure adequate

protection of the health and safety of the public and workers, the Board is empowered to oversee

DOE’s programs for managing the safety of its defense nuclear facilities. A major goal of the

Board is to ensure that, in carrying out its mandate for maintaining the nation’s nuclear weapons

stockpile, DOE does so safely.

1.1.1 Board Responsibilities

The Board is responsible for independent oversight of the management by DOE of the

safety of all defense nuclear and related activities. DOE continues to be actively engaged in the

disassembly of numerous nuclear weapons while maintaining the remaining weapons in the

stockpile in a safe and reliable condition, and in the conduct of research to ensure the continued

safety of DOE's stewardship of the stockpile. DOE also pursues safe disposition of fissionable

material removed from dismantled weapons and of hazardous material remaining in facilities that

abruptly ceased production activities more than 9 years ago. As in recent years, many of DOE’s

current activities are associated with characterization, stabilization, and safe storage of special

nuclear materials; facility deactivation; and safe management of radioactive wastes.

The law establishing the Board, 42 U.S.C. § 2286, et seq., requires the Board to review

and evaluate the content and implementation of health and safety standards relating to the 

design, construction, operation, and decommissioning of DOE’s defense nuclear facilities, and to 

make recommendations to the Secretary of Energy that are necessary to ensure adequate 

protection of public health and safety. In making recommendations, the Board must consider the
1-2

technical and economic feasibility of their implementation, while the Secretary must report to the

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

budgetary or stockpile management considerations. If the Board determines that there is an

imminent or severe threat to public health and safety, it must transmit its recommendations to the

President, the Secretaries of Energy and Defense, and the Congress.

1.1.2 Powers of the Board

In the legislative history of the Board’s enabling statute, Congress gave guidance on how

the Board was expected to carry out its functions. Congress chose to provide the Board with

action-forcing rather than regulatory powers. Congress anticipated that in exercising these

powers, the Board would help ensure that DOE safely manages the production, use, and storage

of defense nuclear materials and attendant nuclear waste streams, to ensure protection of worker

and public health and safety. Congress was aware that the safety policies and standards issued by

DOE needed upgrading, and that operations by DOE and its contractors had in the past left

extensive residual contamination in buildings and their environs. Congress also expected the

Board to help raise the technical expertise of DOE’s staff and to assist and monitor the continued

development of DOE’s internal Environment, Safety and Health (ES&H) organization.

Its enabling statute empowers the Board to conduct investigations, issue subpoenas, hold

public hearings, gather information, conduct studies, establish reporting requirements for DOE,

and take other actions in furtherance of its review responsibilities. The law requires DOE to give

the Board its full cooperation.

The Board’s review and advisory responsibilities apply throughout the life cycle of DOE's

defense nuclear facilities, covering design, construction, operation, and decommissioning. The

Board is also required to recommend to the Secretary of Energy any specific measures, such as

changes in the content and implementation of those standards, that it believes should be adopted

to ensure that public health and safety are adequately protected. In addition, the statute mandates

that the Board review the design of new defense nuclear facilities and modifications to older

facilities before the start of construction and recommend any changes found necessary to ensure

adequate protection of the health and safety of the public.

1.1.3 Avoidance of Interference with DOE Functions

The Board recognizes that in performing its essential national defense work, DOE must

not be hampered by unwarranted delay. The Board has been able to keep its safety reviews

synchronized with DOE’s activities by timely assignment of its staff to monitor and review work

involving design, construction, preparations for readiness to operate, operations in facilities, and

decommissioning of facilities. The technical staffs of the Board and of DOE and its contractors

frequently resolve technical issues that arise during these reviews without the need for formal

action-forcing measures by the Board. If the Board identifies safety issues that must be resolved

before work may proceed, it can, and frequently does, formally define those issues and suggest

that they be resolved by DOE. 
1-3

1.1.4 Formal Mode of Communication

The Board communicates the most substantive of its findings to DOE using the formal

recommendation process set forth in the Board’s enabling statute. These recommendations

describe safety matters meriting Secretarial attention and provide guidance on what the Board

considers to be advisable solutions. The Secretary may either accept a recommendation from the

Board or reject a recommendation, requesting that the Board reconsider; to date, however, no

Secretary has found cause to reject a Board recommendation. Following the Secretary’s

acceptance of a recommendation, a mutually acceptable plan of action is established. The Board

monitors the progress of each step in implementation of the mutually agreed-upon plan until the

committed actions have been completed. As of the end of the year, the Board had issued and

DOE had accepted 39 sets of recommendations containing 178 specific recommendations. DOE

has completed most of these recommendations and is making progress in implementing others,

although at times more slowly than agreed upon. During the last year, the Board closed six of its

recommendations (93-3, 93-5, 94-2, 94-3, 94-5, and 95-1), and continued its follow-up of seven

recommendations (92-4, 94-1, 95-2, 96-1, 97-1, 97-2, 98-1, and 98-2). The Board is awaiting the

issuance of DOE Implementation Plans for two recent recommendations (99-1 and 2000-1). The

status of actions on the Board’s recommendations during 1999 is presented in Table 1.

Table 1. Status of Board’s Recommendations

Number Subject Status

92-4 Multi-Function Waste Tank Facility at the Hanford Site In Progress

93-3 Operational Readiness of the HB-Line at the Savannah River Site Closed

93-5 Hanford Waste Tanks Characterization Studies Closed

94-1 Improved Schedule for Remediation in Defense Nuclear Facilities Complex In Progress

94-2 Low-Level Waste Disposal Closed

94-3 Rocky Flats Plutonium Storage Closed

94-5 Integration of DOE Safety Rules, Orders, and Other Requirements Closed

95-1 Improved Safety of Cylinders Containing Depleted Uranium Closed

95-2 Safety Management In Progress

96-1 In-Tank Precipitation System at the Savannah River Site In Progress

97-1 Uranium-233 Storage Safety at Department of Energy Facilities In Progress

97-2 Criticality Safety In Progress

98-1 Integrated Safety Management In Progress

98-2 Safety Management at the Pantex Plant In Progress

99-1 Safe Storage of Fissionable Materials Called “Pits” Implementation Plan

Pending

2000-1 Prioritization for Stabilizing Nuclear Material Implementation Plan

Pending

1.1.5 Nature of the Board’s Work

The Board's primary function is to assist DOE in upgrading its management of safety 

at its defense nuclear facilities. The integration of work planning and safety planning is a
1-4

fundamental objective. The Board remains closely attuned to the content and implementation of

DOE standards for the planning and execution of DOE’s defense nuclear programs, gathering

information from a broad range of sources. These sources include, but are not limited to:

! On-site technical evaluations, reviews, and observations by the Board and its staff.

! Critical review of DOE safety analyses and proposed safety control schemes by the

Board, its staff, and competent technical experts.

! Public meetings at Board Headquarters and in the field.

! Daily input from the Board’s Site Representatives, as well as their weekly summary

reports, which are placed on the public record.

The Board has optimized its resources by assigning Site Representatives to five highpriority defense nuclear sites. In addition, extensive travel by the Board and its technical staff to

defense nuclear facilities remains essential for the Board to accomplish its safety oversight mission

through direct observation of facilities and activities, and through interactions with the public,

workers, and officials at defense nuclear facilities.

To remain better informed about DOE’s activities and initiatives, the Board also receives

regular briefings by senior DOE officials. The Board uses information from these briefings to

synchronize its oversight of DOE’s priority programs, to gauge progress being made on safety,

and to monitor upgrade programs to which DOE has committed.

On the basis of information gained from the above sources, the Board chooses from the

spectrum of action-forcing mechanisms granted to it by law to formally communicate its

observations and advice, and to promote appropriate corrective actions by DOE. These actionforcing mechanisms include the Board’s recommendations to the Secretary of Energy, requests

for reports from DOE, public meetings or hearings, technical exchanges, and issuance of technical

reports, investigations, and testimony to congressional committees. In addition, the Board often

sends DOE reports prepared by its staff, thereby sharing the staff’s observations and findings.

Individual Board Members and the Board’s staff also engage in direct technical dialogue

with DOE and its contractors on specific safety-related matters, and participate in technical

workshops and conferences where information relevant to safety improvement and risk reduction

is exchanged. The Board has directed its senior staff members to meet frequently with their 

DOE counterparts to ensure that the staff is aware of and able to brief the Board on the status of

safety issues and programs and on key safety questions, and that DOE understands the Board’s

safety objectives and initiatives. This type of direct interaction conserves federal resources by

ensuring that DOE and the Board understand each other’s positions in depth. This 

understanding, in turn, permits the Board to focus its recommendations, letters, requests for

information, and public meetings and hearings on the most important health and safety issues to

be addressed. It averts the waste of resources of both DOE and the Board on false starts and

contention over easily resolved side-issues. In many cases, the simple exchange of ideas is
1-5

sufficient to motivate DOE to take appropriate actions without the Board having to make formal

recommendations.

In addition to the broad scope of the Board’s communications with DOE, the Board has

exchanged information with other government agencies (e.g., Nuclear Regulatory Commission,

General Accounting Office, Office of Management and Budget, Department of Defense,

Environmental Protection Agency, and Department of the Navy’s Strategic Systems Program

Office), as well as outside agencies (e.g., National Research Council and National Academy for

Public Administration). Such interactions facilitate the exchange of knowledge, experience, and

factual information on matters involving the safety of DOE’s defense nuclear facilities.

The Board remains committed to this policy of enhanced communication in the belief that

in the end, safety is best served by spending federal dollars on real improvements at defense

nuclear facilities, not on correspondence. Direct communication and discussions with DOE in an

open forum have proven to be powerful, cost-effective tools for advancing the Board’s nuclear

safety initiatives. During 1999, the Board held four public meetings involving substantive

interactions with senior DOE officials.

1.2 BOARD’S STRATEGIC PLANNING

In 1993, the Government Performance and Results Act (GPRA) was enacted. GPRA

requires federal agencies to develop strategic plans that articulate the agency’s mission and goals,

as well as proposed methods for achieving its goals. The first edition of each agency’s 

5-year strategic plan was to be submitted by the end of September 1997. Furthermore, starting

with FY 1999, agencies are required by GPRA to submit annual performance plans to the Office

of Management and Budget that establish target levels of performance for program activities. 

Performance target levels are required to be defined in objective, measurable terms so that

actual achievement can compare against the targets. Agencies are required to report their

performance annually to the President and Congress, comparing program achievements with the

targets specified in their performance plans. Whenever a target has not been met, these

performance reports must explain why and describe actions needed to achieve the unmet goals. 

1.2.1 Board’s Planning Goals

The Board has developed seven general outcome goals that describe the intended results,

effects, or consequences from its oversight activities. Using its action-forcing powers, the Board

seeks to achieve the following goals:

1. The safety of nuclear weapons at DOE defense nuclear facilities will continue to be

assured.

2. Events or practices at hazardous DOE defense nuclear facilities that have adversely

affected or may adversely affect public health and safety will be identified, and, as
1

 Integrated Safety Management is the means by which DOE is institutionalizing the process of

incorporating into the planning and execution of every major defense nuclear activity involving hazardous

activities those controls necessary to ensure that environment, safety, and health objectives are achieved.

1-6

needed, recommendations will be made to the Secretary of Energy identifying

technically and economically feasible measures to address these hazards.

3. A flexible and adaptable DOE standards-based safety management program will be

established that incorporates recognized good nuclear safety practices and allows for

integration of work and safety planning for work that DOE and contractors perform at

DOE’s hazardous defense nuclear facilities.

4. DOE’s technical expertise will be improved to permit DOE to better manage the

hazardous work associated with defense nuclear facilities.

5. Integrated Safety Management programs will be implemented for operations at

defense nuclear facilities, with processes and controls tailored to the hazards 

involved.1

6. New defense nuclear facilities under design or construction will meet appropriate

safety standards.

7. Facilities used in the past for defense nuclear purposes will be safely cleaned up and

deactivated in such a manner as to permit safe eventual disposition.

These outcome goals serve as the primary drivers for all oversight activities the Board 

has planned for FY 1999 and beyond. The Board focuses its actions on those activities and

facilities that have reached a stage of development that is best suited to constructive safety

oversight, and on those operations for which safety improvements offer the greatest potential for

risk reduction. 

1.2.2 Board’s Strategic Plan

In accordance with the requirements of GPRA and the guidance of the Office of

Management and Budget, the Board issued its first strategic plan in September 1997. That plan

set forth the Board’s mission according to its congressional mandate, the nature of the Board’s

work, the Board’s planning assumptions and external factors with a potential impact on planning,

and the oversight principles and general goals under which the Board’s oversight mission is

conducted. In addition, the plan identified the Board’s three strategic areas of concentration for

the period FY 1997–FY 2002: 

! Complex-wide health and safety issues,

! Management and stewardship of the nation’s nuclear stockpile and nuclear weapons

components, and
1-7

! Hazardous remnants of weapons production.

This Annual Report is structured according to the above three strategic areas of concentration.

In planning work in these three strategic areas of concentration, the Board and its staff

have developed a set of seven strategic objectives and sixteen associated action plans that, in the

aggregate, support implementation of the general goals noted above. As required by GPRA, the

Board and its staff further refined their planning for the FY 1999 and FY 2000 budget requests to

produce measurable performance goals that, when executed, will demonstrate progress toward

the Board’s strategic objectives in each area of concentration, and consequently toward its general

goals. The first GPRA required performance reports, addressing each agency’s FY 1999

performance goals, are due to the President and Congress by March 31, 2000. The Board’s

performance report will indicate that the Board met all of its FY 1999 performance goals.

It is anticipated that during each annual performance reporting period, DOE’s mission and

associated schedules for major actions will continue to change and that the Board’s independent

evaluations will require adjustments accordingly. As this occurs, the Board may be required to

redeploy resources within and among the primary areas of concentration addressed in the Board’s

strategic plan. The specific facility or activity that is the focus of a performance plan action may

change; however, the same or an increased level of performance and output should be achieved in

support of the Board’s general outcome goals.

In addition to changes in DOE’s mission and schedule and the emergence of new safety

concerns, other external forces have the potential to influence the Board’s execution of its

strategic plan and annual performance plans. In particular, the Board must retain the flexibility to

respond if there were a major accident or other safety-significant event involving special nuclear

material at a DOE facility. Such an event could necessitate an expeditious reallocation of

resources and a substantive revision to the Board’s performance planning goals, and could impact

the Board’s strategic plan objectives and action plan as well. 
2-1

2. COMPLEX-WIDE HEALTH AND SAFETY ISSUES

CONTENTS OF THIS SECTION

Section Page

2.1 SAFETY MANAGEMENT UPGRADE PROGRAM ...................................... 2-1

2.2 INTEGRATED SAFETY MANAGEMENT ............................................ 2-1

2.2.1 Complex-wide Upgrades to Integrated Safety Management .......................... 2-4

2.2.2 Site/Facility-Specific Upgrades .............................................. 2-11

2.2.3 Cross-Cutting Issues ...................................................... 2-18

2.3 REVIEW OF DEPARTMENT OF ENERGY DIRECTIVES ............................... 2-20

2.3.1 Requirements and Directives ................................................ 2-21

2.3.2 Guidance Directives ....................................................... 2-23

2.4 UPGRADING DOE’s TECHNICAL COMPETENCE .................................... 2-24

2.4.1 Implementation Status ..................................................... 2-24

2.4.2 Upgrading of Criticality Safety Expertise ....................................... 2-25

2.1 SAFETY MANAGEMENT UPGRADE PROGRAM

The Board devoted a substantial portion of its resources during 1999, as in previous years,

to advising and assisting DOE in the upgrade of its internal safety management program. This

activity was focused on:

! Implementing standards-based safety management programs that integrate work

planning and safety planning, and that treat requirements for protection of the public,

workers, and the environment from all hazards, including chemical and nuclear, in a

holistic way.

! Upgrading the safety content of DOE’s substantial body of existing safety management

directives.

! Recruiting and retaining highly qualified technical personnel, and upgrading the

technical competencies of DOE’s workforce.

2.2 INTEGRATED SAFETY MANAGEMENT 

In 1995, the Board issued Recommendation 95-2, Safety Management, to urge DOE to

integrate work planning and safety planning more effectively. The methodology that evolved

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

Management (ISM). The term “integrated” is used to indicate that all aspects of safety and work
2-2

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

management. ISM provides a more effective way for DOE to discharge its responsibilities for

protecting the public, workers, and the environment. To amplify Recommendation 95-2, the

Board issued DNFSB/TECH-16, Integrated Safety Management, which sets forth a more detailed

vision of what can be accomplished through ISM.

As noted, ISM represents an attempt to provide a single safety management program

rather than multiple, unintegrated programs. It is a structured, comprehensive, common-sense

approach to performing work safely. Through ISM, the Board has encouraged DOE to capture

the essence of good practices developed for each of the sectors to be protected—the public,

workers, and the environment—as well as the major types of hazards—nuclear, chemical, and

physical—and to effect these practices as an integrated whole. The Board recognizes that DOE’s

missions involve widely varying degrees of risk and hazard, and that requirements based on a

concept of “one size fits all” will not succeed. Instead, through ISM, DOE can address any type

of hazard encountered in the defense nuclear complex by combining work planning and safety

planning, and establishing in advance the controls necessary for protection of the public, workers,

and the environment.

Secretary of Energy Hazel O’Leary accepted the Board’s Recommendation 95-2, and in

April 1996 provided an Implementation Plan, developed in collaboration with the Board, for

moving forward. Her successor, Secretary Federico Peña, reaffirmed DOE’s commitment to ISM

and issued DOE Policy 450.6, Secretarial Policy Statement: Environment, Safety and Health,

making the implementation of the concept a requirement for all of DOE’s hazardous activities in

the complex, nuclear and otherwise. In 1998, Secretary Bill Richardson reinforced these earlier

initiatives by issuing strong statements in support of DOE’s continuing actions to upgrade its

safety management program. In 1999 Secretary Richardson tasked the DOE complex to

implement ISM at every DOE facility by September 2000.

The basic tenets of ISM are expressed in the Implementation Plan for Recommendation

95-2 and are captured in DOE Policy 450.4, Safety Management System Policy, as five core

safety management functions and seven guiding management principles. These functions and

principles are to be applied universally and systematically in the management of all hazardous

activities, large or small, with control measures tailored to the specific hazards involved. The

formal structure of commitment and activities embodying the site’s or facility’s ISM is called the

Integrated Safety Management System. Figure 1 depicts how the core functions and seven

guiding principles are linked to form an ISM System. 
2-3

Provide

Feedback

and Continuous

Improvement

Authorization

Operations

Line Management

Responsibility for

Safety

Define Scope

of Work

Analyze the

Hazards

Clear Roles and

Responsibilities

Develop

and Implement

 Hazard

Conrols

Perform Work

Within Contols

Hazard Controls

Tailored to Work

Being Performed

Identification of

Safety Standards

and Requirements

Priorities

Balanced

Commensurate with

Competence

Responsibilities

Figure 1. Integrated Safety Management: Core Functions and Guiding Principles

DOE has made substantial progress in upgrading its directives, implementing and

institutionalizing ISM at facilities within the complex, and establishing a growing number of

specific sets of control measures (Authorization Agreements) at major DOE sites. In 1998, the

majority of DOE’s institutional directives and guidance documents for ISM had been developed;

thus the Board was able to shift its focus in 1999 to reviewing the implementation of DOE’s

guidance and the establishment of control measures for the safe conduct of work. The Board has

also been stressing that doing work safely is the foremost objective of ISM. Nuclear safety is an

important but not an exclusive target of ISM. Nonradioactive but hazardous materials and

operations require attention at least in proportion to the risks they pose to the public, workers,

and the environment. As implementation of ISM progresses, the Board will continue to assess

how DOE addresses all hazards associated with its work, how DOE uses contracting mechanisms

to hold the operating contractors accountable for ISM implementation, and how DOE uses

performance measures to evaluate and improve ISM effectiveness.
2-4

2.2.1 Complex-wide Upgrades to Integrated Safety Management

The Board has been following closely DOE’s implementation of ISM. Implementation

was initially focused on 53 facilities and activities involving the most significant nuclear hazards. 

DOE has subsequently expanded ISM to all of its work.

In 1999 Secretary Richardson reaffirmed his commitment to implementing ISM by

adopting a number of safety enhancements. These included stronger accountability through

contracts; timely resolution of safety deficiencies; establishment of a Secretarial Safety Council;

and the expectation that all sites, not just those under the Board’s jurisdiction, will implement

ISM by September 2000.

As DOE has institutionalized and implemented ISM, the Board has provided significant

technical oversight. The Board has held 12 public meetings in which DOE has presented the

status of its implementation of Recommendation 95-2. In addition, the Board and its staff have

conducted numerous reviews of the implementation of ISM Systems at defense nuclear facilities

at every major site. The Board’s staff has been present during every review conducted by DOE to

verify the efficacy and implementation of the ISM Systems at the sites. In addition, the staff has

reviewed and commented on each major ISM document (e.g., Functions, Responsibilities, and

Authorities Manual [FRAM], ISM Guide, and Department of Energy Acquisition Regulations

[DEAR] clauses).

The Board’s oversight has progressed through three phases. In the first phase, the Board

worked with DOE to develop the necessary guidance documents for implementing ISM. These

documents continue to be revised as lessons are learned from ISM implementation. In the 

second phase, the Board has focused on ISM implementation at the sites. The Board is now

shifting its focus to confirming that the implemented ISM Systems are effective, that DOE is

performing its functions and responsibilities as assigned in the FRAM, and that DOE’s 

contractors are held accountable for completing their work within agreed-upon safety 

constraints. 

In 1999, the Board found that sites were beginning to show improvements in safety and

efficiency as DOE’s contractors began to apply ISM to the work at defense nuclear facilities. 

Upper-level management of both DOE and its contractors has remained highly supportive and

proactive. The progress of implementation is more advanced at some sites than at others; the

sites with multiple contractors are experiencing the most problems in achieving site-wide

consistency in the application of ISM concepts. 

Several key indicators for gauging progress in the implementation of ISM have been

identified as a result of the Board's reviews. These indicators are reviewed in the following

subsections. 

Department of Energy Acquisition Regulations Clauses

The first key indicator of progress in ISM implementation is incorporation of the ISMrelated DEAR clauses in contracts. As the Board urged in Recommendation 95-2, DOE
2-5

published two DEAR clauses related to ISM (48 CFR § 970.5204-2, Integration of Environment,

Safety, and Health into Work Planning and Execution, and 48 CFR § 970.5204-78, Laws,

Regulations, and DOE Directives). In April 1999, DOE published an additional DEAR clause

(48 CFR § 970.5204-86, Conditional Payment of Fee, Profit, or Incentives). A key element of

this clause ties payment of contractor fees directly to meeting specific ISM performance

measures. Because the rigor of the performance measures developed by the contracting officer is

critical to the effectiveness of this clause, the Board will closely follow DOE’s development of

guidance for contracting officers and monitor field implementation. The Board views these

clauses as critical to the long-term improvement of ISM programs, and as an important

reinforcement of DOE’s commitment to safety management.

Selection of Contractual Environment, Safety, and Health Requirements

The second indicator is the progress being made by DOE and its contractors in

establishing a requirements base that serves as the foundation for a site-wide ISM program. Once

approved by DOE, the resulting requirements become binding contract terms. During 1999, the

Board ascertained that all contracts included a DOE-approved set of requirements and that each

site had a process for maintaining configuration control of this set. The Board and its staff also

worked with DOE to update DOE's guidance for determining or revising requirement sets to

bring the process more into consonance with ISM principles. 

Integrated Safety Management System Descriptions 

The Board has followed the development of ISM System Description documents required

by the DEAR. These documents describe how the contractor will integrate the tenets of ISM into

work practices. DOE is required to review and approve each contractor’s ISM System

Description. DOE’s approval of the document signifies its acceptance of how the contractor will

manage work using the principles of ISM. The process for reviewing ISM System Descriptions

and a key step in their approval is the Verification Review, which is discussed in the next

subsection. In 1999, DOE approved ISM System Descriptions for Idaho National Engineering

and Environmental Laboratory (INEEL), the Hanford Tank Farms, Sandia National Laboratories

(SNL), Lawrence Livermore National Laboratory (LLNL) Superblock, Los Alamos National

Laboratory (LANL), and Oak Ridge National Laboratory (ORNL). ISM System Descriptions

were approved in 1998 for the Savannah River Site (SRS), the Y-12 Plant, the Waste Isolation

Pilot Plant (WIPP), and the Rocky Flats Environmental Technology Site (RFETS). ISM System

Descriptions for the Pantex Plant, the Nevada Test Site (NTS), and the Hanford Site are pending

DOE approval, which is expected to occur in 2000. 

ISM System Verification Reviews

In Recommendation 95-2, the Board recommended that a formal process be established

for reviewing and approving contractors’ safety management programs. In response to the

Board’s urging, DOE established a protocol for performing ISM System Verification Reviews,

and in February 1998 issued the Integrated Safety Management Systems Verification Process

Team Leader’s Handbook (DOE-Handbook-XXXX-98, February 1998). This initial version of
2-6

the Handbook was revised in 1999 to address the Board’s comments and to reflect additional

lessons learned from the ISM System verification process. 

There are two types of Verification Reviews—Phase I and Phase II. Phase I is a review of

the description of the ISM System developed by the contractor in response to formal direction

provided by the senior DOE manager at the site (Approval Authority) in accordance with the ISM

DEAR clause. The review evaluates the adequacy of the procedures, policies, and manuals of

practice used to implement ISM. The primary goal of the Phase I review is to provide a

recommendation to the Approval Authority as to whether the ISM System documentation is

adequate and should be approved. The purpose of the Phase II review is to evaluate whether the

contractor has implemented the ISM System at the site, facility, or activity. 

During 1999, the Board’s staff continued its previous practice of observing and

constructively critiquing all DOE Verification Reviews conducted at defense nuclear facilities. 

These Verification Reviews, led by senior DOE technical staff and supplemented by outside

subject matter experts, have been highly beneficial to both those performing the work

(contractors) and those providing the technical oversight (DOE management). These benefits

accrue from an enhanced understanding of the work that results from the systematic application of

the functions and principles of ISM. The results of these reviews have shown that, in general, all

sites have considerable site-wide safety management infrastructures in place, but all can benefit

from the capture of good practices for planning and performing hazardous work. Such upgrade

efforts are under way. Since 1997, DOE has conducted 29 Verification Reviews, 19 of which

covered Recommendation 95-2 priority or follow-on facilities; 6 reviews will be conducted in

2000 to complete the priority and follow-on facilities. DOE must complete almost 30 reviews in

2000 to meet Secretary Richardson’s goal of implementing ISM at all facilities in the complex by

September 2000.

In 1999, the Board urged DOE to examine the results of all ISM System Verification

Reviews completed through 1999 for common issues and lessons learned throughout the DOE

complex. A DOE team formed to review the verification reports identified commonalities 

in documented noteworthy practices and opportunities for improvement, and made

recommendations for maintaining continuity of ISM during changes of contractors. The team’s

report was released to the DOE complex in October 1999, and the lessons learned are scheduled

to be incorporated into the next revision of DOE-Handbook-XXXX-98.

In 2000, the Board will continue to perform a key oversight role as DOE implements and

refines its ISM programs. Much work remains to ensure that the intent of Recommendation 95-2

is fulfilled. In a memorandum to the DOE complex dated October 25, 1999, the Deputy

Secretary provided criteria for ISM implementation. These criteria, reviewed extensively by the

Board and its staff, build on the verification process, focus on DOE’s actions and implementation,

and provide the minimum criteria necessary to declare that an ISM System has been implemented. 

A critical component of these criteria is the implementation of Authorization Agreements. The

Board will work with DOE to ensure that Authorization Agreements become contractually

binding agreements to ensure that work is performed safely. The Board will also focus on

ensuring that the federal workforce is held accountable for performing its functions and
2-7

responsibilities as designated in the FRAM, and that DOE’s contractors are held accountable for

completing their work within agreed-upon safety constraints. 

ISM implementation efforts to date have revealed the need to update some of the existing

Safety Analysis Reports to better reflect current missions and report standards. Such reports, or

their equivalents, are the underpinning of an ISM System. Documented in such reports are the

potential dangers that attend the work planned, and the controls and other safety measures

required to perform work safely. Such documents need to be kept current as the work changes. 

While the functions and principles of ISM remain constant as a management concept applicable to

diversified hazardous activities, the safety control measures must be tailored to the specifics of

each hazardous activity. The application of ISM functions and principles requires dynamic,

ongoing analysis as a part of work planning and implementation of safety measures.

DOE has programmed updates of safety analyses for some older facilities and operations,

and requires that safety analyses for new facilities under design be performed to revised standards. 

In 2000, the Board will continue its review of such documents. 

Feedback and Improvement and Recommendation 98-1 

In response to the Board’s March 20, 1998, reporting requirement on DOE’s feedback

and improvement program, DOE committed to upgrading its lessons learned process. Improved

guidance on the subject is included in the latest revision to DOE G 450.4-1A, Integrated Safety

Management Guide, May 27, 1999. The FRAM was also updated to define more clearly the

manager’s role in this key area. The Secretary of Energy’s March 3, 1999 memorandum on safety

accountability and performance tasked the newly established DOE Safety Council with developing

performance standards that will be used to hold federal personnel accountable for effective and

timely ISM implementation. The Board and its staff worked closely with DOE on this activity. 

The Deputy Secretary of Energy’s October 25, 1999, memorandum included criteria that will be

incorporated into senior manager performance plans.

The Board issued Recommendation 98-1, Integrated Safety Management, to address the

internal independent oversight element of the feedback and improvement program, which the

Board believed was not being adequately addressed in DOE’s feedback and improvement

initiatives. The Board had determined that independent assessments by DOE-Headquarters of

safety management in the field were being treated largely as advisories, and that follow-up actions

by DOE’s line management were discretionary. DOE accepted Recommendation 98-1 and

provided an acceptable Implementation Plan that addressed DOE’s need for a clearly defined,

systematic, and comprehensive process to resolve safety issues identified by internal independent

oversight. The Board and its staff worked closely with DOE to develop a process for addressing

these safety issues, including a Web-based system for tracking the status of corrective actions. 

This process was institutionalized in the DOE directives system. In 2000, the Board will monitor

the process to ascertain that it is fully implemented and that DOE’s system for tracking corrective

actions provides meaningful status reports to senior DOE managers.
2-8

Authorization Agreements 

The Board continues to assign great importance to the timely execution of Authorization

Agreements for high-hazard defense nuclear facilities. An Authorization Agreement is a

documented agreement between DOE and a contractor that incorporates a statement of work

authorized to be done and the contractor’s proposed means for conducting the work safely. An

Authorization Agreement includes appropriate limits on safety-related parameters and activities,

and sets forth key terms and conditions under which the contractor is authorized to perform the

work. Some restrictions may be identified as administrative controls, and technical requirements

necessary for safety are specified as commitments, thereby making the use of certain procedures

and practices contractually binding. Authorization Agreements (analogous to the licenses of

commercial nuclear facilities) greatly facilitate the identification, implementation, and maintenance

of safety controls needed to prevent any accidental release of radioactive materials in or from the

workplace, or to mitigate the consequences of an accident should one occur. 

To assist DOE and its contractors in developing Authorization Agreements, the Board

issued DNFSB/TECH-19, Authorization Agreements for Defense Nuclear Facilities and

Activities (April 1998). As a result of this and other actions, more than 100 facilities or major

activities are operating within the bounds of signed Authorization Agreements. This

accomplishment by DOE is a notable outcome of the ISM activity and a substantive measure of

successful ISM implementation. It is particularly noteworthy that to date, Authorization

Agreements for all but two of the defense nuclear facilities that merit such agreements have been

approved. Table 2 provides the current status of Authorization Agreements for these 53 facilities

(10 priority and 43 follow-on).

Table 2. Status of Authorization Agreements for Priority and Follow-on Facilities

Priority Facilities AA in

Place Approval Date/Status

DEFENSE PROGRAMS

Lawrence Livermore National Laboratory

1 Superblock:

Bldg. 332, Plutonium Facility Yes 6/97

Bldg. 334, Weapon Design & Testing Facility Yes 1/28/99

Bldg. 331, Tritium Facility Yes 1/28/99

Los Alamos National Laboratory

2 TA-55, Bldg. 4, Plutonium Facility Yes 1/99

3 TA-3, Bldg. 29, Chemistry and Metallurgy Research (CMR) Facility Yes 1/99

Oak Ridge National Laboratory

4 Y-12 Plant

Bldg. 9212, Wet Chemistry, Casting, Storage Yes 5/15/98

Bldg. 9206, Enriched Uranium Chemical Processing No Expected 2/00

Bldg. 9720-5, Warehouse Operations Yes 4/6/98

Bldg. 9204-2E, Disassembly Operations Yes 4/6/98

Bldg. 9204-4, Quality Evaluation Yes 4/6/98
2-9

Table 2. Status of Authorization Agreements for Priority and Follow-on Facilities

(Continued)

Follow-on Facilities AA in

Place Approval Date/Status

Bldg. 9215, Special Nuclear Materials (SNM) Processing &

Fabrication

Yes 5/15/98

Pantex Plant

5 Zone 12, Nuclear Explosive Bays and Nuclear Explosive Cells No AAs will be approved for

specific weapon activities,

not for the facility. See

follow-on facilities list.

Hanford Site

6 K-Basins Facility Yes 9/24/98

7 Tank Farms Yes 7/24/98

Rocky Flats Environmental Technology Site

8 Bldg. 371, Plutonium Chemical Processing Facility Yes 9/11/97

9 Bldg. 771, Plutonium Recovery Facility Yes 12/31/97

Savannah River Site

10 Canyons

F-Canyon Yes 9/9/97

FB-Line Yes 9/26/97

H-Canyon Yes 8/1/97

HB-Line Yes 3/19/98

Lawrence Livermore National Laboratory

1 Bldg. 231 Complex (Vaults) No Not required for Cat. 3

facilities.

2 Bldg. 251, Heavy Element Facility No Not required for Cat. 3

facilities.

Los Alamos National Laboratory

3 TA-18, Pajarito Laboratory Yes 12/99

4 TA-16, Weapons Engineering Tritium Facility Yes 8/2/99

5 Defense Nuclear Activities at TA-15, Dual Axis Radiographic

Hydrotest Facility

 No No defense nuclear work

planned for this year.

6 Defense Nuclear Activities at TA-53, Los Alamos Nuclear Scattering

Center

No No defense nuclear work

planned for this year.

Nevada Test Site

7 Abel Site, Area 27 (to be replaced by the Device Assembly Facility,

Area 6)

Yes 1/14/99

8 U1a Complex Yes 1/14/99

Oak Ridge National Laboratory

9 Material Storage (Bldg. 3019) Yes 10/99

Pantex Plant

10 Bldg. 12-116, SNM Staging Facility Yes 7/98

11 Bldg. 12-104A, Special Purpose Bays (New - not operational) No No defense nuclear work

planned in FY00.

12 Dynamic Balancer (Bldg. 12-60) Yes 11/97
2-10

Table 2. Status of Authorization Agreements for Priority and Follow-on Facilities

(Continued)

Follow-on Facilities

AA

in

Place

Approval Date/Status

13 Weapons Programs

W56 Yes 2/99

W69 Yes 7/97

W76 No New program. 

Expected 7/00

W78 No New program. 

Expected 12/00

W79 Yes 7/98

14 Paint Bays (Bldg. 12-41) No No plans for AA. 

12-104A will replace.

Sandia National Laboratories

15 Sandia Pulse Reactor Facility Yes 12/14/99

Savannah River Site

16 Tritium Facilities

Tritium Inventory Storage Area (217H) Yes 8/26/97

Tritium Isotope Separation/Purification Facility, Lines I/II (232H) Yes 8/26/97

Tritium Reservoir Finishing/Packing Facility (234H) Yes 8/26/97

Tritium Reservoir Loading/Unloading Facility (233H) Yes 8/26/97

Tritium Burst Test Facility (236H) Yes 8/26/97

Tritium Byproduct Purification Facility (236H) Yes 8/26/97

Tritium Extraction Facility, Line III (232H) Yes 8/26/97

Tritium Reservoir Reclaiming Facility (238H) Yes 8/26/97

Tritium Storage/Spare Parts/Shipping (237H) Yes 8/26/97

ENVIRONMENTAL MANAGEMENT

Hanford Site

17 Waste Encapsulation and Storage Facility Yes 3/25/99

18 Plutonium Finishing Plant Yes 8/12/99

Idaho National Engineering and Environmental Laboratory

19 Underwater Fuel Storage (CPP-603-A) Yes 3/31/99

20 Irradiated Fuel Storage Facility (Dry SNM Storage) (CPP-603-B) Yes 3/31/99

21 New Waste Calcining Facility (CPP-659) Yes 3/31/99

22 Underwater Fuel Storage Facility (CPP-666) Yes 3/31/99

23 Radioactive Waste Management Complex Yes 3/31/99

24 Unirradiated Fuel Storage Facility (CPP-651) Yes 3/31/99

Nevada Test Site

25 Radioactive Waste Management Sites in Area 5, Area 3, and the

TRU Pad

Yes 1/14/99

Oak Ridge National Laboratory

26 K-25 (East Tennessee Technology Park) highly enriched uranium

(HEU) Remediation Deactivation

27 Depleted Uranium Tailings Facility Yes 11/30/98

28 Material Storage (Molten Salt Reactor Experiment) No Expected 12/00
2-11

Table 2. Status of Authorization Agreements for Priority and Follow-on Facilities

(Concluded)

Follow-on Facilities

AA

in

Place

Approval Date/Status

Rocky Flats Environmental Technology Site

29 Bldg. 707, Plutonium Manufacturing Bldg. Yes 8/15/97

30 Bldg. 776, Manufacturing Bldg. Yes 8/25/99

31 Bldg. 559, Analysis Laboratory Yes 3/17/98

32 Bldg. 774, Waste Processing Yes 8/31/99

Savannah River Site

33 FA-Line No No plans to operate.

34 HA-Line Yes Covered in H-Canyon

AA.

35 235-F Yes 12/15/98

36 Defense Waste Processing Facility Yes 10/6/97

37 In-Tank Precipitation/Extended Sludge Processing Yes 7/16/98

38 High Level Waste Storage Tanks Yes 3/9/98

39 Receiving Basin for Offsite Fuel Yes 9/17/97

40 K-Reactor Basin Yes 9/17/97

41 L-Reactor Basin Yes 9/17/97

WIPP

42 Waste Isolation Pilot Plant Yes 4/21/99

NUCLEAR ENERGY

Idaho National Engineering and Environmental Laboratory

43 Advanced Test Reactor Yes 4/9/99

The Board’s reviews revealed that the Authorization Agreements varied in quality and

completeness. The Board therefore urged DOE to conduct its own review of Authorization

Agreements for defense nuclear facilities. Two teams performed independent reviews of all the

approved Authorization Agreements. These reviews confirmed the findings of the Board, and

resulted in more than 15 suggestions for improving Authorization Agreements, including updating

guidance in DOE G 450.4-1A and the roles and responsibilities for Authorization Agreements in

the FRAM. DOE provided the results and lessons learned from these reviews of Authorization

Agreements to the entire DOE complex. 

2.2.2 Site/Facility-Specific Upgrades

As noted, Secretary Richardson has tasked the complex with having ISM Systems in 

place by September 2000. Although the key indicators discussed in the previous section reveal

that DOE is making progress in implementing ISM, there still is a need to review the quality and

effectiveness of the application of ISM functions and principles to specific hazardous work. The

Board and its staff have focused considerable resources on determining whether the requirements

established in each contract are reflected in safety management processes or implementing

procedures used in specific work activities covered by the site’s ISM System. The staff has also

continued to review the adequacy of facilities’ ISM System implementation. In general, the
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Board has observed that many sites are finding that the implementation of ISM at the facility and

individual hazardous-task levels often requires the changing of old habits. Embedding this new

safety culture in the workplace is proving to be more involved and complex than the sites had

expected. However, most sites have in place at least the basic elements of an acceptable ISM

System. More work remains to be done to embed the functions and principles of ISM deeply into

the planning and execution of work at all levels of an organization, thereby achieving the goal of

enhanced safety for the public, workers, and the environment. The following subsections describe

the progress on ISM upgrades at each site.

Y-12 Plant, Tennessee

In 1998, DOE conducted a combined Phase I and Phase II Verification Review of the ISM

System at the Y-12 Plant. While the verification team recommended approval of the Y-12 ISM

System Description, it noted that the ISM System was in the early stages of implementation. 

Therefore, the team concluded that additional focused management attention would be required

to ensure the mature and consistent implementation of the ISM System. During 1999, the

contractor continued to work on implementing a mature ISM System and helped sponsor various

ISM System workshops held across the complex, including a workshop on worker protection that

was conducted in Knoxville, Tennessee, in November 1999. 

In August 1999, without prompting from DOE, the contractor conducted a selfassessment of ISM System implementation—the first of its annual ISM System reviews as

required by the DEAR clause. The assessment team noted strengths in the implementation of an

ISM System in the Special Materials Organization and the H-1 Foundry, but also noted

weaknesses in such areas as performance indicators and maintenance work control processes. In

addition, the team noted that a reduction in force was being implemented site-wide during the

performance of the assessment, and that while its potential impact on ISM work control processes

could not be evaluated by the team, the staff responsible for issues management and lessons

learned programs has been virtually eliminated.

Several mishaps experienced at Y-12 late in 1999 dramatically underscored the need to

enhance work planning/safety planning at the activity level in accordance with the functions and

principles of ISM if the safety of workers is to be ensured. These incidents involved 

(1) inadequate quality control of welds in piping for hydrogen fluoride (a highly hazardous gas),

and (2) a lithium fire and explosion in a casting process involving sodium-potassium as a coolant. 

This Y-12 experience emphasizes the absolute necessity of bringing safety planning and execution

to the workplace if the objectives of ISM are to be achieved. A well-conceived paper description

is simply not enough. The Board will be working with DOE to improve the Y-12 safety

management program.

Pantex Plant, Texas

The Board's staff observed the conduct of ISM System Verification Reviews by DOE at

Pantex initially in September 1998. The DOE team concluded at that time that the processes for

executing safety management functions for the Pantex mission of nuclear explosive operations

required further definition in the ISM System Description and implementing documentation.
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Improvements were needed in the flowdown from safety requirements to plant directives,

standards, and manuals. In addition, the team identified inconsistent execution of ISM functions

for nuclear explosive operations. The DOE verification team recommended that DOE and the

contractor complete their ongoing action to formally define the processes unique to nuclear

explosive operations that would provide an evolved system of safety management, and that the

ISM System Verification Reviews be repeated for the nuclear explosive mission area after an

appropriate implementation period.

In 1999, DOE made progress in clarifying the roles and responsibilities of DOE, the

Pantex contractor, and the nuclear weapons design laboratories with regard to ISM System 

implementation. DOE also made substantial progress in defining a system for conducting the core

functions of ISM at Pantex in a manner that is more consistent with the approach taken at other

DOE defense nuclear facilities. These improvements in ISM System definition were codified in a

supplemental directive issued by DOE’s Albuquerque Operations Office. This progress

notwithstanding, DOE and its contractor have not yet completed site-wide implementation of an

ISM System at the Pantex Plant. The application of ISM functions and principles for two of the

major missions at Pantex—high explosives fabrication and nuclear material storage—was

considered adequate during the initial DOE reviews. Substantial work is still required in the third

mission area—nuclear explosive operations.

Pantex's progress in 1999 with respect to implementing the refined ISM System has been

slow and difficult. The program has been disappointing, in view of the Board’s additional

emphasis on implementation of ISM. In its Recommendation 98-2, Safety Management at the

Pantex Plant, the Board urged DOE to take fundamental actions to improve the safety of all

weapons-related work at the Pantex Plant. Foremost among the Board’s specific

recommendations was that DOE increase the formality of the processes designed to ensure the

safety of activities at Pantex so that resultant safety improvements will be expedited and

accelerated. DOE accepted Recommendation 98-2 and made specific commitments to improve

safety management at Pantex, including accelerated efforts to establish weapon-specific safety

bases for all ongoing activities at the plant.

Implementation of the requirements of the new process has not been observed during

nuclear explosive activities. Pantex has continued to rely on less efficient and less integrated

programs to start up each new activity. This approach requires extensive oversight and reviews

to ensure that adequate controls are developed and implemented for safe operations. In addition,

the progress that has been made has occurred at a disappointingly slow pace. As a result of this

slow progress in executing core ISM functions for nuclear explosive activities, the follow-on

Phase I and Phase II ISM System Verification Reviews for the nuclear weapons mission area at

Pantex have slipped to late FY 2000. 

Los Alamos National Laboratory, New Mexico

The current contract between DOE and the University of California for managing LANL

became effective October 1, 1997. LANL and the University identified an initial set of safety

standards and requirements to which the University and DOE agreed contractually. The Work

Smart Standards process has been defined to keep the set current. For example, requirements
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from DOE Order 440.1A on suspect and counterfeit items have now been incorporated into the

contract.

The Board has been encouraged by LANL’s demonstrated commitment to ISM and the

soundness of its approach to ISM implementation. DOE performed a combined Phase I and II

Verification Review of the laboratory’s site-wide ISM System during October 12–22, 1999. 

Preliminary results indicate that the LANL system requires further development. The verification

teams recommended that the ISM System Description be approved while noting some comments. 

However, the teams identified the need to address (1) requirements and expectations for

identifying, analyzing, and categorizing hazards at the facility level;

 (2) procedures to describe the expectations for authorization bases for nuclear and non-nuclear

facilities; and (3) improvements in feedback and improvement programs to ensure continuous

improvement of the ISM System. Reverification or outside review will be necessary after

corrective actions have been completed.

DOE’s Los Alamos Area Office (LAAO) was not found ready for its administration of

ISM. The teams identified the need for processes and procedures to effectively carry out ISM

responsibilities in accordance with the FRAMs of both DOE and the DOE Albuquerque

Operations Office. LAAO will require reverification or outside review after completion of

corrective action. Finally, a commitment was made by DOE’s Albuquerque Operations Office to

conduct an ISM System review of its interfaces with its area offices and the work conducted by

their respective contractors. This review is tentatively planned for June 2000.

Lawrence Livermore National Laboratory, California

LLNL has long had a safety management program based upon safety requirements

specified by rules and contract terms. The laboratory’s health and safety manual and its

environmental compliance manual reflect these requirements. Early in the Board’s oversight of

LLNL’s weapons-related activities, the Board and its staff noted that there was no formal

requirement to use these manuals for planning and performing work, nor was there a clear

correlation between the work practices and procedures and the safety requirements specified by

contract. Early attempts by LLNL to address what appeared to be significant shortcomings

revealed the need to better select for specification by contract those generally applicable DOE

requirements most suitable for laboratory-type activities and the research environment. The

laboratory was challenged by the Board to do so. As LLNL undertook this challenge, the Board

and DOE developed the concept of ISM, which can be universally applied to integrated work

planning and safety planning and tailored to any potentially hazardous activity.

While continuing to operate nuclear facilities under its current contractual safety

requirements, LLNL has been making the transition from the existing management programs to

the ISM framework, tailoring these programs to best fit the laboratory environment. During the

past year, this development was focused on the resumption of nuclear operations in the

Superblock facilities after a systematic reassessment of all hazardous activities had been

conducted, and the adequacy of safety measures had been assessed. Improved practices for

planning, authorizing, and controlling work safely were developed. The Plutonium Facility has

implemented these practices, while the Tritium Facility and Hardened Engineering Test Building
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are beginning to do so. More systematic improvements in areas such as Authorization Basis

development and conduct of Unreviewed Safety Question determinations continue as part of the

laboratory-wide improvement effort.

The ISM System Verification Review for the Superblock was completed in September

1999. Although several areas for improvement were identified, the Superblock ISM System

Description was acceptable, and implementation of ISM was evident. Additionally, DOE’s

Livermore Site Office developed an organization and system for the performance of safety

oversight at LLNL. 

Sandia National Laboratories, New Mexico 

The Board's staff continued to assess improvements in safety management at SNL,

including the Sandia Pulsed Reactor Facility. In October and November 1998, the Board's staff

observed DOE's combined Phase I and Phase II ISM System Verification Review for the SNL

site. DOE found that the ISM System Description for the site had not been fully developed. SNL

and the DOE-Kirtland Area Office developed a corrective action plan to remedy deficiencies

found during the ISM System Verification Review, and appear to be making satisfactory progress

on that plan.

Savannah River Site, South Carolina

Westinghouse Savannah River Company (WSRC) largely completed implementation of its

ISM System in 1998. Authorization Agreements for the priority and follow-on defense nuclear

facilities at SRS are now in place. The WSRC Facility Evaluation Board has demonstrated its

capability to perform an adequate continuing review of ISM principles. WSRC and DOE’s

Savannah River Operations Office (DOE-SR) deserve considerable credit for their success in this

endeavor. In March 1999, the Board's staff observed an ISM System Verification Review of the

site security contractor; no significant deficiencies were noted.

ISM System Verification Reviews for most SRS facilities have been completed, and

Authorization Agreements with DOE-SR have been signed. In site reviews by the Board's staff

and a summer 1999 review by ES&H, some areas for improvement in safety management were

identified. The needed improvements fall into three main categories: (1) safe performance of

work at the activity/task level, (2) identification and analysis of hazards, and (3) identification and

implementation of controls to address those hazards. Specific weaknesses were noted in prejob

planning; excessive use of administrative controls rather than those based on proper use of

equipment; and integrated hazard analyses that address all hazards, including chemical and

radiological hazards.

Rocky Flats Environmental Technology Site, Colorado 

ISM at RFETS is implemented as a site-wide process, with the primary focus being on

individual work activities. In 1999, the Board’s staff assessed preparations for and conduct of

several decommissioning activities at the site. These assessments revealed that RFETS’s

approach to planning and controlling work is improving. However, deficiencies in 
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implementation of the core functions of ISM were identified in some of the individual work

activities assessed. Guidance for control of work and for the development of safety controls and

work procedures has recently been consolidated in a single work control document. RFETS

continues to improve this guidance. While this should ultimately improve work control at the site,

some of the cognizant personnel do not fully understand their roles and responsibilities for

implementation of the process in the field. The Board has encouraged the site to provide training

to better implement the work control process and to clarify the responsibilities of the appropriate

personnel. While individual work planning efforts could be improved, the Board believes overall

implementation of ISM at RFETS has generally been satisfactory. Many of the attributes of

RFETS’s work control program are appropriate for implementation at other sites performing

similar work. The Board has encouraged DOE to promulgate the lessons learned at RFETS to

the rest of the defense nuclear facilities complex.

Hanford Site, Washington 

Because of a recent decision to reorganize the Project Hanford Management Contractor,

Fluor Hanford (formerly Fluor Daniel Hanford), from a management and integration organization

to a new project-focused organization, the final verification and approval of the Fluor Hanford

ISM System Description has been delayed. In October 1999, DOE conducted a Phase I

Verification Review of Fluor Hanford, generating a specific recommendation that approval of the

ISM System Description be deferred until further restructuring has been completed. Further, the

new ISM System Description is to be made consistent with the new organization, and Fluor

Hanford is to continue to update its policies, procedures, and manuals of practice to conform to

its new organization and project focus. During the past year, the Board observed the Verification

Reviews undertaken to validate the status of ISM System implementation for the Tank Farms

(Phase II) and Spent Nuclear Fuel Project (SNFP) (Phases I and II). Both of these reviews

showed an acceptable application of ISM. DOE has scheduled additional Verification Reviews

for the remaining activities at the Hanford Site to support complete ISM System implementation

by September 2000. 

The Board has continued to review the status of ISM implementation in work control

systems within the Tank Waste Remediation System (TWRS), SNFP, and the decommissioning of

nuclear facilities by Bechtel Hanford Incorporated (BHI). The Board has prompted DOE to make

improvements in hazard analysis and development of controls, particularly within BHI. 

Waste Isolation Pilot Plant, New Mexico

The Board and its staff closely followed events leading to the opening of WIPP in March

1999. In 1998, the Board’s staff had observed the ISM System Verification Review for WIPP. 

The results of these reviews indicate that ISM System implementation at WIPP is adequate. 

DOE’s Carlsbad Area Office issued an Authorization Agreement on April 21, 1999. However,

that agreement covered only the receipt of nonmixed (i.e., non-chemically-hazardous) 

transuranic waste at WIPP. Following issuance of the Resource Conservation and Recovery Act

(RCRA) permit by the New Mexico Environment Department in October 1999, DOE initiated

litigation over disputed provisions in the permit. Once the disputed provisions have been
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resolved, the Authorization Agreement may need to be revised to address the RCRA permit

requirements.

Idaho National Engineering and Environmental Laboratory, Idaho

The Board has been actively involved in INEEL’s development of an ISM System. 

INEEL has made substantial progress in this regard. The site has placed great emphasis on the

importance of worker involvement in the success of ISM. The DOE Idaho Operations Office

incorporated worker involvement as an eighth guiding principle for ISM, confirming its

commitment to the workers. A second key to their progress was the establishment of an ISM

project office to coordinate all of the activities for ISM System development and implementation. 

The ISM project office’s use of project management tools for this task was a noteworthy practice. 

In April 1999, INEEL successfully completed a Phase I ISM System Verification Review, and the

site manager approved the ISM System Description. Lockheed Martin Idaho Technologies

Company was the management and operating (M&O) contractor during the Phase I Verification

Review. 

Because of the variety and complexity of operations at INEEL, five representative

facilities were selected to demonstrate the implementation of an ISM System during the Phase II

Verification Review held in September 1999: the Advanced Test Reactor, the Radioactive Waste

Management Complex, the Waste Experimental Reduction Facility, the Transportation Complex,

and the Idaho Research Center. ISM System implementation was successfully demonstrated at

four of the five facilities, the exception being the Radioactive Waste Management Complex, which

failed in one area—execution of written procedures—that was subsequently corrected and will be

verified in March 2000. That facility has the challenge of shipping 3,100 cubic meters of

transuranic waste to WIPP during the next 3 years. It was observed consistently during the

review that managers and workers were appropriately involved; teamwork was pervasive; and

prioritization, scheduling, and allocation of resources were being accomplished effectively to

manage the work. 

A major challenge that faced INEEL in 1999 was the transition to a new M&O contractor,

Bechtel BWXT Idaho, LLC, which became effective October 1, 1999. Key to this transition was

the commitment by the new contractor to use the existing ISM System Description. An ISM

System must be effectively implemented at the Idaho Nuclear Technology Engineering Center

(INTEC), formerly the Idaho Chemical Processing Plant, by March 2000. INTEC presents the

greatest technical and managerial challenge to DOE at INEEL because of the need to process 1.4

million gallons of radioactive liquid waste remaining from the reprocessing of spent nuclear fuel,

store spent fuel (currently in wet pool storage) until it can be shipped to a national repository,

stabilize high-level waste calcine and ship it to a national repository, and clean up many buildings

associated with fuel and waste processing. The Board will closely follow ISM System

implementation at INTEC. The remainder of the INEEL site is to have an ISM System in place

by September 2000, consistent with the Secretary of Energy’s commitment.
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Oak Ridge National Laboratory, Tennessee

The ORNL ISM System Description consists of a corporate-level description, manuals of

practice, and 35 division- or facility-specific ISM System program plans. The Board and its staff

have focused on ISM System implementation for two of these activities—the deactivation and

cleanup of the Molten Salt Reactor Experiment and U-233 storage operations in Building 3019. 

In April 1999, DOE conducted a Phase I ISM System Verification Review, emphasizing Building

3019 operations. The verification team recommended that the DOE Approval Authority give

final approval to the ISM System Description and implementing documents, with a few

modifications to the corporate-level program description. The Board was encouraged by the

commitment of ORNL’s upper management to ISM. This commitment was further demonstrated

in October 1999 when DOE formally implemented an Authorization Agreement for operations in

Building 3019. However, the Board’s staff and other DOE review teams have noted the need for

improvement in the ORNL contractor’s conduct of operations, which is inhibiting the pace of

ISM System implementation. Improving ISM System implementation and conduct of operations

is critical at Building 3019 if ORNL is to implement the U-233 inspection program successfully. 

The Board and its staff will continue to focus attention on this area in 2000.

Nevada Test Site, Nevada

DOE faces a unique challenge in tailoring a safety management program based on the

functions and principles of ISM for operations at NTS because these operations are conducted

and managed by national laboratory personnel who are not under contract to DOE’s Nevada

Operations Office (DOE-NV). This situation makes it difficult for DOE-NV to enter into

contractually binding agreements with the laboratories regarding safety expectations. Partly as a

result of the complex nature of NTS’s operations, DOE has not made substantial progress during

the past year in finalizing a site-wide approach to ISM. Concerned that NTS would be unable to

meet the Secretary of Energy’s commitment to fully implement ISM by the end of FY 2000, the

Board sent DOE a letter dated October 5, 1999, asking that heightened urgency be communicated

to DOE-NV and the national laboratories to ensure that ISM is implemented in a timely manner.

This situation is mitigated by the fact that the hazardous activities currently conducted by

the laboratories at NTS are discrete and relatively infrequent, facilitating their control through an

activity-specific ISM approach. A review of this approach by the Board and its staff during

assessments of the Device Assembly Facility (DAF) and individual subcritical experiment

operations revealed that these operations have been conducted in accordance with DOE-NV

Orders that reflect the functions and principles of ISM.

2.2.3 Cross-Cutting Issues

A number of additional initiatives by the Board have further encouraged DOE to focus

consistently on implementing and institutionalizing ISM in all phases of the life cycle: design and

construction, startup, operation, and decommissioning. Examples of these initiatives are

described in the following subsections.
2

 The Board issued a technical report, Quality Assurance for Safety-Related Software at Department of

Energy Defense Nuclear Facilities, DNFSB/TECH-25, on January 20, 2000. The Board’s forwarding letter called

on DOE to provide a report within 60 days addressing the identified deficiencies and setting forth a plan and

schedule for corrective action.

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Software Quality Assurance

The Board places strong emphasis on establishing and maintaining the validity and proper

application of analytical tools that are used to determine the possible effects of hazards to health

and safety, and the effectiveness of features of the facility that could mitigate any harmful

consequences. Software quality assurance (SQA) is a process for the systematic development,

testing, documentation, maintenance, and execution of software. During 1999, the Board

reviewed the status of SQA for safety-related software used by DOE, including that used to

develop information for decisions on safety-related design and software programs used to control

safety-related systems. Significant SQA deficiencies were identified in both types of software. 

According to recently released studies, fewer than 4 percent of computer codes relied

upon for the safety bases of DOE’s facilities meet current industry standards for SQA. This

situation is of significant concern because the use of software of poor pedigree has the potential to

severely degrade the safety bases. Furthermore, numerous problems regarding the correct

execution of safety analysis codes have been identified, indicating a lack of adequate guidance and

training in this area.

The Board has also determined that nominal SQA requirements for instrumentation and

control (I&C) software, where they exist, often do not flow down to the level of implementation

for specific control systems. Although most software-controlled systems have hard-wired safety

systems, the associated I&C software continues to play a defense-in-depth role. Therefore, SQA

deficiencies in I&C software degrade I&C integrity and decrease the overall safety margin for

these systems. 

The Software Quality Assurance Working Group within DOE has been cognizant of some

of these issues since February 1999, and DOE has been aware of potential SQA problems ever

since the beginning of reliance on computers for storage, processing, and use of data. Specific

problems in certain safety areas have been recognized for at least a decade. However, little

progress has been made in addressing these problems because no senior DOE leader has actively

accepted responsibility for the SQA function. 

The Board believes these problems are symptomatic of underlying deficiencies in the

infrastructure supporting SQA at DOE, and that the lack of a sound SQA infrastructure can be

inimical to safety at DOE-owned defense nuclear facilities. The Board intends to follow DOE’s

resolution of this issue.2

Welding Quality Assurance

A viable quality assurance program is key to preserving the desired conservatism in 

robust safety system design during fabrication and installation of systems, design, and
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construction. The Board has observed several incidents that indicate a breakdown in weld quality

assurance within DOE. In some cases, components and piping that had passed all required

inspections were about to be put into service when, purely by chance, defective welds were

discovered. Although in these specific cases the welds were repaired or evaluated for the

intended service and accepted with the defects, these incidents raise a larger concern. The clear

breakdown in weld quality assurance could have allowed components with defective welds to be

placed into service in systems where weld failure could injure workers, adversely affect public

health and safety, or result in contamination of the environment. The Board requested that DOE

review these incidents and develop a corrective action plan for preventing their recurrence.

Confinement Ventilation Systems

Confinement ventilation systems are important safety features of DOE facilities in which

hazardous materials are handled in dispersible form. High-efficiency particulate air (HEPA) filters

are critical elements of these confinement systems. They are the final physical barrier to the

release of material to the atmosphere and thereby serve to protect the public, workers, and the

environment. For many years, an informal but highly effective nationwide infrastructure

supported production of and quality assurance for HEPA filters for safety-related service in a

variety of hazardous operations, including those conducted in DOE facilities. Today there is

convincing evidence that this infrastructure is failing.

In May 1999, the Board published DNFSB/TECH-23, HEPA Filters Used in the

Department of Energy’s Hazardous Facilities. The report chronicled a number of potentially

significant weaknesses in the maintenance and operation of these systems, particularly in the

procurement, application, and use of HEPA filters. These weaknesses support the conclusion that

confinement ventilation systems at some DOE facilities may be vulnerable to failure when they are

most needed. In its forwarding letter, the Board called on DOE to provide a report addressing

the weaknesses identified in DNFSB/TECH-23. DOE provided a partial response on December

6, 1999, and at year’s end was developing a supplemental report.

2.3 REVIEW OF DEPARTMENT OF ENERGY DIRECTIVES

In its enabling statute, Congress directed the Board to review and evaluate the content and

implementation of standards related to the design, construction, operation, and decommissioning

of DOE’s defense nuclear facilities, and to recommend to the Secretary of Energy those specific

measures that should be adopted to ensure that public health and safety are adequately protected. 

The following subsections present examples of the Board’s actions in helping DOE develop

appropriate and operationally meaningful safety standards, and in ensuring the incorporation of

these standards into clear and consistent requirements for DOE management and contractors. 
2-21

2.3.1 Requirements and Directives

Regulations

Nuclear Safety Rulemaking. DOE has proposed to promulgate through rulemaking

some of its nuclear safety requirements now included in Orders and in contract terms and

conditions, thus bringing them under enforcement provisions of the Price-Anderson Amendments

Act. DOE published the proposed rules in 1991 and 1995, and renewed the effort in 1999. 

Because of the protracted period required for the development of new drafts and the changes

made to earlier versions, DOE is considering issuing the rules as interim final rules to provide

further opportunity for public comment. The Board will review and comment on any new nuclear

safety regulations. To date, the Board has counseled DOE to ensure that the rulemaking does not

impede the ongoing ISM upgrade program, and to integrate regulatory enforcement of the new

nuclear safety requirements with contract enforcement programs recently published in the DEAR.

Directives Associated with Revision of 10 CFR Part 835. In November 1998, DOE

published an amendment to 10 CFR Part 835, Occupational Radiation Protection. DOE revised

or developed the following directives in support of the amended rule or as a result of periodic

review and update:

! DOE Guide 441.1-1, Radiation Protection Programs

! DOE Guide 441.1-2, ALARA Program

! DOE Guide 441.1-3, Internal Dosimetry Program

! DOE Guide 441.1-4, External Dosimetry Program

! DOE Guide 441.1-5, Radiation Generating Devices

! DOE Guide 441.1-6, Evaluation and Control of Radiation Dose to Embryo/Fetus

! DOE Guide 441.1-7, Instrument Calibration for Portable Survey Instruments

! DOE Guide 441.1-8, Air Monitoring

! DOE Guide 441.1-9, Radioactive Contamination Control and Measurement

! DOE Guide 441.1-10, Posting and Labeling

! DOE Guide 441.1-11, Occupational Radiation Protection Record Keeping and

Reporting

! DOE Guide 441.1-12, Radiation Safety Training
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! DOE Guide 441.1-13, Sealed Radioactive Source Accountability and Control

! DOE Handbook 1131-98, General Employee Radiological Training

! DOE Handbook 1130-98, Radiological Worker Training

! DOE Handbook 1122-99, Radiological Control Technician Training

! DOE Standard 1111-98, DOE Laboratory Accreditation Program Administration

! DOE Standard 1098-99, Radiological Control Standard

The Board’s staff reviewed and commented on draft implementation guides and selected

technical standards, handbooks, and training materials. Implementation guides and selected

handbooks and standards were completed in FY 1999. As a result of improvements generated

through review and in part because of repeated interaction by the Board’s staff with DOE,

guidance in support of this important safety management function was clarified and strengthened

to provide more effective tools for the protection of workers.

DOE Safety Orders

Deactivation and Decommissioning Directives Associated with the Life Cycle Asset

Management Order. DOE Order 430.1A, Life Cycle Asset Management, was issued in 

October 1998. In January 1999, the Board’s staff initiated its review of three guides

(DOE G 430.1-2, Surveillance and Maintenance During Facility Disposition; DOE G 430.1-3,

Deactivation Implementation Guide; and DOE G 430.1-4, Decommissioning Implementation

Guide) associated with newly developed requirements of DOE 430.1A for disposition of facilities. 

Throughout most of 1999, the Board’s staff provided comments on the initial drafts and

subsequent revisions of these guides, and frequently met with DOE’s staff. The three guides were

issued in September 1999, incorporating improvements resulting from the participation of the

Board’s staff. These improvements in health and safety guidance included an adequate

description of the process for developing decommissioning end-points, specific reference to

acceptable methods for developing deactivation end-points, and improvements in the rigor of

surveillance and maintenance.

In October 1999, DOE provided draft DOE G 430.1-5, Transition Implementation Guide,

to the Board for review. The Board’s staff reviewed this draft, met with DOE staff, and provided

preliminary comments. Review and comments are expected to continue into 2000 as this draft

document is revised by DOE to incorporate changes such as those responding to comments from

the Board’s staff and from DOE’s internal reviewers.

Manuals

DOE Manual 411.1-1A, Safety Functions, Responsibilities and Authorities. The 

Level 1 FRAM was revised during 1999 to address the Board’s comments, including the need for

subtier documents (Headquarters and field offices) to incorporate the health and safety
2-23

responsibilities of DOE personnel in applicable DOE Orders. In addition, DOE’s organizational

changes and additional responsibilities developed in response to the Board’s Recommendation 98-

1 were incorporated. Comments furnished by the Board’s staff were also addressed by DOE, and

the FRAM was issued in October 1999.

Other Directives

Directives Associated with Recommendation 98-1. To institutionalize the process for

addressing safety issues identified by DOE’s Office of Oversight, DOE revised the Quality

Assurance Order and the FRAM. This guidance articulates the process for developing and

approving corrective action plans and the roles and responsibilities of the federal managers

responsible for these actions. The Board’s staff provided comments on earlier drafts and believes

that the guidance adequately addresses the intent of the deliverable in Recommendation 98-1. 

The handbook, intended to be used by field personnel in verifying compliance with ISM, was

accepted by the Board in August 1999.

2.3.2 Guidance Directives

Guides

Safety Management Guide. During 1997, DOE issued DOE Guide 450.4-1, Integrated

Safety Management Guide, which was developed largely as a result of DOE's initial experience in

implementing ISM at priority facilities. The guide was developed to assist DOE contractors in

describing and implementing ISM. It also provided guidance to DOE line managers tasked with

oversight of contractors’ ISM programs. Updating the guide is a continuing process that benefits

from the additional experience gained from implementation of ISM across the DOE complex. 

The guide was revised in 1999 to incorporate lessons learned from implementing ISM, new DOE

organizational changes, and changes made to feedback and improvement programs in response to

the Board’s oversight in this area. The Board has continued to work with DOE in the updating

effort by reviewing the revisions to ensure that the document continues to be effective and

comprehensive. 

Handbooks

During 1999, members of the Board’s staff met with counterparts at DOE to review drafts

of the Work Smart Standards handbook for site contracts that include topics DOE committed to

addressing in the Board’s June 24, 1998, public meeting. These topics included the following:

! Legislation, statutes, rules, and regulations pertinent to implementation of the

Necessary and Sufficient process and ISM,

! DOE policies and directives,

! Background and source of the Necessary and Sufficient Closure process in ISM,
2-24

! Expectations and explanations for the implementation of the Necessary and Sufficient

Closure process,

! Documentation of experience with the Necessary and Sufficient Closure process,

including feedback and lessons learned in question-and-answer format, and

! Sources of assistance.

DOE Technical Standards

Appendix A of DOE-STD-3009-94 and the Implementation Guide for DOE Order

420.1. Individuals from DOE and the Board’s staff interacted throughout 1999 on the

appropriate use of dose evaluation guidelines for the classification of safety-related structures,

systems, and components, as presented in draft DOE Guide 420.1-X, Implementation Guide for

Non-Reactor Nuclear Safety Design Criteria and Explosives. At the urging of the Board’s staff,

DOE revised the guide and proposed a new appendix to DOE-STD-3009-94, Preparation Guide

for U.S. Department of Energy Non-Reactor Nuclear Facility Safety Analysis Reports, to ensure

that the evaluation guidelines would not be considered as acceptance criteria by the field, that

expected doses from postulated accidents would be much lower than the evaluation guidelines,

and that this guidance would be used properly by the field. In a letter to DOE dated July 8, 1999,

the Board accepted this approach and provided additional comments relating to the classification

of items as safety-significant to protect facility workers. Dialogue between the staffs of the Board

and DOE resulted in a consensus on the wording of the changes to these documents to resolve the

Board’s comments; however, DOE STD-3009-94 needs to be revised further to meet the full

intent of the Board’s letter. 

Other Directives and Related Documents 

In addition to reviewing the directives and related documents discussed elsewhere in this

section, the Board’s staff provided comments on 18 other DOE Orders, guides, handbooks, and

manuals during 1999. These efforts resulted in improvements to the provisions related to ISM.

2.4 UPGRADING DOE’s TECHNICAL COMPETENCE

2.4.1 Implementation Status

The Board’s efforts during the past 6 years have assisted in achieving demonstrable

improvements in DOE’s technical competence in a number of areas. As part of its revised

Implementation Plan for the Board’s Recommendation 93-3, Improving DOE Technical

Capability in Defense Nuclear Facilities Programs, DOE formed a panel of senior line managers

to ensure successful implementation of a corporate program to recruit, develop, deploy, and retain

technically capable personnel at defense nuclear facilities. The panel members performed selfassessments of the technical qualification programs at their respective sites, and upgraded their

plans and procedures accordingly. In November 1999, the Board determined that the major

purposes of Recommendation 93-3 had been met, and the recommendation was formally closed. 
2-25

However, continued vigilance and strong technical leadership at all levels of DOE management

will be required to maintain the necessary technical competence for safe and effective operation of

DOE’s defense nuclear facilities.

Throughout the last 6 years, as a result of intensive Board interactions aimed at having

DOE upgrade its technical staff, DOE has: 

! Obtained authority for 200 excepted service positions under the Defense Authorization

Act, in addition to the 200 positions allowed under the DOE Organization Act through

the end of FY 2000. This authority is being used to fill key engineering, scientific, and

other technical positions.

! Developed customized technical qualification programs tailored to safety-related

duties and enrolled approximately 1,800 federal personnel in these programs.

! Established a technical leadership development program designed to attract and train

promising new scientists and engineers for defense nuclear facilities.

! Identified 251 senior technical safety managers (GS/GM-15 and Senior Executive

Service) who constitute the unbroken chain in line management responsibility for

safety. The background, experience, and qualifications of the incumbents for these

positions were evaluated by their line management. Shortfalls in training or experience

were documented, and action was taken to fill the identified gaps.

! Recruited, trained, and qualified 201 Facility Representatives across the DOE complex

through a rigorous qualification and training program comparable to that for resident

inspectors in the nuclear power industry. 

The Board intends to follow closely the institutionalization of processes designed to develop and

preserve key DOE technical capabilities.

2.4.2 Upgrading of Criticality Safety Expertise

During 1999, DOE continued actions to upgrade its criticality safety programs and

improve the training, qualification, and retained expertise of both federal employees and

contractor personnel. Two draft guides were issued: Review Guide for Criticality Safety

Evaluations and Guide for Nuclear Safety Engineer Training and Qualifications. In addition, a

draft standard addressing criticality safety qualification was prepared that specifically identified

competency requirements expected of a federal criticality safety specialist. The Board’s staff was

extensively involved in the review and acceptance of these documents.

The Board’s staff participated in the development and pilot presentation of a new

advanced criticality safety course at the critical experiments facility at LANL. The pilot

presentation of the course led to the identification of a need to improve the syllabus used in the

course. The Board’s staff participated actively in the development of these improvements.
2-26

A member of the Board’s staff conducted a review of criticality safety requirements at

RFETS, motivated by reports from operations on the floor that the requirements were so

structured as to be difficult to understand or follow. This action led to measures to simplify the

requirements and to structure them along more understandable lines. 

The Technical Area (TA)-18 site at LANL is used for criticality research and for courses

to train criticality engineers at DOE’s sites, both for DOE’s staff and for contractors. As a result,

TA-18 is the location of a substantial amount of fissionable material, primarily highly enriched

uranium. In 1999, a review was conducted of the adequacy of physical security measures to

protect this material. It was concluded that very expensive upgrades of physical security would

be required for the purpose, and that a study should be performed to identify other possible

locations for activities that have historically been conducted at TA-18. Some possibilities being

considered would involve relocating the activities at other sites, in particular NTS.

The activities now conducted at TA-18, particularly the education of criticality engineers,

are considered by the Board to be vital to maintaining criticality safety at DOE’s defense nuclear

facilities. The need to ensure continuance of this capability is even more evident after the recent

criticality accident at Tokai Mura in Japan and the subsequent public focus on criticality safety.

The Board is disturbed to note that skilled personnel suitable for instruction in a criticality

course are rare and are at present largely concentrated at LANL. It is unlikely that the faculty for

such a course could be assembled in the near future at another location such as NTS. The Board

will continue to exercise vigilant oversight over the study now under way.

In 1999, two members of the Board made presentations at a DOE-sponsored workshop

for senior criticality safety managers. Key outputs of this workshop included a plan for selfassessment of criticality safety programs and development of performance measures for these

important programs. At year’s end, a committee of criticality safety specialists was in the process

of implementing the self-assessments called for at the workshop.
3-1

3. MANAGEMENT AND STEWARDSHIP OF THE NATION’S STOCKPILE AND

NUCLEAR WEAPONS COMPONENTS

CONTENTS OF THIS SECTION

Section Page

3.1 STOCKPILE MANAGEMENT OF NUCLEAR WEAPONS ................................ 3-2

3.1.1 Pantex Plant ............................................................... 3-2

3.1.2 Y-12 Plant ................................................................ 3-8

3.1.3 Savannah River Site ........................................................ 3-12

3.2 STOCKPILE STEWARDSHIP OF NUCLEAR WEAPONS ............................... 3-14

3.2.1 Lawrence Livermore National Laboratory ....................................... 3-14

3.2.2 Los Alamos National Laboratory .............................................. 3-15

3.2.3 Nevada Test Site .......................................................... 3-18

3.2.4 Sandia National Laboratories ................................................. 3-19

3.3 DEFENSE PROGRAMS-WIDE TOPICS ............................................. 3-20

3.3.1 Recommendation 93-1/Nuclear Explosive Safety Study Correction Action Plan ........... 3-20

3.3.2 Collection and Analysis of Safety-related Information .............................. 3-20

3.3.3 Weapon Surveillance Program ................................................ 3-21

3.3.4 Handling of Insensitive High Explosives ........................................ 3-21

The Board has a unique role in overseeing the safety of operations in the DOE nuclear

weapons complex. These vital national security activities include assembling, disassembling, and

verifying nuclear components; conducting research and experiments supporting stockpile

maintenance; and providing replacement components and materials. A major thrust of the

Board’s oversight has been to review and assess safety management programs for these activities

to ensure that they are conducted in a manner that adequately protects public health and safety.

The defense nuclear complex has changed considerably since the Board’s charter members

were appointed in 1989. Production of new weapon systems has stopped, and dismantlement of a

large fraction of the nuclear weapons stockpile is under way. Underground testing of nuclear

weapons has ended as well. 

Existing nuclear weapons are likely to remain in the nation's stockpile longer than in the

past, potentially much longer than their original design lifetime. It will be necessary to ensure 

that nuclear weapons within DOE custody remain safe. In the absence of underground nuclear

testing, alternative means to confirm the safety and reliability of weapons throughout their life

cycle are being developed. DOE's strategy for dealing with this challenging new mission is
3

 U.S. Department of Energy, The Stockpile Stewardship and Maintenance Program, Office of Defense

Programs, Washington, D.C., May 1995.

3-2

embodied in its stockpile stewardship and management plan.3 This plan provides for continuation

of the ongoing defense missions at eight DOE sites, and includes appropriate adjustments

consistent with post-cold war national security policies. 

Many of the facilities used for assembly and disassembly of nuclear weapons were

constructed in the period between the late 1940s and 1960s, and are now quite old. DOE is

refurbishing facilities intended for continued use; the functions of other facilities will change. 

DOE’s plans also call for the construction of facilities with enhanced experimental capabilities at

the nuclear weapons laboratories. Manufacturing capabilities at some existing plants are to be

maintained, but at reduced capacity. The last tritium production reactor was closed a decade ago

at SRS, and DOE has initiated a project to secure a new source of tritium, which will likely

require new defense nuclear facilities at SRS. In addition, a limited capability for manufacturing

components of plutonium pits is planned for a weapons laboratory.

DOE must also institute life extension programs (LEPs) for specific weapon systems.

LEPs are required at the Pantex Plant and the Y-12 Plant. Accordingly, the Board posted one

full-time Site Representative at the Y-12 Plant in June 1998 and added another in 1999. Two

Board Site Representatives have been located at the Pantex Plant since July 1992. 

3.1 STOCKPILE MANAGEMENT OF NUCLEAR WEAPONS

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

DOE nuclear weapons complex. A program of research and development has also been initiated

to improve DOE’s means of ensuring the safety and reliability of nuclear explosives in the absence

of physical testing; this program is termed stockpile stewardship. Stockpile management activities

at major sites with defense nuclear facilities are discussed in the following subsections.

3.1.1 Pantex Plant

The Pantex Plant, located near Amarillo, Texas, plays a central role in stockpile

management. Operations at Pantex include the assembly, disassembly, dismantlement, and

surveillance of nuclear weapons. Pantex also serves as an interim storage site for plutonium pits

removed from retired weapons.

Recommendation 98-2, Safety Management at the Pantex Plant

In response to the Board’s Recommendation 93-1, Standards Utilization in Defense

Nuclear Facilities, DOE developed and began implementing an upgraded work/safety planning

process, called Seamless Safety for the 21st Century (SS-21), to guide the development of safety

bases, procedures, and tooling for nuclear explosive operations at the Pantex Plant. Where it has

been applied, the SS-21 process has yielded excellent results by integrating work planning and
3-3

safety planning for dismantlement operations. However, the process has been executed for only a

few programs because of its reported complexity and labor-intensive requirements.

In 1998, the Board observed that the SS-21 process was so cumbersome that it could not

be followed simultaneously for the multiple types of weapons to be dismantled or surveilled. As a

result, safety improvements were being deferred, and assurance of safety had begun to suffer. 

The Board’s Recommendation 98-2, Safety Management at the Pantex Plant, was issued in

response to this situation. Recommendation 98-2 calls for redesign and simplification of the 

SS-21 process with a reemphasis on the responsibility of line management, which had suffered

under the existing process. Recommendation 98-2 is not prescriptive; it proposes that DOE and

the Pantex contractor—Mason & Hanger Corporation (MHC)—identify and implement the

necessary improvements to the system.

The pace of progress on the part of DOE and the Pantex contractor in response to

Recommendation 98-2 has been disappointing. The process has not been simplified; in fact, it

may have become even more complex. Recent delays caused by this process, which continues to

be cumbersome and time-consuming, have resulted in the deferment of safety improvements and a

prolonged dependence on less reliable or less robust safety controls and processes.

On November 22, 1999, the Board transmitted to DOE a letter concerning safety

management at the Pantex Plant. In this letter, the Board affirmed its commitment to supporting

DOE in improving safety at the plant in such a manner that DOE can still meet its obligations to

national defense while conducting mutually agreed-upon actions designed to ensure the safety of

operations.

Specific Weapon Programs

W56 Dismantlement Program. The W56 is a retired Minuteman II warhead. The full

SS-21 process was employed in the development of the W56 dismantlement operation. The

Board and its staff closely reviewed preparations for this major dismantlement program, including

the identification and implementation of safety controls derived from the SS-21 process. As part

of this effort, the Board’s staff reviewed the Hazard Analysis Report (HAR) for the W56. This

review revealed relatively few issues; rather, the analysis in the HAR was found to be methodical

and generally comprehensive. The HAR initially identified numerous specific controls to ensure

the safety of the dismantlement operation. When the results of the HAR were analyzed, the

process designers were able to improve the procedures and tooling employed. For example,

lifts—which pose the potential for accidental drops that would threaten the high explosive in the

weapon—have been eliminated, including crane lifts of the warhead in any configuration. In

addition, the tools used in dismantlement have been designed to better protect the weapon and its

components by eliminating or reducing hazards.

In conducting its review, the Board’s staff questioned the way it was intended that the

W56 dismantlement program identify, implement, and preserve the important controls that are

relied upon to prevent inadvertent detonation of the high explosive components in the weapon. 

In the early drafts of the Activity-Based Controls Document, there was little to differentiate these

vital controls from the many other safety controls identified for the W56 dismantlement 
3-4

operation. To address this issue, DOE revised its approach and committed to clearly identifying

the most important controls, defining the bases for these controls, mandating appropriate

requirements to maintain the functionality of these controls, and specifying actions to be taken

should a control be compromised. This effort represents a substantial improvement in DOE’s

management of the safety of nuclear explosive operations, since it helps preserve those controls

most relied upon to prevent a high-consequence accident.

The Board’s staff also observed the Nuclear Explosive Safety Study (NESS) for the W56,

as well as a Readiness Assessment for the W56 that was completed in December 1998. The

common purpose of these two different forms of readiness reviews by panels of experts is to

assure DOE that the contractor is ready to perform work safely. The staff found briefings to the

NESS to be an improvement over those of earlier studies, as they were appropriately interspersed

with physical demonstrations of the dismantlement procedures by production technicians—the

hands-on operators. The importance of providing such realistic demonstrations has repeatedly

been noted by the Board and its staff, since doing so enables the reviewers to better associate the

assessed hazards with actual operations. 

In a letter to DOE dated January 15, 1999, the Board communicated a number of issues

concerning safety-related controls for the W56 dismantlement operations. As a result of the

Board’s engagement, DOE satisfactorily addressed these issues and implemented a much more

robust and effective set of controls. The W56 dismantlement program started operations in 1999.

W79 Dismantlement Program. The W79 is an artillery-fired atomic projectile.

Dismantlement of the W79 began on June 3, 1998, after a year of preparations involving readiness

reviews and demonstrations of the process, tooling, and equipment. In last year’s Annual Report

to Congress the Board observed the many difficulties encountered by DOE while readying the

W79 for dismantlement. In a letter to DOE dated March 12, 1999, the Board transmitted an issue

paper by the Board’s staff that addressed each of the Integrated Safety Management System

functions as they apply to nuclear weapons operations at the Pantex Plant. The letter also noted

that the Readiness Assessment process for the W79 had eventually resulted in a safe operation,

but that lessons learned needed to be incorporated, along with those provided in the Board’s

January 5, 1999 letter, into a more efficient and effective model for future readiness assessments. 

The Board’s staff conducted a review of W79 dismantlement operations in June 1999,

finding no adverse safety issues. The staff also observed that the technicians were well trained,

that issues encountered during the process were addressed appropriately, and that authorization

basis controls were being maintained. The Board acknowledged this good progress in a letter to

DOE on August 10, 1999.

W87 Life Extension Program and Disassembly and Inspection Operations. The 

W87 is a warhead used on the Peacekeeper missile system. Throughout 1998, DOE prepared to

begin a LEP for the W87. A HAR at the Pantex Plant for a LEP was completed; safety controls

were identified in the HAR and in an Activity-Based Controls Document. As DOE was 

preparing to approve the activities base for the W87 LEP in early 1999, the Board’s staff
3-5

identified a number of deficiencies. These included (1) a lack of adequate direction for readiness

reviews; (2) inconsistent application of DOE Orders 425.1A, Startup and Restart of Nuclear

Facilities, and 452.2A, Safety of Nuclear Explosives Operations, with regard to readiness

reviews; and (3) ineffective validation of readiness, which adversely impacted the ability of MHC

and DOE to confirm readiness for weapon operations before their startup/restart. In response to

the staff’s observations, DOE’s Albuquerque Operations Office (DOE-AL) initiated an

assessment of its readiness review process. DOE-AL improved its local directives and established

a clear expectation that all future readiness reviews would conform to and meet the objectives of

DOE Order 425.1A. Unfortunately, subsequent readiness reviews (e.g., the Readiness

Assessment for the DOE-AL W62 Disassembly and Inspection [D&I] Program) have not met that

expectation. Nevertheless, nuclear explosive operations under the W87 LEP began in early

summer 1999 with a well-defined and effective safety basis.

W62 Disassembly and Inspection Program. The W62 is an enduring stockpile warhead

used in the Minuteman III missile system. The NESS authorization for D&I of the W62 expired

in 1997. DOE decided to revalidate the expired NESS in June 1998 instead of pursuing a tailored

SS-21 set of actions to develop an improved set of controls that would then be the subject of a

new full-scope NESS review. Such a revalidation process is allowed under DOE Orders related

to nuclear explosive safety, but in some cases it is not advisable from a safety perspective. The

Board noted that at this stage, the W62 was one of those cases; indeed, this observation was a

principal reason for the Board’s issuance of Recommendation 98-2. In response to this

recommendation, DOE agreed that an additional hazard analysis and other actions would be

needed to support safe D&I operations for the W62. These actions included reviews of the W62

authorization basis, a walkdown of the W62 operations, and development of a HAR and an

Activity-Based Controls Document. 

In a letter to DOE dated July 30, 1999, the Board emphasized the importance of

completing safety improvement efforts for nuclear explosive operations in a timely and effective

manner to support safe and reliable operations associated with the nation's enduring nuclear

weapons stockpile. In addition, the Board observed that DOE needed to ensure the quality of

each individual initiative to analyze operations and develop controls, as well as to carefully

coordinate the interdependencies among separate safety improvement initiatives. The Board

expressed its concern that the management attention and resources needed to resolve these issues

had not been focused as necessary to meet safety and programmatic objectives.

A report prepared by the Board’s staff, dated May 11, 1999, addressed DOE’s efforts to

upgrade the W62 safety basis and controls. The staff identified a number of areas requiring

improvement in the development of W62-specific activities. Among these were the flowdown of

controls to implementing (floor-level) documents, the effectiveness of the controls for fire

suppression, and the apparent absence of failure modes and effects analyses for enhancements to

tooling design. The staff also identified potential problems with the integration of various safety

upgrade projects at Pantex. 

A subsequent report by the Board’s staff highlighted deficiencies in the information 

being provided to the Pantex contractor by the nuclear design laboratories concerning warhead

response to specific environments, as well as in the use of this information for determining the
3-6

hazards and resulting controls associated with nuclear explosive activities. Although the Pantex

contractor is responsible for conducting these safety analyses, only the nuclear design laboratories

can provide such information. This input must be of the highest fidelity possible, with a defensible

technical basis and a report of appropriate uncertainties, to be useful for safety basis development. 

Also in December 1999, the Board's staff reviewed activities associated with the 

DOE-AL Readiness Assessment and the NESS for the W62 D&I. The staff found that the 

DOE-AL Readiness Assessment team did not conduct a sufficient review to justify its

conclusions; the team was neither fully qualified nor adequately prepared, and did not devote

sufficient attention to activities in the bay and cell. However, the intent of a Readiness

Assessment (to validate that controls have been implemented and that the process is ready to start

safely) was met because the NESS Group was able to compensate for the shortcomings of the

Readiness Assessment team. Pantex is expected to complete the corrective actions resulting from

these reviews and begin D&I operations in early 2000.

As a result of the Board’s interactions with DOE, the safety basis for the W62 D&I

process is better defined and controlled, and more effectively implemented. However, the Board

believes that DOE and its contractor took an excessively long time to establish and execute an

adequate safety basis for W62 D&I nuclear explosive operations. The objective of the Board’s

Recommendation 98-2 is ultimately to expedite these types of safety improvements. 

Additional Safety Issues and Advances in Safety Management at Pantex

Throughout 1999, the Board and its staff identified or continued to pursue a number of

additional matters that pertain more generally to the safety of all weapon system operations at the

Pantex Plant. The following discussion highlights actions taken by the Board to address these

matters.

Upgrades of Site-wide Basis for Interim Operation. In 1999, DOE and MHC

continued to pursue initiatives to upgrade the Basis for Interim Operation (BIO) for the Pantex

Plant; these initiatives began in 1997, primarily as a result of the Board’s urging during the

previous several years. The BIO contains analyses of common operations at the Pantex Plant,

identifies hazards from a facility perspective or hazards that are common to more than a single

weapon system, and demonstrates that the work can be done safely. The safety basis will retain

an interim status until systematic safety analyses have been completed for all activities, and a 

site-wide ISM System has been fully developed. With technical input from the Board and its 

staff, DOE changed its goal to upgrading the site-wide BIO. The approach will now be to

upgrade the BIO and implement it in a modular fashion by subject areas (e.g., lightning

protection, on-site transportation, fire protection), rather than deferring implementation of new

controls and safety improvements until all analytical work has been completed and approved. 

The new approach is intended to ensure that additional safety improvements will be made as

expeditiously as possible. However, progress in this area has been disappointingly slow, and the

Board has expressed its concern in this regard to DOE on a number of occasions. An additional

complication has developed because DOE and its contractor have not done a good job of

managing the interfaces between the BIO modules and other authorization basis initiatives. 
3-7

Unless DOE senior management exhibits a significant increase in commitment to this effort in the

coming year, the Board anticipates that this trend will continue well into 2000. 

The following are additional examples of the Board’s activities related to the site-wide

BIO upgrades: 

! Lightning Protection—In 1997, the Board requested that DOE prepare a technical

report addressing the hazards posed by lightning to nuclear explosive operations at the

Pantex Plant and the controls necessary to prevent and mitigate those hazards. In

response, DOE established a project team to address the lightning protection issue. 

Since then, DOE and MHC have identified and installed additional protective

measures. For most facilities, engineered controls (such as electrical bonding of

metallic penetrations) are being implemented effectively. However, two problem areas

continue to require attention: the development of concise and effective surveillance

and administrative control procedures, and the installation of equipment to facilitate

long-term maintenance of these controls. A letter to DOE dated September 21, 1999,

forwarding a report by the Board’s staff entitled Lightning Protection for Nuclear

Explosive Operation at Pantex, acknowledged the substantive response by DOE and

the Pantex contractor to the Board’s observations and suggestions for upgrading of

lightning protection measures at Pantex. With further progress on the completion of

additional upgrade efforts, the Board anticipates closure of this issue in 2000. 

! On-site Movement of Nuclear Explosives—The Board and its staff continue to

emphasize the safe movement of weapons at the Pantex Plant. DOE’s progress in this

area during 1999 was limited. A draft BIO module for weapon transportation has

been in development since 1997, yet was only recently (September 1999) submitted to

DOE for approval. In a December 1999 letter to DOE regarding a subsequent review

by the Board’s staff, the Board concluded that integration of the appropriate safety

analyses will require considerable work because of the large number of safety basis

products involved, including the facility BIO and Technical Safety Requirements

(TSRs), multiple BIO modules, weapon-specific HARs, and Activity-Based Controls

Documents. Unfortunately, no evidence was provided to the Board’s staff during its

review that such an improvement had been initiated. The staff also found an almost

exclusive reliance on administrative controls to provide protection. Implementation of

the identified controls in 2000 may be difficult from operational, programmatic, and

budgeting standpoints. These matters will be taken up with Pantex management in

early 2000.

Pit Storage at Pantex

In 1992, DOE decided to cease the fabrication of pits for nuclear weapons at the Rocky

Flats Environmental Technology Site and to begin the dismantlement of nuclear weapons. The

pits from dismantled weapons have been stored in special containers, the AL-R8. It has been

recognized for some time that the environment provided by the AL-R8 container used for both

storage and shipping of pits is unacceptable for extended pit storage from the perspectives of 
3-8

both safety and reliability, yet attempts to remedy the situation have to date been unsuccessful. 

Poor programmatic direction and management have led to large expenditures with little

corresponding improvement in the storage conditions of the pits.

DOE policy decisions have established three classes of pits—those that are stockpilecapable, those for possible reuse, and those bound for disposition (known as “excess” pits). The

first two classes make up the set of national security asset pits and are to be stored indefinitely,

while pits in the third class are to be stored until they can be dispositioned. There is no

comprehensive plan for pit management that outlines the way these general intentions are to be

executed safely; however, a program commenced in July 1999 for upgrading the pit storage

containers from the AL-R8 to the AL-R8 Sealed Insert (SI) in the interim. This interim upgrade

was proceeding at a very slow pace, with 2006 being the most favorable estimated date for

completion of repackaging. Accordingly, the Board issued Recommendation 99-1, Safe Storage

of Fissionable Materials called "Pits," on August 11, 1999. The Board recommended that DOE

accelerate repackaging of pits into acceptable storage configurations.

At year’s end, DOE had drafted an Implementation Plan for Recommendation 99-1 that

appears to address the Board’s technical concerns regarding pit repackaging on a timetable that

may be the best attainable under the circumstances. However, an adequate Integrated Pit

Management Plan (IPMP) addressing the broader pit management issues has yet to be provided. 

The Board expects development of the next revision of the IPMP to accelerate upon finalization

of the Implementation Plan for Recommendation 99-1. The Board’s staff is closely monitoring

DOE’s IPMP development activity, and expects to see an adequate plan developed and the

repackaging program initiated in 2000.

3.1.2 Y-12 Plant 

The Y-12 Plant, near Oak Ridge, Tennessee, is the site where nuclear explosive secondary

components and weapon cases are fabricated. The Y-12 mission also includes fabrication,

surveillance, inspection, and testing of some weapon components.

Enriched Uranium Operations Restart

Enriched Uranium Operations (EUO) at the Y-12 Plant involve a system of metallurgical

operations (casting, rolling, forming, and machining), waste processing operations (thermal,

solution, and wet chemistry processes), and metal production. These operations, among other

nuclear activities at the Y-12 Plant, were suspended by the contractor in 1994 following the

identification of numerous criticality safety problems. Resumption of operations conducted in

Building 9212 is necessary to support high-priority national security missions. 

In 1998, Phase A operations (metallurgical operations and waste processing) were

restarted successfully. In addition, DOE’s Oak Ridge Operations Office (DOE-OR) and

Lockheed Martin Energy Systems (LMES) committed to conducting an Operational Readiness

Review (ORR) for Phase B metal production operations and associated activities. LMES 

decided to split the Phase B processes into Blocks 1 and 2, with the understanding that ORRs

would be conducted for both blocks. An ORR for Block 1 processes, which encompass the
3-9

hydrogen fluoride (HF) system and a reduction furnace, was scheduled to occur in September

1999. However, as a result of delays in the construction of the HF system, DOE-OR and LMES

decided in July 1999 to restart the reduction furnace separately from the HF processes. DOE-OR

and LMES were planning to conduct a contractor Readiness Assessment concurrently with a

“validation” by DOE-OR to confirm readiness for restart of the reduction furnace process. The

justification for this less rigorous review included the perceived low risk of the operations, the

small number of controls, and the observation that the operations were similar to those performed

prior to shutdown. Additionally, DOE-OR management indicated that LMES would be the

restart authority, with DOE-OR as an approval authority. 

The Board’s staff reviewed the status (including the safety basis) of the planned restart of

the reduction furnace in July 1999, along with the less rigorous approach to ensuring readiness to

operate safely. As a result of subsequent interactions with the Board, DOE-OR agreed to

perform an independent DOE Readiness Assessment for the reduction furnace, as required by

DOE Order 425.1A, Startup and Restart of Nuclear Facilities. The DOE Readiness Assessment

eventually revealed numerous safety issues. DOE ultimately concluded that the process was not

ready to resume operations safely. DOE and LMES are now reviewing their approach to the safe

startup of wet chemistry operations.

Additionally, on December 13, 1999, the DOE Facility Representative in Building 9212

identified a fissile material container located in a storage array that was not permitted by the

governing nuclear criticality controls. This nuclear criticality safety concern was immediately

confirmed by LMES, but a further search revealed no other suspect containers. On December

14, 1999, however, the DOE Facility Representative found an additional container not in

accordance with storage array limits. Since the search by LMES staff had failed to reveal this

container, the DOE Facility Representative directed that all fissile material handling activities in

Building 9212 be stopped. On December 16, 1999, DOE issued a memorandum formally

confirming the stop work order, requesting a corrective action plan within 5 days, and confirming

that resumption of fissile material activities in Building 9212 would require DOE approval. 

Resumption of those activities will now have to be factored into EUO restart plans.

Design and Construction Projects

The Board believes that replacing aged defense nuclear facilities and maintaining a

technically competent staff to build and manage those facilities are two of the most important

safety challenges currently facing DOE. Activities by DOE and LMES to resume EUO and

construct the Highly Enriched Uranium (HEU) Materials Facility are key projects requiring Board

attention to ensure that these safety challenges are being met.

Following reviews of recent facility upgrades at the Y-12 Plant and a staff assessment of

the conceptual design report for the HEU Materials Facility, the Board transmitted a letter to

DOE dated May 2, 1999. In this letter, the Board noted that (1) an increased effort was required

to integrate safety into the planning process and ensure the overall success of these projects, and

(2) a disciplined process for controlling the design of facilities—based on the principles of systems

engineering and ISM, as well as the guidance contained in DOE Order 430.1A, Life Cycle Asset

Management—would be appropriate.
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Continuing problems with the HF supply system project (which, as noted above, supports

resumption of EUO activities) and safety management issues prompted the Board to delve into

other aspects of EUO activities. ISM for Y-12 design and construction programs was lacking. 

As a result, the Board sent a letter to DOE dated November 9, 1999, observing that the

contractor’s safety management leadership was weak in this life-cycle phase. The Board noted

that the responsible managers lacked detailed involvement in and understanding of all aspects of

the project, from design and procurement to testing and evaluation. The Board also noted that

DOE had not exercised its oversight responsibilities to identify safety problems, determine their

cause, and undertake necessary steps to prevent their recurrence. 

As a result of these findings, the Board requested that DOE prepare a report addressing

how it intends to (1) identify the root causes of problems associated with the execution of ISM

principles during design and construction, and (2) resolve those and other safety issues. The

Board also requested that once the root causes have been identified, DOE provide an additional

report outlining the corrective actions to be taken to remedy the causes and the associated

problems, as well as specifying the necessary changes to ISM practices at the Y-12 Plant.

Safety Basis 

In June 1999, the Board’s staff conducted a review of the safety bases for Y-12 nuclear

facilities, identifying inconsistencies and deficiencies in the authorization bases. Unreasonable

delays in approval of the authorization basis documents led to schedule slips in the development

of Safety Analysis Reports (SARs) and an overreliance on the use of cursory BIOs. The staff also

observed that LMES and DOE-OR had decoupled their approval of the SARs (i.e., analysis),

which do not adequately address the safety of the public, workers, and the environment, from

their approval of the TSRs (i.e., controls), thus introducing inconsistencies. DOE-OR and LMES

acknowledged these problems and indicated they would attempt to improve the situation through

reorganizations and the conduct of workshops. In an October 6, 1999, letter to DOE, the Board

transmitted the results of the staff’s review of the Y-12 safety basis. In response to that letter,

DOE-OR has directed LMES to accelerate its schedule for updating the authorization bases for its

nuclear facilities, and to ensure that all safety basis analyses and documentation for nuclear

facilities meet the goal of DOE Order 5480.22, Technical Safety Requirements, and DOE Order

5480.23, Nuclear Safety Analysis Reports, as soon as practical. Both DOE-OR and LMES plan

to acquire additional technical talent through the use of excepted service and subcontracting.

Secondary Dismantlement 

In August 1999, the Board’s staff conducted a review of (1) safety basis documentation

and preparations for surveilling canned subassemblies, and (2) the first new dismantlement

campaign in more than 5 years for dismantlement of weapon secondaries at the Y-12 Plant. In a

letter to DOE dated November 11, 1999, the Board transmitted a report documenting the results

of this review. The staff observed that delays in establishing an updated authorization basis were

continuing, and noted inadequacies in the performance of job hazard analyses in Unreviewed

Safety Question Determinations, and in implementation of safety-related controls.
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Year 2000 Issues 

In a letter to DOE dated November 24, 1998, the Board transmitted an issue report

prepared by its staff, identifying Year 2000 (Y2K) issues at the Y-12 Plant. A follow-on staff

review of electrical and instrumentation and control systems at the Y-12 Plant was conducted in

March 1999. At that time the staff observed that DOE had acknowledged the issues raised in the

report, and encouraged DOE to continue its efforts in addressing those issues. 

Chemical Hazards 

In reviews conducted in 1998 and 1999 regarding the management of chemical hazards at

the Y-12 Plant, the Board’s staff identified problems with activity-level work planning, related

specifically to the identification and analysis of hazards and the subsequent development and

implementation of controls. These problems contributed to circumstances that led to a number of

fires and explosions involving lithium operations (the latest fire occurring on December 14, 1999),

as well as a chemical explosion involving depleted uranium operations (on December 8, 1999).

In May 1999, the Board’s staff conducted a follow-up review of the management of

chemical hazards at the Y-12 Plant. In a letter to DOE dated July 8, 1999, the Board transmitted

the findings of this review, highlighting the contractor’s tardy response to Secretarial directives; a

lack of up-to-date, accurate information concerning the inventory of potentially hazardous

chemicals; and failure to follow up on open occurrence reports and Unreviewed Safety Question

Determinations. In response, DOE has stepped up efforts to complete a chemical management

program at the Y-12 Plant, including a renewed commitment to characterizing chemical

inventories for emergency planning purposes and to disposing of excess chemicals. DOE-OR

issued a chemical safety action plan on September 23, 1999, but did not allocate resources for its

implementation until November 15, 1999. The schedule for this plan, therefore, is not being met. 

The Board will continue to stress this issue with senior DOE management.

Emergency Management 

During a visit to the Y-12 Plant in May 1999, the Board’s staff reviewed the

implementation by DOE-OR and LMES of DOE Order 151.1, Emergency Management. The

staff found that the DOE emergency management program was ineffectively led and supported by

senior DOE management. In response to a letter from the Board dated July 8, 1999, DOE-OR

assembled a working group that prepared and then began executing a corrective action plan. 

Though implementation of this plan extends to June 2000, DOE-OR is devoting high levels of

management attention and adherence to the plan’s schedule and deliverables. The Board will

monitor this progress closely until the action plan has been completed.

Review of Worker Protection 

In December 1998, the Board’s staff conducted a review of worker protection for

maintenance and operations in Building 9212 E-Wing and for construction of the HF system. It

was not apparent to the staff that work planning and control processes in effect at the Y-12 Plant
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could be adequately and consistently relied upon to ensure worker safety. In a letter to DOE

dated January 28, 1999, transmitting an issue report on the subject prepared by the staff, the

Board noted that the rigor that characterized the performance of hazard analyses for lithium

hydride operations was not being applied universally across the site (i.e., in design and

construction activities and in maintenance and operations in E-Wing). In addition, the Board’s

staff identified issues regarding the use of respirators in high-airborne-activity areas in E-Wing. In

response, DOE is developing additional engineered controls to mitigate the elevated levels of

airborne uranium. 

Overall, the Board’s oversight of the Y-12 activities relative to safety has revealed the

need for Y-12 to strengthen its work planning/safety planning program and its conduct of

operations. The Board has engaged DOE’s senior officials on this matter which is now receiving

DOE attention. The Board will continue to monitor the situation.

3.1.3 Savannah River Site

The tritium facilities at SRS, located near Aiken, South Carolina, have 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. Tritium, a radioactive isotope of hydrogen, has

a relatively short half-life (12.3 years) and must be replaced periodically. Tritium was last

produced in the K-Reactor at SRS, which was shut down in 1988. Currently, DOE does not have

the capability to produce tritium. The H-Area tritium facilities at SRS consist of Buildings 

233-H (formerly the Replacement Tritium Facility), 232-H (tritium extraction facility), 238-H

(tritium reclamation facility), and 234-H (tritium receiving, packaging, and storage facility). 

Production of Tritium

On May 6, 1999, the Secretary of Energy issued a consolidated Record of Decision for the

tritium supply program. The Commercial Light Water Reactor–Tritium Extraction Facility

alternative was chosen as the primary supply program to support national stockpile management

activities. The Accelerator for Production of Tritium (APT) alternative was designated as the

backup; this project is scheduled to continue with developmental work and completion of the

preliminary design. During the past year, the Board by request briefed the U.S. Department of

Defense’s (DoD) Defense Science Board and representatives of the U.S. General Accounting

Office on the technical advantages and disadvantages of these tritium production alternatives. In

general, the APT project requires more engineering development and will take longer to bring into

production; with proper oversight, however, either alternative can be operated safely. During

1999, the Board’s efforts focused upon the review of the safety aspects of designs being

developed for these facilities.

Safety Analysis Report for Consolidated Tritium Facility

The Board’s staff has been actively involved in reviewing the SAR for the Consolidated

Tritium Facility, which combines the safety basis documentation for all tritium facilities in the 

H-Area at SRS. Since 1993, WSRC has been engaged in developing authorization basis

documentation for SRS facilities, an effort that includes upgrading SARs to meet the 
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requirements and implementation guidance of DOE Order 5480.23, Nuclear Safety Analysis

Reports. In producing the SAR for the Consolidated Tritium Facility, the latest DOE guidance

and industry standards were used to perform hazard analyses and identify the controls needed to

protect the public and workers. The Board’s reviews and subsequent interactions with the 

DOE-SR and WSRC resulted in changes to the assumed worst-case fire scenarios.

Conservative industry standards and practices were used in the design and safety analyses

for the Consolidated Tritium Facility. The result is a design more likely to provide the preventive

and mitigating functions required of vital safety systems. An important example of this is the

application of revised National Fire Protection Association guidance in estimating the maximum

room temperature in an unmitigated fire. For some fire scenarios, the new analysis estimates the

average room temperature during a fire to be higher than was previously assumed. The new

analysis also emphasizes the importance from a risk reduction standpoint of preventing such large

fires and avoiding the associated higher temperatures, which would exceed the environmental

qualification of some existing safety-class systems and components. The control of incipient fires

through use of a more reliable fire suppression system would make large fires less likely to occur. 

To reduce the predicted likelihood of such fires to the “extremely unlikely” level, WSRC

reclassified the fire suppression (and some detection) systems as safety class. TSRs will be

applied to fire protection systems falling in this category. In addition, administrative controls on

combustibles will be used to provide greater assurance that combustible loading limits will not be

violated. 

As a part of its conservative design development, WSRC used defense in depth in

establishing the safety features for the consolidated tritium facilities. Use of this approach will

result in a design in which multiple barriers would have to be breached in series during accident

conditions before radioactive materials would be released outside the work stations. The Board

encouraged and commended the use of defense in depth by WSRC and urge DOE to apply the

principle more widely. The Board will continue to monitor the design development as it

progresses.

Non-Nuclear Reconfiguration

The Board and its staff have devoted substantial effort to overseeing the safety aspects of

the development and startup of new tritium-related activities associated with the Non-Nuclear

Reconfiguration program. In December 1999, the Board’s staff reviewed the design and safety

analyses associated with the Tritium Facilities Modernization and Consolidation (TCON) project. 

The TCON project will relocate existing tritium process capabilities and equipment from older to

more modern tritium facilities through several construction projects, including a major

modification to Building 233-H and the construction of a new environmental

chambers/contaminated metallography laboratory, Building 234-7H. The intent of the TCON

project is to improve the safety of operations, reduce environmental releases, improve

productivity, and reduce operating costs. Revisions to the authorization basis for the Building

233-H modification and the Consolidated Tritium Facility SAR for Building 234-7H are being

developed as part of the modernization effort.
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By year’s end, the Board’s staff had reviewed the draft SAR Addendum for Building

234-7H. The staff found the overall quality of the hazard analysis and functional classification of

structures, systems, and components to be adequate. The Board will continue to encourage

WSRC to use engineered design features instead of administrative controls (e.g., fire suppression

versus emergency planning) for worker protection. The Board’s staff will continue to follow the

progress of the TCON project and tritium operations to ensure that the quality of the

authorization basis is maintained and that identified safety controls are adequately implemented.

3.2 STOCKPILE STEWARDSHIP OF NUCLEAR WEAPONS

Stockpile stewardship is the term used by DOE to refer to activities carried out in the

absence of nuclear testing 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-nuclear 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.

3.2.1 Lawrence Livermore National Laboratory

Lawrence Livermore National Laboratory, located 45 miles southeast of San Francisco,

California, is a DOE 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 Building 332 (B332)

Plutonium Facility and the Tritium Facility.

Integrated Safety Management at the Superblock

LLNL halted operations at the B332 Plutonium Facility in July 1997 as a result of issues

related to safety management, criticality safety, and conduct of operations. In 1998, LLNL

developed and implemented a plan for resumption of Plutonium Facility operations. This plan

incorporated rigorous compensatory measures to permit the resumption of operations in stages,

provided for interative improvements in work practices in subsequent work, and allowed for the

gradual development of standing work practices. In 1999, the standing practices for the

Plutonium Facility were documented in a work control manual and in facility and operations

safety procedures. The practices were generally applied to the other Superblock facilities.

Throughout 1999, the Board and its staff continued to review actions aimed at upgrading

the safety management program at the B332 Plutonium Facility and the remainder of the

Superblock. In a letter to DOE dated May 6, 1999, the Board noted that significant

improvements had been implemented at the B332 Plutonium Facility, and that continuing 

progress on safety enhancements could best be achieved through full development and

implementation of an ISM System. The staff continued to focus on helping to develop and

improve programs and procedures for LLNL’s nuclear facilities and related programmatic
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activities with regard to the identification of hazards and implementation of controls for

operations and storage involving special nuclear and radiological materials. The Board and its

staff also assisted DOE’s Livermore Site Office in developing a capability to monitor and ensure

safe operations at LLNL’s defense nuclear facilities.

In developing a process for the resumption of operations at the Plutonium Facility, LLNL

developed and, to a large degree, implemented an ISM System. The Superblock developed its

own ISM System Description because it was significantly ahead of the rest of LLNL in

implementing more rigorous safety practices for its operations. The Superblock completed its

ISM System verification in September 1999. Although several areas for improvement were noted

(particularly with regard to developing and maintaining safety bases, feedback, and improvement),

the Superblock ISM System Description was considered acceptable, and an ISM System is being

implemented at the Plutonium Facility. An ISM System is also being implemented in the Tritium

Facility and the Hardened Engineering Test Facility. Activities are also underway at the site-level

to address systemic issues such as those noted above.

Electrical and Instrumentation and Control Systems

As a result of a review conducted in October 1999, the Board’s staff found that LLNL’s

emergency power system did not meet current safety-class standards and that the preventive

maintenance and calibration program for the emergency power system was inadequate. In a letter

dated December 21, 1999, the Board so advised DOE. The Board’s letter also noted other

potential areas for improvement, such as (1) addressing the inadequacy of mechanical supports for

certain components of the safety-class electrical power system in the event of a significant

earthquake, (2) developing appropriate standards and guides for safety-related instrumentation

and control systems, and (3) providing for an adequate lightning protection system for Building

332. The Board’s staff will continue to follow these issues until they are resolved.

3.2.2 Los Alamos National Laboratory

Los Alamos National Laboratory, located in northern New Mexico, is the DOE weapons

laboratory with the largest number of defense nuclear facilities and weapon-related activities. It is

the main site for ongoing research and development regarding means of certifying the safety and

reliability of nuclear weapons in the absence of nuclear testing. LANL will also be the location of

DOE’s limited-scale capability for manufacturing replacement pits for nuclear weapons.

Integrated Safety Management for Criticality Experimentation

Nuclear criticality research and development activities are performed at TA-18 Pajarito

Laboratory. Operations at TA-18 were halted by LANL management on August 12, 1998, as a

result of a series of occurrences that indicated deficiencies in planning and scheduling of work,

inadequate procedures, and problems with formality of operations. The Board's staff reviewed

the ensuing resumption plans in late 1998 and closely followed the resumption process 

throughout 1999. As part of the resumption process, a comprehensive safety management

assessment was conducted. This assessment identified a number of issues with regard to
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organizational structure and management systems. Satisfactory resolution of key issues and

action items has permitted the incremental resumption of activities.

Complications encountered in updating the SAR, along with other issues, led the Board’s

staff to propose an alternative approach that would permit the signing of an Authorization

Agreement after completion of a BIO by addressing the core safety requirements of DOE 

Order 5480.23, Nuclear Safety Analysis Reports. In a September 1999 review, the Board’s staff

noted that the TA-18 facility was operating under restricted conditions, without an Authorization

Agreement, and suggested that DOE and LANL complete an interim Authorization Agreement to

confirm the acceptability of and limits on current operations. LANL subsequently agreed to issue

an interim Authorization Agreement and has prepared one that has now been approved by DOE. 

It includes a commitment to complete the BIO by May 31, 2000, and the final Authorization

Agreement 1 month later.

Potential Relocation of Technical Area-18 Activities 

As discussed earlier, DOE had directed LANL to investigate alternatives for moving the

activities at TA-18 to another location in order to upgrade security measures. During a visit to

NTS on September 28–29, 1999, the Board’s staff was advised that the feasibility of moving the

TA-18 activities, the Sandia Pulse Reactor III, and special nuclear materials to the DAF was

under review. However, only the cost of the physical relocation of these activities to DAF was

being considered; the associated safety requirements and the potential cost of upgrading DAF as

necessary to collocate these activities with existing and planned DAF missions were not being

addressed.

Early identification of mission and objectives is key to successful decision making for large

projects such as the potential relocation of TA-18 activities. DOE has now established an options

study group to address the potential relocation of TA-18 activities originally scheduled to be

completed during a period of about 6 months, but now accelerated to be done in 4 months. There

are several national security programs that would be affected by the relocation, and for which

mission statements and objectives, including continuity of operations, need to be developed. 

These programs include critical experiment research and development in support of the nuclear

weapons program; emergency response for incidents involving special nuclear materials; and

nonproliferation-related programs, such as counterterrorist training. The impact on current and

planned operations also needs to be addressed for each of the alternatives. The Board is

concerned that the planned move may lead to the potential loss of technical expertise now resident

at LANL arising from any geographical relocation of TA-18 activities. Because of the negative

effects such a loss would have on criticality safety training, the Board intends to maintain its

position that no steps in remediation of this situation should weaken the program of training

criticality engineers—a crucial program needed to prevent criticality accidents in DOE’s facilities.

The Board continues to devote attention to certain developments affecting the future

viability of DOE’s programs for prevention of criticality accidents. The Board will maintain the

position that no steps in remediation of this situation should weaken the program of training the
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criticality engineers needed to prevent criticality accidents in DOE’s facilities. The Board will

continue its review of the safety implications of these alternative studies.

Hydrodynamic and Dynamic Experiments

LANL plans to conduct a series of hydrodynamic and dynamic experiments as part of the

stockpile stewardship program. Several issues remain to be resolved before operational readiness

for these experiments can be declared, including updates to the safety analysis and technical safety

specifications, and DOE must review and approve the revised authorization basis. 

Needed upgrades to lightning protection have not yet been initiated, but LANL has

assured the Board’s staff that it remains committed to making those upgrades. The final SAR and

TSRs need to be updated to address new information on hazards (including the lightning hazard

and new mitigation controls). LANL expects these updates will soon be completed. Several

safety issues remain unresolved and are being followed by the Board’s staff.

The Board’s staff has been reviewing the safety basis for these experiments for several

years. Inadequate resource allocations by LANL have caused delays in the program, but new

management has pledged strong backing for startup in 2000. DOE directed LANL to appoint

experts to a blue ribbon panel that would review the safety of the experiments. The Board has

proposed, and DOE has accepted, a broader charter for this panel. Members of the panel have

been named, and they held their first meeting in September 1999. 

A credible resource-loaded schedule for the program is not yet available. Current plans

call for the contractor and DOE to conduct ORRs during 2000, and authorization to proceed with

the experiments is anticipated as early as May 2000. However, no plan of action for either

readiness review is yet available. 

Worker Protection

As part of ongoing improvement of the implementation of ISM at the activity level, the

Board’s staff reviewed the plans for implementation of activity-level worker protection practices

in research and development at DOE facilities. On July 26, 1999, the Board sent a letter to DOE

commending LANL for its substantial implementation of ISM concepts. The Board also noted

that a number of practices could be improved further. Examples include providing better

guidance to workers for writing hazard control plans, estimating risks of activities, using

integrated teams to plan work, performing hazard analyses using various methodologies, and

conducting ISM System training. Since the staff’s review, LANL has issued revised manuals and

codes of practice that appear to incorporate several of these improvements.

Facility Upgrades

The Board continued to review facility upgrades, focusing on safety management

processes and practices for a number of important nuclear projects. For several years the Board

has emphasized the need for more effective management of construction projects at LANL to 
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ensure that health and safety risks are identified early, and effective controls are developed during

the design stage. In a letter to DOE in December 1997, the Board also stressed the need for

LANL to develop appropriate project management controls consistent with DOE Order 430.1A. 

In its June 2, 1998 response to the Board’s letter, DOE concluded that such changes were

necessary for all stockpile management construction projects at LANL.

DOE and LANL have taken significant initial steps to improve the safety management of

stockpile management projects, including an overall long-term strategy for resolving related

problems. During 1999, DOE and LANL completed agreements on incorporating DOE 

Order 430.1A in the DOE/University of California contract for the management of LANL. While

this was a significant initial step, DOE and LANL have not reached agreement on their respective

roles, responsibilities, and authorities, nor have they fully elaborated the contents typically

expected in key documents such as program requirement documents, design criteria, project

execution plans, baseline documents, and design reports.

In a review conducted in June 1999, the Board’s staff identified deficiencies related to

site-wide requirements for electrical, instrumentation and control, and fire protection systems. In

a letter to DOE dated September 22, 1999, the Board observed that although the current LANL

standards provide extensive direction on the design of industrial electrical systems, LANL has not

required any standards related to the design of safety-class or safety-significant systems. Thus,

there is little contractual assurance that safety-class and safety-significant systems within new or

upgraded facilities will meet DOE’s requirements. However, LANL stated its intention to add to

its contract with DOE both the Institute of Electrical and Electronics Engineers Class 1E

standards for electrical systems and the Instrument Society of America Standard S84.01 for

safety-related instrumentation and control systems.

In addition, the Board’s staff concluded that the contract for operating LANL does not

include many of the specific program requirements for fire protection that are in DOE Order

420.1, Facility Safety. Moreover, the LANL implementation guidance for fire protection is not

fully reflective of either DOE Order 420.1 or other DOE guidance on fire protection.

The Board further indicated that the Work Smart Standards need to be upgraded to

include standards for safety-related systems, to ensure that LANL adheres to established and

proven industry design practices for safety systems. These upgrades are especially important

given the near-term need to design and construct new facilities, such as a replacement for the

Chemistry and Metallurgy Research Facility. The Board also noted that it expects the Work

Smart Standards for safety-related systems to comply with the safety system requirements in DOE

Order 420.1.

3.2.3 Nevada Test Site

Underground testing of nuclear weapons is no longer being conducted at NTS. However,

NTS is required to maintain readiness for resumption of underground testing within a certain time

frame, if required by the President to do so. 
3-19

Subcritical Experiments

The subcritical experiments program at NTS is a vital materials research component of

DOE’s stockpile stewardship and management program. Subcritical experiments involve devices

containing both high explosives and special nuclear material. The experimental configurations are

designed, however, to preclude the possibility of nuclear criticality.

During 1999, the Board and its staff reviewed proposed operations for an upcoming series

of experiments. These experiments, subsequently conducted by LLNL, used vessels for

containment, thereby allowing reuse of individual underground chambers (which are expensive to

excavate). The staff found that the proposed operations had been adequately reviewed by DOE

under the existing safety management program for subcritical experiments. 

Disposition of Damaged Nuclear Devices

The potential exists that DOE might sometime in the future be faced with the need to deal

with a damaged nuclear device (DND). The Board has been exploring this matter with DOE

officials. DOE’s capability to safely perform the work necessary to dispose of DNDs is rapidly

disappearing. In the past, maintenance of the facilities and personnel necessary to support this

mission depended on nuclear test resources and expertise. However, the personnel and the facility

infrastructure required to support testing operations are diminishing. Planning DND operations

so they can be executed safely presents a unique challenge.

In September 1999, DOE outlined a path forward to address these matters. A disposition

focus group involving key DOE and laboratory personnel has been tasked to define the basic

elements and associated resources needed to reestablish and maintain a long-term capability to

conduct DND work safely. In turn, this group has chartered an exercise working group to plan

and conduct DND disposition exercises aimed at evaluating the adequacy of command

arrangements, as well as the state of readiness of the personnel and facilities necessary for DOE to

conduct this mission safely. Although the disposition focus group has conducted initial meetings

to define its charter and to begin development of the list of issues that must be addressed, much

work remains. Progress continues to be slow, and increased attention by senior management is

vital to this mission. The Board will continue to pursue this activity.

3.2.4 Sandia National Laboratories

Sandia National Laboratories manages research and development installations at several

sites, particularly Albuquerque, New Mexico, and Livermore, California. SNL has a major

responsibility to conduct engineering research and development on nuclear weapons systems and

components. All of SNL’s major defense nuclear facilities are located at the New Mexico site;

they include the Annular Core Research Reactor, the Hot Cell Facility, the Gamma Irradiation

Facility, and the Sandia Pulsed Reactor Facility, all located in Technical Area-V. The Manzano

Waste Storage Facilities and the Neutron Generator Facility are located elsewhere at the New

Mexico site.
3-20

During 1999, the Board's staff assessed the status of ISM System implementation at the

Sandia Pulsed Reactor Facility and the Gamma Irradiation Facility. The commitment to an ISM

System on the part of TA-V management was evident, but full flowdown to the activity and

worker levels is still ongoing. The Board’s staff is continuing to follow the progress of ISM

System implementation at this site.

3.3 DEFENSE PROGRAMS-WIDE TOPICS

3.3.1 Recommendation 93-1/Nuclear Explosive Safety Study Corrective Action Plan 

For several years, the Board has worked with DOE to improve the directives governing

the safety of nuclear explosive operations. In implementing the Board’s Recommendation 93-1,

Standards Utilization in Defense Nuclear Facilities, and the NESS corrective action plan, DOE

produced a revised and expanded set of safety-related Orders, standards, and guides that, taken

together, significantly improved the definition of what DOE expects of its contractors to ensure

the safety of operations. In carrying out the last open action of the response to this

recommendation, DOE formally issued a standard that provides guidance on the preparation of

HARs for nuclear explosive operations. In 1999, the Board closed Recommendation 93-1 and

encouraged DOE to continue to seek ways of simplifying the process developed for implementing

the new Orders. This matter of simplification was stressed again by the Board in its

Recommendation 98-2.

3.3.2 Collection and Analysis of Safety-related Information 

During 1999, the Board closed Recommendation 93-6, Maintaining Access to Nuclear

Weapons Expertise in the Defense Nuclear Facilities Complex, which urged DOE to capture the

safety-related design and operational knowledge of experts within the complex. DOE’s Office of

Defense Programs had initiated several programs for preserving and archiving this knowledge at

the nuclear weapons laboratories, NTS, the Pantex Plant, and the Y-12 Plant. 

One of these programs involved the status of the development of system-specific weapon

safety specifications. The Board's staff performed a comprehensive review of the weapon safety

specifications for the W56, W76, and W83 nuclear weapon systems. This review revealed

deficiencies that were determined to hinder the efficient development of HARs for nuclear

weapon operations at the Pantex Plant. In addition, identification of lessons learned from the

nuclear weapons complex and substantive archival data were found to be lacking in the weapons

safety specifications reviewed. The Board communicated this finding to DOE, and actions were

subsequently initiated to increase the efficacy with which the nuclear design laboratories supply

weapon response information in support of HAR development. The Board's staff continues to

follow this issue, with particular emphasis on making the maximum use of archival data and

information on lessons learned.
3-21

3.3.3 Weapon Surveillance Program

The Board continues to monitor DOE’s weapon surveillance program to determine

whether adequate attention is being given to the safety of activities and to safety-related materials

and components. Members of the Board’s staff attended the 1999 Annual Enhanced Surveillance

Program Review at the Allied Signal Kansas City Plant in March 1999. In May 1999, members of

the staff reviewed aging of high explosives in weapon components. High explosives in the main

charge and other components are carefully reviewed in the Enhanced Surveillance Program

because these materials are very energetic and subject to change over time. In addition, the staff

reviewed the aging characteristics of high explosives and how they may affect the safety of

weapon handling. The staff is continuing to follow ongoing studies of high explosives in main

charges, detonators, and other components for indications of significant changes.

In March 1998, the Board urged DOE to reexamine the significant finding investigation

(SFI) system. DOE subsequently changed its policy with regard to SFIs to require the design

laboratories to act on all significant finding notifications within 30 days of reporting. Also, LANL

has opened an increased number of SFIs in recent years.

The Enhanced Surveillance Program is now in its fifth year, and several significant

elements of the program are being reviewed and monitored by the Board’s staff. In the study of

pit materials, several mature projects to support determination of pit lifetimes are nearing

conclusion, although lifetime projections have not been developed. High explosive studies done

in support of stockpile life extension programs are approaching the point at which analysts can

provide lifetime projections for the high explosives in several weapon systems. Also, several nonnuclear components are being examined—in a risk-based prioritized manner— for defects that

could affect safety. The design laboratory is on track to support studies of non-nuclear

components in the W76 and the W80 stockpile life extension programs.

3.3.4 Handling of Insensitive High Explosives

Following a comprehensive review by its staff, the Board issued DNFSB/TECH-24, Safe

Handling of Insensitive High Explosive Weapon Subassemblies at the Pantex Plant. In this

report, the Board observes that the technical basis for performing operations on composite

insensitive high explosive (IHE) and conventional high explosive (CHE) subassemblies does not

fully support the assumptions used in establishing safety controls. For such subassemblies, the

inferred negligible likelihood of violent reaction in credible abnormal environments at Pantex

cannot be statistically defended on the basis of the small number of tests performed. As noted in

DNFSB/TECH-24, the size of the CHE booster or the level of stimulus that would cause the

CHE to react with enough power to initiate the IHE main charge to a violent reaction is

unknown. In the letter forwarding this report to DOE, dated December 6, 1999, the Board

requested that DOE reexamine its technical safety basis for handling composite IHE/CHE weapon

subassemblies. Additional modeling, experimentation, and analysis would clearly strengthen

DOE’s understanding of the safety margin in handling this class of subassemblies.
4-1

4. HAZARDOUS REMNANTS OF WEAPONS PRODUCTION

CONTENTS OF THIS SECTION

Section Page

4.1 STABILIZATION OF LEGACY MATERIALS ......................................... 4-2

4.1.1 Plutonium ............................................................... 4-3

4.1.2 Enriched Uranium ......................................................... 4-7

4.1.3 Uranium-233 ............................................................. 4-8

4.1.4 Special Isotopes ........................................................... 4-10

4.2 STABILIZATION OF SPENT NUCLEAR FUEL ...................................... 4-10

4.2.1 Hanford Site ............................................................ 4-10

4.2.2 Savannah River Site ........................................................ 4-11

4.2.3 Idaho National Engineering and Environmental Laboratory .......................... 4-12

4.3 STORAGE OF HAZARDOUS MATERIALS .......................................... 4-13

4.3.1 Building 371 at the Rocky Flats Environmental Technology Site ...................... 4-13

4.3.2 Storage of Uranium Hexafluoride .............................................. 4-14

4.4 WASTE MANAGEMENT ........................................................ 4-14

4.4.1 High-Level Waste ......................................................... 4-15

4.4.2 Low-Level Waste .......................................................... 4-18

4.4.3 Transuranic Waste ......................................................... 4-19

4.5 DEACTIVATION AND DECOMMISSIONING ........................................ 4-19

4.5.1 Rocky Flats Environmental Technology Site ..................................... 4-20

4.5.2 Hanford Site ............................................................. 4-21

4.5.3 Y-12 Plant ............................................................... 4-23

4.5.4 Miamisburg Environmental Management Project .................................. 4-23

As DOE attempts to close facilities and sites that are no longer needed for weapons

production, it is faced with many unique challenges. Numerous one-time activities must be

accomplished safely to ensure adequate protection of the public, workers, and the environment. 

The Board has consistently encouraged DOE and its contractors to undertake these activities in a

methodical and controlled manner; that is, they must understand the hazards presented by the

activity and materials involved, control those hazards, perform the work using appropriate safety

controls, and learn how the activity could be performed better. These are fundamental tenets of

ISM embodied in the Board’s Recommendation 95-2, Safety Management. 

In Recommendations 94-1, 95-1, 96-1, 97-1, and 99-1, the Board urged DOE to take

action to correct the storage problems resulting from the shutdown of many defense nuclear

facilities, recognizing that such unsafe conditions would become worse with time. Since then,

DOE has taken action to mitigate some of the most immediate concerns, but much of the 
4-2

material has yet to be stabilized and packaged for long-term storage or prepared for ultimate

disposition. This need to stabilize and confine unsafe material is seen by the Board as having the

utmost urgency.

During the processing of material for stabilization, packaging, and storage, it is important

for safety that the fundamental tenets of ISM be satisfied. Such control remains essential as DOE

facilities no longer needed for the weapons mission make the transition to deactivation and

decommissioning. In many cases, greater hazards, particularly to workers, arise during

deactivation and decommissioning of these facilities than those which existed when the facilities

were in operation.

In the discussion that follows, the Board reemphasizes the importance of stabilizing and

packaging legacy materials on an expedited basis and providing the necessary resources to

accomplish this objective. This is not a matter of preference; rather, it is an issue of public health

and safety that must be dealt with aggressively. The Board intends to assist DOE in this regard

through its strong focus on the safety of defense nuclear facilities and activities and through its

analysis of issues deserving high-priority attention.

4.1 STABILIZATION OF LEGACY MATERIALS

Significant stabilization of nuclear materials has been accomplished under the Board’s

Recommendation 94-1. The Board continues to monitor DOE’s progress on the Implementation

Plan for this recommendation and to request adjustments to the plan as required.

Accomplishments include mitigation of urgent risks (e.g., the repackaging of plutonium in contact

with plastic, the venting of thousands of drums containing plutonium residues to prevent the

buildup of explosive gases, and the stabilization of a number of types of nuclear materials), and

development of a plutonium storage standard (DOE-STD-3013), together with the processes and

equipment necessary to meet this standard. The more important hazards have been mitigated, and

large quantities of nuclear material have been stabilized, including more than 300,000 liters of

plutonium-239 solutions, nearly 16,000 deteriorating Mark-31 spent fuel elements, and more than

13,000 liters of plutonium-242 solutions.

In December 1998, DOE drafted a revision to the Implementation Plan for

Recommendation 94-1 to update the remaining activities and reflect changes in the approach from

the original plan of 1995. However, the revision was incomplete in key areas. Several plutonium

stabilization, packaging, and storage plans had been removed because of DOE’s decision not to

proceed as planned with construction of the Actinide Packaging and Storage Facility (APSF) at

SRS. This decision disrupted the SRS plan for stabilization, packaging, and storage of plutonium,

as well as stabilization plans at Hanford’s Plutonium Finishing Plant and other sites in the

complex.

The Board responded to the proposed Implementation Plan in a January 1999 letter to the

Secretary of Energy, accepting the plan subject to three conditions. The first two conditions were

partially satisfied by a March 26, 1999, letter from DOE providing contingency plans for

stabilization of HEU solutions at SRS and a path forward for stabilization of classified metal 
4

 Recommendation 2000-1 presents the Board’s determination of the relative risk for most of the

materials remaining to be stabilized. The recommendation also urges the Secretary of Energy to comply with the

provision of the Atomic Energy Act to report situations in which implementation of the Board’s recommendations

is impracticable because of budget constraints. The Board will continue to follow DOE’s implementation of

Recommendation 94-1 and to urge DOE to address the remaining problems.

4-3

parts at RFETS. However, DOE has not adequately responded to the third condition that it

evaluate the impact of not constructing the APSF as planned, and develop a path forward for

achieving the desired end-states for the affected materials. To satisfy this third condition, DOE

studied alternatives for stabilizing and packaging SRS plutonium and also evaluated the storage

requirements for stabilized plutonium packages. These studies were completed earlier this year,

but DOE has not yet decided on a path forward.

On September 9, 1999, the Board held a public meeting to gather information relative to

the reasons for delays in finalizing the revised Implementation Plan and accomplishing specific

stabilization activities, and to identify actions necessary to complete the remaining stabilization

activities in a timely manner. DOE personnel provided the status of delayed activities that involve

processing uranium and plutonium into stable storage forms, packaging plutonium for interim

storage, stabilizing spent fuel, and maintaining the facilities needed to perform these activities

during the next few years. The Board followed up on matters addressed during the public

meeting by letters to DOE dated September 22 and November 15, 1999. The thrust of the

Board’s correspondence was to urge DOE to devote the high-priority attention and resources

required to stabilize and store these unsafe materials, as had originally been committed to by the

Secretary of Energy. The desirability of such stabilization is not the issue, but apparently the

allocation of funds relative to other tasks is. This impasse led the Board to issue

Recommendation 2000-1, Prioritization for Stabilizing Nuclear Material in January 2000. This

recommendation addresses a priority-based approach for dealing with these legacy materials,

based upon such considerations.4 The Board is prepared to work with DOE to restructure the

program accordingly.

4.1.1 Plutonium

Stabilization of Plutonium Metals and Oxides 

In Recommendation 94-1, the Board urged DOE to place plutonium metals and oxides in

storage configurations that meet DOE’s standard for long-term storage (DOE-STD-3013,

Criteria for Preparing and Packaging Plutonium Metals and Oxides for Long-Term Storage). 

The Board and its staff have continued to actively follow each site’s preparations for stabilizing

and packaging plutonium metals and oxides to this standard. During 1999, the Board successfully

worked with DOE to ensure that the revision to DOE-STD-3013 currently being finalized would

continue to provide effective criteria for safe, long-term storage of plutonium metals and oxides. 

In December 1999, the Board issued a letter to DOE concurring with the revised storage standard

and requesting clarification of how a particularly important requirement controlling the scope of

the standard would be implemented in practice. 
4-4

DOE continues to make some progress on stabilizing plutonium metals and oxides. At the

Hanford Site, progress is being made in thermally stabilizing plutonium in accordance with DOESTD-3013, albeit slowly and without packaging per the standard’s requirements. SRS has

packaged numerous plutonium metal items in welded cans that may serve as the inner containers

in DOE-STD-3013 packages. However, no site except LLNL is currently packaging materials in

full compliance with DOE-STD-3013, and the SRS inner-canning system has been shut down

because of significant contamination of an FB-Line vault after a weld on one of the cans failed. 

The deferral of construction of APSF will further delay DOE’s progress.

A prototype automated plutonium stabilization and packaging system is currently being

installed at RFETS. RFETS has raised the issue that this system may not be able to meet the

DOE-STD-3013 requirement to avoid contaminating the outside of the inner can. RFETS has

requested that DOE remove this requirement from the standard, asserting that it serves no safetyrelated function. At year’s end, DOE was considering the RFETS proposal and other options for

addressing this issue.

Largely as a result of problems experienced with the RFETS prototype, DOE is moving to

less-automated systems for the other sites. The Board’s staff has actively encouraged DOE to

incorporate lessons learned from the prototype unit into the procurement of follow-on units for

SRS, LLNL, and the Hanford Site.

Plutonium Storage and Stabilization at the Savannah River Site 

DOE had planned to ship stabilized plutonium metal and oxide from the Hanford Site and

RFETS and store them in two SRS facilities—APSF and the K-Area Material Storage (KAMS)

facility. Numerous reviews by the Board and its staff have focused on the planning, design, and

safety analyses for these two facilities. At the end of 1998, SRS had an essentially complete

design for APSF and was starting modifications to the existing K-Reactor building for KAMS. 

While SRS made much progress on KAMS during 1999, work on APSF was halted with

indications that the program had been canceled. This situation adversely impacts SRS-related

commitments under Recommendation 94-1 since APSF was intended not only to store, but also to

stabilize and package SRS materials by May 2002.

KAMS is scheduled to begin receiving RFETS material in February 2000. During 1999,

DOE completed the first of two phases of preparing KAMS and conducted an ORR. KAMS

resides in a 45-year-old reactor building (105-K). Its safety posture is dependent on high-quality

containers that provide multiple barriers to release. The building no longer provides confinement,

but does protect against external hazards, such as tornadoes and earthquakes. Internal hazards

(e.g., fires, criticality) are addressed by new fire walls, the container design, and other design

features and controls. Since KAMS will not provide any capability to open or repackage

containers, a container surveillance program and a planned method for dealing with a damaged

container appear warranted, but they do not yet exist. DOE has stated that KAMS will be used

for interim storage for up to 10 years, until the containers can be moved to APSF or otherwise

dispositioned. Because of delays with APSF and with the proposed plutonium disposition

facilities, the Board believes that KAMS may be required for a longer period and that facility

redesign should be structured accordingly.
4-5

As noted earlier, in February 1999, DOE decided to defer APSF construction, primarily

because of higher cost estimates and insufficient allowance of funds for contingency, and began

demobilizing the project. This decision had a broad effect not only on material stabilization at

SRS, but also on the planned consolidation of plutonium storage at SRS from other sites

(particularly Hanford) and on the design of plutonium disposition facilities which, at that stage,

were dependent on APSF features.

In a March 1999 letter to the Board, DOE stated that it was prudent to halt the APSF

project, given significant increases in the estimated construction costs and DOE’s decision to

designate SRS as the preferred location for plutonium disposition facilities. In addition, DOE

stated that a systems engineering study would be performed that would consider the benefits

available through sharing functions with the plutonium disposition facilities. Later in the year,

however, DOE decided not to pursue such efficiencies, and began to revise the designs of the

disposition facilities to make them independent, as discussed in the Final Environmental Impact

Statement for Surplus Plutonium Disposition (November 1999). In a May 14, 1999 letter to the

Secretary of Energy, the Board reiterated its belief that the APSF functions are vital to SRS

stabilization activities, as well as to complex-wide efforts to consolidate plutonium storage in

modern, safe facilities at sites with enduring missions. The Board observed that the decision not

to pursue APSF construction appeared to have been made already in advance of engineering

evaluations.

In July 1999, DOE informed the Board that it was deferring the decision on how

plutonium would be stabilized and packaged at SRS. Instead, DOE began the conceptual design

for a stabilization and packaging system to be installed in an existing, 1950s-vintage,

contaminated building (235-F). DOE indicated that a decision regarding use of this system could

be made in July 2000 after the design is 35 percent complete, and that if pursued, this option

would support stabilizing and packaging SRS plutonium by July 2006 (i.e., a 4-year delay beyond

earlier schedules). In October, DOE expanded the scope of this study to include increased

storage in 235-F and KAMS to consolidate storage of plutonium from other sites, such as

Hanford, in these aging SRS facilities. In the case of 235-F, however, adding the storage mission

to planned stabilization and packaging would introduce inefficiencies. Preliminary estimates

indicate that doing so could delay completion of stabilization and packaging of SRS materials

until beyond 2008. This would amount to a 7-year deferral of the commitment in DOE’s current

Implementation Plan for Recommendation 94-1 (i.e., May 2002). 

As 1999 closes, it appears that the DOE strategy is likely to result in substantial delays in

stabilization and packaging of SRS materials. Furthermore, it is likely that pursuing the 

235-F/KAMS option could result in less useful facilities with less remaining service life, but with a

cost comparable to that of a new facility, such as the APSF design of a year ago. To date, DOE

has not committed to the out-year expenditures needed to either build a new facility or modify an

existing one. As a result, SRS is exploring other options, not involving capital expenditures for

stabilizing SRS materials. DOE has informed the Board to expect a new strategy in April 2000. 

The Board continues to follow developments in this area.
4-6

Plutonium Stabilization at Hanford

The current mission of the Plutonium Finishing Plant (PFP) is storage of plutonium,

stabilization of plutonium-bearing materials, and ultimately, transition to deactivation. PFP

contains approximately 3 metric tons of plutonium that is included in the safety issues in the

Board’s Recommendation 94-1. Most of these materials are stored in forms or configurations

that are not suitable for long-term storage. Throughout 1999, the Board urged DOE to

accelerate plutonium stabilization at PFP while continuing to ensure that operations are conducted

safely. Following a 2-year stand-down due to repeated instances of poor conduct of operations,

PFP resumed thermal stabilization of high-purity plutonium oxides in January 1999. On March 3,

1999, the Board transmitted a letter to DOE expressing concern that preparations for these

operations were not adequately thorough and systematic. The Board issued a letter to DOE on

May 26, 1999 urging DOE to aggressively implement the magnesium hydroxide precipitation

process for solution stabilization and to resolve seismic issues associated with startup of the

prototype vertical calciner. Stabilization of a small volume of pure plutonium nitrate solutions

using the prototype vertical calciner began in September 1999.

The technical staff also held several meetings with DOE-Headquarters, the DOE Richland

Operations Office, and PFP contractor personnel to discuss PFP’s commitments in the

forthcoming Revision 2 to the Implementation Plan for Recommendation 94-1. The Board

believed that some of the proposed changes involved imprudent and excessive delay, notably (1) a

19-month delay in completing polycube stabilization, and (2) significant delays in completing

packaging of plutonium metal and oxides for long-term safe storage, resulting from the plan’s

reliance on early shipment of materials to SRS. The early shipment is no longer possible because

of the delay and likely cancellation of APSF construction. In response to the Board’s concerns,

the PFP contractor proposed modifications to PFP’s vaults to accommodate the long-term

storage containers for plutonium, thus eliminating the reliance on early shipment to SRS; in

addition, DOE made a tentative commitment to restore the previously committed schedule for

polycube stabilization. 

The proposed revision to the Implementation Plan for Recommendation 94-1 now defines

milestones for achieving stabilization and safe long-term storage of all plutonium-bearing material

at PFP by May 2004. However, the aggressiveness of the completion dates proposed in the

revised Implementation Plan is questionable, and the Board has continued to encourage

improvements in that area. At the urging of the Board and its staff, PFP recently committed to

initiatives that will further accelerate stabilization, including a 300 percent increase in allowable

charge size for thermal stabilization of oxides and startup of three additional muffle furnaces for

thermal stabilization operations months ahead of the original estimates.

Plutonium Stabilization at RFETS

Within the DOE complex, the most substantial quantity of residues resides at RFETS. As

noted previously by the Board, expeditious disposal of low-risk residues at WIPP would satisfy

the intent of Recommendation 94-1. RFETS continued its characterization program and—with

the agreement of the Board—determined that certain salt, combustible, and crucible residues fell
4-7

in the low-risk category. In response to Recommendation 94-1, the following risk reduction

activities were accomplished at RFETS during 1999:

! Processed more than 6 metric tons of salt residues,

! Processed more than 7.5 metric tons of ash residues,

! Processed more than 8 metric tons of wet combustible residues, and

! Processed more than 12 metric tons of dry residues.

Most of the processing consisted of repacking low-risk materials for shipment to WIPP. To

resolve issues related to plutonium dispersibility raised by the Board’s Recommendation 94-3,

DOE is repackaging dispersible residues into robust containers (pipe overpack containers)

pending their shipment to WIPP.

Where they continue to exist, plutonium-bearing solutions present a significant hazard due

to the potential for spills and inadvertent criticality. The Board has strongly encouraged DOE to

process its inventory of plutonium-bearing solutions to a more stable form. During 1999, RFETS

continued to make progress in stabilizing its plutonium-bearing solutions and has now completely

drained the solutions from Building 371 and stabilized more than 3500 liters of solution. The site

has now processed all of its solutions except for a small quantity held in piping and tank heels in

Building 771. These solutions are being addressed during deactivation of the building. The

Board’s staff encouraged DOE to address plutonium-bearing systems early during Building 771

deactivation. DOE agreed and has now drained 10 systems containing plutonium-bearing

solutions, surpassing the Recommendation 94-1 commitment for FY 1999.

Stabilization of Surplus Plutonium Pits

The mission of the proposed Pit Disassembly and Conversion Facility (PDCF) is to

disassemble surplus pits and convert them to unclassified oxide for use in mixed-oxide fuel. DOE

plans to disassemble and process up to 35 metric tons of plutonium pits within a 10-year period. 

The Board’s staff met with the staff of DOE’s Office of Fissile Materials Disposition to discuss

important design issues for PDCF, such as the facility hazard category; seismic performance

category; classification of structures, systems, and equipment; hazard analysis; and incorporation

of the Nuclear Regulatory Commission licensing standards into the design. The staff also held

preliminary discussions on the geotechnical aspects of PDCF, the safety classification of fire

protection equipment, and ventilation system design.

4.1.2 Enriched Uranium

Highly Enriched Uranium Solutions at SRS

SRS is currently storing 230,000 liters of HEU solution in tanks outside H-Canyon. If

stabilization of HEU solution does not begin in a timely manner, continued operations at 
4-8

H-Canyon will result in a potential shortfall in tank storage of more than 100,000 gallons by 2002. 

If this problem is not resolved, H-Canyon operations may need to be curtailed. Furthermore,

continued accumulation of HEU solutions at SRS will require continued reliance on single-walled,

seismically vulnerable tanks in outdoor facilities. The potential exists for an inadvertent transfer,

equipment degradation and failure, or chemical reactions that could result in an inadvertent

criticality or compromise barriers to release.

The Board has been closely monitoring disposition plans for these solutions. The Board’s

staff visited SRS in February 1999 to review the hazards of continued storage of the solutions and

evaluate DOE’s plans for their stabilization. DOE intends to blend down the HEU solutions to

low-enriched uranium (LEU) solutions and transfer the material to a vendor designated by the

Tennessee Valley Authority (TVA) for use in the manufacture of commercial reactor fuel. DOE

plans to transfer the uranium solutions by spring 2003, assuming timely development of an

interagency agreement. However, this proposed schedule could be delayed as a result of

increased project costs and a lack of funding. 

In a letter dated January 28, 1999, which conditionally accepted Revision 1 to the DOE

Implementation Plan for Recommendation 94-1, the Board asked DOE to develop a contingency

plan for use in the event that an agreement with TVA is not reached within the time frame

established in the Implementation Plan. DOE recently initiated action to identify possible

alternatives to the TVA scenario, including downblending the solution to 1 percent uranium-235

in HA-Line and converting it to oxide in FA-Line. However, plans and schedules for

implementing this contingency plan are not fully developed. The Board will continue to press

DOE to eliminate these continuing uncertainties and stabilize these solutions.

4.1.3 Uranium-233

Uranium-233 (U-233) is a man-made isotope of uranium which contains varying quantities of Uranium-23

radioactive. Most of this material is stored at ORNL and INEEL, with a smaller quantity at LANL. The Board is

DOE to characterize, stabilize, and safely store its U-233 materials. Because most of the U-233 has not been insp

as to the safety of its current storage condition. 

During 1999, the Board conducted extensive reviews of ORNL’s preparations for its 

U-233 inspection program. As a result of these reviews, DOE has made a number of safety

improvements. The improvements included (1) implementing increased controls against the

possibility of a hydrogen explosion when vaults are opened to access the U-233 stored within, (2)

improving the radiation protection plan for the inspection program, and (3) developing specific

inspection criteria. The Board’s staff also identified the need for modifications to ventilation

systems to limit the potential spread of U-233 contamination from the handling of containers

during the inspection program. The staff found that improvements were needed as well in the

equipment used for handling U-233 containers, and that the ORNL contractor needed to improve

its conduct of operations significantly, particularly in the areas of formality of test controls and

use of procedures. Subsequently, on October 12, 1999, DOE implemented a 30-day pause,

followed by a DOE peer review to reassess the safety, scope, and approach of the U-233 
4-9

inspection and repackaging program. The Board now understands that initial U-233 inspection

operations will not commence until the latter part of 2000.

In response to a letter from the Board dated December 14, 1998 providing comments on

the draft U-233 storage standard, INEEL inspected one 55-gallon drum containing U-233 fuel

materials. INEEL found that, contrary to previous reports, the fuel pins and fuel pellets were not

wrapped directly in plastic. The U-233 fuel materials and the containers (including plastics within

the drum) showed no significant degradation or pressurization, providing some confirmation that

the sintered fuel pellets are remaining stable in storage.

Also in response to the Board’s December 14, 1998 letter, DOE has significantly

improved the draft U-233 storage standard and has conducted research and development to

bolster the standard’s technical basis. More significant, DOE revised the standard to be more

consistent with the requirements for plutonium storage, including the use of two nested welded

containers.

In accordance with its commitment in response to Recommendation 97-1, LANL recently

moved U-233 material from the Critical Experiments Facility (Technical Area 18) to a more

robust vault with filtered ventilation in the Chemistry and Metallurgy Research Facility. LANL

has also initiated plans to ship the U-233 to ORNL for long-term storage. However, ORNL’s 

U-233 is stored in Building 3019, part of which was constructed during the Manhattan Project. 

The Board’s staff recently conducted reviews of the fire protection and ventilation systems of

Building 3019. ORNL is in the early stages of completing a new Safety Analysis Report, a

requirements analysis for the ventilation system, a fire hazards analysis, and a seismic analysis for

the building. The completion of all these actions is required to identify upgrades needed to

support safe long-term storage of U-233 within Building 3019, or to enable a decision as to

whether the U-233 material needs to be stored in a more modern facility.

In 2000, the Board and its staff will continue to review DOE’s actions aimed at achieving

readiness to safely conduct the U-233 inspection program at ORNL, finalize the U-233 standard,

and develop a path forward for safe long-term storage of U-233 at ORNL.

Oak Ridge Molten Salt Reactor Experiment

The Board continued its oversight of the stabilization and removal of uranium fluoride

gases from the Molten Salt Reactor Experiment at ORNL, which is being carried out in

accordance with Recommendation 94-1. The successful removal of reactive gas (primarily

fluorine and uranium fluoride) from the head spaces of drain tanks and from off-gas system piping

reduced the total amount of U-233 remaining in the system from more than 37 kg to less than 15

kg. Preparations to remove U-233 deposits from the Auxiliary Charcoal Bed were delayed

because of technical problems associated with the discovery that the bed charcoal was no longer

in an easily removable (i.e., granular) form. The Board’s staff will follow the readiness review for

removal of uranium deposit and assess the results in 2000. Subsequent risk reduction activities

include removal of fuel and flush salt from the drain tanks, and stabilization/conversion of uranium

salts to oxides.
4-10

4.1.4 Special Isotopes

Americium/Curium Solutions

In Recommendation 94-1, the Board recommended expediting the stabilization of

americium/curium solutions stored in F-Canyon at SRS. In 1999, SRS completed 35 percent of

the conceptual design of a coupled induction melter system for the americium/curium solutions. 

Review of the design by the Board’s staff found that essential requirements for safety had been

adequately considered. Although DOE provided funding to allow early design work to proceed in

1999, there will be a significant funding shortfall in FY 2000 and FY 2001. In an attempt to defer

costs, DOE issued a request for proposals from industry to design, construct, and test the melter

systems. This action may allow work to proceed in the near term, but the effort could stall again

in the future unless additional funding or cost efficiencies are identified. The Board believes it is

important to expedite this project to eliminate the significant hazard posed by the

americium/curium solutions, and is continuing to pursue this issue with DOE.

Neptunium Solutions at SRS

SRS has 6,000 liters of neptunium-237 nitrate solution in tanks in H-Canyon. DOE plans

to stabilize this material by firing it to an oxide in the HB-Line facility. A decision on its ultimate

disposition has been delayed until DOE’s Office of Environmental Management and Office of

Nuclear Energy reach agreement on the stabilization of this solution and its transfer from the site. 

The Implementation Plan for Recommendation 94-1 committed DOE to stabilizing and packaging

the neptunium by December 2002. A subsequent revision of this date to September 2003 was

accepted by the Board. However, funding shortfalls and personnel shortages have again delayed

activities at HB-Line by at least a year. DOE now estimates that HB-Line, Phase II, can start up

in December 2001 and begin processing 34,000 liters of plutonium solutions that also remain in

H-Canyon. After this processing campaign, HB-Line Phase II could switch to the neptunium

solutions in FY 2003 or later. The Board is continuing to press DOE to identify the resources

needed to stabilize these solutions expeditiously.

4.2 STABILIZATION OF SPENT NUCLEAR FUEL

DOE’s spent nuclear fuel program encompasses coordination of activities at the various

DOE sites involved in placing spent nuclear fuel into safe interim storage. An additional goal of

this program is to ensure that the canisters used for interim storage can be used for shipment to

and burial at a national repository without repackaging. During 1999, the Board’s staff worked

with DOE’s staff to emphasize coordination of spent fuel storage activities at the Hanford Site,

SRS, and INEEL.

4.2.1 Hanford Site

Reviews by the Board and its staff identified shortcomings in the SNFP at the Hanford

Site K-Basins. These shortcomings included a continued lack of sound project management, 
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poor implementation of quality assurance requirements, and continuing difficulty in resolving

emerging technical issues in a timely manner. 

Since 1998, the Board and its staff had been urging that the new containers for storing the

spent fuel be code-stamped to the requirements of the American Society of Mechanical Engineers

(ASME) Boiler and Pressure Vessel Code. The project has successfully contracted for these

containers from a certified supplier at competitive prices. This is expected to ensure enhanced

quality to support ultimate disposal in a planned repository. 

During 1999, the project discovered that if a postulated drop of a loaded spent fuel cask in

the water-filled basin occurred, it could damage the pool to such an extent as to cause an

excessive leak of radioactivity into the ground and potential contamination of the nearby

Columbia River. The Board and its staff reviewed the planned system modifications and urged a

simple concept for resolution of this issue. As a result, additional actions are being taken to

minimize the likelihood of a cask drop event and to provide a means for stopping a leak should

one occur. Also as a result of discussions with the Board’s staff, DOE accepted the need for a

diesel generator to provide power for safety-significant electrical loads in the event of a loss of

power. 

A review by the Board’s staff of the experimental data developed by the SNFP to confirm

the oxidation rate of irradiated N-reactor fuel revealed that test data with extremely high

oxidation rates had been discarded as erroneous. The apparent high rates could, however, have

been due to crumbling of the solid fuel pieces and the generation of a large amount of reactive

surface area. At the urging of the Board’s staff, the project evaluated this phenomenon and

concluded that crumbling of irradiated uranium metal is realistic, and should be evaluated for

potential impact on the existing safety bases for operations.

4.2.2 Savannah River Site

In a technical report issued by the Board (DNFSB/TECH-7, Stabilization of Deteriorating

Mark 16 and Mark 22 Aluminum-Alloy Spent Nuclear Fuel at the Savannah River Site), the

technical rationale was established for using chemical separation to stabilize the deteriorating

defense-related spent nuclear fuel stored in the basins at SRS. During 1999, spent nuclear fuel

elements continued to be processed in the H-Canyon. To date, 492 of the 1883 Mark 16 and

Mark 22 assemblies have been processed. However, processing was stopped in September 1999

because of delays in starting second cycle operations in H-Canyon. Resumption of stabilization

activities is now expected in April 2000. Mark 16 and Mark 22 processing produces highlyenriched uranium solutions that are stored in H-Area awaiting a disposition path (see Section

4.1.2). Tank storage limitations in H-Area may require that spent nuclear fuel processing be

curtailed prior to completing this campaign. If the highly-enriched uranium solutions are

dispositioned as planned, Mark 16 and Mark 22 processing is now expected to be complete by

December 2003.

A large inventory of non-defense-related, aluminum-alloy spent fuel is also in wet 

storage in defense nuclear facilities at SRS. This inventory will continue to increase as 

additional fuel is received from off-site research reactors and other DOE sites. This fuel cannot
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be left in wet storage indefinitely, and will likely require treatment before ultimate disposal. In a

draft Environmental Impact Statement (EIS) issued in December 1998, DOE identified a new

technology (the melt and dilute process) as the preferred alternative.

There are potential safety risks associated with the melt and dilute process. The process

would involve molten, highly-enriched spent nuclear fuel elements and volatilized fission products

without the benefit of a canyon structure for confinement. In addition, fuel melting operations

could result in significant contamination of the facility that could impact equipment operation and

maintenance and introduce new challenges for the ultimate decommissioning of the facility.

The Board issued a technical report in February 1999 (DNFSB/TECH-22, Savannah

River Site Spent Nuclear Fuel) that identifies the risks associated with developing this technology

and recommends using existing stabilization and processing capability at SRS (i.e., H-Canyon). 

The draft EIS noted that the melt and dilute process could be implemented by 2005. Current

estimates have slipped this date to at least 2008, and additional delays are likely for implementing

a new processing technology. The Board will continue to monitor DOE’s progress in choosing

and safely implementing a spent nuclear fuel processing technology.

In 1997, the Board suggested that continued future operation of F- and H-Canyons would

require resolving several safety issues associated with the canyon’s exhaust system, electrical

equipment near its diesel fuel tank, control room fire hazards, firewater supply piping, emergency

power systems, diversion valves, and lightning protection systems. DOE committed to resolve

these issues. However, the long-term resolution of several of these issues required completion of

the canyon upgrade project which would return critical portions of the F- and H-Canyon exhaust

systems and their auxiliary equipment to acceptable reliability.

The Board’s staff has been closely following the upgrade project during the past two years

and has identified additional issues, including cable aging, diesel generator loading, coordination

of protective devices, and compliance with the Institute of Electrical and Electronics Engineers

(IEEE) standards. DOE has designed and is completing installation of new safety-class power

systems at F- and H-Canyons that comply with relevant safety-class IEEE standards. DOE is also

working to resolve other open issues, including contamination control procedures, seismic

adequacy of ventilation duct supports and circuit breakers, compliance of the installation of the

station batteries to relevant industry standards, and adequacy of missile barriers to protect

building openings.

4.2.3 Idaho National Engineering and Environmental Laboratory

The Implementation Plan for Recommendation 94-1 committed DOE to removing fuel

from an underwater storage basin for spent fuel (the CPP-603 Basin) at INTEC, by December

2000, because of concerns regarding storage conditions. DOE has met its milestones to date;

however, problems with conduct of operations, as well as delays in availability of lifting gear and

development of production-mode testing equipment for determination of moisture in fuel pins

removed from the Experimental Breeder Reactor (EBR-II), have caused a change in plans for fuel

movement. Current plans call for direct transfer of the EBR-II fuel from CPP-603 to
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CPP-666, a state-of-the-art fuel storage basin, without determination of the moisture levels, since

the fuel will be transferred to Argonne-West for treatment prior to disposal. Approximately 143

fuel units were removed from the CPP-603 Basin during 1999, leaving only 86 units to be

transferred in 2000. The Board and its staff will continue to review these activities to ensure that

they are performed in a timely and safe manner.

4.3 STORAGE OF HAZARDOUS MATERIALS

Since ultimate disposition of most legacy materials is many years away, it is important to

ensure that these materials are adequately and safely stored in the interim. During recent years,

the Board has issued several recommendations intended to upgrade storage conditions for these

materials, and the Board continues to review new storage areas and evaluate existing storage

conditions.

4.3.1 Building 371 at the Rocky Flats Environmental Technology Site

The Board issued Recommendation 94-3, Rocky Flats Plutonium Storage, to ensure that

the large quantity of special nuclear materials at RFETS would be safely stored. The Board

recommended that DOE take a systematic approach to evaluating the suitability of Building 371

for the proposed new mission of storing the site’s entire special nuclear materials inventory, and

prepare a program plan for building upgrades and improvements consistent with the building’s

mission. In response, DOE determined that upgrades to structures, systems, and components of

Building 371 were needed, as well as to its safety basis. The Board and its staff followed DOE’s

progress closely and were instrumental in leading DOE to take a systems engineering approach to

evaluating and developing upgrades, as well as integrating this approach into project management. 

Without the Board’s intervention, these evaluations would not have been completed in a timely

manner. 

In May 1999, the Board’s staff reviewed progress on the final phases of the Board’s

Recommendation 94-3. The upgrades to Building 371 required to ensure safe storage have been

satisfactorily completed, and a new safety basis has been implemented. Recommendation 94-3

has enhanced the ability to store material safely at the site. These enhancements include the

following:

! Modification of the building structure to make it more robust, increasing its ability to

withstand natural phenomena.

! Modifications of the safety system that protects the air filters in the ventilation system

to better ensure that fires would not cause a breach in filters that could lead to a

release of plutonium contamination from the building.

! Addition of an air filtration system to the ventilation supply system to prevent the

release of plutonium contamination in the event of a large fire in the building.
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! Storage of dispersible materials in more robust containers to minimize the potential for

release of these materials.

! Updating of the safety basis for operations in the building to ensure that necessary

safety systems were clearly identified, maintained, and operated to prevent or mitigate

the consequences of potential accidents.

On the basis of these accomplishments, the Board closed Recommendation 94-3 on May 27,

1999.

4.3.2 Storage of Uranium Hexafluoride 

Approximately 55,000 cylinders containing more than 500,000 metric tons of depleted

uranium hexafluoride (UF6) from the production of enriched uranium for both defense and civilian

purposes are stored outdoors at gaseous diffusion plants in Oak Ridge, Tennessee; Portsmouth,

Ohio; and Paducah, Kentucky. In early 1995, the Board found that the corrosion-resistant

coatings of the cylinders had not been maintained, and that many cylinders were being handled

and stored under conditions that could lead to an increased possibility of breaching of the

cylinders. In May 1995, the Board issued Recommendation 95-1, Improved Safety of Cylinders

Containing Depleted Uranium, recommending that DOE (1) begin an early program to improve

the corrosion resistance of the cylinders, (2) evaluate additional measures that would protect the

cylinders from corrosion, and (3) determine the proper form for long-term storage of UF6. Since

then, DOE has taken substantial actions to slow the degradation of cylinders from external

corrosion.

In November 1999, the Board was briefed by the Director of the Office of Nuclear

Energy, Science and Technology and his staff on the status of the implementation of

Recommendation 95-1. The Board was particularly impressed by DOE’s use of the systems

engineering process to develop a workable and technically justifiable program for management of

cylinders, which is now being used to govern the maintenance and surveillance of the cylinders. 

Although concerned that funding was not available for painting of cylinders during 1999, the

Board was pleased that DOE has committed to continuing implementation of the cylinder

management program as part of its accelerated program to convert these materials to a stable

form.

In recognition of DOE’s progress and the completion of all DOE commitments,

Recommendation 95-1 was closed on December 16, 1999. Nevertheless, the Board will continue

to monitor the long-term storage of the cylinders and the eventual conversion of the depleted UF6.

4. 4 WASTE MANAGEMENT

In keeping with the Board’s statutory mandate to ensure the establishment of appropriate

safety standards for DOE’s activities, the Board has consistently emphasized the importance of

finalizing and issuing DOE Order 435.1, Radioactive Waste Management. As a result of the
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 Board’s continuing attention to this issue, the Order was issued on July 9, 1999, and is expected

to be fully implemented by July 9, 2000. The final Order reflects numerous safety-related

provisions that resulted directly from the Board’s extensive review of the proposed requirements,

and incorporates the safety-related measures of Recommendation 94-2. The Order addresses

three major waste types—high-level, transuranic, and low-level waste—and the safety

requirements for design, construction, operation, and decommissioning of associated facilities. 

The following subsections address, for each of these waste types, those activities in defense

nuclear facilities essential for the protection of the health and safety of the public.

4.4.1 High-Level Waste

Idaho National Engineering and Environmental Laboratory

Processing of liquid waste at the INTEC at INEEL is driven by the requirements of the

Settlement Agreement entered into by DOE, the U.S. Navy, and the State of Idaho in October

1995. To reduce the risks associated with long-term storage of high-level waste in tanks at

INTEC, INEEL calcines the liquid waste in the New Waste Calcining Facility and stores this

solidified product in on-site bins. In addition, a high-level waste evaporator was constructed and

operated to reduce the volume of liquid waste to be stored prior to calcination. 

All non-sodium-bearing waste was calcined by June 1998, leaving only sodium-bearing

waste, which is more difficult to calcine. By February 1999, INEEL was able to satisfy the

environmental requirements of the State of Idaho and the U.S. Environmental Protection Agency

for characterizing the atmospheric effluents from the calciner so that calcining of sodium-bearing

waste at elevated temperatures could be initiated. However, operational upsets caused the

calciner to be shut down in May 1999. Approximately 1.3 million gallons of sodium-bearing

waste remains in tanks awaiting processing. Some of this liquid waste is in tanks that are

vulnerable to earthquakes. While INTEC plans to resume calciner operation in January 2000, the

ultimate disposition of the sodium-bearing waste will be decided by the outcome of an EIS issued

for public comment at the end of 1999, followed by a record of decision in the spring of 2000. 

The Board will review the results of these evaluations when they become available.

During 1999, several reviews of INTEC were conducted by the Board’s staff. Problems

were identified in work planning and the safe conduct of work. These problems have been

identified to DOE for corrective action. The Board and its staff will continue to oversee

operations at INEEL and work with DOE to ensure that safety is paramount in operations at

those facilities under the purview of the Board.

Savannah River Site

In-Tank Precipitation Facility. The In-Tank Precipitation (ITP) facility at SRS was

intended as a pretreatment facility for use in concentrating and removing radioactive fission

products from high-level waste liquids. The separated fission products would have been

processed at the Defense Waste Processing Facility. The decontaminated liquids would have been

processed at the Saltstone Production Facility. Chemical and radiolytic decomposition of the

tetraphenylborate precipitating agent occurs during the ITP process, generating substantial
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quantities of benzene, a flammable and carcinogenic gas. If the accumulated precipitates were to

decompose rapidly, the resulting benzene release could be very large, posing a major flammability

hazard. The Board’s Recommendation 96-1, In-Tank Precipitation System at the Savannah

River Site, was issued in August 1996 to ensure that the hazards associated with the ITP process

would be adequately understood and controlled before the ITP Facility commenced operations. 

Laboratory experiments carried out in response to Recommendation 96-1 confirmed the Board’s

concerns and led DOE to conclude early in 1998 that the ITP process could not be operated

safely without significant upgrades to the ITP Facility. As a result, DOE has halted efforts to

begin operations at the ITP Facility, and alternatives to the ITP process are under evaluation. 

The Board has carefully reviewed the methodology DOE is using to evaluate alternative

waste treatment technologies, as well as the results of these evaluations. DOE began with a wide

variety of candidate technologies and systematically reduced the field to four finalists: small-scale

tetraphenylborate precipitation, nonelutable ion exchange, caustic-side solvent extraction, and

direct grouting of tank liquids without cesium removal. The Board agrees that each of these

options could be carried out safely, but each also has its strengths and drawbacks. Notable

drawbacks include the need to deal with benzene in downstream facilities for the small-scale

tetraphenylborate option, the large radiological source term of the loaded nonelutable exchange

media, the immaturity of the caustic-side solvent extraction process, and the on-site disposal of

large quantities of radioactive cesium for the direct grouting option. DOE has not yet decided

how to proceed from this point, and it is not clear when DOE will choose a primary option. 

Immobilization of high-level waste at SRS remains one of the Board’s highest priorities, and the

Board will continue to review DOE’s efforts to select a safe and effective process to replace ITP.

High-Level Waste Facilities. A major activity of the Board in 1999 was the review of

DOE’s preparations for startup of the new replacement high-level waste evaporator in the SRS HArea tank farm. The new evaporator is needed to concentrate high-level waste from the 

H- and F-Canyons at SRS, as well as liquids generated by washing of high-level waste sludge and

by the Defense Waste Processing Facility. A review by the Board’s staff of the engineered and

administrative controls designed to prevent or mitigate postulated accidents revealed several

safety issues regarding implementation of controls. For example, the system to control the

evaporator level does not meet the requirements for a safety-class system, and the proposed

controls do not adequately ensure that waste would be removed from a shut-down evaporator in a

timely manner to prevent a potential hydrogen explosion. Subsequent discussions with site

personnel led to a satisfactory plan for improvements to address all of the identified safety issues.

The Board’s staff also observed the contractor’s and DOE’s ORRs for the evaporator. 

Based on observation of the contractor’s ORR, the Board’s staff concluded that the ORR began

prematurely and was used inappropriately as a means of achieving readiness, rather than

confirming it. This problem is frequently observed in the DOE complex, and the Board will

continue to emphasize to DOE that better preparations are needed before commencement of

readiness reviews. The staff also noted that the plan and procedures for the phased startup of

radioactive operations had not been completed, and that these items are key to ensuring a safe,

controlled startup of the facility. The subsequent ORR by DOE confirmed these findings. The
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Board will review the startup plans and procedures once they have been completed, and will

provide close oversight of the commencement of radioactive operations at the facility.

Hanford Site 

Characterization of High-Level Waste in Tanks. The system for storage, retrieval,

processing, and immobilization of the high-level waste currently in 177 underground storage tanks

at the Hanford Site has consistently been one of the Board’s top priorities. The Board issued

several recommendations between 1990 and 1993 regarding the safe storage and characterization

of the wastes, as well as the need to use an effective systems engineering approach in the

development of waste disposal facilities. Continued attention to these matters by the Board

resulted in the institutionalization of the tank characterization program and the development and

implementation of controls to ensure that the wastes remain safely stored.

As a result of the progress made in the characterization of high-level tank wastes, the

Board closed Recommendation 93-5, Hanford Waste Tanks Characterization Studies, on

November 15, 1999. In responding to Recommendation 93-5, DOE has completed core sampling

of 132 of the 177 tanks and performed a tank-by-tank evaluation of the remaining tanks to ensure

that adequate characterization information is available to ensure continued safe storage without

further sampling. DOE has removed the high-heat sludge that was inappropriately stored in Tank

C-106 and transferred it to a tank designed for the storage of such waste. Finally, DOE has

resolved safety issues associated with nuclear criticality, flammable gases, and potentially

hazardous organic complexants and ferrocyanide compounds, and has developed and begun

operating in accordance with an updated tank farm authorization basis document that takes into

account the information gathered under the characterization program responding to

Recommendation 93-5.

In closing Recommendation 93-5, the Board recognized that considerably more

characterization information is needed to support the programs that will ultimately dispose of the

Hanford tank wastes. The Board therefore strongly encouraged DOE to maintain the existing

infrastructure supporting characterization, with particular emphasis on retention of technically

competent staff and continued use of the systems engineering architecture developed for the

waste disposal programs.

High-Level Waste Tank SY-101. In late 1997, DOE discovered that the waste level in

Tank SY-101 had risen 2 to 4 inches during the year. Subsequently, the level continued to rise,

and DOE discovered that, as a result of the formation of a crust layer, flammable gas was being

trapped in the upper region of the waste. These changes in gas retention behavior have not

resulted in new credible mechanisms that could cause gas accumulating in the vapor space in the

tank to reach flammable concentrations. However, DOE has determined that the increased

volume of flammable gas stored within the tank represents an unacceptable risk. Applying

information gained from its tank waste characterization program and using the systematic

approach developed in response to Recommendation 92-4, DOE methodically investigated this

phenomenon and developed a plausible explanation and plans for remediating the situation. 
4-18

DOE’s existing plan involves a series of transfers and dilutions of waste in Tank SY-101

to facilitate destruction of the crust and controlled release of gases. DOE designed, constructed,

and installed a system of pumps and transfer lines and on December 18, 1999, successfully

transferred 89,500 gallons of Tank SY-101 waste into Tank SY-102. Following this transfer,

dilution water was also successfully added to Tank SY-101 in preparation for the next transfer. 

In addition, DOE met its objective of safely releasing a portion of the flammable gas trapped in

the tank. The Board closely evaluated these activities and is continuing to encourage DOE to

proceed with this strategy with the appropriate caution. 

High-Level Waste Tank C-106. In late 1998, DOE began the process of removing

about 200,000 gallons of high-level waste sludge from a 50-year-old single-shell tank (C-106) and

transferring the waste to a double-shell tank (AY-102) that is designed to handle the high heat

output of the waste. Tank C-106 had the highest heat content of any single-shell tank at the

Hanford Site, and the addition of 6,000 gallons of water each month was required to cool the

waste. The removal of waste from Tank C-106 was desirable both to reduce the potential for

leakage to the environment and to eliminate the monthly addition of water, which had significantly

complicated attempts at sensitive leak detection. The waste is removed via a sluicing process that

uses a high-pressure liquid jet and vertical lift pumps to mobilize and retrieve the waste. This is

the first attempt to transfer radioactive waste sludge at the Hanford Site since 1978. 

Although some difficulties were encountered initially, the transfer of the wastes to Tank

AY-102 has been completed. The Board closely reviewed the resolution of issues associated with

the release of volatile organic compounds during transfer; the redesign, construction, and

replacement of waste transfer lines to eliminate leaks at fittings; the formulation of lessons learned

from this project for use in upcoming waste retrieval; and the modeling performed to show that

sufficient sludge had been retrieved to ensure the safe long-term cooling of the residual contents

of Tank C-106. The Board has encouraged the dissemination of important lessons learned

regarding the retrieval system to support further retrieval and disposition of high-level wastes at

the Hanford Site. The Board considers the safety issues associated with the high-heat contents of

Tank C-106 to be closed and has communicated this conclusion to DOE through closure of

Recommendation 93-5.

4.4.2 Low-Level Waste

Recommendation 94-2, Conformance with Safety Standards at DOE Low-Level Nuclear

Waste and Disposal Sites, called for a complex-wide review of DOE’s low-level radioactive

waste program to establish the dimensions of the low-level waste problem and to identify 

suitable corrective actions. By the end of 1998, most of the actions proposed in the

recommendation either had been completed or were being addressed appropriately. The

remaining open actions included meeting the requirement for development and issuance of

additional requirements, standards, or guidance on low-level waste management that would

address (1) the safety aspects of the waste form and packaging; (2) siting and performance

assessment of sites used in burial of the wastes; and (3) facility design, construction, operation,

closure, and environmental monitoring. This action was accomplished through issuance of a 

new waste management directive, DOE Order 435.1, on July 9, 1999. The two additional 
4-19

actions necessary for closure of Recommendation 94-2 were (1) evidence of satisfactory progress

toward completion of the remaining analyses for comprehensive performance assessment for

existing low-level waste burial grounds, and (2) implementation of an acceptable strategy for

meeting needs for research and development on outstanding low-level waste. Following

completion of these requirements, the Board closed this recommendation in December 1999.

4.4.3 Transuranic Waste

Waste Isolation Pilot Plant 

WIPP, located 26 miles east of Carlsbad, New Mexico, is a geologic repository for

defense transuranic (TRU) nuclear wastes. The Board has been reviewing the operational safety

of WIPP since early 1990. The Board increased such activity in late 1997 in response to DOE’s

planned mid-1998 startup of WIPP disposal operations. The Board’s staff reviewed the WIPP

authorization basis documentation, as well as the waste characterization and certification audit

process used by the DOE Carlsbad Area Office for the sites expected to make initial shipments to

WIPP for disposal. The Board’s staff also evaluated DOE’s ORR for WIPP, an emergency

preparedness exercise, and the safety and reliability of the mine hoist intended for lowering waste

below ground for disposal. The Board concluded that WIPP could be operated safely.

On March 23, 1999, WIPP became operational with receipt of the first shipment of TRU

waste from LANL. The Board monitored the first receipt and emplacement of waste in March

and continued to observe operations during the remainder of the year as the operations

progressed with shipments from INEEL and RFETS. The Board will continue to monitor

operations in 2000 as WIPP continues to ramp up to its full capacity of 17 shipments per week.

Advanced Mixed Waste Treatment Project

The Advanced Mixed Waste Treatment Project (AMWTP) at INEEL is a privatized

activity to retrieve, characterize, treat, and package a large inventory of low-level/TRU waste that

originated from defense nuclear facilities elsewhere in the DOE complex. The design is at the

20–30 percent stage, and operations are scheduled to begin by 2003. Questions were raised in a

1998 review by the Board’s staff concerning the adequacy of preliminary safety analyses and the

identification of structures and systems relied upon to perform safety functions. Three of the four

issues (electrical systems, seismic design, and life safety code) are now closed, but the fourth

issue, criticality control, requires further review. In addition, the staff is continuing to review a

number of issues associated with the authorization basis, controls, and safety systems. Overall,

however, the AMWTP design is progressing well. 

4.5 DEACTIVATION AND DECOMMISSIONING

A key objective of the Board regarding the hazardous remnants of weapons production is

to ensure that DOE is aggressively pursuing the safe decommissioning of defense nuclear 

facilities that are no longer needed to meet national security missions, and that pose a significant
5

 Formerly referred to as the Mound Plant.

4-20

risk to workers or the public. This objective is achieved by conducting reviews of the following

general types:

! Evaluating the condition and contents of inactive facilities to determine where more

expeditious stabilization actions are required.

! Evaluating proposed decommissioning activities and technologies.

! Reviewing the application of the principles of ISM to the planning and execution of

decommissioning activities.

! Observing activities to confirm that decommissioning of nuclear facilities is performed

safely.

During 1999, the Board focused its attention on DOE’s development of guidance used to

implement requirements related to deactivation and decommissioning, and on deactivation and

decommissioning activities at RFETS, the Hanford Site, the Y-12 Plant, and the Miamisburg

Environmental Management Project (MEMP).5 The number of cleanup projects selected by the

Board for priority attention, based on the considerations set forth above, is small relative to

DOE’s total environmental restoration program.

4.5.1 Rocky Flats Environmental Technology Site 

In 1999, the Board’s staff was involved in several reviews at RFETS associated with the

planning and implementation of deactivation and decommissioning activities. Throughout the

year, the Board staff followed issues related to the development and implementation of controls

for such work. 

Building 771

Among DOE’s defense nuclear facilities slated for decommissioning, the Board has

identified Building 771 (the former Plutonium Recovery Facility) at RFETS as one having the

highest priority. Building 771 originally contained more than 50 kg of plutonium held up in

gloveboxes, ducts, equipment, plenums, furnaces, tanks, piping, and contaminated rooms or areas. 

Tapping and draining the piping used for actinide and reagent solutions and cleaning out residual

liquids in nominally empty tanks began in 1998 and continued in 1999. The Board encouraged

RFETS to begin early to process high-risk systems containing plutonium solutions. The removal

and size reduction of gloveboxes began in earnest in 1999. Based on observation of activities at

RFETS, the Board became concerned that RFETS tended to rely principally on personal

protective equipment (PPE) during decommissioning, rather than using engineered controls that

eliminate or mitigate hazards more effectively. In response to the Board’s concern, RFETS has

embraced the revised goal of dependance on engineered controls, and has expanded the use of

such controls to mitigate hazards. 
4-21

The Board’s staff has overseen the development and implementation of engineered

controls for size reduction of gloveboxes in Building 771. Weaknesses were noted in systems

engineering, integration of safety disciplines during design and systems testing, and the approach

taken to achieve worker proficiency. Following discussions with the contractor, some

improvements were observed. For example, RFETS decided to provide workers the opportunity

to gain proficiency by working on a clean glovebox prior to size reducing radioactively

contaminated gloveboxes and before conducting tests. The Board and its staff will continue to

closely follow decommissioning activities at Building 771, which are expected to continue

through 2004.

Building 779

Decommissioning activities at Building 779 (the former Plutonium Process Development

Building), a moderate-risk plutonium facility, began in early 1998 and continued in 1999. 

Building 779 was the first major plutonium building at Rocky Flats to undergo decontamination

and decommissioning. Decontamination, removal of 133 gloveboxes, and removal of plutonium

holdup have been completed. Demolition of the structure began in October 1999 and was

completed in January 2000. 

During 1999, the Board’s staff reviewed selected activities within the facility, including

removal of gloveboxes and ventilation systems, and structural decontamination. Activities of the

Board’s Site Representative included numerous walkdowns of the facility to observe operations,

follow-up on contamination incidents, attendance at prejob briefs to observe discussions of

lessons learned, review of procedures for glovebox size reduction, and assessment of the

implementation of radiological corrective actions.

4.5.2 Hanford Site

In 1999, the Board’s staff reviewed various deactivation and decommissioning activities at

the Hanford Site. The staff performed facility walkdowns, discussed issues with DOE and

contractor personnel, and reviewed documents related to safety.

Plutonium Concentration Facility

The U-233-S Plutonium Concentration Facility (233-S Facility) was built in 1955 to

further concentrate the plutonium nitrate solution produced by solvent extraction in the REDOX

Plant. The 233-S Facility operated until July 1967, at which time the building was added to

DOE’s program of surplus facility management as a retired facility. An estimated 1.5 kg of

plutonium-239 remains in the process portion of the facility. DOE’s program for removal calls

for dismantlement and disposal of highly contaminated process systems, decontamination and/or

stabilization of the facility, then demolition and disposal.

During this year, the staff monitored readiness reviews that were conducted by the

contractor and DOE personnel in preparation for work that was to include a major ventilation

modification and removal of a hot cell panel, reviewed work planning for various activities

associated with deactivation and decommissioning, and reviewed safety basis documents. The
4-22

staff has found persistent weaknesses in work planning in the areas of hazard identification and

analysis. The staff identified in the safety documentation a significant underestimation of the

dispersible plutonium inventory contained in the facility. Although the contractor resisted making

changes in the safety basis to reflect this shortcoming, subsequent characterization data confirmed

much higher levels of plutonium contamination than had previously been assumed. The

contractor has now initiated revisions to the safety basis for the 233-S Facility that will have an

impact on hazard controls, procedures, and work activities. The Board has requested that DOE

describe actions to correct the programmatic deficiencies that led to this improper hazard

identification.

Bulk Reduction Building

The Bulk Reduction Building (224-T), built in the early 1940s as part of Hanford’s 

T-Plant complex, was used to concentrate plutonium solutions. After the process cells ceased

operation in 1956, they were sealed and isolated from the rest of the facility. The section

including the offices and operating gallery was renamed the Transuranic Storage and Assay

Facility (TRUSAF) in 1985, and was used to store drums containing TRU waste. With its

mission now at an end, TRUSAF is almost completely empty. 

Until recently, no DOE Richland Operations Office or contractor organization

acknowledged ownership of the process cells in 224-T, although various organizations were

responsible for TRUSAF. No one has entered the process section of the facility for at least 20

years, and contents of the process cells are not well known. On April 15, 1999, DOE’s Office of

Nuclear Materials and Facility Stabilization and Babcock and Wilcox Hanford Company (now

Fluor Hanford) assumed responsibility for the entire facility.

Later in 1999, the Board’s staff met with DOE and its contractor to discuss potential

safety issues and the status and management of the facility. As a result of these discussions, Fluor

Hanford installed monitoring equipment, conducted tests, and completed some safety reviews. 

These actions addressed some of the staff’s concerns regarding the configuration of the 

ventilation system and hazards of the facility, and the site is continuing to make progress. For

example, a schedule for entering portions of the facility to identify hazards has been developed. 

The Board’s staff intends to continue to follow the resolution of the outstanding issues associated

with this facility. 

Buildings 324/327

Buildings 324 and 327 in the Hanford 300 area are laboratory facilities with hot cells that

were used for studies related to waste treatment/immobilization and fuel elements, and

examination of radioactive materials. These facilities are only 1.5 miles from the city of Richland,

and they represent one of Hanford’s major radiological hazards. The primary stabilization activity

in Buildings 324/327 is the ongoing cleanout of approximately 550,000 curies of radioactive

materials from Building 324. One large hot cell (B-cell) is of special concern because it contains

about 120,000 curies of contamination in the form of easily dispersible material. B-Cell is

scheduled to be cleaned out by the end of FY 2001. 
4-23

In January 1999, sparks from a plasma arc torch used to size reduce former processing

equipment in B-Cell ignited combustible materials in an open waste container. The resulting fire

was extinguished by operators using a manual water spray. The Board’s staff held discussions

with project personnel following the fire and reviewed the proposed corrective actions. 

Procedures were changed to require operators to maintain the inventory of combustible material

and to place protective barriers that would isolate the materials from any sparks from cutting. 

The corrective actions have been successful in allowing continued plasma arc cutting to proceed

safely.

4.5.3 Y-12 Plant

Building 9206 at the Y-12 Plant is a Hazard Category 2 nuclear facility currently

functioning in warm standby as an in-process storage building. There are no plans to restart

operations in the building. Many vulnerabilities in the facility have been identified by both the

Board and DOE's HEU Vulnerability Assessment of 1996. The facility is being prepared for

deactivation, which will involve removing fissile and other hazardous materials (2,600 batches of

uranium-bearing material containing 3,200 kg of uranium-235).

In a letter to DOE in February 1998, the Board noted that a lack of attention to the

building was causing the hazards and risks associated with the building to increase. Based on a

recent staff review, it is apparent that many of the same issues persist almost 2 years later (e.g.,

insufficient progress toward stabilization of excess in-process material, lack of quantification of

holdup). In another letter to DOE in November 1999, the Board reiterated the importance of not

allowing the facility and its systems to deteriorate any further, and the need to expedite risk

reduction activities. The Board requested that DOE provide a written path forward for proposed

risk mitigation. The response provided by DOE in December 1999 did not commit to the timely

response needed to address these hazards. The Board is continuing to press this issue.

4.5.4 Miamisburg Environmental Management Project

The mission of MEMP in Miamisburg, Ohio, is cleanup, environmental restoration, and

private economic development. The site was built in the 1940s to produce components for

nuclear weapons using tritium. In September 1998, a significant milestone was reached at the site

when the last quantity of bulk tritium was removed. 

The cleanup of the residual tritium and the dismantlement of the facilities and process

equipment pose new challenges to the health and safety of the workers performing these activities. 

During this year, the Board’s staff followed technical issues associated with the radiation

protection program for work in areas suspected of being contaminated with tritium compounds,

such as metal tritides. The MEMP contractor has prepared a corrective action plan in response to

the staff’s issues.

Because radiation protection measures for metal tritides may be applicable to other DOE

defense nuclear facilities, and because some metal tritides and organically bound tritium may

behave differently from elemental tritium or tritium oxide, new radiation protection approaches

appear to be needed. In a letter to DOE dated April 29, 1999, the Board requested information
4-24

regarding a technical position on the approach that should be used, and requested that DOE

describe any new requirements, guidance, and compensatory measures that may be necessary. As

a result of this action, DOE responded in a letter to the Board dated June 10, 1999, identifying a

path forward for evaluating this issue throughout the complex and developing an updated

technical approach. DOE committed to taking compensatory measures to remind its sites of the

possible presence of metal tritides and organically bound tritium, and to inform them of the

technical information about these tritium compounds that is currently available.

DOE has made progress toward meeting its commitments. DOE has determined that

there is a need to enhance its policy pertaining to special tritium compounds, and has developed

an approach that is expected to lead to the promulgation of needed formal requirements and

guidance. In the interim, DOE will work with MEMP and other field organizations to provide the

guidance and compensatory measures required to allow needed work to continue. The Board will

continue to assess DOE’s progress to ensure that decommissioning work at MEMP is supported

by adequate technical analysis and controls.
5-1

5. ADMINISTRATIVE MATTERS

CONTENTS OF THIS SECTION

Section Page

5.1 HUMAN RESOURCES ............................................................ 5-1

5.1.1 Recruiting of Technical Staff ................................................. 5-1

5.1.2 Statutory Ceiling and Location of Staff .......................................... 5-1

5.1.3 Continuous Training and Education Levels of Staff ................................. 5-2

5.1.4 Recruitment and Retraining Tools .............................................. 5-2

5.2 ACQUISITION AND FINANCIAL MANAGEMENT ..................................... 5-3

5.3 INFORMATION TECHNOLOGY AND SECURITY ..................................... 5-3

5.3.1 Information Technology ...................................................... 5-3

5.3.2 Information Security ........................................................ 5-4

5.3.3 Preparation for Year 2000 .................................................... 5-4

5.4 INQUIRIES INTO HEALTH AND SAFETY ISSUES ..................................... 5-4

5.5 PUBLIC INTERACTION WITH THE BOARD .......................................... 5-5

5.1 HUMAN RESOURCES

5.1.1 Recruiting of Technical Staff

Each year the Board actively seeks the brightest engineering graduates from colleges and

universities across the country, as well as talented engineering professionals who share the

Board’s dedication and commitment to carrying out its public health and safety mission. The

Board's ongoing efforts to recruit individuals of high intellectual caliber and exceptional technical

capabilities have enabled it to acquire a staff competent in all major aspects of nuclear safety, with

multidisciplinary backgrounds that include extensive experience in nuclear, mechanical, electrical,

chemical, and structural engineering, as well as physics and metallurgy. Moreover, most mid- to

senior-level technical staff members possess practical nuclear experience gained from duty in the

U.S. Navy’s 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. Also notable is the fact that three members of the General

Counsel’s office have technical/scientific degrees in addition to their law degrees, and two are

licensed professional engineers.

5.1.2 Statutory Ceiling and Location of Staff

By law, the Board is authorized to hire up to 150 full-time employees. As of 

December 31, 1999, it had 5 full-time Board Members and 95 full-time staff. The Board plans to

staff approximately 10 technical positions within the next year; 3 of the 10 positions are 
5-2

expected to be entry-level interns who will be part of the Board's 3-year professional development

program..

While most of the Board’s technical staff operates from offices in Washington, D.C.,

10 staff members are located at various DOE field sites. Specifically, there are 2 Site

Representatives at the Pantex Plant near Amarillo, Texas; 2 at the Hanford Site in Richland,

Washington; 2 at the Rocky Flats Environmental Technology Site near Denver, Colorado; 2 at the

Savannah River Site near Aiken, South Carolina; and 2 at the Oak Ridge Site near Oak Ridge,

Tennessee. The Site Representatives are aided in their work by regular visits from the Board’s

Washington-based technical staff, who can and do bring specialized disciplines to assist in solving

technical problems.

5.1.3 Continuous Training and Education Levels of Staff

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

knowledge. Therefore, the Board encourages its technical staff to improve their skills continually

through academic means. Currently, 91 percent of the staff hold advanced degrees, of which 23

percent are at the Ph.D. level. 

The other technical staff members, all of whom are select college graduates, have been

recruited through the Board’s professional development program. This program is highly

prestigious and fully funded by the Board. Entry-level employees recruited into this 3-year

program receive a formal graduate-school education and intensive on-the-job training by

experienced technical mentors. Currently, there are three entry-level employees in this program,

and by summer 2000, each of these individuals should be awarded a masters degree from an

engineering program. 

During fall 1999, four employees in the Board’s professional development program

completed 3 years of training with outstanding academic achievement and on-the-job

performance. While this program continues to evolve, at the core it remains an extremely useful

recruiting tool in attracting high-quality entry-level engineers and prepares them for challenging

assignments in their fields.

5.1.4 Recruitment and Retraining Tools

From its inception, the Board has had specific statutory authority to pay competitive

salaries to high-quality candidates interested in filling the Board's technical positions. Other

flexibilities include the Board’s discretionary authority to offer a recruitment bonus in the form of

a lump-sum payment of up to 25 percent of basic pay. In an effort to retain quality employees,

the Board has continued its pay-for-performance system. This system gives employees the

opportunity to receive cash bonuses and increases in their base pay in addition to promotions. 

Employees are also provided health and life insurance, and thrift savings and retirement benefits,

plus an annual cost-of-living increase in salary. Nonmonetary attractions include family-friendly

work options, an alternative work schedule that allows an employee one day off in a biweekly pay

period, a metro subsidy, and a fitness facility on site.
5-3

5.2 ACQUISITION AND FINANCIAL MANAGEMENT

The Board acquires outside experts to provide a variety of specialized technical expertise

in areas such as nuclear weapons assembly and disassembly, plutonium processing, and conduct of

operations. This expertise has been, and will continue to be, a valuable resource to the Board in

the conduct of its complex and challenging health and safety oversight responsibilities.

In the area of financial management, the Board initiated reviews of its internal controls to

ensure that they were effective and were achieving the intended results. Improvements were

implemented in selected areas to strengthen the controls. The increased use of electronic

payments and reimbursements to employees has resulted in greater efficiencies and higher levels

of customer service.

The Board has continued to improve the efficiency of its procurement operations through

streamlining initiatives and the expanded use of credit cards for various purchases. Specifically,

the number of individuals using credit cards has increased throughout the agency; the result has

been more timely and efficient acquisition of goods and services, and a significant reduction in the

creation of purchase orders and related paperwork. These initiatives have also included a

comprehensive review of internal management controls and resulted in new or revised procedures

where appropriate.

5.3 INFORMATION TECHNOLOGY AND SECURITY

5.3.1 Information Technology

To ensure that its information and communications capabilities remain at the highest levels

possible, the Board has made necessary upgrades to system hardware and software throughout

the year. Several key initiatives were implemented to improve and protect the Board’s

information technology infrastructure. In addition, the Board initiated a review of all agency

information systems to streamline and integrate them to the extent possible.

The Board has begun to use media streaming technology to deliver audio and video

information to its staff and the public. The streaming format allows information that was

previously available only on videotape to be seen by multiple viewers simultaneously without

having to leave their desks. This approach allows the Board to provide richer content to its staff

and the public, and will be used in the future to improve the way the Board provides employee

training, coverage of public hearings and meetings, and many other business services.

The Board has continued its successful use of video teleconferencing technology for the

rapid exchange of information during briefing sessions with multiple DOE field sites on issues that

impact the entire weapons complex. This technology enables the Board’s Headquarters and field

staff to receive briefings from DOE and its contractors with minimal burden to DOE’s staff. 
5-4

5.3.2 Information Security

Recently the Board began a comprehensive review of its information security policies and

practices, aimed at improving its security posture in the face of today's rapidly changing threats. 

By taking a proactive approach to information security, the Board hopes to prevent attacks

against its information resources instead of merely reacting to them.

As part of its emergency response capability, the Board has maintained a node connection

on the DOE emergency communication network since that program's inception about 2 years ago. 

This node connection is maintained 24 hours a day. Should an incident occur at a DOE facility,

the connection allows for immediate updates and communications.

5.3.3 Preparations for Year 2000

In preparation for the Y2K rollover, the Board developed a comprehensive business

continuity and contingency plan. The Board addressed Y2K contingencies both internally and

with respect to potential failures at DOE facilities.

5.4 INQUIRIES INTO HEALTH AND SAFETY ISSUES

During 1999, combined teams of legal and technical members of the Board’s staff pursued

inquiries into health and safety issues at several defense nuclear facilities pursuant to 

42 USC § 2286a. Inquiries were conducted at the Rocky Flats Environmental Technology Site,

Oak Ridge National Laboratory, the Savannah River Site, the Waste Isolation Pilot Plant, Los

Alamos National Laboratory, Lawrence Livermore National Laboratory, and Idaho National

Engineering and Environmental Laboratory. Several of these inquiries produced significant

improvements in practices or conditions that involved public health and safety and supported

national security missions. Most of the lessons learned and corrective actions resulting from these

inquiries had applications throughout the defense nuclear complex.

Through continuing review of DOE’s infrastructure for protecting safety-related

structures, systems, and components from nonconforming or suspect/counterfeit parts, the

Board’s staff discovered that DOE failed to respond to an interagency alert issued by the

Department of Defense (DoD) regarding suspect/counterfeit electronic components sold to

several federal agencies, including DOE. Intervention by the Board’s staff included legal,

technical, and administrative assistance that enabled DOE to protect potentially compromised

missions and to cooperate fully with actions of DoD and the Department of Justice.

DOE subsequently took effective measures to prevent the introduction of

suspect/counterfeit parts into applications that could adversely affect worker and public safety and

the safe maintenance of the nuclear weapons stockpile. Specifically, with regard to suspect items

identified by DoD, DOE technically evaluated the adequacy of the items and provided assurance

that they would not compromise safety.
5-5

In response to allegations raised by a concerned individual that radiological sources and

the use of cargo containers for temporary storage presented safety hazards at the Rocky Flats

Environmental Technology Site, the Board’s staff conducted an on-site inquiry. The staff found

no safety hazards associated with the issues raised by this individual. As a result of inquiries made

by the staff, however, weaknesses in the control of radiological sources, cargo containers, and

storage conditions for low-level radioactive waste were identified. The DOE Rocky Flats Field

Office and contractors have since taken actions to institute effective controls on sources, to

improve controls on the use of cargo containers for temporary storage, to reduce the number of

cargo containers at the site, and to effectively control storage conditions for low-level radioactive

waste.

The Board’s staff also conducted reviews at WIPP to thoroughly evaluate allegations of

safety deficiencies brought to the Board’s attention by anonymous sources prior to the planned

opening of WIPP. The staff concluded that the allegations were unfounded and that WIPP was in

a condition to be safely operated.

5.5 PUBLIC INTERACTION WITH THE BOARD

Since 1990, the Board has held 71 public meetings at sites across the nation and in

Washington, D.C. The Board has found these meetings to be a highly effective tool for

encouraging responsiveness on the part of DOE representatives and for exchanging information

with state and local officials, labor leaders, DOE facility workers, public interest groups, and area

residents. The Board’s public reading room is open to the public every working day. The staff

has received numerous complimentary letters from private citizens, public interest groups,

corporations, and other government agencies on the availability of the Board’s technical and

administrative documents.

During 1999, the Board conducted four public meetings at its Washington, D.C., office,

and one in Richland, Washington. At three of these meetings, the Board and its technical staff

reviewed the status of DOE’s Implementation Plan for the Board’s Recommendation 95-2, Safety

Management. One public meeting was held to examine DOE’s progress on the implementation of

Recommendation 94-1, Improved Schedule for Remediation in the Defense Nuclear Facilities

Complex. The meeting in Richland, Washington, was held to review the status of DOE’s

implementation of Recommendations 92-4, Multi-Function Waste Tank Facility at the Hanford

Site, and 93-5, Hanford Waste Tanks Characterization Studies. In addition to these meetings,

members of the Board’s staff have provided informational briefings to local officials, citizens’

advisory boards, and other public interest groups in the vicinity of the Pantex Plant, the Savannah

River Site, the Hanford Site, and the Rocky Flats Environmental Technology Site.

Notices of the Board’s public meetings are published in the Federal Register and are

mailed to more than 400 organizations and individuals that have requested to be on the Board’s

mailing list. In addition, each notice is published in local newspapers serving the communities

near the facilities involved, along with being placed on the Board’s Internet Web site, located at

www.DNFSB.gov.
A-1

APPENDIX A. BOARD RECOMMENDATION 99-1

46894 Federal Register / Vol. 64, No. 166 / Friday, August 27, 1999 / Notices

DEFENSE NUCLEAR FACILITIES

SAFETY BOARD

[Recommendation 99–1]

Safe Storage of Fissionable Material

Called ‘‘Pits’’

AGENCY: Defense Nuclear Facilities

Safety Board.

ACTION: Notice, recommendation.

SUMMARY: The Defense Nuclear

Facilities Safety Board has made a

recommendation to the Secretary of

Energy pursuant to 42 U.S.C 2286a(a)(5)

concerning safe storage of fissionable

material called ‘‘pits.’’

DATES: Comments, data, views, or

arguments concerning this

recommendation are due on or before

September 27, 1999.

ADDRESSES: Send comments, data,

views, or arguments concerning this

recommendation to: Defense Nuclear

Facilities Safety Board, 625 Indiana

Avenue, NW, Suite 700, Washington,

DC 20004–2901.

FOR FURTHER INFORMATION

CONTACT:

Kenneth M. Pusateri or Andrew L.

Thibadeau at the address above or

telephone (202) 694–7000.

 Dated: August 23, 1999.

John T. Conway,

Chairman.

[Recommendation 99–1]

Safe Storage of Fissionable Material

Called ‘‘Pits’’

Dated: August 11, 1999.

 Fissionable components are at the

heart of all nuclear weapons, and have

therefore been of central importance to

that part of the nation’s defense posture

that relies on nuclear deterrence. Most

of the defense nuclear programs of DOE

and its predecessor agencies have been

devoted to production of the fissionable

material for these components and the

working of this material into weapons

parts. Most fissionable material in nuclear

weapons is in components

called ‘‘pits,’’ which are the primary

parts of the weapons, and which have

geometrical forms, dimensions, and

other features which are highly

classified. Pits are predominantly made

of plutonium metal which by itself

would corrode in an air atmosphere,

causing a possibility of dispersion of

this hazardous material. Therefore, pits

normally have a corrosion-resistant

cladding, and where possible they are

kept in an inert atmosphere. The design

purpose of pits and their constituent

material leads them to have singular

importance, both from the standpoint of

national security and that of safety. In

particular, when pits are stored by

themselves, not incorporated in a

nuclear weapon (‘‘stand-alone’’ pits),

special attention is required to avoid

any undue risk.

 Most plutonium pits in this country

were formerly made at the Rocky Flats

Plant of the Department of Energy,

situated between Boulder and Golden,

Colorado. When manufacture of new

pits was ended in 1989, a number of

previously made but still unused pits

existed outside of completed weapons,

along with some others that had been

manufactured but that required rework.

Also, when weapons are dismantled,

their pits are stored as stand-alone pits.

In the following, the term ‘‘pits’’ will be

reserved to those components not

incorporated in nuclear weapons.

 The number of stand-alone pits

continues to grow as more nuclear

weapons are dismantled in accordance

with international agreements and

national policy, and it is now in excess

of 10,000. Most of the nation’s pits are

stored at this time at the Pantex Plant of

the Department of Energy, near

Amarillo, Texas, under conditions

considered to be secure and also safe for

the time being.

 Current plans envisage three principal

destinies for pits stored at Pantex. Some

pits are to be retained in a strategic

reserve, in case a decision should be

made to use them in nuclear weapons

at a future time. Other pits regarded as

surplus to any conceivable future

defense mission are to be converted

from metallic form to a plutonium

oxide, which is to be added to depleted

uranium oxide. The combination is to

serve as the fissionable material in

mixed oxide fuel in certain commercial

nuclear reactor plants. Plutonium from

some surplus pits that will be difficult

to use in this way will be disposed of.

Numerous decisions must still be

made to convert such tentative plans to

reality. The most basic ones would

establish where certain actions and

processes are to take place. They are:

 1. Where is the strategic stockpile of

pits to be stored?

 2. Where is the conversion of metallic

plutonium to plutonium oxide to take

place?

 3. Where is the manufacture of mixed

oxide fuel to occur?

 4. Where will surplus pits awaiting

disposition be stored?

Current actions of DOE are consistent

with storage of pits for the strategic

stockpile at the Pantex Plant. Pits

destined for conversion to plutonium

oxide and subsequent incorporation in

mixed oxide fuel must be processed into

feedstock prior to fuel manufacture.

DOE has announced in its Record of

Decision following an Environmental

Impact Statement that Savannah River is

the preferred site for this conversion to

feedstock. For this to take place, pits in

the latter category must be shipped to

the Savannah River Site from their

present location at the Pantex Plant at

Amarillo, Texas.

 Almost as basic are decisions still

awaited regarding the structures in

which both medium-term and long-term

storage will take place, and the nature

of the storage itself including the

containers that will be used for shipping

and storage. For most of the pits now in

storage at Pantex, the outer metallic

cladding is the only reliable

containment. Although the cladding of

pits has rarely failed or been breached,

most pits have been protected

throughout their existence by the sealed

atmosphere within a nuclear weapon,

limiting their exposure to incompatible

or corrosion-producing materials.

However, most pits at Pantex are now in

AL–R8 containers with a normal

atmosphere, along with celotex packing

material that is a potential source of

moisture and chlorides. The containers

are not tightly sealed, and they are kept

in magazines with an atmosphere that

communicates with the outside air

through a normal ventilation system.

The AL–R8 container is used for storage,

but not for shipping pits. It is regarded

as noncertifiable for shipping.

Furthermore, inspection, cleaning,

and other operations associated with

dismantlement of nuclear weapons

makes use of chemicals that could

conceivably initiate corrosion or

otherwise damage a pit in the long term.

The condition of pits following

dismantlement is not well documented,

and some long-term modes of possible

degradation are not well understood.

Some types of pits must be kept cool.

 In 1992, as the forthcoming size of the

inventory of pits came to be realized,

DOE began to plan for measures to

better protect them. A surveillance

program was instituted. A plan was

developed to place pits in sealed

stainless steel containers called AT–

400A, each having a sealed stainless

steel insert holding a pit in an inert

atmosphere. The AT–400A would have

fully protected its enclosed pit, and

would have been certifiable as a

shipping container. As plans developed,

repackaging of pits was to start in 1995

and was to have been completed in five

years. However, this repackaging never

became a reality. The Pantex contractor

found the final weld seal on the AT–

400A’s insert to be very difficult, and

the cost of the AT–400A was concluded

to be too high. Use of the AL–R8

continued.
A-2

Federal Register / Vol. 64, No. 166 / Friday, August 27, 1999 / Notices 46895

The design laboratories have stated in

letters to DOE and to Pantex in 1995 and

1997 that pits, when in AL–R8 containers

for an extended period, face a possibility of

corrosion. They recommended that no pits

should be stored an appreciable period of

time in

these containers. Further, they stated that

if pits are to be stored in AL–R8s for more

than five years, aggressive

surveillance should be applied and

humidity control should be used.

 DOE has since pursued a course

intermediate between continued use of

the AL–R8 alone and introduction of a

totally new container such as the AT–

400A, and has developed a design of a

stainless steel pit container with a

bolted, flanged closure, to be an insert

for the AL–R8. Some materials

compatibility problems have been

attached to the design, but these seem

surmountable.

 The Board has been actively following

the development of plans for pit storage,

and has discussed the issues with DOE

and the Pantex contractor on numerous

occasions during the years since 1992.

On December 31, 1997, the Board sent to

the Assistant Secretary for Defense

Programs a comprehensive review of the

matter, defining a number of steps

believed to be necessary for conduct of an

adequate program, and stating that it may

be prudent to assign overall responsibility

for the endeavor to a senior line manager

within DOE to ensure success. No formal

reply to the letter was made, although the

issue was pursued during briefings of the

Board, including some at Pantex. The next

written communication on the matter

occurred in a letter from the Deputy

Assistant Secretary for Military Application

and Stockpile Management, DOE, on

October 14, 1998. The letter informed the

Board that proposed use of the AT–400A

container had been abandoned in favor of

the AL-R8 with a sealed insert.

 On November 6, 1998, a letter from

the same source transmitted a copy of

an Integrated Pit Storage Program Plan

(IPSPP) which included up-to-date plans

for interim storage of all Pantex pits (an

earlier version of the IPSPP had been

furnished the Board in January 1998, but

that had been withdrawn). The Board

responded on March 12, 1999, finding that

the IPSPP did not adequately address the

concerns stated in its letter of December

31, 1997. The IPSPP continued to be

focused on short-term goals and did not

take into account the need for informed

decisions to be made regarding critical

elements of the pit management system,

such as the selection of pit packaging and

storage

facilities and preparation for eventual

shipment to disposition facilities.

 On April 15, 1999, the Assistant

Secretary for Defense Programs

responded in a letter agreeing that the

IPSPP does not fully address all pit lifecycle issues. He stated that the Plan was

intended to ensure safe storage in the

near-term. He also promised to form a

multi-disciplinary team in the summer

of 1999 to identify appropriate issues

and develop the desired end-states, to

assign, subject to higher approval, the

responsibilities for their achievement,

and to identify the resources. The IPSPP

would be modified accordingly.

 The rate of repackaging of Pantex pits

is not well predictable, but one estimate

places corresponding completion of the

task at no sooner than the year 2008. The

Pantex contractor is seeking a means to

operate two shifts within present budgets,

which could mean a completion date

approximately in the

year 2006. Startup of a second

repackaging line might speed the process

by about two years. Since the

original plan was to repackage all pits

in AT–400A containers by the year

2000, even the most intensive of these

possibilities would amount to a long

delay during which pits would reside in

present AL–R8 containers in conditions

regarded by the design laboratories as

undesirable.

 There are some safety questions

regarding the present design of the AL–

R8 system with the sealed insert. The

celotex in the outer container may

constitute a chemical threat to the

sealed insert because of questions of

moisture and chlorides. The principal

question relates to the carbon steel bolts

used for the flanged closure of the

sealed insert because these bolts may be

more subject to corrosion, and their

failure would expose the pit within to

the conditions which had caused bolts

to fail. The Board considers these design

questions to be readily solvable.

Finally, the end product of the repackaging

into the AL–R8 would be

placement of all pits in containers

unsuitable for shipping, and pits slated

for conversion to mixed oxide for

reactor fuel might not be available for

repackaging in containers that could be

certified for shipping until well into the

21st century. To conduct the necessary

repackaging into shipping containers

not yet even designed would subject

personnel to additional radiation

exposure. There are no present plans to

avoid this situation.

 Apart from possible effects of readily

avoidable design problems of sealed

inserts for AL–R8 containers, the Board

regards the use of these sealed inserts

for repackaging of pits stored at Pantex

to be the basis for acceptable solution

during the near term. Repackaging pits

into the improved AL–R8 should

adequately solve the problems that the

design laboratories identified as

attached to the existing system of

storage. Inspection over time will tell

how long such storage can be relied on.

 On the other hand, the length of time

foreseen for arriving at repackaging of

pits into this acceptable state is not

compatible with avoidance of safety

problems identified by the design

laboratories. The Board is also

concerned regarding these potential

problems. They are a legacy of past

manufacture of nuclear weapons and are

among the questions raised by the

Board’s Recommendation 94–1, which

addressed the need for safe interim

storage of these legacy materials.

 Pits in the strategic reserve at Pantex

have great value to national defense.

These pits, manufactured at great cost

and great effort by the Department of

Energy and its forebears, are probably only

second in importance to nuclear weapons

in the military stockpile. In the nuclear

weapons defense system, they are

effectively irreplaceable. Their assured

safe protection should be a vital

component of national defense.

 Furthermore, DOE’s program plan for

materials disposition is in peril

regarding recycling excess pits into

mixed oxide fuel, because there is no

container suitable for shipping the pits

from the Pantex Plant to the Savannah

River Site, and no plans exist for

development of such a container.

To further the safety of pits at the

Pantex Plant, the Board recommends

that:

 1. The remaining questions of

materials compatibility affecting the

possibility of chemical attack on closure

of sealed inserts for AL–R8 containers

be settled expeditiously;

 2. Action be taken to accelerate the

repackaging of pits into containers

suited to safe storage for the near term;

 3. A system of statistical sampling for

continued integrity of containers and

their sealed inserts for repackaged pits

be put into effect suited to forecasting

the horizon for need for further

repackaging; and

 4. The importance of the above

measures be emphasized by defining

them as the specific responsibility of a

designated individual of the stature,

position, and technical knowledge

necessary for their accomplishment, and
A-3

46896 Federal Register / Vol. 64, No. 166 / Friday, August 27, 1999 / Notices

who is given the authority and resources

required.

John T. Conway,

Chairman.

APPENDIX—Transmittal Letter to the

Secretary of Energy

DEFENSE NUCLEAR FACILITIES SAFETY

BOARD

625 Indiana Avenue, NW, Suite 700,

Washington, D.C. 20004–2901, (202) 694–

7000

August 11, 1999.

The Honorable Bill Richardson,

Secretary of Energy 1000 Independence

 Avenue, SW, Washington, DC 20585–

 1000.

 Dear Secretary Richardson: On August 11,

1999, the Defense Nuclear Facilities Safety

Board (Board), in accordance with 42 U.S.C.

2286a(5), unanimously approved

Recommendation 99–1, which is enclosed for

your consideration. Recommendation 99–1 deals

with the safe storage of fissionable material called

‘‘pits.’’

 41 U.S.C. 2286d(a) requires that after your

receipt of this recommendation, the Board

promptly make it available to the public in

DOE’s regional public reading rooms. The

Board believes the recommendation contains no

information that is classified or otherwise

restricted. To the extent this recommendation

does not include information restricted by DOE

under the Atomic Energy Act of 1954, 42 U.S.C.

2161–68, as amended, please arrange to have it

promptly placed on file in your regional public

reading rooms.

 The Board will also publish this

recommendation in the Federal Register.

 Sincerely,

John T. Conway,

Chairman

Enclosure

 c: Mr. Mark B. Whitaker, Jr.

[FR Doc. 99–22278 Filed 8–26–99; 8:45 am]

BILLING CODE 3670–01–P
B-1

Appendix B. LIST OF ABBREVIATIONS AND ACRONYMS

AMWTP Advanced Mixed Waste Treatment Project

APSF Actinide Packaging and Storage Facility

APT Accelerator for Production of Tritium

B332 Building 332

BHI Bechtel Hanford Incorporated

BIO Basis for Interim Operation

Board Defense Nuclear Facilities Safety Board

CHE conventional high explosive

D&I disassembly and inspection

DAF Device Assembly Facility

DEAR Department of Energy Acquisition Regulations

DND damaged nuclear device

DoD Department of Defense

DOE Department of Energy

DOE-AL DOE Albuquerque Operations Office

DOE-NV DOE Nevada Operations Office

DOE-OR DOE Oak Ridge Operations Office

DOE-SR DOE Savannah River Operations Office

EIS Environmental Impact Statement

ES&H DOE Office of Environment, Safety and Health

EUO Enriched Uranium Operations

FRAM Functions, Responsibilities, and Authorities Manual

FY fiscal year

GPRA Government Performance and Results Act

HAR Hazard Analysis Report

HEPA high-efficiency particulate air

HEU highly enriched uranium

HF hydrogen fluoride

I&C instrumentation and control

IEEE Institute of Electrical and Electronics Engineers

IHE insensitive high explosive

INEEL Idaho National Engineering and Environmental Laboratory

INTEC Idaho Nuclear Technology Engineering Center

IPMP Integrated Pit Management Plan

ISM Integrated Safety Management

ITP In-Tank Precipitation

KAMS K-Area Material Storage

LAAO DOE Los Alamos Area Office

LANL Los Alamos National Laboratory

LEP life extension program

LEU low-enriched uranium

LLNL Lawrence Livermore National Laboratory
B-2

LIST OF ABBREVIATIONS AND ACRONYMS (Concluded)

LMES Lockheed Martin Energy Systems

M&O management and operating

MD DOE Office of Fissile Materials Disposition

MEMP Miamisburg Environmental Management Project

MHC Mason & Hanger Corporation

NESS Nuclear Explosive Safety Study

NTS Nevada Test Site

ORNL Oak Ridge National Laboratory

ORR Operational Readiness Review

PDCF Pit Disassembly and Conversion Facility

PFP Plutonium Finishing Plant

PPE personal protective equipment

RCRA Resource Conservation and Recovery Act

RFETS Rocky Flats Environment Technology Site

SARs Safety Analysis Reports

SFI significant finding investigation

SI Sealed Insert

SNFP Spent Nuclear Fuel Project

SNL Sandia National Laboratories

SNM special nuclear material

SQA software quality assurance

SRS Savannah River Site

SS-21 Seamless Safety for the 21st Century

TA Technical Area

TCON Tritium Facilities Modernization and Consolidation

TRU transuranic waste

TRUSAF Transuranic Storage and Assay Facility

TSRs Technical Safety Requirements

TVA Tennessee Valley Authority

TWRS Tank Waste Remediation System

U-233 uranium-233

UF6 uranium hexafluoride

WIPP Waste Isolation Pilot Plant

WSRC Westinghouse Savannah River Company

Y2K Year 2000