SIXTEENTH ANNUAL REPORT

TO CONGRESS

DEFENSE NUCLEAR FACILITIES

SAFETY BOARD

FEBRUARY 2006
A.J . Eggenberger, Chairman

Joseph F Bader

John E. Mansfield

To the Congress of the United States :

The Defense Nuclear Facilities Safety Board is pleased to submit to Congress its Sixteenth

Annual Report . The Board is an independent executive branch agency responsible for providing

advice and recommendations to the Secretary of Energy, and to the President if necessary,

regarding public health and safety issues at the Department of Energy's defense nuclear

facilities .

As required by statute, the Board's report summarizes activities during calendar year 2005,

assesses improvements in the safety of defense nuclear facilities, and identifies remaining health

and safety problems .

Respectfully submitted,

Joseph F. Bader

Member

DEFENSE NUCLEAR FACILITIES

SAFETY BOARD

625 Indiana Avenue, NW, Suite 700 Washington, D.C. 20004-2901

(202) 694-7000

February 28, 2006

A.J . Eggenberger

Chairman

hn E. Mansfield

Member
PREFACE

Congress created the Defense Nuclear Facilities Safety Board (Board) as an independent

agency within the Executive Branch (42 U .S .C. § 2286, et seq .) to identify the nature and

consequences of potential threats to public health and safety at the Department of Energy's

(DOE's) defense nuclear facilities, to elevate such issues to the highest levels of authority, and to

inform the public .

The Board is required to review and evaluate the content and implementation of health and

safety standards, including DOE's orders, rules, and other safety requirements, practices, and

events relating to system design, construction, operation, and decommissioning of DOE's

defense nuclear facilities . The Board makes recommendations to the Secretary of Energy that the

Board believes are necessary to ensure adequate protection of public health and safety . The

Board must consider the technical and economic feasibility of implementing the recommended

measures. The Secretary may accept in whole or in part or reject the recommendations . If the

Secretary rejects a recommendation in whole or in part for any reason, the Board does not

withdraw or modify the recommendation, and the Secretary maintains the rejection, the

Secretary's decision and reasoning must be published in the Federal Register and provided to

both Houses of Congress . The Secretary must report to the President and Congress if

implementation of a recommendation is impracticable because of budgetary considerations .

Should the Board determine that an imminent or severe threat to public health or safety exists,

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

Defense.

In addition to issuing recommendations, the Board may conduct investigations, issue

subpoenas, hold public hearings, gather information, conduct studies, and take other actions such

as establishing reporting requirements . Requests for detailed reports on safety issues have

generally resulted in prompt remedial actions by DOE .

The Board is required by law to submit an annual report to the Committees on Armed

Services and Appropriations of the Senate and to the Speaker of the House of Representatives .

This report is to include all recommendations made by the Board during the preceding year, and

an assessment of: (1) the improvements in the safety of DOE's defense nuclear facilities during

the period covered by the report ; (2) the improvements in the safety of DOE's defense nuclear

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

Board; and (3) the outstanding safety problems, if any, of DOE's defense nuclear facilities .

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Table of Contents

Summary of Accomplishments in 2005	 7

Outstanding Safety Problems of Defense Nuclear Facilities 	13

Section 1: Introduction	 17

1 .1 Background	 17

1 .2 Oversight Strategy	 17

1 .3 Strategic Plan	 17

Section 2 : Nuclear Weapons Operations	 21

2.1 Safe Conduct of Stockpile Management	 21

2.1 .1 Pantex Plant	 21

2.1 .2 Y-12 National Security Complex	 23

2.1 .3 Nuclear Material Packaging	 23

2.2 Safe Conduct of Stockpile Stewardship 	 25

2.2 .1 Los Alamos National Laboratory	 25

2.2.2 Lawrence Livermore National Laboratory	 27

2.2 .3 Nevada Test Site	 28

2 .2 .4 Sandia National Laboratories	 30

2.2 .5 Research and Development for Explosives Safety 	30

Section 3: Nuclear Materials Processing and Stabilization	31

3 .1 Stabilization and Storage of Remnant Materials 	 31

3 .1 .1 Complex-Wide Program	 31

3.1 .2 Plutonium	 31

3.1 .3 Uranium	 32

3.1 .4 Neptunium	 32

3.2 Stabilization of Spent Nuclear Fuel 	 33

3.2 .1 Hanford Site	 33

3.2.2 National Spent Nuclear Fuel Program 	 33

3.3 Waste Management	 33

3 .3 .1 High-Level Waste	 33

3.3 .2 Low-Level Waste and Transuranic Waste	 35

3.4 Facility Deactivation and Decommissioning 	 36

3.4.1 Overview	 36

3 .4.2 Fernald Closure Project	 37

3 .4 .3 Miamisburg Closure Project	 37

3 .4 .4 Rocky Flats Closure Project	 37

3 .4 .5 Savannah River Site	 38

3 .4 .6 Hanford Plutonium Finishing Plant	 38

3 .4 .7 Hanford K-East Basin	 38

3.4 .8 Lawrence Livermore National Laboratory	:	38

3 .4 .9 Idaho National Laboratory	 39

Section 4 : Nuclear Facilities Design and Infrastructure	 41

4.1 Introduction	 41

4.2 Hanford Site	 41

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4.3 Savannah River Site	 42

4.4 Y- 12 National Security Complex 	 43

4.5 Los Alamos National Laboratory	 44

4.6 Pantex Plant	 44

4.7 Idaho Cleanup Project	 45

4.8 Nevada Test Site	 45

Section 5: Nuclear Safety Programs and Analysis 	 47

5 .1 Federal Oversight	 47

5.1 .1 Overview	 47

5.1 .2 Recommendation 2004-1	 47

5.1 .3 Small Business Involvement in Defense Nuclear Activities 	47

5.2 Integrated Safety Management	 48

5.2.1 Overview	 48

5.2 .2 Vital Safety Systems 	 48

5.2 .3 Activity-Level Work Planning	 48

5.3 Health and Safety Directives	 49

5.3 .1 Improvement of Directives	 49

5.3 .2 Worker Safety Rulemaking	 49

5.3 .3 Scope of the Directives System	 50

5.4 Safety Programs	 50

5.4 .1 Administrative Controls	 50

5.4 .2 Active Confinement Systems	 50

5.4 .3 Quality Assurance	 51

5.4 .4 Software Quality Assurance	 51

5.4 .5 Risk Assessment Methodologies 	 51

5.4 .6 Criticality Safety	 51

5.4 .7 Suspect and Counterfeit Parts 	 51

5.4 .8 Hazard Categories	 52

5.5 Technical Competence	 52

5.5 .1 Training and Qualification	 52

5.5 .2 Facility Representatives 	 52

Section 6: Public Outreach and Agency Administration	 53

6.1 Public Meetings	 53

6.2 Responding to Public Requests	 53

6.3 Electronic Access	 53

6.4 Inquiries Into Health and Safety Issues 	 53

6.5 Site Representative Activities	 54

6.6 Human Resources	 54

6.7 Information Technology and Security	 54

6.8 Dispute Resolution Programs	 55

Appendices

A. Recommendation 2005-1	 57

B. Recommendations Cited	 61

C. Reporting Requirements	 63

D. Correspondence	 65

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Summary of Accomplishments in 2005

The nuclear weapons program of the Department of Energy (DOE), which includes nuclear

weapons operations conducted by the National Nuclear Security Administration (NNSA), is a

complex and hazardous enterprise . Missions include maintenance of the national nuclear arsenal,

dismantlement of surplus weapons, stabilization and storage of surplus nuclear materials,

disposition and disposal of hazardous waste, and cleanup of surplus facilities and sites . Some of

these missions are carried out with aging facilities ; others demand the construction of new

facilities . The constant vigilance of the Defense Nuclear Facilities Safety Board (Board) is

required to ensure that all of these activities are carried out by DOE in a manner that protects the

public, workers, and environment .

During this past year, actions by the Board resulted in numerous health and safety

improvements that are summarized briefly below and in more depth in the main body of the

report . These improvements are described in accordance with the Board's four strategic areas of

concentration :

•Nuclear Weapons Operations ;

• Nuclear Materials Processing and Stabilization ;

• Nuclear Facilities Design and Infrastructure ; and

• Nuclear Safety Programs and Analysis.

Nuclear Weapons Operations

The Board's strategic performance goal for this area is to ensure that DOE operations

directly supporting the nuclear stockpile and defense nuclear research are conducted in a manner

that provides adequate protection of the health and safety of the workers and the public . The

Board's safety oversight activities in this area focus on assembly and disassembly of weapons ;

processing and storage of tritium ; and research, development, manufacturing, and testing .

As a result of the Board's efforts during 2005, DOE has taken actions to upgrade the safety

of these activities . These actions include improving safety systems and controls in aging

facilities, achieving safe packaging of nuclear weapons materials, improving the formality of

nuclear explosive and nuclear processing operations, enhancing the quality of engineered safety

systems, and correcting deficiencies in the safety bases for new and ongoing activities .

Specific examples of safety improvements in weapons operations made by DOE in

consequence of the Board's work are as follows .

Multiple Sites :

•

In support of nuclear explosive operations at the Pantex Plant, DOE has improved the

weapons laboratories' use of tests and modeling for mechanical impact .

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• The Board issued and DOE accepted Recommendation 2005-1, Nuclear Material

Packaging (reprinted in Appendix A) . The principal goal of this recommendation is to

ensure that packaging of nuclear material at sites with ongoing missions meets

technically defensible criteria for safe storage and handling .

Pantex Plant :

• DOE completed repackaging the backlog of surplus pits that were the focus of the

Board's Recommendation 99-1 . The pits are now stored in containers capable of

maintaining a benign environment for up to 50 years .

• As part of its implementation plan for Recommendation 98-2, DOE has implemented

all of the technical safety requirements that support the onsite transportation of nuclear

and hazardous materials .

•DOE is carrying out near- and long-term plans to improve conduct of operations.

• DOE has made substantial improvements in the special tooling program for nuclear

explosive operations .

Y-12 National Security Complex :

•DOE is enhancing the earthquake resistance of Building 9212.

• DOE completed installation and activation of a new fire suppression system and other

engineered fire safety upgrades in a key uranium processing area .

• DOE completed thermal imaging and evaluation of all electrical panels and is taking

action to repair or replace them as appropriate, reducing the risk of fire .

Los Alamos National Laboratory:

•Prior to issuing the request for proposal for engaging a new management and operating

contractor, DOE revised the request based on the Board's objection to proposed terms

that would have placed inadvisable limits on the government's right to inspect and

oversee activities of the contractor .

•DOE is examining deficiencies in confinement ventilation at the Plutonium Facility .

• DOE has implemented an effective process for validating the completeness `and

sustainability of corrective actions designed to correct findings identified during the

laboratory-wide suspension of work in 2004 .

•DOE has significantly improved conduct of engineering at the laboratory .
Lawrence Livermore National Laboratory :

•DOE was able to resume operations in the Plutonium Facility after ensuring that

adverse findings by the Board and DOE's Office of Independent Oversight had been

investigated and procedures revised as needed for safe operations .

•DOE strengthened conduct of operations and confirmed the operability of vital safety

systems in the Plutonium Facility.

• DOE developed a schedule to improve the configuration management program for vital

safety systems .

Nevada Test Site :

•

DOE is characterizing cracking in the concrete structure of the Device Assembly

Facility and taking corrective actions, including mapping the cracks, collecting data on

the construction of the facility to assess the significance of the cracks and structural

capability of the facility, and developing a plan to prevent rainwater infiltration .

•

DOE continued to make improvements in the facilities and processes necessary to

dispose of a damaged nuclear weapon .

DOE is performing rigorous reviews of the safety bases for subcritical experiments .

Sandia National Laboratories :

•

DOE is correcting deficiencies in safety analyses and remediating significant shortfalls

in the site's integrated safety management system .

Nuclear Materials Processing and Stabilization

The Board's strategic performance goal for this area calls for the Board to review and

assess the safety of DOE's efforts to stabilize remnant materials from past weapons production .

The effort also includes oversight of the packaging, storing, and disposing of these excess

materials . Materials that fall within the scope of these reviews include inactive actinide materials

at NNSA sites, high-level wastes, low-level wastes, transuranic wastes, and spent nuclear fuels .

The Board also provides oversight of the decontamination and decommissioning of related

defense nuclear facilities .

The Board's oversight of the processing of nuclear materials has resulted in several safety

improvements at DOE facilities . These improvements include completing the processing and

stabilization of many hazardous materials cited in the Board's Recommendations 94-1 and,

2000-1 . DOE has also taken action to improve conduct of operations, readiness preparations, and

work planning for deactivation and decommissioning work .

Specific examples of safety improvements in materials processing and stabilization made

in consequence of the Board's work are as follows .

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Savannah River Site :

•DOE provided better controls and a more rigorous readiness review to ensure that the

retrieval of waste from Tank 5 proceeds safely .

• When the Board pointed out the potential for an uncontrolled explosion hazard in

transuranic waste drums, DOE halted operations, analyzed the hazard, and

implemented new safety controls for drum handling .

•DOE completed stabilizing all remaining plutonium and uranium materials at Savannah

River Site that were included in the implementation plan for the Board's

Recommendations 94-1 and 2000-1 .

•When the Board identified weaknesses in the controls used to ensure neptunium oxide

purity for safe storage, DOE restabilized the suspect material and enhanced process

controls and verification sampling for product quality .

Hanford Site:

•

DOE safely removed 12 drums containing plutonium oxides from a burial trench .

• In light of new information regarding corrosion in high-level waste tanks, the Board

requested a detailed review of the corrosion program at the Tank Farm ; DOE used the

review to strengthen the program .

•

DOE enhanced the criticality safety program at the Plutonium Finishing Plant by

improving the accuracy and reliability of the nondestructive assay program (which

measures the mass of holdup fissile material) .

Rocky Flats Closure Project :

•DOE completed ahead of schedule the clean up of the Rocky Flats site in October

2005.

Fernald Closure Project:

•DOE corrected several deficiencies identified by the Board in the site's preparations for

treatment of uranium wastes in silos .

Nuclear Facilities Design and Infrastructure

The Board's strategic performance goal for this area is to ensure that new defense nuclear

facilities and major modifications to existing facilities are designed and constructed in a manner

providing adequate protection of the health and safety of the workers and the public . In the past

few years, there has been a substantial increase in the number of design and construction projects

under the Board's jurisdiction . DOE has undertaken design and construction projects with a

projected total cost in excess of $13 billion . The Board continues to devote extensive resources

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ensuring that designs for defense nuclear facilities incorporate multiple layers of safety controls

commensurate with the hazards presented .

During the past year, the Board concluded that DOE was failing to establish a conservative

design early in the design process . Moreover, in addition to an increasing number of new

projects, DOE planned to make use of "design-build" techniques for large-scale facilities,

including some that will house incompletely-designed, hazardous processes . This approach

entails considerable risk when combined with DOE's shortage of personnel qualified to

adequately manage such projects . To highlight these problems and to gain further information,

the Board held a public hearing in December 2005 on "Incorporating Safety into Design and

Construction." This hearing is the first in a series to investigate DOE's program for ensuring the

safe design and construction of nuclear facilities and to focus on processes for identification and

resolution of safety issues early in the design effort .

Specific examples of safety improvements in design and infrastructure made as a result of

the Board's work are as follows .

Hanford Site:

•DOE identified and is correcting potential safety flaws in the design of the Waste

Treatment Plant. Improvements were made in safety basis calculations, coating of

structural steel for fire resistance, design bases for mitigation systems used to prevent

hydrogen deflagrations and detonations, concrete quality, and calculation of seismic

loads .

•

DOE is correcting deficiencies in the confinement of radioactive materials and in

worker protection for the Demonstration Bulk Vitrification Project.

Savannah River Site :

•DOE revised the performance categorization of the Salt Waste Processing Facility to

ensure adequate confinement of hazardous materials .

• DOE made improvements in the design methodology used to assess safety margins in

the building foundation for the Pit Disassembly and Conversion Facility .

Y-12 National Security Complex :

•For the Highly Enriched Uranium Materials Facility, DOE is correcting weaknesses

identified by the Board in quality assurance and control practices for concrete

placement in the foundation and building walls .

Nuclear Safety Programs and Analysis

The Board's strategic performance goal for this area is to ensure that DOE develops,

maintains, and implements regulations, contract requirements, guidance, and safety programs

that ensure adequate protection of health and safety of the workers and the public . The Board's

1 1
oversight activities in this area focus on generally applicable safety standards and on generic

issues affecting a variety of defense nuclear facilities .

As a result of the Board's efforts during 2005, DOE has taken actions to strengthen the

technical competence of its contractors and federal employees, establish and implement safety

standards, and improve the quality of engineered systems . DOE has also taken measures to

enhance the effectiveness of oversight and integrated safety management, using attributes

derived from high-reliability organizations and from lessons learned in the loss of the Columbia

Space Shuttle and the near-miss event at the Davis-Besse . Nuclear Power Plant .

Specific examples of improvements in nuclear safety programs and analysis made in

consequence of the Board's work are as follows .

• DOE strengthened its fundamental policies for oversight of complex, high-hazard

nuclear operations and issued new directives for the complex . (Recommendation

2004-1)

•

DOE restructured line management to align it more closely with the attributes of a

highly reliable organization . (Recommendation 2004-1)

• DOE developed and provided training to all field elements on the standards and

expectations associated with Specific Administrative Controls . (Recommendation

2002-3)

•

DOE finalized a field review aimed at verifying the adequacy and effectiveness of the

implementation of Specific Administrative Controls . (Recommendation 2002-3)

• DOE developed and conducted a training course for safety professionals, senior

managers, and decision-makers responsible for nuclear safety and oversight .

(Recommendation 2004-1)

•

DOE completed a guidance document on work planning and control processes that also

includes criteria and review approaches to assess these processes comprehensively .

(Recommendation 2004-1)

•

DOE committed to evaluating confinement ventilation approaches and, where

appropriate, to shifting to reliance on active rather than passive systems .

(Recommendation 2004-2)

•

DOE committed to develop a new policy governing the use of risk assessment and risk

management at defense nuclear facilities .

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Outstanding Safety Problems of Defense Nuclear Facilities

Technical Capacity and Highly Reliable Organizations

Information developed by the Columbia Accident Investigation Board with respect to the

loss of the space shuttle, and by the Nuclear Regulatory Commission in connection with the

"near miss" at the Davis-Besse Nuclear Power Plant, suggests that a weakening of federal

oversight of contractor operations can have dire consequences . Unfortunately, lessening of

federal oversight has been an objective of DOE's senior management . To examine the hazards of

this course of action more fully, the Board completed a series of eight public hearings between

September 2003 and March 2004. During the public hearings, the Board received testimony

from representatives of the Nuclear Regulatory Commission, the Naval Reactors Program, the

Columbia Accident Investigation Board, and DOE managers .

Based on its review in this area, the Board concluded that DOE's reduced-oversight

initiatives could increase the possibility of a nuclear accident in the defense nuclear complex . In

particular, the Board saw evidence of (1) increased emphasis on productivity at the expense of

safety, (2) loss of technical competence in DOE upper management, (3) insufficient safety

research, and (4) inadequate central oversight of safety . To reset DOE's course of action, the

Board issued Recommendation 2004-1 in May 2004. The recommendation is supported by a

technical report entitled Safety Management of Complex, High-Hazard Organizations,

DNFSBt1'ECH-35 .

Execution of DOE's ambitious implementation plan for this recommendation will require

at least two more years to reach fruition . DOE has created two fledgling Central Technical

Authority positions and has established a nuclear safety research function . DOE has also issued

two directives on federal oversight . The Board will be working closely with DOE throughout the

next two years to put in place the detailed requirements on oversight and integrated safety

management that are necessary to sustain a safe and successful defense nuclear complex .

Reinvigorating Integrated Safety Management

In 1995, the Board issued Recommendation 95-2, urging DOE to integrate work planning

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

and from DOE's implementation plan is termed "integrated safety management ." The term

"integrated" is used to indicate that all aspects of safety and work planning and performance are

integrated into a single process under the responsibility of line management . Integrated safety

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

Through integrated safety management, the Board has encouraged DOE to identify and

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

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

protective measures should be carried out in an integrated way .

In 2001, DOE achieved a major goal in its commitment to integrated safety management

by verifying through comprehensive assessments that the basic elements of integrated safety

management had been implemented at defense nuclear facilities . This was a commendable

achievement . However, it was recognized at the time that full implementation of integrated

1 3
safety management was not yet a reality complex-wide . Since then, implementation has faltered.

In Recommendation 2004-1, the Board identified the need to reinvigorate integrated safety

management through rigorous attention, with technical and operational excellence based on

nuclear safety standards subject to rigorous oversight . DOE's implementation plan of June 2005

contains three major thrusts-one of which directly addresses integrated safety management .

The Board also conducted an extended, in-depth evaluation of integrated safety management at

each of the major NNSA sites, identifying cross-cutting issues as a means of targeting the

revitalization efforts . The results of this evaluation were published early in January 2006 as

DNFSBIIECH-36, Integrated Safety Management: The Foundation for an Effective Safety

Culture . Overseeing the execution of DOE's implementation plan, plus additional actions

devised to address the findings of the technical report, will continue to be a major focus of the

Board's work in 2006 .

Reliable Operation of Safety Systems

As in previous years, the Board remains interested in ensuring that DOE properly

maintains safety systems at defense nuclear facilities . Many defense nuclear facilities were

constructed decades ago . It is often difficult, but important, that protective features be

maintained in a serviceable and effective condition. For new facilities, on the other hand, the

Board focuses, its attention on ensuring that safety systems are correctly identified, designed, and

constructed .

Unfortunately, the Board continues to identify weaknesses in programs critical to

continued reliable operation of safety systems : maintenance, testing, surveillance, quality

assurance, prevention of counterfeit parts, configuration management, training, conduct of

operations, and confinement strategies . DOE is working to make improvements in many of these

areas in response to related recommendations from the Board such as Recommendations 2000-2,

2002-1, 2004-1, and 2004-2. However, as DOE continues to extend the life of aging facilities,

and budgets tighten, there is constant pressure to reduce the number of safety systems and to

provide less effective maintenance . The Board will continue to stress to DOE the importance of

ensuring the long-term reliability of vital safety systems and the infrastructure needed to

maintain them .

Recommendation 2004-2 will require significant effort in this regard in the immediate

future . DOE completed development of the implementation plan in August 2005 . Under this

plan, DOE (and the Board) will be reviewing the confinement strategy of all new and existing

Hazard Category 2 and 3 defense nuclear facilities to ensure that they meet DOE's expectations .

Priority will be given to new facilities or major modifications, but all facilities will be reviewed

to ensure that they do not rely on building integrity to mitigate the consequences of an event if

such strategy cannot be justified . To date, DOE has identified more than a dozen facilities that

may need potential upgrades to ventilation systems .

Adequacy of Design for New Defense Nuclear Facilities

One of the Board's statutory responsibilities is to ensure that adequate health and safety

requirements are embedded in the design of new defense nuclear facilities and are properly

implemented during construction . Needed safety controls must be identified early in the design

1 4
process to avoid unnecessary increases in cost and construction delays . Integrated safety

management provides the framework for the identification and application of safety

requirements in design and construction . The Board expects that when DOE initiates a project to

build a new defense nuclear facility, which may need to operate for as long as 50 years,

integrated safety management principles and core functions will be used in all phases of the

project .

There have been several recent instances where an appropriate level of safety was not

initially designed into new defense nuclear facilities . These projects reached advanced stages of

design without adequate consideration of design features and engineered controls, even though

project personnel believed they were following closely DOE's design directives . For example,

the Board was particularly concerned with the performance categorization of one new facility,

where the existing DOE directives appeared to allow a high hazard facility (Hazard Category 2)

to be designated as a lower design level (Performance Category 2) facility .

The Board has requested that DOE make changes to the appropriate DOE directives to

address this concern . The design performance category specified for a high-hazard facility must

be the higher-level performance category (Category 3) if confinement of material is needed to

protect site or facility workers . DOE has agreed to this request and has proposed changes to the

applicable DOE directives . The Board believes that further improvement in the incorporation of

safety in design of new defense nuclear facilities may be possible and convened a public hearing

in December 2005 to investigate DOE's expectations and methodologies for incorporating safety

into design of defense nuclear facilities and potential areas for improvement . Further public

hearings will be convened in 2006 to continue the investigation in this arena .

Safe Retrieval, Handling, and Stabilization of Nuclear Materials

DOE continues to struggle with technical and programmatic difficulties at the K-Basins

Closure Project at Hanford . The Board uncovered programmatic breakdowns in engineering and

project management that have substantially delayed efforts to retrieve sludge from the basins. By

the end of 2005, DOE had approved a revised implementation plan to modify the milestones and

deliverables that address the sludge milestones associated with the Board's Recommendations

94-1 and 2000-1 . DOE rescheduled several milestones leading to the removal and packaging of

sludge and moved the planned completion date from April 2007 to November 2009 . The Board

intends to continue to give high priority to continued close oversight of this effort .

The high-level waste program at Savannah River Site also presents numerous challenges

and uncertainties for DOE . DOE persists in not considering the operation of the high level waste

system as a tightly-coupled, integrated system with diminishing operational margins . These

include limited tank space in useable high-level waste tanks, lack of salt processing capability,

less-than-reliable performance of some evaporators, and the fact that one of the former In-Tank

Precipitation tanks (Tank 48) has remained out of service seven years after the suspension of that

project . In 2005, the Board worked with representatives of DOE while they revised the

implementation plan for Recommendation 2001-1 . The purpose of the revision is to update the

milestones to reflect the current strategy and place renewed emphasis on addressing these longstanding high-level waste issues . The Board will continue to push DOE to take meaningful

1 5
action to begin processing salt waste and recover tank space, and reduce these significant

hazards to the workers and the public .

Recommendation 2005-1 . In March 2005, the Board issued Recommendation 2005-1,

Nuclear Material Packaging . This recommendation advised DOE to (1) issue a requirement that

nuclear material packaging meet technically defensible criteria for safe storage and handling,

(2) identify which nuclear materials should be included in the scope, and (3) prioritize

implementation of the improved nuclear material packaging requirement . By August 2005, DOE

had developed an acceptable implementation plan ; by the end of 2005 DOE had already met the

first five deliverables and commitments due under the plan . The Board will continue to work

with DOE throughout 2006 to successfully execute the remainder of the implementation plan .

Vigilance During Deactivation and Decommissioning

DOE has begun deactivating and decommissioning many nuclear facilities that have

completed their missions in the nuclear weapons complex . The Board has been monitoring this

growing decommissioning effort at the Hanford Site, Savannah River Site, Idaho National

Laboratory, Fernald Closure Project, and the Miamisburg Closure Project . The Board has noted

several challenges that face DOE and its contractors .

First, although the potential for an inadvertent criticality accident during deactivation and

decommissioning of DOE's nuclear facilities is small, the consequences would be very large .

Nevertheless, there is a tendency for facility personnel to prematurely relax criticality safety

vigilance once bulk quantities of radioactive materials have been removed from a facility .

Second, a significant number of fires have occurred during deactivation and decommissioning of

nuclear facilities . Although most fires have been extinguished with little or no spread of

radioactive materials, the potential exists for the spread of contamination and for significant

radiological exposure to workers due to a fire . Third, work planning and safe execution of

deactivation and decommissioning work is a concern . The shift from production operations to

decommissioning work involves new tasks and changing facility conditions . The magnitude of

the effort required for decommissioning work has not always been recognized, and work has

been started while plans remained incomplete and hazard evaluations remained inadequate .

DOE has not always retained an adequate force of competent staff due to cost

considerations . This has been a particular concern to the Board in areas such as the retention of

acceptable numbers of experienced radiological control technicians and criticality experts-both

areas of high concern when substantial amounts of radioactive and special nuclear materials

remain in place . The Board will continue to review deactivation and decommissioning efforts

closely until DOE can demonstrate an improved capability to plan and execute such activities .

1 6
1.1 Background

The Defense Nuclear Facilities Safety Board is an independent federal agency established

by Congress in 1989. Simply stated, the Board's mandate under the Atomic Energy Act is safety

oversight of the nuclear weapons facilities managed by the Department of Energy . The nuclear

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

a nuclear arsenal, dismantle surplus weapons, dispose of excess radioactive materials, maintain

aging facilities, clean up surplus facilities, and construct new, complex, one-of-a-kind, and highhazard facilities for many purposes . All of these functions must be carried out in a manner that

protects the public, workers, and environment.

Congress established the Board as an independent agency to provide sound technical

oversight of DOE's defense nuclear weapons facilities and operations . For that reason, members

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

turn, assembled a permanent staff with broad experience and competence in all major aspects of

safety.

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

Plant in Texas, Los Alamos National Laboratory in New Mexico, Y-12 National Security

Complex in Tennessee, Savannah River Site in South Carolina, Hanford Site in Washington

State, and Lawrence Livermore National Laboratory in California. The site offices provide the

Board with a continuous presence at these locations . At other locations, the Board maintains

safety oversight by means of regular onsite reviews by members of its technical staff.

During the Board's 16 years of operation, its priorities have evolved with changes in the

nuclear weapons program. The Board uses its Strategic Plan, required by the Government

Performance and Results Act, to ensure that its limited resources remain focused on the most

significant health and safety challenges and keep pace with shifts in those challenges from year

to year. The Board's health and safety activities are closely tied to goals and objectives

embodied in this plan.

This Annual Report summarizes the Board's work during calendar year 2005 . Sections

2, 3, 4, and 5 describe progress in the four major areas of the Board's operations : Nuclear

Weapons Operations, Nuclear Materials Processing and Stabilization, Nuclear Facilities Design

and Infrastructure, and Nuclear Safety Programs and Analysis . Section 6 explains the Board's

interactions with the public and reports on administrative matters . Appendix A reprints

Recommendation 2005-1, Appendix B lists all recommendations cited in this report, Appendix C

lists all reporting requirements imposed on DOE in 2005, and Appendix D contains a full list of

the Board's 2005 correspondence .

1 .2 Oversight Strategy

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

Board's enabling legislation requires continuing reassessment of health and safety conditions

throughout DOE's defense nuclear complex . The Board concentrates its resources on the most

1 . Introduction

1 7
hazardous operations and complex safety issues, guided by its strategic plan and the following

principles:

• Oversight Role - As an oversight but not a regulatory agency, the Board uses a variety

of statutory powers to ensure adequate protection of the public and worker health and

safety . While the Board is empowered to identify current and potential safety problems

and to recommend solutions, DOE remains responsible for taking actions based on the

Board's insights .

•Risk-based Oversight - The Board's safety oversight activities are prioritized

predominantly on the basis of risk to the public and the workers, types and quantities of

nuclear and hazardous material at hand, and hazards of the operations involved .

•

Technical Competence - The Board has endeavored since its inception to ensure that

DOE obtain and maintain the high level of technical expertise essential to the

management of nuclear activities .

• Line Management - Primary responsibility for safety resides in DOE and contractor

management. Safety oversight can reinforce but not substitute for the commitment of

line management and workers to safe work planning and performance .

•Clear Expectations - Effective safety management demands that safety expectations

be clearly defined and tailored to specific hazards . Work instructions that are clear,

succinct, and relevant to the work are more likely to be embraced by workers .

• Effective Transition Planning - The Board's safety oversight of defense nuclear

facilities is coordinated with other federal agencies and with state governments to

ensure a smooth transition from deactivation to environmental regulation.

The Board is provided by statute with a number of tools to carry out its mission . Among

these are recommendations (typically broad and comprehensive in nature), reporting

requirements (focused on specific safety issues), and public hearings (used to obtain information

from DOE, other expert sources, and the public at large) . Since 1989 when the Board began

operations, it has issued 48 formal recommendations, comprising 221 individual subrecommendations . In that same period of time, the Board has issued 171 reporting requirement

letters . In 2005 alone, the Board issued 25 such letters to DOE.

1.3 Strategic Plan

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

statute with the requirements of the Government Performance and Results Act . The Board's

Strategic Plan identifies the serious hazards of handling nuclear weapons and weapons materials,

and disposing of aging and surplus facilities . These hazards include the following :

•

Tons of radioactive and toxic materials throughout the defense nuclear complex, some

stored in an unstable state.

1 8
• Aging facilities that require ever-increasing maintenance and surveillance to assure

safety.

•

The potential for accidental releases caused by inadequate safety controls, human

errors, equipment malfunctions, chemical reactions, building fires, detonations, and

criticality events .

•

Natural phenomena such as wildfires, earthquakes, extreme winds, floods, and

lightning .

Given these threats, safety can be assured by the adoption of a conservative engineering

philosophy that hinges on reliable systems and multiple layers of protection . This concept is

called "defense in depth," and it has been a precept of nuclear safety in the United States for

many decades . Defense in depth is especially important with respect to the handling of high

explosives in proximity to radioactive material .

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

•

Nuclear Weapons Operations : Operations that directly support the nuclear stockpile

and defense nuclear research are conducted by DOE in a manner that ensures adequate

protection of the health and safety of the workers and the public .

•

Nuclear Materials Processing and Stabilization : Processing, stabilizing, and disposing

of hazardous nuclear materials are performed by DOE in a manner that ensures

adequate protection of the health and safety of the workers and the public .

•

Nuclear Facilities Design and Infrastructure : New defense nuclear facilities and major

modifications to existing facilities are designed and constructed by DOE in a manner

that ensures adequate protection of the health and safety of the workers and the public .

•Nuclear Safety Programs and Analysis : Regulations, requirements, guidance, and

safety management programs adequate to protect public health and safety, including

workers, are developed and implemented by DOE .

19
2. Nuclear Weapons Operations

2.1 Safe Conduct of Stockpile Management

Stockpile management refers to the industrial aspects of maintaining the nation's nuclear

weapons stockpile . Examples of the Board's activities to improve health and safety in stockpile

management are discussed in the following subsections .

2.1 .1 . Pantex Plant

The Pantex Plant, located near Amarillo, Texas, serves a central role in stockpile

management . Operations at the site include assembly, disassembly, dismantlement, and

surveillance of weapons, as well as interim storage of special nuclear material removed from

retired weapons . In 2005, the Board sought health and safety improvements in weapons,

operations, onsite transportation operations, tooling program implementation, facility safety

systems, and electrical and lightning protection systems .

Safety Management. DOE's implementation plan for Recommendation 98-2 includes

commitments to improve the safety of nuclear explosive operations and to implement safety

controls for onsite transportation of nuclear material . Satisfactory completion of these

commitments has been delayed. Senior DOE management's obligation to provide monthly status

briefings to the Board has focused management attention on the completion of these

commitments . In November 2005, the Pantex Site Office reported the completion of readiness

reviews to validate the implementation of all technical safety requirements for onsite

transportation of nuclear and hazardous materials .

The implementation plan for Recommendation 98-2 also includes a commitment to

formalize and improve the process for analyzing weapons responses to potential accident

environments . DOE's draft document submitted to the Board in October 2005 failed to establish

consistent criteria for evaluating and documenting weapons responses . In a December 2005

letter, the Board identified the key deficiencies and requested that DOE report on how it planned

to proceed .

Conduct of Operations . Continuing deficiencies in the conduct of operations at Pantex

led the Board to send a letter to DOE on May 2, 2005, identifying operational issues and

requesting a briefing on plans to improve this critical area . In a briefing to the Board on May 25,

2005, DOE outlined improvements it planned to make in (1) training of first-line supervisors and

production technicians, (2) metrics for performance monitoring, and (3) upgrading the conduct

of operations manual and work procedures . A followup review by the Board later in the year

revealed that progress had been made, but more time is needed to see if the corrective actions

have staying power .

Electrical and Lightning Protection . DOE has improved electrical and lightning

protection systems at Pantex by installing surge suppression capability in defense nuclear

facilities . The Board is also encouraged that the electrical safety committee has been reestablished. In a November 2004 letter, the Board reported problems in low-voltage testing used

to characterize the lightning response of nuclear explosive facilities . During an electrical review

21
conducted by the Board in November 2005, DOE revealed plans to eliminate such testing

because of the difficulty in obtaining repeatable results . The Board did not accept this position

and has suggested that DOE work harder to find a suitable test protocol .

Safe Storage of Pits . During 2005, DOE completed repackaging the backlog of pits that

were the subject of Recommendation 99-1 . The pits are now stored in containers capable of

maintaining a benign environment for up to 50 years . A surveillance program has been

established to monitor the repackaged pits in storage, and a process is being established to place

future accumulations of pits into sealed containers for long-term storage . Based on these

accomplishments, the Board closed Recommendation 99-1 in a September 9, 2005 letter.

Special Tooling Program. The special tooling program plays a vital role in the overall

safety of nuclear explosive operations at Pantex . During 2005, in response to issues raised by the

Board in 2004, DOE pursued improvements to the tooling program . These efforts have produced

improvements in the overall tooling program, including both quality and availability of special

tools . A new plant standard was published that better defines the overall tooling program

responsibilities and interfaces . Tool receiving, repair, storage, and maintenance facilities have

been upgraded, and new equipment items, computers, fabrication machines, inspection

instruments, and associated hardware have been purchased to enhance the tooling program's

capabilities . The Board observed a tooling review performed by DOE in September 2005 and

agreed with the review team's conclusion that the program has improved significantly .

Weapons Laboratory Support . In response to Recommendation 2002-2, DOE enhanced

the process for communicating and resolving safety issues between the weapons laboratories and

the production sites . In a November 2005 letter, the Board accepted DOE's proposal to close this

recommendation.

Nuclear Explosive Safety Review. In response to a commitment made to the Board in

March 2005, DOE conducted a top-down review of its nuclear explosive safety directives to

determine if existing requirements are being implemented effectively and to propose

improvements to the requirements for ensuring the safety of nuclear explosive operations .

Approximately 40 representatives from the Board, NNSA Headquarters and Service Center, the

weapons laboratories, Pantex and Nevada Site Offices and their respective contractors, and the

Office of the Chief of Defense Nuclear Safety, participated in a series of meetings .

The results of these meetings were documented in a draft report reviewed by the Board in

December 2005 . The top-down review identified deficiencies in both requirements and in the

implementation of requirements . DOE plans to revise its nuclear explosive safety directives to

correct deficiencies in requirements . The Board is continuing to pursue several additional

improvements proposed during the top-down review that DOE does not currently plan to

implement.

Seamless Safety for the 21st Century . Implementation of this process for the B83

weapon system, originally scheduled for May 2002, remains significantly behind schedule .

Although the Nuclear Explosive Safety Study began in February 2005, B83 operations at Pantex

using Seamless Safety likely will not begin until late 2006 . The Board is now reviewing work by

22
the weapons laboratories to address pre-start findings identified during the Nuclear Explosive

Safety Study .

2.1 .2 Y-12 National Security Complex

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

activities at Y-12 include production, maintenance, refurbishment, dismantlement, evaluation,

and storage of certain components of nuclear weapons . Production activities include

manufacture or re-manufacture of unique nuclear weapons components . The Board's most recent

efforts to improve safety at Y-12 concentrated on highly enriched uranium processing, fire

protection, electrical safety, and the safety of several new or modified processing capabilities .

Seismic Deficiencies . The "9212 Complex" at Y-12 is a collection of structures built

between 1948 and 1958 for processing highly enriched uranium . While updating the complex's

safety basis, DOE found numerous seismic deficiencies, including missing or loose bolts,

missing or structurally inadequate braces, inadequate beam supports, and designs that are

deficient when measured by current criteria . In these aging structures, glass sections in tall

columns and sight glasses are vulnerable to breakage, cans and storage racks are not adequately

secured, and horizontal and vertical tanks are not adequately supported .

In a letter dated April 20, 2005, the Board suggested that DOE pursue a balanced plan for

constructing a new facility for uranium processing, and in the interim, reducing material-at-risk

and implementing practical facility modifications . In response, DOE has developed a phased

approach: first, repair deficiencies attributable to faulty maintenance, and second, evaluate the

need for seismic upgrades . For the evaluation, DOE planned to use a risk-based methodology to

prioritize upgrades and make implementation decisions on an annual basis . The Board concluded

that such an approach might well lead to a series of short-term decisions to accept existing

deficiencies . In a letter dated November 28, 2005, the Board requested that DOE link decisions

on upgrades to the existing facility with achievement of specific milestones in the design and

construction of the new processing facility .

Fire Protection, Building 9212 . In 2002, the Board challenged the adequacy of fire

protection in the B-1 wing of Building 9212 that included a wet chemistry process area without a

fire suppression system . In July 2004, DOE decided to install a fire suppression system on the

first floor, a new shutdown interlock for the process system, fire-protective coatings on certain

structural supports, and modifications to divert combustible liquids to the first floor . In 2005,

DOE completed installation and activation of the new fire suppression system and the other

engineered fire safety upgrades .

Site-Wide Fire Protection . In addition to the installation of a new fire suppression

system in Building 9212, DOE continued work under a 10-year comprehensive improvement

plan for fire protection at Y-12 . Significant progress has been made in many facets of fire

protection such as maintenance of systems, analysis of fire hazards, and inspection of fire

barriers .

Electrical Safety . As a result of a small electrical fire in Building 9212 in 2003, DOE

initiated a corrective action plan that included thermal imaging and evaluation of all Y-12

electrical panels . Initial inspections determined that more intrusive inspections were required for

23
some of the panels . In a letter dated June 22, 2005, the Board noted that these inspections were

being delayed and urged DOE to complete them in a timely manner . DOE then applied

additional resources and completed the intrusive inspections, which uncovered several problems .

Appropriate actions are being taken to repair or replace the deficient panels .

Quality Evaluation Capability . In 2005, the Board reviewed DOE's efforts to relocate

the quality evaluation capability for examination of returned nuclear weapons components, a

critical national security mission at Y-12 . The Board examined the preparations for the critical

lift of a key glovebox associated with this project . In addition, the Board noted that DOE

appropriately directed the contractor to develop a Preliminary Documented Safety Analysis for

the project .

Safety Basis Controls . In 2003, the Board highlighted the lack of a process to ensure

implementation of new or revised safety basis controls . In response, DOE instituted independent

validation protocols at Y- 12. Initial reviews conducted in 2004 revealed the need for several

enhancements in protocols and personnel training . In 2005, DOE completed a baseline series of

reviews in most of the site's nuclear facilities . The Board noted that such reviews may be needed

on a periodic basis to ensure continued implementation of safety controls . In response, DOE

revised procedures to require comprehensive independent validation every three years .

Reduction Process . In 1999, the Board found safety deficiencies in the design and

structural integrity of the reactor vessel used to reduce uranium tetrafluoride to metal . These

vessels are subject to significant internal pressures and temperature gradients, but had not been

designed to meet the American Society of Mechanical Engineers Boiler and Pressure Vessel

Code. In response, DOE started a limited test program using vessels of the existing design to

support design of a new, code-compliant vessel . The new reactor vessel is made of stronger

material and incorporates new pressure sensing and relief capabilities . In early 2005, DOE

completed testing and in September started using the new vessel for producing uranium metal .

Nondestructive Assay . Following the August 2005 discovery that the Y-12 contractor

had significantly underestimated the uranium hold-up associated with a process filter in Building

9212, the Board reviewed the site's programs for performing nondestructive assays . In response

to the Board's review, DOE is improving the techniques for accurately identifying uranium holdup, including uncertainty evaluation and the formality of communicating and responding to holdup estimates to ensure criticality safety .

Criticality Safety. The Board, as well as DOE, noted a series of criticality safety issues

at several Y-12 facilities in February 2005 . In particular, at the main uranium storage facility,

numerous containers had been received and stored on separate occasions with contents

exceeding criticality safety mass limits . The Board's review of these events found that personnel

performance and conduct of operations failures were major factors, but these factors had not

been fully addressed by initial corrective actions . To correct this deficiency, DOE requested that

the contractor perform a full evaluation of failures in conduct of operations .

24
2.1 .3 Nuclear Material Packaging

Recommendation 2005-1 . On March 10, 2005, the Board issued Recommendation

2005-1, Nuclear Material Packaging . (The Recommendation is reprinted in its entirety in

Appendix A .) This recommendation advised DOE to (1) issue a requirement that nuclear

material packaging meet technically defensible criteria for safe storage and handling, (2) identify

which nuclear materials should be included in the scope and then determine the technicallyjustified handling and storage criteria, and (3) prioritize implementation of the improved nuclear

material packaging requirement consistent with the material hazards and the risk posed by the

existing packages . On May 6, 2005, DOE accepted the recommendation, and on August 17,

2005, submitted an implementation plan which the Board accepted on September 13, 2005 . DOE

has met the first five deliverables and commitments due thus far under this plan .

2.2 Safe Conduct of Stockpile Stewardship

Stockpile stewardship refers to activities carried out in the absence of underground

nuclear weapons testing to ensure confidence in the safety, security, and reliability of nuclear

weapons in the nation's stockpile . Stockpile stewardship includes using past nuclear test data in

combination with future non-weapons test data and aggressive application of computer

modeling, experimental facilities, and simulations . Safety aspects of activities at the major sites

engaged in stockpile stewardship are discussed in the following subsections .

2.2 .1 Los Alamos National Laboratory

Los Alamos National Laboratory, located in New Mexico, is the DOE weapons

laboratory with the largest number of defense nuclear facilities and weapons-related activities .

In 2005, the Board focused its attention on resumption of operations, active confinement

ventilation, work planning, conduct of engineering, fire protection, and oversight by the Los

Alamos Site Office .

Resumption of Work . The Board reviewed the resumption of laboratory operations and

corrective action plans following the 2004 suspension of work. Early in 2005, the Board

provided continual feedback to the laboratory about its process for verifying that corrective

actions completely addressed the intended issues and were sustainable . These discussions

contributed to the laboratory's decision to establish a formal Corrective Action Review Board,

the primary mechanism for ensuring that corrective actions captured in the Operational

Efficiency Project are likely to be effective. In a letter to DOE dated July 21, 2005, the Board

noted that full implementation of the Operational Efficiency project is critical and will require

the dedication of significant resources for several years . The Board encouraged DOE to make

adequate resources available for all needed corrective actions at the laboratory . The Board

remains concerned that DOE ensure corrective actions, once initiated, are sustained .

Confinement Ventilation, Plutonium Facility . The Plutonium Facility is a high-hazard

facility with a long expected operating life . Several postulated accident scenarios have

unmitigated consequences that exceed the 25 rem offsite evaluation guideline ; therefore, the

Plutonium Facility needs safety-class controls . The current safety basis credits a passive

confinement strategy as a safety-class mitigative control to address these scenarios . The Board

previously questioned the capability of passive confinement strategies to adequately limit

25
potential releases from the Plutonium Facility . In a letter to DOE dated May 31, 2005, the Board

noted that an active confinement ventilation system is a preferable safety class control . This

issue is to be resolved as part of DOE's response to Recommendation 2004-2 .

Fire Protection . The Board reviewed the fire protection program and concluded that

while the laboratory and DOE had increased their attention to fire protection and taken some

appropriate actions, resolution of issues had been piecemeal . Issues that had languished for years

included (1) incomplete documentation and delays in the completion of inspections, tests, and

maintenance, (2) recommendations of fire hazard analyses not implemented on a timely basis,

(3) no formal plan to address the Baseline Needs Assessment for fire and emergency services,

(4) no long-term contract for fire and emergency services with Los Alamos County, and (5) fire

alarm systems in several defense nuclear facilities still requiring upgrades . The Board has

requested that DOE define a multi-year strategy for timely resolution of all fire protection

deficiencies and achievement of site-wide improvements .

Processing of Plutonium-238 . In preparation for near-term startup, the Board continued

to evaluate the safety of the full-scale aqueous processing line for plutonium-238 . The Board

observed that the laboratory had not adequately resolved some previously identified issues, such

as flammability hazards posed by generation of hydrogen gas in process equipment . The

laboratory subsequently committed to strengthen the technical bases and add necessary safety

controls . The Board is awaiting the results of additional evaluations of the adequacy of existing

safety controls and potential modifications to process equipment .

Operations in Technical Area 18 . In a letter dated May 21, 2004, the Board observed

that the unmitigated consequences for postulated worst-case nuclear accidents at this facility

were quite high and are fundamentally different from worst-case scenarios at other laboratory

facilities . A sequence of operator errors could initiate an uncontrolled reactivity excursion

leading to melting and partial vaporization of a metallic plutonium core or sample . During 2005,

DOE curtailed the types of experiments having even a remote potential for melting plutonium .

Most special nuclear materials now have been removed from Technical Area 18 .

Request for Proposal. On December 1, 2004, DOE issued a draft request for proposal

for the management and operation of the laboratory . The Board's review of the proposal found

that it placed unnecessary and ill-advised limitations on DOE's right to inspect and oversee the

activities of the contractor, undermined DOE's system for identifying and implementing safety

requirements, and omitted relevant safety requirements . The Board issued a letter to DOE on

December 16, 2004, identifying these problems . The Board subsequently evaluated the final

request for proposal and found that it strengthened DOE's ability to perform oversight without

excessive contractual limitations .

Strategic Pause in Federal Oversight . In November 2005, the Board was briefed by

DOE on a planned 3-month "strategic pause" at the Los Alamos Site Office . The purpose of the

strategic pause was to reassign personnel in the site office to preparations for the transition to a

new prime contractor. Approximately two-thirds of the site office's workforce was assigned to

the transition effort, leaving the remaining third to perform essential functions and oversee

laboratory operations . As a compensatory measure, the site office requested that the laboratory

contractor increase its internal self-assessment activities for an indefinite period of time . In a

2 6
letter to DOE dated November 29, 2005, the Board challenged this retreat from federal oversight

responsibility . The Board stated that executing a substantial reduction in federal oversight

concurrent with a number of higher-risk laboratory activities was not consistent with ensuring

safe operations . This is of particular concern as it is occurring during the first contractor

transition period in Los Alamos's history-a period when oversight by the site office is most

needed.

Conduct of Engineering . Prior to 2005, the Board had noted continued delays in the full

implementation of DOE Order 420.1 A, Facility Safety, which provides design requirements for

nuclear facilities . The Board also observed that some of the more complex and higher-hazard

research, development, demonstration, testing, and production work would benefit from a

structured application of engineering standards and practices, a formal conceptual design phase

similar to that for large facility projects, and design reviews following completion of conceptual

and final designs . Los Alamos has now taken corrective actions to address most of these issues

as part of the Operational Efficiency project.

Integrated Work Management . The Board reviewed progress in improving integrated

work management as part of the Operational Efficiency project . Among the various subprojects,

integrated work management has the greatest potential to improve worker safety. However, the

Board found that the improvements are not fully and consistently implemented nor completely

understood by the workforce . Consequently, not all senior managers and scientists fully support

the initiative . Active engagement and support for the improvements by DOE has been minimal .

While further improvements in integrated work management are desirable, changes must be

carefully considered in terms of potential for acceptance by laboratory staff, particularly during

the contract transition period . The need for continued attention by the site office and the

laboratory staff to sustain improvements, once made, has been emphasized by the Board .

2.2.2 Lawrence Livermore National Laboratory

Lawrence Livermore National Laboratory, located 45 miles southeast of San Francisco,

California, is a nuclear weapons research and development laboratory . It provides technical

expertise to support stockpile stewardship and management, including consulting on the

surveillance and dismantlement of nuclear weapons . Most defense nuclear activities are

conducted in the Superblock complex, which includes the Plutonium Facility and the Tritium

Facility. During 2005, the Board conducted reviews of integrated safety management, conduct of

operations, configuration management of vital safety systems at the Superblock facilities, and

the resumption of operations in the Plutonium Facility .

Resumption of Plutonium Facility Operations . In January 2005, DOE's Office of

Independent Oversight and Performance Assurance issued a report identifying serious

deficiencies in the administrative control programs mandated by the Technical Safety

Requirements for the Plutonium Facility (including the configuration management program), as

well as deficiencies in the supporting analyses for safety systems . Because of these findings, the

laboratory suspended operations in the Plutonium Facility. The Board issued a letter to DOE on

March 8, 2005, cautioning against resuming operations until the assessment report's findings had

been adequately studied and requesting a report on planned corrective actions . In July 2005,

DOE briefed the Board on a generally acceptable path forward toward achieving and verifying

2 7
readiness to resume a limited scope of operations. DOE provided the details of this plan to the

Board in a September 2005 letter.

Configuration Management. In a November 2004 letter, the Board identified the

apparent lack of configuration management of vital safety systems at Lawrence Livermore

facilities . DOE responded on January 4, 2005, agreeing that prompt action needed to be taken to

review the configuration and condition of all vital safety systems in defense nuclear facilities .

During 2005, DOE completed evaluations of the application of configuration management for

the vital safety systems at Lawrence Livermore defense nuclear facilities and developed plans to

establish the needed configuration management program . The review of the Plutonium Facility

confirmed deficiencies in the application of configuration management but concluded that all of

its vital safety systems were operable and capable of performing their safety functions . The

Board is now evaluating DOE's plans for establishing configuration management for vital safety

systems in all of the laboratory's defense nuclear facilities .

Verification of Plutonium Facility Readiness . The Board reviewed the adequacy of the

readiness assessments performed by DOE and the laboratory for resumption of limited

operations in the Plutonium Facility and was generally satisfied with DOE's progress . DOE

authorized resumption of limited operations in the Plutonium Facility on October 10, 2005 .

Deactivation of Building 251. The deactivation of Building 251 involves the removal of

nearly 300 radioactive items, some posing a significant risk of radiation exposure to workers and

potential for release of contamination in the building . The project is being carried out on an

accelerated schedule to achieve near-term risk reduction and thus avoid costly safety basis

upgrades. DOE completed the reduction of the nuclear material inventory in the facility to meet

"Radiological Facility" criteria on April 10, 2005 .

2.2 .3 Nevada Test Site

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

Vegas. Stockpile activities at the Test Site include test readiness preparations, disposition of

damaged nuclear weapons, and subcritical experiments . Underground testing of nuclear weapons

is no longer being conducted ; however, the site is maintained in a state of readiness should

national security requirements demand the resumption of underground testing . The Board seeks

to ensure that if testing is resumed, it will be done safely . During 2005, the Board focused its

attention on the Device Assembly Facility, test readiness posture, capability to dispose of a

damaged nuclear weapon, subcritical experiments, and conduct of transuranic waste operations .

Device Assembly Facility . In 2004, the Board requested that DOE assess the Device

Assembly Facility's safety systems and management programs . DOE attempted to respond by

using the site office's assessment program, but this proved inefficacious in delivering a

comprehensive assessment . The Board wrote to DOE again on November 28, 2005, requesting

that more aggressive action be taken with respect to the assessment of the Device Assembly

Facility's safety systems and management programs needed to ensure that the facility is ready

for the increased scope of work . DOE is still working to respond to this request .

2 8
In a related matter, the Board evaluated the physical condition of the Device Assembly

Facility, finding extensive rainwater leakage and extensive cracking in the facility's walls and

floors . The Board advised DOE in a letter dated March 18, 2005, that an immediate and

thorough evaluation was needed . In response, DOE has mapped the cracks and collected data on

the construction of the facility to assess impacts on structural stability . DOE is also taking steps

to plug the leaks .

Damaged Weapons. The Board continued to press DOE to develop a program and

infrastructure to safely dispose of a damaged or improvised nuclear weapon . During 2005, the

Board reviewed the condition of the proposed facility (G-tunnel) for handling such a device,

including safety basis implementation, electrical safety, lightning protection, ground support,

and seismic sensitivity . The Board also reviewed the formality of operations for disposition

activities . In a March 28, 2005 letter to DOE, the Board noted the slow progress in defining and

executing an action plan for addressing known problems with G-tunnel . As a result, DOE

developed priorities for safety improvements and, according to those priorities, has continued to

make physical improvements, improve disposition practices and procedures, and conduct

training on device disposition activities . Progress remains slow .

Subcritical Experiments. The Board previously reviewed DOE's assessments and

readiness for subcritical experiments and found inadequate nuclear safety management

programs, inadequate mechanisms for verifying readiness, and inadequate commitment to

improving the readiness review process for subcritical experiments and nuclear weapons testing .

In 2005, the Board reviewed preparations for subcritical experiments, including safety bases,

facilities at the U1a Complex and U6c Site, infrastructure improvements, and safety

management programs . The Board observed that DOE's Nevada Site Office conducted a more

rigorous safety basis review, which led to improved safety basis documents for subcritical

experiments and a commitment to improve the implementation of controls and conduct of

readiness reviews .

Safety Basis Reviews . The Board continued to review the safety bases for nuclear

facilities and activities, including the Device Assembly Facility, the Ula Complex and

subcritical experiments, the Radioactive Waste Management Complex, G-tunnel, and onsite

transportation . Although the safety bases are improving substantially, in 2005 the Board

identified deficiencies in submitted documented safety analyses and technical safety

requirements, in classification of a facility, and in a Transportation Safety Document.

Lightning Protection and Electrical Systems . In 2003, the Board advised DOE that

improvements in lightning protection and electrical systems were needed . The Board's review in

2004 found that lightning protection controls and features, were now included in the safety basis

of several nuclear facilities . The Board's review of lightning protection and electrical systems

during 2005, sent to DOE on March 28, 2005, acknowledged many improvements . However,

issues still remain including deficient uninterruptible power supply switches and oil-insulated

transformers at the Device Assembly Facility, an antiquated ventilation system in G-tunnel, lack

of a Faraday cage in G-tunnel, and absence of a site-wide lightning protection program .

29
2.2 .4 Sandia National Laboratories

Sandia National Laboratories are located primarily in Albuquerque, New Mexico . Major

defense nuclear facilities at Sandia, most of which are located at Technical Area V at the New

Mexico site, include the Annular Core Research Reactor, Hot Cell Facility, Gamma Irradiation

Facility, and Pulsed Reactor Facility . In September 2004, the Board issued a letter questioning

the adequacy of safety bases at Sandia . Since then, DOE has been working to correct

deficiencies identified in the documented safety analyses. Because all required corrective actions

could not be completed prior to the planned restart of the Annular Core Research Reactor, a

readiness review was conducted to permit operations in a reduced operating mode .

DOE has developed a corrective action plan to ensure that integrated safety management

is fully implemented . The Board evaluated the corrective action plans during 2005 and will

perform a follow-up review on the effectiveness of the corrective actions in 2006 .

2.2 .5 Research and Development for Explosives Safety

In April 2005, the Board reviewed research and development on explosives safety at the

weapons laboratories . Such research includes testing and modeling results for mechanical impact

and electrostatic discharge scenarios for nuclear explosive operations at Pantex . Lawrence

Livermore and Los Alamos laboratories clarified and coordinated their use of laboratory test data

and modeling for impact scenarios .

The weapons laboratories and Pantex personnel provided their periodic briefing to the

Board on weapons safety research and development program priorities on September 21, 2005 .

Lightning effects on weapons, electrostatic discharge, and multi-unit processing were high on all

prioritized lists . In a November 22, 2005 letter to DOE, the Board requested that an updated list

of weapon-specific points of contact be provided to the Board at the periodic briefings on the

status of laboratory research and development for weapons safety, to ensure that the laboratories

continue to assign personnel with appropriate expertise to these positions .

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3. Nuclear Materials Processing and Stabilization

3.1Stabilization and Storage of Remnant Materials

3.1.1 Complex-Wide Program

Inactive Actinide Materials. DOE has chartered the Defense Programs Nuclear

Materials Management Team to continue the work of the Inactive Actinide Working Group in

managing non-programmatic actinide materials stored at several NNSA sites . The Board

reviewed the efforts of the new team to define and execute a strategy to characterize materials

for storage or disposition, to identify which materials fall under this effort, and to analyze and

upgrade material packaging and storage facility conditions . The Board found that the final report

on nuclear materials characterization and storage adequacy failed to meet fully any of the

commitments made by DOE in its February 7, 2003 letter to the Board.

Some DOE sites failed to provide or develop a technically defensible means of linking

characterization with storage adequacy . The report by the Nuclear Materials Management Team

also excluded active nuclear materials from its scope even though DOE's letter to the Board

contained a commitment to do so. Ultimately, these unresolved issues led the Board to issue

Recommendation 2005-1, Nuclear Material Packaging (see Appendix A), as a means of

remedying these deficiencies throughout DOE . The Nuclear Materials Management Team did

make progress toward disposing of unneeded nuclear materials and identifying technically

feasible disposition pathways for materials previously categorized as having no disposition path .

However, progress with respect to disposition of many of these materials has been hampered by

DOE's inability to approve the pathways .

Surveillance and Monitoring Program for Plutonium Storage . DOE's safety standard

entitled Stabilization, Packaging, and Storage of Plutonium-Bearing Materials (DOE-STD3013) establishes requirements for the long-term storage of plutonium metal and oxides,

including a surveillance and monitoring program to verify safe storage parameters . Studies by

Los Alamos National Laboratory using salt-bearing plutonium oxides have indicated that

hydrogen gas generation is highly unlikely to lead to over-pressurization of 3013 containers

during storage . Predictions for corrosion of 3013 containers are much less certain . Nonetheless,

short-term tests by Los Alamos have shown extensive corrosion pitting of 304L and 316L

stainless steel containers holding salt-bearing plutonium oxide with 0 .2 to 0 .5 weight percent

water. In 2005, the Board urged DOE to develop an integrated corrosion study using scientists

from Savannah River Site and Los Alamos National Laboratory as co-principal investigators

and, if necessary, shift resources from gas generation to corrosion studies . This effort has yielded

a new publication, A Comprehensive, Site-Wide Program for Addressing Potential Corrosion

Issues.

3.1 .2 Plutonium

Plutonium Stabilization and Disposition . During 2005, DOE achieved several

significant milestones while implementing the Board's Recommendations 94-1 and 2000-1 . At

Savannah River Site, stabilization and packaging of all applicable pre-existing plutonium metals

and oxides and the dissolution of pre-existing plutonium residues have been completed . At the

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Rocky Flats Closure Project, shipment of all transuranic waste (including wet combustibles) to

the Waste Isolation Pilot Plant was accomplished . DOE is continuing to stabilize and repackage

the highest risk items at Los Alamos, a project that will continue through 2011 .

Drums Containing Plutonium-238 . In 2003, the contractor at the Hanford Site began

work to retrieve more than 38,000 transuranic waste containers from burial trenches on site .

Within these trenches were 12 drums containing amounts of plutonium-238 that required special

handling to ensure safety . In 2005, the Board reviewed DOE's work planning and safety strategy

for retrieving these transuranic drums . DOE then retrieved the drums, verified the packaging

configuration, and transferred the drums to safe interim storage . DOE is still working to

implement the previously developed disposition plan where the preferred alternative is to ship

the drums to Savannah River Site for dissolution in H-Canyon and disposition within the highlevel waste system .

3.1 .3 Uranium

Oak Ridge National Laboratory . Based on direction from Congress regarding the

uranium-233 disposition and medical isotopes production program, DOE began writing a report

to Congress on how the uranium-233 materials are to be managed . The Board will continue to

assess safe storage and disposition of these materials as this program is reviewed and revised .

Savannah River Site . The Board continued to monitor DOE's efforts initiated in

response to the Board's Recommendations 94-1 and 2000-1 . In 2005, DOE completed the

disposition of pre-existing enriched uranium solution and enriched uranium solution resulting

from the dissolution of Mk-16/22 spent nuclear fuel .

3.1 .4 Neptunium

Oxide Production and Storage . The Board reviewed the adequacy of the process

controls used to ensure the purity of neptunium oxide at the HB-Line facility at Savannah River

Site. Subsequent to the Board's inquiries, analysis of archived samples revealed higher moisture

content than anticipated. The presence of elevated levels of moisture or other contaminants could

lead to container pressurization, flammability, and corrosion concerns during storage. The

suspect containers were recalcined, and additional process controls and verification sampling

have been implemented. The neptunium oxide will be stored at Idaho National Laboratory and

used as feed to support the production of plutonium-238 for use in radioisotope power systems .

Developments at Idaho National Laboratory in 2005 included the transition of operating

contractor responsibilities from the University of Chicago to Battelle Energy Associates . The

Board has worked closely with Battelle and DOE's Office of Nuclear Energy, overseeing the

developing plans for the storage and surveillance of neptunium oxide, in anticipation of its use

for future space and national security missions . The Board plans additional reviews of the

adequacy of the storage configuration and surveillance program in 2006.

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3.2

Stabilization of Spent Nuclear Fuel

3.2.1 Hanford Site

The Board continued to provide oversight of spent nuclear fuel and sludge removal

activities at the Hanford K-Basins . DOE revised the implementation plan for Recommendations

94-1 and 2000-1 on May 3, 2004 . However, by the beginning of 2005, the project had missed a

milestone to complete consolidation of sludge in the K-East basin, an activity that has still not

been completed.

In a letter dated February 4, 2005, the Board called DOE's attention to continuing design

and engineering problems at the Sludge Retrieval Project . DOE responded by directing

independent reviews of the design and engineering processes within the sludge project .

However, the transfer of sludge from K-East Basin to K-West Basin has been significantly

delayed. At the Board's insistence, DOE developed a new implementation plan based on a

rigorous and formal risk assessment process, and more realistic assumptions . DOE issued the

new implementation plan on November 28, 2005 .

With regard to high-activity sludge, DOE approved a strategy in November 2004 for

treatment of the sludge that relied on a subcontractor to design, build, and test equipment and to

commence operations of the system . The Board reviewed the strategy, finding that requirements

related to integrated safety management and facility operations were not adequately applied to .

the subcontractor . In addition, no design verification of the sludge stabilization system was

required, despite its important safety role . Subsequently, DOE revised the subcontract to include

the missing requirements and design verifications .

3.2 .2 National Spent Nuclear Fuel Program

The Board reviewed the activities of the National Spent Nuclear Fuel Program . In late

2005, DOE held two high-level meetings wherein managers reassessed the status, direction, and

schedule of the program . DOE directed Savannah River Site to initiate a comprehensive life

cycle analysis of swapping spent nuclear fuel with the Idaho National Laboratory . Aluminumbased fuel would go to Savannah River Site for a combination of processing in H-Canyon and

direct disposal, and non-aluminum fuel would go to the Idaho National Laboratory for packaging

and shipment to the geologic repository . All of the proposed activities have significant

implications for worker and public safety .

3.3 Waste Management

3.3 .1 High-Level Waste

Hanford Tank Farms

Tank Integrity. The Board reviewed the effectiveness of the high-level waste tank

integrity program for double-shell tanks at Hanford . Following that review, the Board issued a

letter to DOE on January 18, 2005, questioning the technical basis for the waste chemistry limits

established for corrosion mitigation in the tanks . The Board also requested a report on long-term

3 3
management of tank space while maintaining waste chemistry within specified limits. In

response, DOE provided a plan for the long-term management of tank space and initiated a

laboratory corrosion program to establish the technical basis for the waste chemistry limits . In

another letter to DOE dated June 1, 2005, the Board noted that laboratory studies for vapor space

corrosion within the tanks were not included in the laboratory corrosion program . DOE agreed to

include vapor space corrosion in the laboratory program . In support of these studies, DOE has

also scheduled an expert panel review of vapor space corrosion in early 2006 to evaluate the

current state of knowledge and determine the appropriate laboratory techniques for this program .

Savannah River Site

High-Level Waste Management . The original implementation plan for the Board's

Recommendation 2001-1 included milestones for a salt processing capability and an integrated

plan for high-level waste tank space management. While many of these milestones were

completed, three milestones remained open due to delays resulting from legal actions, technical

difficulties, and changes to the salt processing strategy . Meanwhile, some of the original

problems that led to the recommendation continue to affect Savannah River Site . These

problems include limited tank space in compliant high-level waste tanks, the lack of salt

processing capability, mixed evaporator performance, and the fact that one of the former In-Tank

Precipitation tanks (Tank 48) has remained out of service for seven years after the suspension of

the precipitation process .

In 2005, the Board urged DOE to revise the implementation plan for Recommendation

2001-1 . By way of response, DOE developed new milestones for removal and treatment of salt

waste from the tanks . These milestones cover the deliquification, dissolution, and adjustment

process, the Actinide Removal Process Facility, the Modular Caustic Side Solvent Extraction

Unit, and the Salt Waste Processing Facilities . Additional milestones address returning Tank 48

to service . These processes and facilities, when properly integrated, will be used to remove salt

waste and to achieve ultimate closure of the tanks . In order to support these new milestones, the

Board conducted technical reviews of Tank 48 flammable gas generation, evaporator

performance, and the interim processing plan for high-level waste . The Board determined that

additional testing was required to show that the waste in Tank 48 could be disposed of safely at

the Saltstone Facility. Due to the risks of this disposal method, the Board encouraged DOE to reevaluate potential alternatives . Subsequently, DOE's analysis identified two technically credible

alternatives .

The Board also reviewed the risks of hydrogen accumulation in the piping and equipment

at the Defense Waste Processing Facility and tank farms . DOE has been working to identify

potential hydrogen accumulation points in the Defense Waste Processing Facility, calculate the

flammable gas generation rates, and model the impacts of a hydrogen explosion on nearby safety

equipment. Once this analysis is complete, the Board will review the calculations and the

proposed control strategy . In addition, DOE's revised work planning processes for high-level

waste tanks to ensure that the potential hazard to facility workers from hydrogen accumulation in

failed tank cooling coils has been assessed .

High-Level Waste Operations . At Savannah River Site, DOE initiated an effort to

mobilize sludge and remove it from three older-style high-level waste tanks (Tanks 4, 5, and 6)

3 4
using new mixer and transfer pumps . The Board observed the readiness review performed by the

contractor for the first retrieval (Tank 5) and found its rigor and scope to be inadequate . In

response, DOE required the contractor to perform additional reviews to demonstrate the

readiness of the facility to begin operations safely. The contractor also established a new

position, Manager of Readiness Assurance, to ensure that the readiness process described in

DOE Order 425.

Startup and Restart of Nuclear Facilities, was properly implemented on all

subsequent projects at Savannah River Site . By October 2005, DOE had adequately

demonstrated facility readiness, and had begun retrieving waste from Tank 5.

Idaho National Laboratory

High-Level Waste Tank Closure. During 2005, the Board reviewed the methods used to

clean the laboratory's high-level waste tanks and examined DOE's subsequent chemical analyses

showing low levels of residual radioactivity . The Board found the methods acceptable and level

of cleanliness adequate to protect the public and the environment . Overall, DOE made good

progress in cleaning the high-level waste tanks, and most are ready for closure . Disposition of

the waste awaits a Nuclear Regulatory Commission decision that it is waste incidental to

reprocessing .

3.3 .2 Low-Level Waste and Transuranic Waste

Drum Handling at Savannah River Site. In 2004, the Board reviewed transuranic

waste handling activities at Savannah River Site and found deficiencies in the identification of

deflagration hazards and corresponding controls for protection of the site workers . The Board

noted these concerns in a letter to DOE . In early 2005, DOE managers halted transuranic drum

handling until the deflagration hazard was fully understood . DOE then implemented new

controls to protect the workers and restarted transuranic drum handling and shipping to the

Waste Isolation Pilot Plant . Later in the year, DOE realized that the same type of deflagration

hazard in transuranic waste boxes was not properly analyzed in the facility's safety analysis .

Advanced Mixed-Waste Treatment Project . The Board continued its oversight of the

Advanced Mixed-Waste Treatment Project at the Idaho National Laboratory through a change of

contractors in early 2005 . The new contractor improved the organization, staffing, equipment

reliability, and training, and resolved outstanding software problems . The Board also directed

management attention to two fires that had occurred in the Box Opening Gantry Robot cell,

where robots cut the covers off wooden and metal waste boxes . In response, DOE made changes

to the vacuum system to eliminate the accumulation of cutting debris that might be ignited by

sparks. DOE has successfully shipped more than 4,600 cubic meters of transuranic waste to the

Waste Isolation Pilot Plant as of. December 2005 .

Accelerated Retrieval Project . The Board noted problems with the fire protection

system in the original design for the Accelerated Retrieval Project (a tent-enclosed half acre

portion of Pit 4) where drums containing radioactive waste are being retrieved at the Idaho

National Laboratory. As a result, DOE made design improvements to this system . When the new

operating contractor took over in May 2005, all operations were halted to reassess work practices

and review radiological control of the work spaces to reduce both external and potential internal

exposures . On November 21, 2005, a waste drum exploded during retrieval . DOE assembled an

3 5
investigation team to assess the cause of the event and recommend corrective actions . The Board

is monitoring DOE's performance to ensure findings are identified and corrective actions

enacted.

Tank W-1A. During a review in November 2005, the Board identified deficiencies with

work planning for the Tank W-1A soil characterization and sampling project at Oak Ridge

National Laboratory. The soil sampling activity has the potential to expose workers to high

radiation levels of 6 rem/hr or more . The Board found weaknesses in the application of

integrated safety management regarding analysis of hazards and identification and

implementation of safety controls . At year's end, DOE acknowledged that additional work is

necessary before the soil characterization can proceed safely .

Melton Valley Waste Treatment . The Melton Valley Waste Treatment Project near Oak

Ridge National Laboratory is designed to process liquid and solid transuranic waste and lowlevel radioactive waste for offsite disposal . The Board observed DOE's Operational Readiness

Review for the startup of the Treatment Project in mid-November of 2005 . The review team

discovered that the Melton Valley contractor intended to begin processing 55-gallon drums in a

box breakdown area and not take advantage of the main glovebox intended for drum processing .

Such an approach would fail to utilize the engineered hazard control afforded by the glovebox

and instead rely on personal protective equipment for worker protection . The Board and the

review team brought this problem to the attention of DOE, which subsequently directed its

contractor to use the main glovebox.

National Transuranic Waste Program . Several DOE sites store large quantities of

transuranic waste on concrete pads and in soil-covered trenches . Many sites are retrieving such

waste and shipping it to the Waste Isolation Pilot Plant for disposal . During the past two years,

the Board observed weaknesses in quality assurance and compliance with program requirements

at some sites . The Board has encouraged DOE to improve cooperation and communications

between the Waste Isolation Pilot Plant and various transuranic waste generator sites to

overcome weaknesses in coordination .

Waste Isolation Pilot Plant . The Waste Isolation Pilot Plant in New Mexico is a

geologic repository utilized for the disposal of defense transuranic wastes . During 2005, the site

received and deposited more than 950 shipments of contact-handled transuranic waste with a

total volume in excess of 8,000 cubic meters . Throughout 2005, the Board verified that these

operations were conducted safely. The Board also began monitoring early preparations for the

receipt of remote-handled transuranic waste . Disposal of this more hazardous form of transuranic

waste is expected to begin in 2006.

3.4 Facility Deactivation and Decommissioning

3.4.1 Overview

Accelerated deactivation and decommissioning projects are occurring at more and more

sites as a result of DOE's accelerated cleanup initiative . Successful decommissioning work has

reduced or eliminated hazards at a number of defense nuclear facilities, but the Board has

observed difficulties in maintaining a high standard for work planning and safe work execution.

3 6
The shift from production operations to decommissioning work involves constantly changing

tasks and facility conditions. This problem is further aggravated by a tendency for DOE to view

decommissioning work as routine and to relax safety vigilance once bulk quantities of

radioactive materials have been removed from a facility . Often, operations personnel in a facility

do not have the decommissioning experience necessary to plan and conduct work in a safe and

efficient manner. Recognizing this problem, DOE is hiring experienced decommissioning

personnel to supplement existing staff .

3.4.2 Fernald Closure Project

During 2005, the Board continued to emphasize worker safety at the Fernald Closure

Project . The Board reviewed the safety analysis documentation for the Silo 3 project and

suggested changes that DOE's contractor incorporated in the final safety documents . The Board

also reviewed readiness preparations to ensure the project was ready to safely begin operations .

Remediation activities began in March 2005 and are nearly complete .

The Board performed oversight of the readiness review for startup of the Silos 1 and 2

project . The readiness review was terminated early by project leaders because of several

deficiencies . The Board sent a letter to DOE on February 2, 2005, stating that improvements

were needed in the management self-assessment process used to verify that the project was ready .

to begin operations . DOE corrected the deficiencies and improved its management selfassessment process, allowing offsite shipments of waste from Silos 1 and 2 to begin in June

2005 .

3.4.3 Miamisburg Closure Project

Activities at Miamisburg Closure Project include cleanout and demolition of buildings

formerly used for nuclear materials and explosives research ; development, testing, and

production activities ; removal of contaminated equipment and soil from the site ; and

environmental restoration . Nine buildings are being transferred to the Miamisburg Mound

Community Improvement Corporation, which will operate the site as a technology park after

DOE's cleanup activities are completed . Reviews by the Board in 2005 indicated that safety

oversight of work activities is adequate . All site closure work is expected to be completed by

mid-2006.

3.4.4 Rocky Flats Closure Project

Building 371, the last plutonium processing building at Rocky Flats, was dismantled,

and the concrete rubble from the building was shipped offsite . In October 2005, DOE announced

that all decontamination and decommissioning operations at the site had been completed . During

2005, the Board strongly encouraged DOE to utilize the lessons learned from the Rocky Flats

Closure Project at other DOE cleanup sites .. Carrying with them experience and lessons learned,

contractor personnel from Rocky Flats have moved on to other DOE sites .

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3.4 .5 Savannah River Site

Significant lapses in work planning and control during decommissioning work caused

several incidents with safety implications in 2004 . In response to a December 13, .2004 letter

from the Board, DOE strengthened work planning and control. During 2005, the Board

continued its oversight of site decommissioning work . Work continued ahead of schedule, but a

series of events caused a shutdown for safety reasons in June 2005 . The common causes of these

events included inattention to detail, failure to stop work when unexpected conditions arose, and

less-than-adequate communication during task performance . Continued lapses in work planning

and control have caused DOE to reevaluate corrective actions instituted earlier in the year and to

evaluate the implementation of these corrective actions .

3.4.6 Hanford Plutonium Finishing Plant

DOE had planned to demolish the Plutonium Finishing Plant at Hanford by 2009 .

However, recent funding decreases have resulted in postponing demolition of some process

equipment, systems, and rooms for a period of 5 to 15 years . Moreover, the plan to send all

excess plutonium to Savannah River Site is in doubt . DOE has commenced work on the design

of an Interim Secure Storage Facility to be located near the Plutonium Finishing Plant .

Early in 2005, the Board concluded that the corrective actions to fix the previously

inaccurate nondestructive assays of plutonium mass were adequate . However, during the year,

several violations of criticality requirements occurred . These were caused by the use of improper

assumptions in the nondestructive assays and by weaknesses in conduct of operations for

movement of fissile materials . The corrective action plans to fix these deficiencies appear

adequate to the Board. However, the Board will conduct followup reviews to verify the

effectiveness of these corrective actions .

3.4.7 Hanford K-East Basin

The Board reviewed DOE's efforts to plan and conduct deactivation work at K-East

Basin, work that will likely be delayed significantly until the radioactive sludge in the basin is

removed. After sludge removal, DOE plans to hydrolase the basin walls to remove

contamination, grout the basin, and cut it into sections for disposal at the low-level waste facility

at Hanford. DOE plans to award two contracts for conceptual design for the cutting and removal

of the basin. The Board's review of the work found no safety problems . Reviews will continue as

the design is finalized.

3.4.8 Lawrence Livermore National Laboratory

Lawrence Livermore National Laboratory is decommissioning 49 gloveboxes and

enclosures. with a wide range of elemental and isotopic contamination at the Heavy Element

Facility. In general, this work requires removal of equipment from the gloveboxes, followed by

decontamination of the internal surfaces to low-level waste limits to allow disposal at the

Nevada Test Site. Sufficient inventory of radioactive material was removed from the Heavy

Element Facility to allow it to be downgraded to a radiological facility . The Board has been

observing these activities to ensure safety problems are avoided .

38
3.4 .9 Idaho National Laboratory

During 2005, DOE announced the selection of a new contractor responsible for the Idaho

Cleanup Project, which will extend through the year 2012 . This contractor is responsible for

treatment and disposal of buried waste, safe management of spent nuclear fuel, disposition of

nuclear materials, disposition of reactor and non-reactor nuclear facilities, and other

environmental remediation activities . The Board visited the site to monitor this work for safety

problems . While operational problems have occurred, the Board has not identified significant

adverse trends .

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4. Nuclear Facilities Design and Infrastructure

4.1

Introduction

The Board's strategic performance goal for this area is to ensure that new defense nuclear

facilities and major modifications to existing facilities are designed and constructed in a manner

providing adequate protection of the health and safety of the workers and the public . There has

been a substantial increase in the number of design and construction projects under the Board's

jurisdiction . DOE has undertaken design and construction projects with a projected total cost in

excess of $13 billion . The Board continues to expend extensive resources to ensure that designs

for defense nuclear facilities incorporate multiple layers of safety controls commensurate with

the hazards presented .

The Board is required by statute to review the design and construction of defense nuclear

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

efficient operations for 20 to 50 years . This demands an exacting design process, guided by

integrated safety management principles, that will ensure appropriate safety controls are

identified early in the design . The Board's expectation is that the design and construction phases

of defense nuclear facilities will demonstrate clear and deliberate use of integrated safety

management principles, core functions, and manuals of practice to be followed throughout

design and construction.

During the past year, the Board determined that the design of several new facilities (e .g .,

the Salt Waste Processing Facility at Savannah River Site and the Demonstration Bulk

Vitrification Project at Hanford) did not provide an adequate level of safety for workers . The

Board identified these projects to DOE, and corrective actions are being taken . However, DOE

continues to have difficulty establishing a conservative design from the beginning of a project .

To inquire into the reasons why this is so, the Board convened a public hearing in December

2005 on incorporating safety into design and construction .

4.2

Hanford Site

Waste Treatment Plant . The Waste Treatment Plant is a multi-facility complex

designed to treat Hanford's high-level radioactive liquid wastes . It consists of three primary

nuclear facilities known as Pretreatment, Low-Activity Waste, and High-Level Waste . The

Pretreatment facility receives high-level waste from Hanford's tank farms and separates it into

high and low activity streams . The low activity portion will be transferred to the Low-Activity

Waste facility where it is mixed with glass-forming materials and converted to a stable

borosilicate glass, or "vitrified." The glass canisters from the Low-Activity Waste facility are

subsequently placed in an onsite, near-surface disposal facility . The high-activity waste stream is

transferred from the Pretreatment facility to the High-Level Waste facility where it is also

vitrified. After vitrification, high-level waste glass logs are temporarily stored at the Hanford site

in the Canister Storage Building pending shipment to DOE's high-level waste repository .

Construction progress varies among the facilities. Currently, construction of the LowActivity Waste facility is furthest along . Work on the Pretreatment and High-Level Waste

facilities has been temporarily halted by DOE to consider the effects of a calculated increase in

41
seismic ground motion . Engineering design based on the higher calculated ground motion is

continuing.

Structural Design . During 2005, the Board's activities concentrated on the resolution of

ground motion issues and on approaches to mitigate the impact of the resulting increase in

calculated ground motion. In 2002, the Board challenged DOE's analysis of seismic ground

motion. In a report to the Board dated March 16, 2005, DOE acknowledged that the seismic

hazards had been substantially underestimated . DOE thereafter slowed construction of the High

Level Waste and Pretreatment facilities until more progress could be made on the ground motion

question . DOE subsequently developed revised seismic ground motion criteria . The Board

believes it would be prudent for DOE to obtain geotechnical data (by drilling deep bore holes) to

support the criteria . Such data could be used to support a site-wide seismic hazard analysis for

future facilities at the Hanford site.

Fire Protection. For several years, the Board had objected to DOE's decision not to apply

fire resistant coatings to structural steel . DOE finally changed course, and a somewhat limited

fire proofing project is now in progress . The project is, strictly speaking, consistent with the

applicable fire code, but the selective approach taken requires a detailed load analysis to

determine which steel members need to be coated . DOE's contractor has prepared structural

design criteria for implementing this strategy across the project and is now in the process of

completing the calculations .

Hydrogen Gas Hazards . The Board has been reviewing DOE's research into hydrogen

generation caused by mixing non-Newtonian liquids . In 2005, DOE's research contractor

continued work on a design for 'a mixing process . While the design is not yet complete, it has

proceeded to a degree that the Board has some confidence these liquids can be handled safely .

DOE is also examining the build-up and potential burning or explosion of hydrogen in pipes and

ancillary vessels . Recently, DOE engaged additional technical expertise to assist in the project, a

step viewed positively by the Board . These efforts are planned to continue through early 2006 .

Demonstration Bulk Vitrification Project . The Demonstration Bulk Vitrification

Project is a research and development project intended to demonstrate the suitability of bulk

vitrification for disposing of low-activity waste from the Hanford Tank Farms. In a letter to DOE

dated September 7, 2005, the Board pointed out weaknesses in the design for confinement of

materials and worker protection . DOE subsequently conducted an independent review and

further analyses of hazards, leading to improvements in the design .

Interim Secure Storage Facility. The Interim Secure Storage Facility is a new project at

Hanford in the conceptual design phase. Its purpose will be to store Hanford's inventory of

plutonium until 2035 . While DOE's original plan was to upgrade an existing facility, structural

weaknesses in that facility led DOE to consider construction of a new facility .

4.3

Savannah River Site

Plutonium Storage . DOE is planning to consolidate its excess plutonium at Savannah

River Site pending final disposition . Some of the material will be used as feed to manufacture

mixed-oxide reactor fuel . DOE is in the preliminary stages of design for modifications to the

42
K-Area facility that would allow immobilizing excess plutonium in glass logs and shipping the

logs to the planned Yucca Mountain repository . As requested by Congress, the Board evaluated

the facilities planned to be used for this storage. The Board sent its initial report to Congress in

2003 and has issued follow-up reports in 2004 and 2005 . The Board's original report concluded

that storage of plutonium in K-Area could be safely accomplished but that improvements in fire

protection should be undertaken . The Board's study further concluded that DOE should not plan

on extended storage of plutonium in Building 235-F without substantial modernization of the

safety systems and confirmation of the building's structural adequacy . DOE has recently

determined that meeting new security requirements in multiple facilities will not be cost

effective and is now planning to store all excess plutonium in the K-Area facility.

Salt Waste Processing Facility. The Board continued its review of the Salt Waste

Processing Facility's design and processes . The Board had previously identified weaknesses in

the performance categorization and potential seismic interactions of various portions of the

facility. In a letter to DOE dated August 27, 2004, the Board questioned the adequacy of the

facility's confinement of hazardous radioactive materials during a design earthquake . In 2005, an

independent review of the design confirmed the Board's view . DOE now plans to upgrade the

structure and safety equipment to provide adequate confinement of the radioactive materials .

Pit Disassembly and Conversion Facility . In 2005, the Board continued its design

review of the Pit Disassembly and Conversion Facility. The Board found that improvements in

the design methodology are needed to ensure that safety margins in the building's capacity to

resist ground settlement are properly evaluated . Such settlement could result from an earthquake

causing subsidence of geologic soft zones under the facility . Soft zones can cause additional

surface settlements that could add more design stresses on the Plutonium Processing Building

and on the confinement structure of the facility . The Board believes that DOE has adequate time

to manage this problem in the design. The Board also has been closely following other aspects of

the design including ventilation, safety analysis, criticality safety, seismic criteria, process

safety, and fire protection . The design of safety systems appears to be progressing adequately,

but the Board did suggest in its letter dated October 17, 2005, some improvements in the

electrical system to account for a possible loss of offsite power .

Tritium Extraction Facility. The Tritium Extraction Facility will be used to extract

tritium from target rods irradiated in commercial light water reactors . The extracted tritium is

used to replenish tritium reserves for the nation's nuclear weapons stockpile . During 2005, the

Board conducted several reviews of component testing and preparations for startup of the

facility . In general, the project appears to be progressing acceptably. The facility has an

advanced computerized process control and worker protection system . At the Board's

suggestion, an independent team of experts assessed the adequacy of this system . Because some

maintenance and operations tasks cannot be conducted during the scheduled Operational

Readiness Review, the Board suggested that Operational Readiness Review team members

observe these tasks during the testing and set up of equipment . DOE accepted this suggestion .

4.4

Y-12 National Security Complex .

Highly Enriched Uranium Materials Facility . The Board completed a review of the

design of the Highly Enriched Uranium Materials Facility and concluded that it provides

43
adequate protection to workers and the public . DOE began construction in early 2005 . The Board

then evaluated quality assurance and control practices for placement of concrete in the

foundation and walls ; these practices were found to be deficient . At year's end, DOE had

assigned additional personnel to monitor construction activities and initiated other corrective

actions in response to the Board's observations .

Uranium Processing Facility. The Uranium Processing Facility is a new project

intended to replace a number of aging facilities that process enriched uranium . In 2005, the

project's completion schedule was in doubt due to funding reductions . In a letter to DOE dated

November 28, 2005, the Board noted that either this new facility or a major upgrade of existing

facilities is needed at Y-12 to support long-term performance of national security missions .

4.5 Los Alamos National Laboratory

Research Facility Replacement Project . The Board performed a detailed review of the

conceptual design for the Chemistry and Metallurgy Research Facility Replacement Project. To

expedite the schedule, DOE is planning to use a design-build approach for the final design and

construction of this facility . In a letter dated February 14, 2005, the Board stressed that for this

approach to be successful, intense oversight will be required by federal and contractor personnel

experienced in the management and oversight of large, complex projects . In response, DOE

developed an integrated review plan for the preliminary design phase and committed to further

develop this plan as the design moves ahead . The Board also questioned the role of ventilation

system design in the overall confinement strategy for the facility . (For details, see

DNFSBIIECH-34, Confinement of Radioactive Materials at Defense Nuclear Facilities .) DOE

has agreed to focus on the design of the ventilation system during the early stages of the

preliminary design .

4.6Pantex Plant

Component Evaluation Facility. The Component Evaluation Facility is a new project at

Pantex intended to provide additional capability for qualifying, certifying, and inspecting

assembled weapons and components . This project is in the conceptual design phase and is

currently scheduled to be operational in 2012 . In April 2005, the Board performed an onsite

review of the safety aspects of the project's activities . The Board was informed that the new bay

complex will adopt an overpressure venting strategy for accidental internal explosions different

from the strategy used in existing bays . The Board questioned this approach on the grounds that

it could increase the risk to workers .

Building 12-64. DOE is considering an upgrade of Building 12-64 so that it can support

nuclear explosive operations . The Board reviewed the final design of the upgrade project and

determined that DOE had properly established the structural integrity of the roof slabs and an

administrative limit on the quantity of high explosives permitted in the bays . Initial bids on this

project were unfavorably high; the project is now at a standstill .

Special Nuclear Material Facility . The Board has continued its design review of the

Special Nuclear Material Component Requalification Facility . The project is in the startup phase

and is expected to be operational in the summer of 2006 . The Board conducted reviews of the

44
ventilation and fire protection systems and of safety basis documentation. The Board noted that

although the facility is equipped with an active ventilation system, this system is not credited in

the safety analysis . This issue will be evaluated in connection with Recommendation 2004-2 .

4.7 Idaho Cleanup Project

Interim Waste Treatment Unit. The Interim Waste Treatment Unit is a new facility

designed to treat approximately 900,000 gallons of sodium-bearing, high-level nuclear waste . A

steam reforming process will be used to treat such waste prior to disposal at one of two sites, the

Waste Isolation Pilot Plant or Yucca Mountain . Preliminary design has been completed, but the

Board has questioned the technical basis for specified safety controls for the processing . DOE's

current plan is to dispose of the waste product at the Waste Isolation Pilot Plant, but this

disposition path has not been approved . Due to the uncertainty of this disposition path, the Board

suggested that testing and evaluation be performed on an alternative waste form that could be

disposed at Yucca Mountain . DOE has agreed to include this approach in an expanded simulant

testing program .

4.8Nevada Test Site

Criticality Experiments Facility . The Criticality Experiments Facility is a major

modification of the Device Assembly Facility . This modification will permit transfer of

criticality machines and fuel from Building TA- 18 at Los Alamos to the Nevada Test Site .

Design is proceeding on modification of the rooms within the Device Assembly Facility needed

for this project. The Board is reviewing the Preliminary Documented Safety Analysis and is

evaluating the safety controls for seismic events, criticality, and fire protection . DOE has

prepared a safety analysis that would allow some existing fire protection and ventilation systems

.to be eliminated. The Board does not agree with this approach unless justified by a more detailed

technical evaluation that specifically considers accident consequences to workers located near

the facility .

45
5. Nuclear Safety Programs and Analysis

5.1Federal Oversight

5.1 .1 Overview

To meet its statutory health and safety mandate, the Board must continuously assess

DOE's ability to achieve adequate oversight of contractor work . Oversight, in this context,

includes Federal line-management assessment of contractors, contractor self-assessment, and

independent assessment . For much of the work conducted in the defense nuclear complex, DOE

relies upon contractors to perform inherently risky activities in government-owned facilities .

These activities are nevertheless governed by nuclear safety requirements promulgated by the

government. Thus, DOE fills three simultaneous roles : owner, customer, and regulator .

Preventing conflict among these roles requires a complex oversight system strained by

competing demands that must be reconciled to ensure that the overall mission is achieved safely .

5.1.2 Recommendation 2004-1

On December 23, 2004, DOE submitted to the Board its proposed implementation plan

for this recommendation. The Board rejected the plan in a letter to DOE dated February 14,

2005, and identified areas requiring further attention . On June 10, 2005, DOE delivered a more

thorough implementation plan that was accepted by the Board on August 5, 2005 . By way of

carrying out this plan, DOE has created two Central Technical Authority positions-one for

NNSA and one for Energy, Science and Environment, each supported by a small technical staff

under a Chief of Nuclear Safety . DOE has established a nuclear safety research function ;

developed and conducted a training course for safety professionals, senior managers and

decision-makers responsible for nuclear safety and oversight ; and completed a guidance

document on work planning and control processes that also includes criteria and review

approaches to comprehensively assess these processes .

DOE also issued a new policy and order on federal oversight, bringing together for the

first time specific guidance and detailed requirements for federal oversight of safety, security,

and business operations . In development is an oversight manual providing more detailed

guidelines and lines of inquiry . These steps are intended to ensure a more uniform process for

oversight of the DOE's activities.

5.1 .3 Small Business Involvement in Defense Nuclear Activities

Section 6022(c) of Public Law 109-13 mandated that the Administrator of the Small

Business Administration, the Chief Counsel for Advocacy of the Small Business Administration,

the Chairman of the Defense Nuclear Facilities Safety Board, the Secretary of Energy, and the

Administrator of NNSA, jointly conduct a study on means to promote opportunities for small

business participation in DOE's contracting system . While the study covered contracting for all

DOE facilities, the Board limited its involvement to contracts at defense nuclear facilities .

The Board provided its input to DOE for the report on September 2, 2005 . The Board

noted that in exercising its safety oversight responsibilities, it has no preference on the size of

4 7
contractors managing defense nuclear facilities or activities . The Board expects defense nuclear

work to be conducted safely. Hence, regardless of the size of the contractor, work should be

conducted under the same contractual requirements, with the same degree of formality, and with

the same level of safety oversight by DOE and the Board . The Board noted that substantially

increasing the number of prime contractors increases the number of DOE staff necessary to

discharge non-delegable safety functions . DOE is already short of adequate numbers of trained

staff.

5.2 Integrated Safety Management

5.2 .1 Overview

Integrated safety management is a concept that evolved from Recommendation 95-2 . The

basic tenets of this approach provide the framework for safely performing all of the diverse

hazardous activities in the defense nuclear complex . Integrated safety management provides for

a single safety management program rather than multiple, unintegrated programs (e.g., quality

assurance and environmental management) . Nuclear safety is an important but not exclusive

target, because nonradioactive hazardous materials and operations can also present significant

risk. Integrated safety management builds upon standards of safe practice for nuclear, chemical,

and other hazardous operations to ensure protection of the public, workers, and the environment .

5.2.2 Vital Safety Systems

In response to Recommendation 2000-2, DOE has taken steps to ensure the operability of

vital safety systems . During 2005, DOE actions in this regard included in-depth reviews of

specific systems and programs (such as configuration management) known to have problems .

These reviews uncovered weaknesses in the operability of safety systems, leading to further

evaluations . As a result of the evaluations, DOE's Office of Environmental Management has

formulated corrective actions and has demonstrated an intent to meet individual milestones in

Recommendation 2000-2.

On the other hand, the Board has found that several sites have failed in this regard .

DOE's own review of Lawrence Livermore National Laboratory in 2005 confirmed significant

failures in configuration management, failures the Board had already pointed out to DOE in a

letter sent November 3, 2004 . During 2005, DOE worked to correct the deficiencies that were

previously identified . Actions included the development of a resource-loaded plan to implement

configuration management for vital safety systems at Lawrence Livermore .

5.2.3 Activity-Level Work Planning

The Board has continuously emphasized the importance of ensuring that hazards are

identified and controlled, that work is performed in a careful manner in accordance with the

safety controls, and that DOE uses appropriate feedback mechanisms to ensure continuous

improvement at the individual activity level . In its implementation plan for Recommendation

2004-1, DOE acknowledged the need to strengthen this area and committed to enhanced focus

on work planning and work control at the field office level . In 2005, the Board provided

4 8
technical oversight for NNSA's effort to write criteria to be used by all NNSA and

Environmental Management sites for future reviews of activity-level work planning .

5.3Health and Safety Directives

5.3.1 Improvement of Directives

During 2005, the Board reviewed approximately 35 new or revised drafts of health and

safety directives and policy letters developed by DOE . Highlights of the Board's reviews follow .

Nuclear Facility Safety Order . The Board reviewed and commented on numerous drafts

of revised DOE Order 420.1, Facility Safety . DOE acted on the Board's comments and published

the final version on December 22, 2005 .

DOE Oversight Policy and Order . In accordance with the implementation plan for

Recommendation 2004-1, DOE developed a new policy and order on oversight . The Board

provided extensive comments on both directives that resulted in improvements . DOE is

developing a companion safety oversight manual that will provide more detailed expectations for

conducting assessments of nuclear operations .

NNSA Policy Letters . On several occasions the Board expressed concern over a new

family of directives called policy letters that had no standing in the current directives system . In

response, NNSA agreed to suspend using these directives on issues affecting health and safety at

defense nuclear facilities until a satisfactory system architecture was developed . In 2005, .NNSA

decided to eliminate the policy letter system and replace it with a new directives system .

Natural Phenomena Hazards. In an August 27, 2004 letter to DOE, the Board

requested improved technical criteria for systems, structures, and components relied upon to

confine radioactive materials threatened by natural phenomena. In 2005, DOE provided a

revision to DOE Guide 420.1-2, Guide for the Mitigation of Natural Phenomena Hazards for

DOE Nuclear Facilities and Nonnuclear Facilities. The Board provided comments on this

revision but suggested that DOE consider adopting ANSI/ANS-2.26-2004, Categorization of

Nuclear Facility Structures, Systems, and Components for Seismic Design, rather than revising

the guide. DOE is considering this course of action .

5.3.2 Worker Safety Rulemaking

On December 8, 2003, DOE published in the Federal Register a proposed rule on worker

protection, 10 Code of Federal Regulations Part 851, Worker Safety and Health . This action was

required under the Bob Stump National Defense Authorization Act, Public Law 107-314, which

directed DOE to promulgate regulations on worker safety and health, rather than rely exclusively

on a contractual approach . On January 26, 2005, DOE published a revised proposed rule for

public comment. Thereafter, the Board continued to provide technical oversight of this effort .

The Board placed particular emphasis on significantly tightening the proposed exemption

criteria, strengthening the tailoring process, and complying with the oversight themes in

Recommendation 2004-1 . DOE modified the proposed rule considerably based on input from the

Board, and published the final rule on February 9, 2006 . DOE deferred action on a significant

49
number of the Board's comments to the rule's implementation guide which will be developed

during 2006 with the Board's oversight .

5.3 .3 Scope of the Directives System

In response to previous input from the Board, DOE offered changes to DOE Policy

251 .1, Directives Program Policy, DOE Order 251 .1X, DOE Directives Program, and DOE

Manual DOE M 251 .1-1X, Directives Program Manual . The Board is currently reviewing the

proposed changes .

5.4 Safety Programs

5.4.1 Administrative Controls

Contractors at defense nuclear facilities are required by DOE's principal nuclear safety

rule (codified in Chapter 10 of the Code of Federal Regulations, Part 830) to submit documented

safety analyses and controls for approval . To meet this requirement, many contractors have

developed new safety analyses and, perhaps more importantly, new safety controls . In many

cases, the choice of these new safety controls was limited because the equipment installed had

been built years or even decades ago . This led some contractors to reclassify existing equipment

as safety-related and to rely on safety-related administrative controls rather than engineered

features. In Recommendation 2002-3, the Board advised DOE to improve its guidance for the

use of administrative controls at defense nuclear facilities .

Responding to the recommendation, DOE developed and implemented a plan to improve

the reliability and effectiveness of administrative controls that serve important safety functions .

As a key step in the implementation plan, DOE developed and issued a new standard, Specific

Administrative Controls (DOE-STD-1 186), and in 2005, completed training for all field offices .

DOE is conducting the final field reviews to verify proper implementation of the new standards

and expectations . Following the implementation of any corrective actions identified as a result of

the field reviews, DOE will revise the safe harbor methodologies associated with the

performance of safety analyses to reflect the requirements associated with specific

administrative controls .

5.4 .2 Active Confinement Systems

The Board issued Recommendation 2004-2 on December 7, 2004 ; DOE accepted it on

March 18, 2005, and submitted an implementation plan on August 22, 2005 . The Board found

this plan acceptable . According to the implementation plan, DOE is to review the confinement

strategy of all new and existing Hazard Category 2 and 3 defense nuclear facilities and ensure

that . they meet the criteria developed in the implementation plan . Priority will be given to new

facilities or major modifications, but all facilities will be reviewed to ensure that they do not rely

on building integrity to mitigate the consequences of an event if such a strategy cannot be

justified . To date, DOE has prepared a draft guidance document for design and performance

expectations of an active confinement system and an evaluation guide that will be used to

perform the assessments of ventilation systems .

5 0
5.4 .3 Quality Assurance

During 2005, the Board continued to demand that DOE improve the implementation of

quality assurance programs . In accordance with its Quality Assurance Improvement Plan, DOE

is reviewing quality assurance processes at its various sites and developing corrective actions

where needed. The Quality Assurance Working Group (under the auspices of the Energy Facility

Contractors Group) assists DOE in making these improvements . The actions taken as part of

NNSA's "Quality Assurance Roadmap to Excellence" also have had a positive effect .

5.4 .4 Software Quality Assurance

The safe design and operation of many defense nuclear facilities rest upon the analysis

and operational support provided by computer codes . Having found safety deficiencies caused

by inadequate software design, implementation, testing, configuration management, and training

of personnel, the Board issued Recommendation 2002-1 to force significant changes in DOE's

policies and practices . During 2005, DOE has worked to complete the implementation plan .

DOE completed revisions to personnel documents, and some of its personnel assigned to

software quality assurance positions achieved qualification under the Technical Qualification

Program. DOE also published several new directives in this area .

5.4.5 Risk Assessment Methodologies

Previously, the Board conducted a comprehensive assessment of DOE's policies,

programs, processes, and procedures with respect to the use of quantitative risk assessment and

related methodologies . This review found that DOE widely employed quantitative risk

assessment but without adequate controls over quality and applicability . This in turn causes risk

management plans, risk mitigative actions, and residual risk identification to be inadequate . DOE

responded by offering to develop a policy governing the use of risk assessment methodologies at

defense nuclear facilities . In a letter to DOE on November 23, 2005, the Board found

deficiencies in the policy as written and objected to the slow pace of its development .

5.4.6 Criticality Safety

When closing Recommendation 97-2 in August 2003, the Board stressed the need for

aggressive self-assessment programs and expanded use of operational facility reviews and

independent oversight. DOE's performance in this regard has been unsatisfactory, leading the

Board to issue a letter on June 22, 2005, criticizing the low number of criticality reviews

conducted by DOE. By way of response, DOE briefed the Board on program improvements it

plans to make . The Board will continue to evaluate DOE's performance in 2006 .

5.4 .7 Suspect and Counterfeit Parts

The Board continued to provide oversight and technical assistance to DOE with the

objective of preventing the use of faulty parts in critical applications . In 2005, DOE refined the

process for finding such parts before they can be used. DOE also conducted extensive field

training for managers, craftsmen, and procurement staff. More than 4,000 internal and external

5 1
reports of suspect parts were reviewed, resulting in five Safety Bulletins (notifications) and two

Safety Alerts (responses required) being distributed to the DOE complex .

5.4.8 Hazard Categories

In a September 14, 2005 letter to DOE, the Board highlighted some instances of reduced

rigor in the selection of readiness review processes for defense nuclear facilities . Such reduced

rigor affects the application of design requirements and preparation of safety documents . One

cause for this situation appeared to be inconsistent interpretation and implementation of rules

and orders that apply to new Hazard Category 1, 2, and 3 nuclear facilities and major

modifications to existing nuclear facilities . In the cases noted by the Board, some sites have used

nonconservative interpretations that can lead to less vigorous readiness reviews and omission of

required reviews of design and safety documentation . The Board requested that DOE take

prompt action to eliminate inconsistent implementation of requirements for startups, restarts,

safety basis documents, and facility design .

5.5 Technical Competence

5.5.1 Training and Qualification

The Board has a longstanding interest in ensuring the adequacy and rigor of training

programs for operators and other health and safety personnel at defense nuclear facilities . In

letters to DOE in 2003 and 2004, the Board criticized a number of weak training programs,

including the programs at the Nevada Test Site, and the Los Alamos and Lawrence Livermore

National Laboratories. In response, DOE has examined the programs and corrective actions

being taken. The Los Alamos corrective action plan was delayed by the 2004 laboratory-wide

suspension of work, but it was provided in a letter to the Board dated November 4, 2005 . Actions

are now underway to bring the Los Alamos program into compliance with DOE Order

5480.20A, Personnel Selection, Qualification, and Training Requirements for DOE Nuclear

Facilities.

5.5.2 Facility Representatives

DOE had previously agreed with the Board's observations on shortcomings in the facility

representative program . In 2005, DOE hired 13 facility representatives and is attempting to

recruit the remaining 7 . Meanwhile, DOE is revising the guidance document used for analysis of

staffing and training needs (DOE-STD-1063-2000, Facility Representatives) . A DOE training

program has been established for interns, a portion of whom are destined for the facility

representative program . The Board has indicated concern that placing interns into this program

may dilute the level of competence of the facility representatives .

52
6. Public Outreach and Agency Administration

6.1Public Hearings

During 2005, the Board conducted one public hearing in Washington, D .C., regarding

DOE's incorporation of safety into design and construction projects. The hearing focused on the

need to identify safety requirements early in the design process. Early resolution of how these

requirements are to be met in the design, construction, and operations stages of the project

results in a safer facility and a reduced chance of costly changes and delays later in the project .

6.2 Responding to Public Requests

The Board answered numerous public requests for documents and information and

responded to 33 requests filed under the Freedom of Information Act . The average response time

for requests was 5 .8 working days, as compared with the statutory requirement of 20 working

days. The Board's website (www.dnfsb.go v) contains a complete list of requests processed since

2001 .

6.3Electronic Access

The Board posts all essential, publicly-releasable documents on its website in a timely

manner. All documents are available electronically, and all recent documents can be downloaded

in Adobe Portable Document Format . The Board upgraded the functionality of its website in

2005 by adding an enhanced search capability, which has greatly improved the ability to find

specific documents . The Board also mails paper copies of certain documents (annual reports,

technical reports, public hearing notices, and others) to a list of more than four hundred

addressees.

6.4Inquiries into Health and Safety Issues

The Board often receives information regarding potential health and safety hazards from

private citizens or from employees at defense nuclear facilities . The Board treats these matters

with the utmost seriousness by assigning members of its legal and technical staffs to investigate

or inquire further. These inquiries, which may involve interviews, review of documents, and site

visits, are continued until the Board is able to reach a technical judgment on the issues raised . If

the Board finds that a health or safety hazard exists, it takes prompt action to inform DOE and

closely monitors DOE's corrective actions . When the Board receives information on matters

outside its jurisdiction, such as alleged criminal activities or unlawful personnel practices, it

refers the information to the appropriate federal agency for action . During 2005, the Board

directed inquiries into health and safety issues at Hanford, Los Alamos, Lawrence Livermore,

and Pantex. The Los Alamos review resulted in improved safety analyses and federal oversight

of work at the laboratory. Similarly, the reviews at the other sites led to safety improvements in

the conduct of work at the respective sites .

53
6.5

Site Representative Activities

The Board enhances its onsite health and safety oversight of defense nuclear facilities by

assigning experienced technical staff members to full-time duty in the field . There are two site

representatives at the Pantex Plant near Amarillo, Texas ; two at Hanford near Richland,

Washington ; two at Savannah River Site near Aiken, South Carolina ; two at the Y-12 National

Security Complex in Oak Ridge, Tennessee ; one at Los Alamos National Laboratory in New

Mexico; and one at Lawrence Livermore National Laboratory in Livermore, California . Site

representatives conduct first-hand assessments of nuclear safety management to identify health

and safety concerns promptly. They meet regularly with the public, union members,

Congressional staff members, and public officials from federal, state, and local agencies . The

Board receives regular briefings from its site representatives in person and maintains continuous

contact with them using all available communications media .

6.6 Human Resources

As of December 31, 2005, the Board employed 87 full-time staff including the full-time

Board members . The Board has assembled a professional staff of exceptional technical

capability. Staff members' expertise covers all major aspects of nuclear safety : nuclear,

mechanical, electrical, chemical, fire protection, and structural engineering, as well as physics

and metallurgy. Most mid- to senior-level technical staff members possess practical nuclear

experience gained from duty in the United States Navy nuclear propulsion program, the nuclear

weapons field, or the civilian nuclear reactor industry . Both the Board and its staff include

individuals experienced in environmental impact assessments and regulatory processes . Four of

the Board's attorneys have technical degrees, and one is also a licensed professional engineer.

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

knowledge, encouraging them to improve their skills continually through academic study .

Ninety-six percent of the Board's technical staff holds advanced science and engineering

degrees, with 20 percent at the Ph .D. level .

Younger technical staff members have been recruited through the Board's professional

development program . Entry-level employees recruited into this 3-year program receive graduate

education and intensive on-the-job training guided by experienced technical mentors . Currently,

there are four entry-level employees in this program . Three completed their master's degrees in

the summer of 2005 and are in their third-year field assignment . The Board's professional

development program remains extremely useful in attracting and retaining high-quality, entrylevel engineers and preparing them for challenging assignments in their fields . Finally, the Board

continues its aggressive recruitment program to attract the brightest engineering students from

colleges and universities across the country.

6.7 Information Technology and Security

The Board has continued to strengthen internal controls and ensure that it is in

compliance with the requirements of the Federal Information Security Management Act as well

as other security guidance . Two significant steps taken in 2005 included the appointment of a

new Chief Information Officer and the development of an agency-wide Information Systems

5 4
Security Program. The Board is also involved in a project to develop policies, procedures, and

technical implementation details for Homeland Security Presidential Directive 12.

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

Desktop hardware, software, and network servers provided to the staff are continually upgraded

to ensure that the latest tools are available. In 2005, the Board completed a "technology refresh

program" and upgraded all of the Board's laptop computers to a standard configuration . Use of a

standard configuration significantly improves computer security and streamlines operational

support requirements . The Board's internet website (www.dnfsb .gov) is continuously updated to

ensure that public documents are available for viewing and downloading. Access to documents

has been improved by the installation of a better search engine .

6.8

Dispute Resolution Programs

The Board, like other federal agencies, is required by the Administrative Dispute

Resolution Act of 1996 to provide an alternative dispute resolution program for use in resolving

appropriate disputes . The Board maintains such a program, making use of cooperative

agreements with other agencies to resolve workplace and contracts disputes economically .

55
DEFENSE NUCLEAR FACILITIES

SAFETY BOARD

[Recommendation 2005-11

Nuclear Material Packaging

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)

regarding the issuance of a requirement

that nuclear material packaging meet

technically justified criteria for safe

storage and handling outside of

engineered contamination barriers .

DATES : Comments, data, views or

arguments concerning the

recommendation are due on or before

April 20, 2005 .

ADDRESSES: Send comments, data,

views, or arguments concerning this

recommendation to : Defense Nuclear

Facilities Safety Board, 625 Indiana

Avenue, NW., Suite 700, Washington,

DC 20004-2001.

FOR FURTHER INFORMATION CONTACT : Kenneth M . Pusateri or Andrew L .

Thibadeau at the address above or

telephone (202) 694-7000 .

Dated : March 15, 2005 .

John T . Conway,

Chairman .

Recommendation 2005-1 To the

Secretary of Energy Pursuant to the 42

U.S .C. 2286a(a)(5), Atomic Energy Act

of 1954, As Amended

Dated: March 10, 2005 .

Background

In Recommendation 94-1, improved

Schedule for Re mediation in the

Defense Nuclear Facilities Complex, the

Defense Nuclear Facilities Safety Board

(Board) urged the Department of Energy

(DOE) to improve the packaging and

storage conditions of its large inventory

of nuclear materials once used for

weapons manufacture . In particular, the

Board recommended that DOE place

plutonium metals and oxides in storage

configurations meeting DOE's standard

for long-term storage (DOE-STD-3013-

2004, Stabilization, Packaging, and

Storage of Plutonium-Bearing

Materials) . Some sites applied

Recommendation 94-1 to excess

materials only . The Board has continued

to evaluate whether other categories of

nuclear materials are stored in a safe

manner .

DOE has made progress in the

stabilization and storage of its excess

nuclear materials . The storage

Appendix A

13482Federal Register/Vol . 70, No . 53 /Monday, March 21, 2005 /Notices

requirements for other categories of

nuclear materials, however, are not as

well defined and controlled,

Specifically, DOE Order 5660 .1B,

Management of Nuclear Materials, does

not address safe storage requirements .

Other than two narrowly focused

standards-DOE-STD-3013-2004 and

DOE-STD-3028-2000, Criteria for

Packaging and Storing Uranium-233-

Bearing Materials-there is no explicit

DOE-wide requirement to ensure the

safe storage of nuclear materials .

Currently, the technical adequacy of

packaging-the combination of

containers and other components

providing a contamination barrier-for

nuclear materials, including liquids, is

dependent on the safety bases of

individual facilities . Typically, facilities

have credited engineered features, such

as the confinement structure and

ventilation system, for protecting offsite

individuals and collocated workers . For

facility workers, however, the controls

are generally administrative, such as

continuous air monitors, personal

protective equipment, periodic

contamination surveys, and other

aspects of the radiological control

program, in conjunction with proper

evacuation training. In accordance with

DOE Standard 3009, Preparation Guide

for U .S . Department of Energy

Nonreactor Nuclear Facility

Documented Safety Analysis (DOESTD-3009-94, Change Notice 02),

accidents that pose the risk of

significant radiological exposure to

workers, such as a breached nuclear

material storage package, should be

prevented or mitigated using safetysignificant controls . The preferred

hierarchy of controls favors engineered,

preventive features over administrative

controls .

Establishing packaging requirements

for nuclear materials within the DOE

complex requires consideration of a

diverse population of material types for

storage for uncertain periods of time .

From a safety standpoint, nuclear

material packaging must protect against

a number of challenges that could

breach the container and release

radioactive material. Many of the

materials of concern generate gases that

result in container pressurization and

may be pyrophoric or highly reactive .

The container design must take into

account corrosion, oxidative expansion

of stored metal, effects of radiolysis,

diurnal pumping, and damage due to

impacts from drops and tooling during

handling . The Board's recent review of

nuclear material packaging at Lawrence

Livermore National Laboratory (LLNL)

revealed that many of these insults had

5 7

not been fully considered when

packaging choices were made for

nuclear materials not covered by

Recommendation 94-1 . In fact, many of

these current packaging configurations

are similar to the inadequate

configurations addressed in

Recommendation 94-1, and are

documented as being susceptible to

eventual'failure in the report of the

Recommendation 94-1 Materials

Identification and Surveillance Working

Group, entitled Summary of Plutonium

Oxide and Metal Storage Package

Failures (LA-UR-99-2896) .

In general, the hazards posed by

nuclear materials covered under DOE's

Implementation Plan for

Recommendation 94-1 are the same as

those for nuclear materials not

considered excess . When nonexcess

materials are removed from glovebox

confinement for interim storage,

relocation to another work station, .

assay, or other purposes, the packages

are susceptible to the same types of

failures as those addressed in

Recommendation 94-1 . The longer the

materials are stored, the greater are the

chances that the packaging will fail,

especially if the packaging has not been

designed appropriately for the actual

duration of storage. The Board found

that approximately 15 percent of the

nonexcess items at LLNL's Plutonium

Facility are stored in packaging more

than 5 years old . Some of the older

items, previously declared excess,

remain in their existing packaging while

awaiting stabilization and packaging

under DOE-STD-3013-2004 . This

situation emphasizes the need to

establish a technical basis for packaging,

such as designating the time period for

which a particular container is

confirmed to perform its function

adequately, in conjunction with tracking

the age of containers in use .

Two recent events serve as further

reminders of the importance of using

packaging that is properly designed for

its function : •

An August 5, 2003, event at Los

Alamos National Laboratory's (LANL)

Plutonium Facility resulted in multiple

workers receiving plutonium-238

uptakes as a result of the degradation of

a package stored longer than planned .

This event is documented in a DOE

Type B investigation report (HQ-EH2004-1). The release of material and the

resulting contamination and worker

uptakes were due, in large part, to the

inadequate packaging of plutonium

being stored and handled outside of a

glovebox . •

An October 6, 2004, incident at

LLNL involved the accidental drop of a

package containing salt-bearing
plutonium oxide. This event is

documented in an Occurrence Reporting

and Processing System report (OAKLLNL-LLNL-2004-0046). Although no

plutonium was released, this event

highlights the need to specify robust

packaging requirements for materials

handled outside of a glovebox . State of Nuclear Material Packaging

DOE-STD-3013-2004 sets forth

requirements for a robust storage

configuration for long-term storage of

plutonium-bearing materials . The

requirements ensure containment

through a combination of material form,

packaging design, and surveillance of

containers . However, the robust, welded

configurations in the standard may not

be desirable when a short storage period

is anticipated pending use of the

material.

There are no equivalent requirements

for interim storage . As part of its

response to Recommendation 94-1,

DOE finalized guidance for the storage

of plutonium-bearing materials not

packaged for long-term storage under

DOE-STD-3013. This guidance,

identified in a January 25, 1996,

memorandum from Deputy Secretary of

Energy Curtis entitled Criteria for

Interim Safe Storage of PlutoniumBearing Solid Materials, provides a

technically justified approach to safe

packaging and storage of plutoniumbearing materials for a period of up to

20 years . Although these Interim Safe

Storage Criteria (ISSC) were not

intended to apply to materials in

working inventory, much of the

guidance remains germane to storage of

all nuclear materials outside of

approved engineered contamination

barriers (e .g ., gloveboxes or certified

shipping containers) .

The ISSC were only implemented for

selected excess materials and were

never formally issued as part of the DOE

Directives System . In practice, the sites

use a wide variety of packages, many of

which do not meet the ISSC . According

to the lessons learned from the DOE

Type B investigation of the worker

uptakes at LANL, packages containing

radioactive material should be assumed

unsafe until proven otherwise or the

materials are repackaged to current

standards . Yet sites continue to rely on

container types that have been used

historically, but have no technically

justified safety or design basis . These

container types are generally forms of

packaging typically used in non-nuclear

applications (e.g., paint cans, food pack

cans) . Thus, they are not designed to

protect against the hazards of the

nuclear materials they contain for the

duration of storage .

Federal Register/Vol . 70, No . 53 /Monday, March 21, 2005 /Notices

13483

Several commonly used containers

and their potential inadequacies are

briefly summarized in an attachment to

this Recommendation . Many other

containers are in use for specialized

applications . Remaining Problems

In response to the Board's May 20,

2002, correspondence on safety of

nuclear materials storage, the National

Nuclear Security Administration

(NNSA) established the Inactive

Actinide Working Group (IAWG), with

the goal of developing a comprehensive

approach to the characterization,

packaging, and storage of a subset of

nuclear materials . As presented in a

February 7, 2003, letter from NNSA to

the Board, the IAWG was to meet this

goal through the development of three

strategies for the following : acceptance

and retention of nuclear materials,

material characterization and storage

adequacy, and disposition . The Board

has been observing the IAWG's efforts

and has made three observations .

First, a key product of the IAWG effort,

will be the strategy for material

characterization and storage adequacy .

Based on discussions with IAWG

participants, the delivery of this strategy

has been delayed, in large part because

of disagreements among member sites

on the requirements necessary for

justifying adequate storage . The Board

believes these requirements should

provide for sufficient characterization

based on an appropriate combination of

analysis and process knowledge to

determine the appropriate packaging .

Characterization information should

also be used to develop a surveillance

program prioritized according to

expected material and container risk

(including, for example, material type,

material form, and the age and type of

container) .

Second, in a June 2000 report entitled

A Strategic Approach to Integrating the

Long-Term Management of Nuclear

Materials, DOE recognized the need to

update the existing DOE Order on

nuclear materials management . In

particular, this report urged

improvements to the nuclear materials

management process. However, neither

the current Order nor the report

explicitly considers storage safety . The

Board believes that DOE should require

a technical basis for nuclear material

packaging and storage safety. Efforts to

meet this requirement should take

advantage of the knowledge about

storage adequacy being developed by

the IAWG, as well as existing guidance,

such as the ISSC .

Third, the IAWG strategy does not

include other program offices in the

5 8

defense nuclear complex, such as the

Nuclear Energy, Science, and

Technology (DOE-NE) facilities

involved in defense nuclear activities .

Currently, materials and activities in

transition between the facilities of

different program offices have the

potential to be overlooked . For example,

operators at the Savannah River Site

have begun converting the neptunium237 solutions covered under

Recommendation 94-1 to oxide and

placing the oxide in packaging intended

for 1 year of storage at that site prior to

offsite shipping . The long-term storage

of large quantities of neptunium oxide

has not been performed previously in

the complex, and the technical basis for

ensuring the safety of such storage is

incomplete . Nonetheless, these

materials will be transferred to DOE-NE

for use, where they may continue to be

stored in their existing packaging for a

period of up to 20 years . In addition, the

Board has learned that DOE-NE intends

to assume more direct control of

activities involving plutonium-238,

which have to date been performed at

NNSA sites. The significant radiological

hazards associated with this material

necessitate appropriate storage

containers for the expected storage

period . The Board believes the

requirement for a technical basis for

nuclear material packaging and storage

should encompass all program offices in

the defense nuclear complex . DOE may

wish to consider implementing this

requirement for all program offices,

including those outside of the defense

nuclear complex .

The Board is encouraged by other

efforts currently under way to improve

nuclear material packaging. As a result

of discussions between the Board's staff

and LLNL, the Livermore Site Office, in

a December 3, 2004, letter, directed

LLNL to develop a technical basis for

the adequacy of storage packages as part

of a Special Nuclear Materials Storage

Plan covering "all packaging activities ."

LLNL replied in a letter of January 31,

2005, outlining the required activities,

milestones, and funding to develop and

implement an approved packaging and

storage program. Implementation of the

plan is contingent upon the availability

of key personnel and funding . Likewise,

the proposed Documented Safety

Analysis (DSA) for the LANL Plutonium

Facility requires the use of a proposed

facility packaging standard and

designates material containers as a

safety-related component . However, the

new DSA has been awaiting NNSA

approval. In general, these efforts

represent an improvement, but they do

not represent a comprehensive DOE-
13484

wide effort, and significant differences

remain in the quality of the efforts at

individual facilities .

Recommendation

Nuclear material packaging provides

the primary containment boundary to

protect facility workers during storage

and handling activities . The Board

believes the development of technically

justified criteria for packaging systems

for nuclear materials is necessary on a

DOE-wide level . Therefore, the Board

recommends that DOE :

1 . Issue a requirement that nuclear

material packaging meet technically

justified criteria for safe storage and

handling. Packaging should, in general,

provide a robust barrier between facility

workers and the stored nuclear

materials once they are removed from

an approved engineered contamination

barrier . It may be appropriate to include

this requirement in an updated nuclear

materials management Order.

2 . Identify which nuclear materials

should be included in the scope of the

above requirement and then determine

the technically justified packaging

criteria needed to ensure the safe storage

and handling of those materials . The

scope need not include waste materials,

fully encapsulated forms, or de minimis

quantities such as analytical laboratory

samples. The criteria should account for

the nuclear material form and

properties, expected future use, and

duration of storage . It may be

appropriate for this information to be

included in a packaging Manual .

The ISSC may provide the beginning

of a sound technical foundation for

developing such criteria . Although some

modifications may be necessary to make

the ISSC more applicable to short-term

storage, the Board believes the basic

ISSC principles-for example, the

requirement for a minimum of two

contamination boundaries for highhazard materials such as plutonium,

assurance that leak-tightness is

maintained for materials requiring a

sealed environment, ability of the

containers to withstand maximum

expected internal pressures, and

protection against common insults such

as drops-should be maintained . The

criteria should also include provisions

for surveillance programs to verify that

the container and any limited-life

components are performing in a manner

consistent with the duration of storage .

3 . Prioritize implementation of the

improved nuclear material packaging

requirement consistent with the hazards

of the different material types and the

Federal Register/Vol . 70, No. 53 /Monday, March 21, 2005 /Notices

risk posed by the existing package

configurations and conditions .

John T. Conway,

Chairman .

Attachment

Selection of Commonly Used Nuclear

Material Packaging

Food-Pack Cans

Food-pack cans are thin-walled

tinned carbon steel containers used in

the food industry . No additional

manufacturing or structural

requirements have been specified for

application with nuclear materials .

These cans typically rely on a doublecrimped metal-to-metal closure with a

thin layer of sealing compound to

provide leak-tightness. Historically,

many sites have reported failures of

food-pack cans . Lawrence Livermore

National Laboratory (LLNL) has

reported anecdotal evidence suggesting

that none of its food-pack cans have

failed to the point of detectable

contamination outside the container

(UCRL-ID-11733) . However, this same

report states further that some degree of

oxidation was observed in all of the

examined food-pack cans containing

plutonium metal, suggesting the lack of

an airtight seal . Leakage of oxygen

through nonairtight food-pack cans has

been responsible for a number of

container failures reported at other sites,

due to oxidative expansion of

plutonium metals (LA-UR-99-2896) .

Improvements have been made to the

technology, including better sealing

equipment, as discussed in a May 1984

report entitled The Effectiveness of

Corrective Actions Taken to Preclude

Events Involving Tin Cans and

Plutonium (RHO-HS-SA-59 P) . Some

evidence suggests, however, that these

containers still may not be adequate for

prolonged storage of nuclear materials .

Approximately half of the sampled lot

of food-pack cans sealed 10 to 14 years

earlier at the Hanford Plutonium

Finishing Plant using the improved

methodology failed leak testing, and

nearly all showed further indications of

a potential lack of seal (LA-UR-99-

3053) .

Additional testing performed at

Pacific Northwest National Laboratory

confirmed that the performance of foodpack cans is highly dependent on the

quality of the seal (PNL-5591) . During

these tests, 33 industry-standard foodpack cans were sealed according to

federal specifications . The testing

revealed leak rates ranging from less

than 10 -5 cubic centimeters per second

(cc/sec) to more than 2 cc/sec . These

findings should receive due

59

consideration when food-pack cans are

used for storage applications in which a

hermetic seal is required . LLNL

continues to use food-pack cans as inner

and outer containers for the storage of

plutonium metal and oxide, and other

sites may be storing nuclear materials

previously packaged in food-pack cans .

Paint Cans

Paint cans are thin-walled cans with

a press-fit lid that are commonly used

to store paint. They have been used as

both inner and outer containers for the

storage of some nuclear materials,

including plutonium metal . The pressfit lid is typically placed by hand using

a mallet, which results in a questionable

seal lacking any evidence of quality

control . According to a January 16,

1987, LLNL site report entitled Incident

Analysis/Plutonium Burn in Storage

Can, oxidation was found to be common

for plutonium metal stored in paint cans

(memorandum from R.H . Condit to K.

Ernst) . The report goes on to calculate

that a 4 micron gap integrated across the

seal area would be sufficient to permit

complete oxidation of 100 grams of

plutonium metal in 1 year . A leak of this

size can reasonably be assumed to be

present in the press-fit closure ;

therefore, the adequacy of these cans for

nuclear material storage applications

requiring a seal cannot be ensured .

Although LLNL reports that ingress of

air is expected because the lid and rim

of the can are not designed to be airtight

(UCRL-ID-117333), paint cans remain

approved for use for certain applications

at the laboratory . Other sites may also be

storing nuclear materials that were

previously packaged in paint cans .

Taped Slip-Lid Cans

Slip-lid cans are thin-walled cans

with a loose-fitting cover that is often

taped . While convenient and

inexpensive, the use of these containers

has resulted in several breached storage

packages, including the plutonium-238

package that led to the Type B event at

Los Alamos National Laboratory

(LANL). Many nuclear material

packages consisting of nested taped sliplid cans remain at the Department of

Energy's defense nuclear facilities . By

design, these cans were never intended

to serve a containment function .

Furthermore, except for tape, a

mechanical closure is absent, resulting

in a container that may not be able to

provide even gross retention of the

materials within . The effectiveness of

tape in performing this sealing function

over time and under high radiation

conditions is poorly understood . For

this reason, the Interim Safe Storage

Criteria (ISSC) specifically prohibit
crediting slip-lid cans as one of the two

required contamination barriers . Yet

several sites continue to use this type of

packaging . For nonmetallic plutonium,

including items containing plutonium238, LANL plans to rely on stainless

steel taped slip-lid cans only as an inner

container ; currently, however, a large

number of items remain at the

laboratory in nested slip-lid cans .

Moreover, several varieties of slip-lid

cans continue to be approved for use as

inner and outer storage containers for

certain materials at LLNL .

Hagan Can

LANL's Comprehensive Nuclear

Material Packaging and Stabilization

Plan approves the use of a standard

container known as the Hagan can, a

robust, screw-top container with an 0-

ring seal and filtered vent . The Hagan

can generally meets the expectations of

the ISSC and has undergone testing to

certify its performance (Wickland and

Mataya, PATRAM 98, 1998) . However,

drop testing was performed at a height

lower than the expected maximum

storage height ; therefore, additional

analysis or testing is required . Under the

proposed Documented Safety Analysis

for LANL's Plutonium Facility, the

Hagan can is classified as a safetysignificant engineered feature . The

Hagan can appears to be an appropriate

outer package for nuclear material

storage, although, as recognized by

LANL, the service life of the Viton (an

organic fluorocarbon compound) O-ring

requires verification through a

surveillance program . Currently, Hagan

cans are widely used only at LANL ;

however, their use may be under

consideration at other sites .

Conflat Can

A can fabricated with a Varian-type

Conflat flange results in a hermetically

sealed, robust container that can be used

to store plutonium metal . A copper

gasket on a bolted flange closure is

designed to maintain a long-term

hermetic seal against oxidation of

plutonium metal . This closure type has

been standard in the high-vacuum

industry for many years and has been

certified to maintain a leak-tight seal

under various temperature and pressure

conditions . The Conflat can is identified

in LANL's Comprehensive Nuclear

Material Packaging and Stabilization

Plan as the inner container for the

storage of plutonium metal . The use of

Conflat cans for storage of other nuclear

materials requiring a sealed

environment may also be appropriate .

Conflat cans have been used

periodically at some sites for special

Federal Register/Vol . 70, No. 53/Monday, March 21, 2005/Notices

13485

storage applications, but their use is not

widespread or uniform .

Metal Drums

Several sites commonly use U .S .

Department of Transportation (DOT)

Type A containers and similar types of

metal drums for overpacking of

packages of nuclear materials for onsite

transportation and storage . These

containers have been certified as Type

A radioactive material packages per

DOT specifications. For transportation

purposes, this certification usually is

limited to a single year . The use of these

containers for interim storage beyond

the certification period appears

appropriate, but consideration should

be given to periodic inspection and

replacement for limited-life

components, such as lid gaskets . The

Criteria for the Safe Storage of Enriched

Uranium at the Y-12 Plant (Y/ES-015/

R2) allow interim storage of enriched

uranium materials for a period of up to

10 years in DOT Type A or Type B

containers .

Y-12 Prolonged Storage Container

The Y-12 Y/ES-015/R2 criteria

specify the use of stainless steel cans

similar to food-pack cans for prolonged

low-maintenance storage for up to 50

years . While the reliance on a single

robust barrier for the storage of enriched

uranium may be appropriate, it is

unclear whether the requirement to

maintain mechanical and seal integrity

during normal handling includes

protection against drops . In addition, a

lid sealant compound is specified in the

appendix to Y/ES-015/R2, but no

discussion of its longevity is provided .

While fewer radiological hazards and

less chemical reactivity are associated

with enriched uranium than with

plutonium and some other nuclear

materials, further testing of these

containers would better demonstrate

their reliability for long-term storage .

Currently, the Y-12 container

specification is planned for use only at

the Y-12 National Security Complex .

Plastic Bags and Bottles

Historically, plastic bags have been

relied upon to provide contamination

control for a limited period. Bag

materials, which include polyethylene,

polyvinyl chloride, and related

polymers, play an important role in the

overall packaging system. Their

principal use is for contamination

control during the "bagout" operation,

when the nuclear material container is

removed from the glovebox .

Unfortunately, some types of bags have

proven to be detrimental to the integrity

of packages left in storage for prolonged

60

periods of time . For example, the

radiation-induced degradation of

polyvinyl chloride bag material led to

the production of hydrochloric acid,

which in turn contributed to the

corrosion and eventual failure of

containers that occurred during the

Type B event at LANL . The choice of

material also impacts the generation of

radiolytic gas and effectively defines the

service life of a package when the outer

container is not leak-tight . In

repackaging campaigns at LLNL, as well

as at other sites, such as Hanford, bags

commonly have been found to be in a

discolored or otherwise degraded state

(UCRL-ID-117333 and WHC-SD-TRP067) . While plastic bags have been in

use for a long time, little quantitative

information exists on the effects of time,

temperature, and radiation field

exposure on maintenance of an effective

contamination barrier, It is recognized

that plastic bags may be necessary for

contamination control, but they should

not be relied upon as a long-term

contamination barrier.

In some cases, plastic bottles (e.g .,

safe bottles) have been used for the

storage of solutions containing nuclear

materials, especially enriched uranium,

outside of processing equipment . While

bottles are constructed of thicker

plastics than are bags, they undergo the

same chemical and radiolytic

degradation with time and must be

compatible with the chemical properties

of the contained liquids . Furthermore,

whereas bags provide only

contamination control, bottles are relied

upon to provide a complete

contamination barrier, including

structural integrity . Any reliance on

plastic bags or plastic bottles for

extended periods of time should be

informed by the available knowledge of

polymer degradation, in combination

with information gleaned from

surveillance programs .

[FR Doc . 05-5450 Filed 3-18-05 ; 8 :45 am]

BILLING CODE 3670-01-P

DEPARTMENT OF EDUCATION

Indian Education Formula Grants to

Local Educational Agencies

AGENCY: Department of Education.

ACTION : Notice reopening the deadline

date for the Indian Education Formula

Grants to Local Educational Agencies

Program.

Catalog of Federal Domestic Assistance

(CFDA) Number: 84 .060A.

SUMMARY: On January 11, 2005 we

published a notice in the Federal
Appendix B : Recommendations Cited

61

Number Date Title

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

Facilities Complex

95-2 October 11, 1995 Safety Management

97-2 May 19, 1997 Continuation of Criticality Safety at Defense Nuclear Facilities

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

99-1 August 11, 1999 Safe Storage of Fissionable Material Called "Pits"

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

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

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

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

2002-3 December 11, 2002 Requirements for the Design, Implementation, and

Maintenance of Administrative Controls

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

2004-2 December 7, 2004 Active Confinement Systems

2005-1 March 10, 2005 Nuclear Material Packaging
Appendix C: 2005 Reporting Requirements

63

March 8 Lawrence Livermore Report < restart

February 24 Los Alamos Briefing 30 days

February 14 Hanford Briefing 60 days

February 11 Hanford Briefing 60 days

February 4 Hanford Report 60 days

February 2 Fernald Report < startup auth .

January 31 10 CFR Part 830 Report 90 days

January 18 Hanford Report 45 days

Date Site or Topic Response Due

December 14 Pantex Report 30 days

November 29 Los Alamos Briefing 7 days

November 28 Y-12 Report 60 days

November 28 Nevada Test Site Report 60 days

November 23 Nuclear Risk Assessment Report 60 days

October 11 Recommendation 2004-1 Briefing 45 days

September 14 Readiness Reviews Report 90 days

September 9 Pantex Briefing annual

September 7 Hanford Briefing 60 days

July 29 NNSA Policy Letters Briefing 60 days

June 1 Hanford Briefing 90 days

May 31 Los Alamos Report 60 days

May 31 Los Alamos Report 90 days

May 2 Pantex Briefing 30 days

April 20 Y-12 Briefing 30 days

March 28 Nevada Test Site Report 120 days

Nevada Test Site Report 45 days
Appendix D: Correspondence

Los Alamos National Laboratory

November 29 letter to the Administrator of NNSA imposing a 7-day reporting requirement to

explain the necessity for a 3-month strategic pause at the Los Alamos Site Office.

September 1 letter to the Administrator of NNSA granting additional time to prepare an adequate

response regarding the confinement ventilation systems at the Plutonium Facility .

July 21 letter to the Administrator of NNSA regarding the resumption of laboratory operations

and corrective action plans .

May 31 letter to the Administrator of NNSA imposing a 60-day reporting requirement regarding

an effective safety-class system at the Plutonium Facility .

May 31 letter to the Administrator of NNSA imposing a 90-day reporting requirement regarding

fire protection .

February 24 letter to the Administrator of NNSA requesting a briefing within 30 days on the

design-build approach for the Chemistry and Metallurgy Research Facility Replacement Project .

Lawrence Livermore National Laboratory

March 8 letter to the Administrator of NNSA imposing a reporting requirement regarding the

path forward for the resumption of programmatic operations in the Plutonium Facility .

Pantex Plant

December 14 letter to the Secretary of Energy imposing a 30-day reporting requirement

regarding the implementation plan for Recommendation 98-2 .

September 9 letter to the Secretary of Energy imposing an annual reporting requirement

regarding the Pit Management Plan, the Pit Packaging Program, and the closing of

Recommendation 99-1 .

May 2 letter to the Acting Deputy Administrator for Defense Programs, NNSA, regarding a path

forward to improve conduct of operations .

Nevada Test Site

November 28 letter to the Administrator of NNSA with a 60-day reporting requirement

regarding safety management programs and vital safety systems at the Device Assembly

Facility.

March 28 letter to the Administrator of NNSA imposing a 120-day reporting requirement on the

desired conditions of readiness for G-Tunnel .

65
March 18 letter to the Administrator of NNSA imposing a 45-day reporting requirement

regarding leaks and structural cracks at the Device Assembly Facility .

Y-12 National Security Complex

November 28 letter to the Administrator of NNSA regarding the structural deficiencies in the

Building 9212 Complex.

July 22 letter to the Acting Deputy Administrator for Defense Programs, NNSA, regarding

electrical systems .

April 20 letter to the Deputy Administrator for Defense Programs, NNSA, imposing a 30-day

reporting requirement regarding structural deficiencies of Building 9212 Complex .

Savannah River Site

October 17 letter to the Administrator of NNSA regarding the review of the electrical system of

the Pit Disassembly and Conversion Facility.

June 10 letter to the Departmental Representative to the Board enclosing a copy of the Board's

Second Annual Report to Congress on Plutonium Storage at Savannah River Site.

February 4 letter to the Administrator of NNSA forwarding a report on the Preliminary

Documented Safety Analysis for the Pit Disassembly and Conversion Facility .

January 4 letter to the Administrator of NNSA forwarding a report on the structural design of the

Pit Disassembly and Conversion Facility .

Hanford Site

October 17 letter to the Secretary of Energy regarding the Board's review of the design and

construction of the Waste Treatment Plant .

September 7 letter to the Assistant Secretary for Environmental Management imposing reporting

requirements regarding the Demonstration Bulk Vitrification Project .

June 1 letter to the Principal Deputy Assistant Secretary for Environmental Management

imposing a 90-day reporting requirement regarding the double-shell tank integrity program .

April 19 letter to the Acting Assistant Secretary for Environmental Management regarding

seismic design criteria for the Waste Treatment Plant.

February 14 letter to the Acting Assistant Secretary for Environmental Management imposing a

60-day reporting requirement regarding the Plutonium Finishing Plant .

66
February 11 letter to the Acting Assistant Secretary for Environmental Management imposing a

60-day reporting requirement concerning criticality safety at the Plutonium Finishing Plant.

February 4 letter to the Acting Assistant Secretary for Environmental Management concerning

fire protection for the Waste Treatment Plant.

February 4 letter to the Acting Assistant Secretary for Environmental Management imposing a

60-day reporting requirement on the Sludge Retrieval and Disposition Project .

January 18 letter to the Acting Assistant Secretary for Environmental Management imposing a

45-day reporting requirement on chemistry control for double-shell tanks .

Fernald

February 2 letter to the Manager, Ohio Field Office, imposing a reporting requirement on actions

taken prior to startup authorization of Silos 1 and 2 at the Remediation Facility .

Rocky Flats

October 3 letter to the Secretary of Energy regarding the Board's responsibilities under the

Memorandum of Understanding .

Other Correspondence

December 16 letter to the Secretary of Energy regarding DOE's new manual on integrated safety

management.

November 23 letter to the Secretary of Energy regarding the draft policy on nuclear risk

assessment .

November 22 letter to the Secretary of Energy regarding the closing of Recommendation 2002-2 .

October 11 letter to the Deputy Secretary of Energy imposing a 45-day reporting requirement

regarding the implementation plan for Recommendation 2004-1 .

September 19 letter to the Secretary of Energy accepting the implementation plan for

Recommendation 2004-2.

September 14 letter to the Deputy Secretary of Energy imposing a 90-day reporting requirement

regarding operational readiness reviews .

September 13 letter to the Secretary of Energy accepting the implementation plan for

Recommendation 2005-1 .

August 5 letter to the Secretary of Energy accepting the implementation plan for

Recommendation 2004-1 and forwarding suggested additions to the project execution plan .

6 7
July 29 letter to the Administrator of NNSA imposing a 60-day reporting requirement regarding

the Policy Letter System .

July 25 letter to the Deputy Administrator for Naval Reactors, NNSA, regarding the Naval

Reactors safety program .

July 21 letter to the Secretary of Energy granting an extension of 45 days in which to submit an

implementation plan for Recommendation 2004-2 .

June 22 letter to the Deputy Secretary of Energy regarding DOE's Second Annual Nuclear

Criticality Safety Program report.

June 21 letter to the Secretary of Energy commending Jeff Cravens and Robert Knighten of the

Y-12 Site Office and Idaho Operations Office as the 2004 Facility Representatives of the Year .

March 10 letter to the Secretary of Energy forwarding Recommendation 2005-1 .

February 18 letter to the Deputy Administrator for Naval Reactors, NNSA, expressing

appreciation for a seminar given to the Board and its staff .

February 14 letter to the Secretary of Energy providing feedback on the DOE's 2004-1

implementation plan.

February 10 letter to the Secretary of Energy granting an extension of 45 days to respond to

Recommendation 2004-2.

January 31 letter to the Deputy Secretary of Energy imposing a 90-day reporting requirement

regarding 10 CFR 830 documented safety analyses.

68