ANNUAL REPORT

TO CONGRESS

DEFENSE NUCLEAR FACILITIES

SAFETY BOARD

FEBRUARY 1994
John T, Conway. Chairman

"'.J. Ejlgrnberrer. Vice Chainun

John W. CrlIIwford. Jr.

Jouph J. DINunno

HNhut John etcH KoulS

DEFENSE NUCLEAR FACILITIES

SAFETY BOARD

625 hldlalla Avenue. NW. Suite 700. Washinglon, D.C. 20004

(202) 20H-64C>lI

February 10, 1994

To the Congress of the United States:

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

fourth annual report, covering activities of the Board during calendar year 1993.

An independent executive branch establishment, the Board provides advice and

recommendations to the President and the Secretary of Ene~gy regarding public health and

safety issues at Department of Energy (DOE) defense nuclear facilities. The Board also

reviews and evaluates the content and implementation of health and safety standards, as well

as other requirements, relating to the design, construction, operation, and decommissioning

of DOE defense nuclear facilities.

As required by statute, the Board's report to Congress summarizes activities during

the past year, assesses improvements in the safety of DOE defense nuclear facilities, and

identifies remaining safety problems at DOE defense nuclear facilities.

During this reporting period, the Board made progress in discharging its health and

safety review responsibilities while addressing the many managerial issues associated with the

operation of a relatively new agency.

Respectfully submitted,

~::7 Chairman

~/r~oI'/ John W. Crawford, Jf

Member

Y~LJJ-S1Hm~~ t/.Io~eph J. Di~nno Member

~~.¥~~

A. J. Eggenberger

Vice-Chairman

Herbert John Cecil Kouts

Member
CONTENTS

REPORT OF BOARD ACI1VITIFS DURING 1993

Page

I. INTRODUCTION . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. 1

A Overview of Board Functions . . . . . . . . . . . . . . . . . . . . . . . . .. 1

B. The Format of the Annual Report to Congress 2

II. TRANSITIONS IN THE DOE DEFENSE NUCLEAR

COMPLEX AND THE BOARD'S 1993 HEALTH

AND SAFETY ACTIVITIES . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. 3

A. 1993 Status of the DOE Defense Nuclear Weapons Complex .. 3

B. The Board's Health and Safety Activities in 1993 4

1. Content and Implementation of Standards,

Including DOE Orders, Regulations,

and Other Safety Requirements. . . . . . . . . . . . . . . . . .. 4

a. Board and DOE Activities Pursuant

to Board Recommendation 90-2

Regarding Safety Standards . . . . . . . . . . . . . . . .. 5

b. Board Recommendation 93-1

Concerning Standards Utilization

in Defense Nuclear Facilities. . . . . . . . . . . . . . .. 8

c. . Adequacy of DOE Orders and Standards 9

d. Summary Assessment of Standards

Issues ReqUiring Resolution 10

2. Safety Aspects of Design and

Construction of Defense Nuclear Facilities . . . . . . . . . .. 11

a. Systems Engineering .. . . . . . . . . . . . . . . . . . . .. 11

b. Seismic and Other Hazards Mitigation. . . . . . . .. 14

c. Other Systems Engineering Activities . . . . . . . . .. 15

3. Recruitment, Retention, Education,

and Training of Qualified Technical

Personnel 15

a. Recruitment, Education, and Training . . . . . . . .. 15

b. Retention of Critical Technical Expertise. . . . . .. 21

4. Safety Aspects of Conduct of Operations , 22

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a. Engineering Safety Through Improved

Conduct of Operations 22

b. Readiness of Facilities to Operate . . . . . . . . . . .. 23

5. Safety Aspects of the Assembly,

Disassembly, and Testing of

Nuclear Weapons 28

6. Safely Managing Special Nuclear

Material, Waste, and Residues. . . . . . . . . . . . . . . . . . .. 32

a. Accelerated Waste Characterization 32

b. Spent Fuel Storage Basins . . . . . . . . . . . . . . . . .. 32

c. Radioactive Residues of

Weapons Production. . . . . . . . . . . . . . . . . . . . .. 33

7. Decontamination, Decommissioning,

and Restoration of DOE Sites . . . . . . . . . . . . . . . . . . .. 34

III. FORMAL SAFETY AND HEALTH INVESTIGATIONS 34

IV. CLOSED BOARD RECOMMENDATIONS 35

V. INTERNAL BOARD MANAGEMENT INITIATIVES,

LITIGATION, AND PUBLIC HEARINGS 36

A Personnel Recruitment, Including the

Intern Program 36

B. Public Hearings, Public Comment, and

Interaction with Board . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. 37

C. LItigation. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. 38

D. Official Site Visits by Board Members

and by Staff . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. 39

VI. PLANNED FOCUS OF BOARD ACTIVITIES IN 1994 39

A. Complex-Wide Safety Issues Requiring

Priority Attention in 1994 42

B. Site-Specific Safety Issues 43

APPENDIX A

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I. INTRODUCI10N

A OVERVIEW OF BOARD FUNCI10NS

The defense nuclear complex was operated by the Department of Energy

(DOE) for decades without independent external oversight. Because of the

increasing number of public health and safety issues that accumulated at aging

defense nuclear facilities, Congress determined that external oversight of those

facilities was necessary. Congress created the Defense Nuclear Facilities Safety

Board (Board) in 1988 as an independent oversight organization within the Executive

Branch to provide advice and recommendations to the Secretary of Energy regarding

public health and safety at DOE's defense nuclear facilities. The President

nominated the initial five members of the Board in the summer of 1989, and the

Senate confirmed those nominations in October of that same year, This is the Fourth

Annual Report provided to Congress by the Board, and it covers activities during

calendar year 1993.

Broadly, the Board reviews operations, practices, and occurrences at DOE's

defense nuclear facilities and makes recommendations to the Secretary of Energy that

are necessary to protect public health and safety. The Board also assesses safety

management and personnel effectiveness both within DOE and the various operation

and management (O&M) contractor organizations. If, as a result of its reviews, the

Board determines that an imminent or severe threat to public health or safety exists,

the Board is required to transmit its recommendations directly to the President, as

well as to the Secretaries of Energy and Defense.

The Board's enablin,g statute, 42 U.S.c. § 2286, requires the Board to review

and evaluate the content and implementation of health and safety standards,

including DOE's Orders, rules, and other safety requirements, relating to the design,

construction, operation, and decommissioning of DOE's defense nuclear facilities.

The Board must then recommend to the Secretary of Energy any specific measures,

such as changes in the content and implementation of those standards, that the Board

believes should be adopted to ensure that the public health and safety are adequately

protected. The Board is also required to review the design of new defense nuclear

facilities before construction begins, as well as modifications to older facilities, and

to recommend changes necessary to protect health and safety. Board review and

advisory responsibilities continue throughout the construction, testing, and operation

of new facilities.

The Board is authorized to conduct special studies pertaining to adequate

protection of public health and safety at defense nuclear facilities. It may seek the

assistance of the federal agencies, organizations outside the government, and private

experts to discharge its duties.

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

gather information, conduct studies, establish reporting requirements for DOE, and

take other actions in furtherance of its review of health and safety issues at defense

nuclear facilities. These ancillary functions of the Board and its staff all relate to the

accomplishment of the Board's primary function, which is to assist DOE in identifying

and correcting health and safety problems at defense nuclear facilities. The Secretary

of Energy and contractors at defense nuclear facilities are required to cooperate fully

with the Board.

B. TIlE FORMAT OF TIlE ANNUAL REPORT TO CONGRESS

By statute, the Board must submit an annual report to the Committees on

Armed Services and on Appropriations of the Senate and to the Speaker of the

House of Representatives at the same time that the President submits the budget to

Congress. The report must include a review of the activities of the Board during the

preceding year, including all recommendations made by the Board. An assessment

is required of the improvements in safety at DOE defense nuclear facilities during the

previous year. The report must also identify safety problems remaining at DOE

defense nuclear facilities.

In past years the Board's annual reports contained three sections which

separately addressed these mandatory topics established by Congress. This led to

duplication and overlap in the reports.

This Fourth Annual Report to Congress is structured to provide Congress with

the statutorily required information in a more concise and readable format. In the

next section of the Report, the Board de$cribes the status of DOE's defense nuclear

facilities complex as it relates to the Board's statutory functions (Section II.A).

Immediately following that description is a summarization of the Board's principal

health and safety activities during 1993 (Section II.B.). That section combines a

discussion of the Board's activities related to Recommendations with an assessment

of improvements in safety within the complex. It also preliminarily identifies major

unresolved health and safety issues requiring continuing attention by the Board and

DOE. Section II.B., which contains most of the statutorily required information, is

organized into narratives which reflect the principal themes of the Board's safety

activities.

Section III of the Report covers formal health and safety investigations

conducted during 1993. Section IV of the Report presents, in tabular form,

information regarding the ten Board Recommendations that have been closed. A

summary of the Board's management activities, litigation, and public hearings is

presented in Section V. Finally, the Board identifies in Section VI those health and

safety issues that are expected to be the focus of 1994 activities by the Board.

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II. TRANSmONS IN TIlE DOE DEFENSE NUCLEAR COMPLEX AND

TIlE BOARD'S 1993 HEALTII AND SAFETY ACI1VfTIES

A 1993 SfAruS OF TIlE DOE DEFENSE NUCLEAR WEAPONS

COMPLEX

The Board's activities during the past year have been strongly influenced by

a defense nuclear complex in the throes of downsizing and mission change. This

transformation has had, and will continue to have, a significant effect on national

security, health, safety, and environmental priorities, as well as the Board's oversight

mission. As a matter of national policy, nuclear weapons production has stopped and

disassembly of a large fraction of the nuclear weapons stockpile is underway. The

United States is maintaining the remainder of the nuclear weapons stockpile with

continuing efforts to ensure the safety and reliability of the nuclear weapons that

remain operational. A moratorium has been placed on nuclear weapons testing. The

federal government is providing the required secure and safe storage of nuclear

components and special nuclear materials removed from the stockpile. Sites for

production of weapons components are being shut down and operations required for

stockpile maintenance are being consolidated at fewer locations. Thus, the nuclear

weapons complex is being reconfigured.

In the meantime, safe management must be provided for large amounts of

radioactive, hazardous, and mixed wastes that have accumulated at the many weapons

production sites over the years. Many former production facilities that were shut

down contain radioactive materials in process lines, tanks, storage vaults, and storage

pools. Safe standby or shutdown conditions must be maintained until the facilities

are readied for clean out of the radioactive residues and decommissioning. Systems

are now being designed imd readied for operation to treat and process the

radioactive and hazardous residues ofthe weapons production program. In shutdown

facilities, radioactive residues are being inventoried, characterized, and readied for

greater stabilization and re-packaging for safer waste management pending final

disposal.

A mammoth, multiple-site cleanup of previously contaminated sites is

underway, requiring a substantially different set of technological solutions and

technical resources than are needed for weapons design, construction, and

disassembly. DOE, the Environmental Protection Agency, the Board, and other

federal departments and agencies, together with their state counterparts and public

interest groups, all play a role in this complex cleanup effort. Federal Court

decisions and consent agreements by parties to litigation heighten the need for

oversight and effective management of these cleanup efforts. In this setting,

assurance of public and worker safety remains highly dependent upon recruitment

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and retention of a well-educated and trained workforce by both DOE and support

contractors, and a disciplined conduct of operations.

B. TIlE BOARD'S HEALTH AND SAFEfY ACIlVITIES IN 1993

In keeping with its enabling legislation, Board activities during 1993 focused

upon seven basic areas related to health and safety at defense nuclear facilities.

These seven areas are: (1) the content and implementation of standards, including

DOE Orders, regulations, and other safety requirements; (2) safety aspects of design

and construction of defense nuclear facilities; (3) recruitment, retention, education,

and training of qualified technical p\lrsonnel; (4) safety aspects of conduct of

operations; (5) safety aspects of the aSsembly, disassembly, and testing of nuclear

weapons, (6) safe management of special nuclear material, waste, and residues; and

(7) decontamination, decommissioning, and restoration of DOE sites. Since

commencing operations in October 1989, the Board has made 26 formal sets of

Recommendations to the Secretary of Energy, totaling III specific

Recommendations. In 1993, the Board issued six sets of recommendations to the

Secretary of Energy, totalling 26 individual public health and safety recommendations

for the year. The Secretary of Energy has responded to and accepted all 26 sets of

the Board's Recommendations. These Recommendations form the primary bases for

the Board's activities last year.

1. Content and Implementation of Standards, Including DOE OrdeIS,

Regulations, and Other Safety Requirements

Congress explicitly set forth in the legislation establishing the Board that: ''The

Board shall review and evaluate the content and implementation of the standards

relating to the design, construction, operation, and decommissioning of defense

nuclear facilities of the Department of Energy (including all applicable Department

of Energy Orders, regulations, and requirements) at each Department of Energy

defense nuclear facility." Congress, in the Board's authorizing legislation, clearly

showed its intent that DOE's self-regulating and oversight activities be based upon

the safe practices embodied in DOE Orders and other standards. The Board's

enabling statute emphasizes the pivotal role standards play in ensuring public health

and safety at defense nuclear facilities. Congress listed the Board's standards

responsibilities first in the enabling statute; standards are then repeatedly referred to

in other sections of the statute, including the provisions for investigations, Board

recommendations, and evaluation of scientific information.

Basic radiation protection policies and requirements for DOE defense nuclear

facilities are set forth in various DOE directives, Orders, and standards. To a

considerable extent, many of these codes of practice parallel those developed and

implemented by the Nuclear Regulatory Commission (NRC). The large difference,

- 4 -
however, is that DOE and its contractors, with few exceptions, have never used DOE

Orders, standards and guides to establish a hard core set of practices which define

"how safe is safe enough." Adherence to Orders has been a condition of O&M

contracts, but compliance has not been rigorously enforced. Without a well-defined

set of Orders and standards to measure the safety of operations against, it is difficult

to demonstrate that public health and safety are adequately protected.

The Board considers the establishment and implementation of applicable

safety-related Orders, regulations, and requirements at defense nuclear sites and

facilities to be strong indicators that public health and safety are adequately

protected. However, DOE has not yet brought the defense nuclear complex around

to fully embracing this basic concept. Despite four years of persistent effort by the

Board, and repeated avowals of intent to improve by DOE management, the overall

program for the identification ofsafety requirements, Order compliance assessments,

and safety requirements implementation by DOE line organizations and contractors

continues to drag. Exacerbating this situation, DOE "oversight" of defense nuclear

facilities does not include effective compliance assessments based upon safety

requirements set forth in Orders, standards, and related documents. Furthermore,

DOE is not yet organized and staffed to perform effectively this oversight function.

a. Board and DOE Activities Pursuant to Board Recommendation 90-2

Regarding Safety Standards

In discharging its responsibilities, the Board determined early in its existence

that many of DOE's Orders and standards were not being used effectively or

uniformly. In its previous Annual Reports, the Board has discussed its ongoing

efforts to encourage DOE'ss.tandards program, including development, promulgation,

implementation, and compliance with suitable safety standards. Those efforts

continued during 1993.

Most importantly, the Board continued to encourage DOE to fully implement

one of the Board's first Recommendations. That Recommendation, 90-2, called for

DOE to (1) identify the DOE Orders, standards, and other safety requirements

applicable at defense nuclear facilities; (2) assess the adequacy ofsuch requirements;

and (3) determine the status of compliance with such requirements at defense nuclear

facilities. Almost four years after the Board issued Recommendation 90-2, DOE has

still failed to adequately implement this Recommendation complex-wide. Indeed, a

fully satisfactory Departmental implementation plan for Recommendation 90-2 has

yet to be developed. The Board's reviews at a wide spectrum of sites continue to

show that DOE Orders and standards are often not adequately used as the basis for

ensuring safe operations.

- 5 -
Major elements of DOE's Revision 4 to the Implementation Plan and, in

particular, the Plan's compliance schedules were rejected by the Board on September

3, 1993. Some schedules for completing identification, assessments for adequacy, and

compliance with standards at specified defense nuclear facilities were either lax, or

absent from the plan altogether. It was not apparent that DOE and its contractors

were committed to taking required actions at a number of defense nuclear facilities

in a timely and effective manner. Although the Secretary wrote to the Board on

September 23, 1993, and committed to submitting a fully acceptable Plan, DOE has

not yet submitted Revision 5 to the Board. The general problem is that some spotty

progress has been made at DOE and its facilities toward full and beneficial use of

Orders and standards. However, a single, coherent DOE program for development

and use of safety requirements as a fundamental base for self-regulation has not

emerged.

Because DOE has not fully developed a standards-based approach to safety,

major deficiencies exist in the implementation of some important DOE-wide safety

initiatives, such as those related to Radiological Protection Orders, Regulations, and

the Radiological Control Manual. Radiation protection standards and practices,

along with trained and competent personnel to implement them, are essential to

providing a safe and healthy work environment at a site where radioactive material

is found. Recommendation 91-6, which has been discussed in detail in earlier Annual

Reports, focused DOE's attention on radiation protection management and

leadership, standards and practices, training and competency of personnel,

identification and analysis of deficiencies, and correction of those deficiencies. In

June 1993, DOE submitted a second revised Implementation Plan for

Recommendation 91-6, which the Board found generally acceptable. However, the

Board stated that commitment dates for full compliance with Radiological Protection

Orders at some facilities were unacceptable. The Board's position was that these

facilities should be brought into compliance more rapidly, particularly since the key

features of DOE's Radiological Protection Orders have been enforceable against

contractors for decades.

During 1993, the Board reviewed radiation protection compliance at several

facilities. These reviews identified numerous deficiencies, as well as some

improvements in DOE's radiation protection program, including an expanded

program for the DOE Radiological Control Manual (RCM).

The Department's development and implementation of its Order and

standards on the subject of Operational Readiness Reviews, in response to Board

Recommendation 92-6, stand in contrast as excellent examples of the use of a

standards-based approach. Other advances in the standards domain were made by

DOE in 1993. The Office of Environmental Restoration and Waste Management

(EM) exerted substantial effort to develop adequate Requirement Identification

- 6 .
Documents (RIDs), and DOE's Office of Defense Programs focused much of its 90-2

related effort on assessing compliance with DOE's safety Orders. Also, the

Department issued and is beginning to implement several new safety Orders and

standards, as well as revisions to existing Orders.

The Board continued its scrutiny of development of RIDs by DOE and its

contractors. RIDs will identify the laws, regulations, Orders, standards, and other

requirements applicable to DOE activities pursuant to Recommendation 90-2. As

part of its implementation of Recommendation 90-2, DOE and its O&M contractors

have developed RIDs in several areas. When they are all completed, RIDs will cover

eighteen functional areas, including, among other things, engineering and design,

safety documentation, training and qualification, conduct of operations and

maintenance. Each functional area will contain three levels of requirements:

(1) generic ; (2) site specific; and (3) facility specific.

During 1993, DOE submitted to the Board several RIDs covering sites

managed by DOE's Office of Environmental Restoration and Waste Management

(EM). Some of these RIDs were quite comprehensive. For example, the Fire

Protection RID for the Defense Waste Processing Facility (DWPF) contains a

significant number of standards which represent the fire protection safety envelope.

DOE has provided this particular RID to other sites and facilities as a model for a

complete RID.

Some DP facilities and sites made substantial progress toward compliance with

DOE Orders and standards. For example, the Westinghouse Savannah River

Company (WSRC), a major O&M contractor, was responsible for some of the most

significant improvements. I.n reviewing WSRC's compliance with DOE Orders in

1993, the Board's staff noted the development of several new procedures to

implement the requirements contained in DOE Orders, a process the Board refers

to as "administrative compliance." Also noteworthy was the documentation of

administrative compliance for the Replacement Tritium Facility (RTF). WSRC

personnel at RTF established a program to ensure that the procedures developed to

implement DOE requirements are complied with and adhered to during plant

operations and maintenance. When a contractor achieves compliance with safety

requirements while conducting operations and activities, the Board refers to the

facilities as having achieved "adherence compliance." DOE and the contractors

conduct "performance-based" compliance assessments to measure the level of

adherence compliance. RTF currently serves as a model of Order compliance for

other defense nuclear facilities. The Board considers WSRC's actions encouraging,

not only because of observed improvements, but also because the personnel

responsible for these improvements have been placed in positions to positively affect

other facilities at that site.

- 7 -
There has been progress at some other sites as well. In the summer of 1992,

the Board identified several non-compliance issues at the Oak Ridge Y-12 Plant. A

follow-up review in May 1993, found that the status of compliance with DOE's

Orders at Y-12 had not improved substantially. The Board pursued this issue further

at a public Board hearing at Oak Ridge in August 1993. DOE and the Oak Ridge

O&M contractor responded by committing to compliance with DOE's Orders and

standards and a reporting requirement to document progress. The progress reports

submitted by the end of 1993 indicate that the Order compliance effort at Y-12 has

improved significantly.

In its ongoing review of compliance with DOE's Orders and standards atDOE

sites and facilities, the Board used as a reference, and encouraged DOE to use,

DOE's Order Compliallce SelfAssessment IllStructioll issued by the Office of Defense

Programs (DP). This instruction provided DP's sites and facilities with detailed

requirements regarding compliance with DOE's Orders, and instructions concerning

how sites and facilities should evaluate their compliance.

b. Board Recommendation 93-1 Concerning Standards Utilization in

Defense Nuclear Facilities

The addition of nuclear weapons assembly, disassembly, and testing to the

Board's oversight responsibilities required that additional attention be directed to

compliance with standards and other safety requirements at those types of facilities.

On January 21, 1993, the Board issued Recommendation 93-1, "Standards

Utilization in Defense Nuclear Facilities." In that Recommendation, the Board noted

that its "ongoing review of the use of standards in defense nuclear facilities has

disclosed a number of potential inconsistencies in the manner in which DOE Orders

related to nuclear safety are applied at facilities that produce and process nuclear

materials and those that assemble, disassemble, and test nuclear weapons....The

Board considers that certain safety principles apply to the handling of fissile

materials, regardless of the form the material is in." Accordingly, the Board

recommended that DOE review the Orders and directives applicable to facilities

involved in the assembly, disassembly, and testing of nuclear weapons and determine

whether they provide safety assurance at least as rigorous as that which applies to

other DOE nuclear facilities, and comparable to the safety assurance provided to the

public and site workers by commercial nuclear material processing facilities. A

verbatim copy of Recommendation 93-1, as it appeared in the Federal Register, is

contained in Appendix 1 to this Report.

DOE's Implementation Plan for Recommendation 93-1 established bimonthly

reporting requirements, provided an analytical method for accomplishing the

objectives of the Recommendation, and set milestones that would drive DOE's

- 8 -
implementation of the Recommendation to completion by June 1, 1994. The Board

and its staff are closely monitoring DOE's implementation of Recommendation 93-1

through regular meetings with DOE, review of the status reports, and detailed

technical evaluations of other DOE documents. The Board intends to follow DOE's

actions until all analyses are complete and the required changes to Orders and

directives have been promulgated and satisfactorily implemented.

c. Adequacy of OOE Orders and Standards

In 1993, the Board focused on the adequacy of those Orders, standards, and

guides that set forth the requirements for safety systeI1;ls, structures, and components

and that provide guidance as to how to satisfy them. Principal among these are DOE

Orders 5480.21, Unreviewed Safety Questions; Order 5480.22, Technical Safety

Requirements; Order 5480.23, Nuclear Safety Analysis Reports; and the supporting

DOE Standards 1027-92, Hazard Calegorizalion and Accidelll Analysis Techniques for

Compliance wilh DOE Order 5480.23, Nuclear SafetyAnalysis RePOrlS; 3005-93 (Draft),

Definitions and erileria for Accidell/ Analysis; 3009-93 !(Draft), Preparation Guide for

u.s. Departmelll ofEnergy Non-Reaclor Nuclear Facility Safety Analysis Reporls; and

Draft Standard SAFf·0019, Guidance for preparation of DOE 5480.22 (TSR) and

5480.23 /mplemelllalion Plans.

Taken as a set, this group of Orders, standards, and guides is particularly

important because it represents DOE's attempt to address key safety issues such as:

The specification of technical requirements that are conditions of

operations as derived from safety analysis.

• Use of relative hazards classification t!> prioritize the complex·wide

upgrading of Safety Analysis Reports. '

• Use of probabilistic techniques and reference radiation exposure limits

to evaluate need for and/or adequacy ofsafety systems, structures, and

components.

The Board is concerned that the concept of "defense·in·depth" as prudent

guidance for facility design and operations is not being fostered in relevant DOE

standards, many of which have established very mechanistic procedures which leave

little room for appropriate engineering judgment. This concern led to the formation

of a Safety Analysis Report/Probabilistic Hazards Analysis review team within the

Board's technical staff in the latter part of 1993, to focus on DOE's approach to

safety criteria, accident analyses, and protection of workers and the public.

·9-
Some current DOE Orders and standards do not provide the necessary

margins of protection for public health and safety because they have not been

updated to meet current consensus and industry guidance. Furthermore, some

important safety areas are not covered by any DOE Order or standard. For example,

DOE does not have adequate Orders or standards in place for configuration

management, decontamination and decommissioning, backfilling safety improvements

to existing facilities, or site cleanup. It should be noted that DOE has drafted a

standard for configuration management, but has not yet issued it. In addition, some

existing DOE Orders and standards may be too detailed and prescriptive, causing

unnecessary difficulties with compliance.

However, since the issuance Of Recommendation 90-2, the Board has

observed some improvement in the development of new DOE Orders to adequately

protect public health and safety. Most of the recently published DOE Orders contain

appropriate requirements and guidance from consensus and industry standards. One

of the first Orders to rely on commercial standards was DOE Order 4330.4A,

Maintenance Management Program. More recently, DOE Order 5480.26, Trending

Analysis of Operational Infonnation Using Perfonnance Indicators, contains several

references to performance indicators used in the commercial nuclear and other

industries.

d. Summary Assessment of Standards Issues Requiring Resolution

While significant progress has been made at some of the DOE facilities, too

many O&M facility managers and DOE personnel simply do not yet understand the

importance of conscientiously implementing Orders and standards that define

requirements and practices that provide reasonable assurance of no undue risk to the

public and workforce and environmental protection. The Board still hears claims that

compliance with Orders and standards is too resource-intensive to justify the effort.

Some personnel have stated that compliance with Orders and standards is not

important at all. Overcoming these attitudinal hurdles is a continuing challenge to

DOE.

A case in point is DOE Order 5480.23, Nuclear Safety Analysis Repons, which

was issued by DOE in the spring of 1992. This Order is reasonably complete, and

compares favorably with commercial nuclear requirements. However, some of the

implementing standards drafted to support the Order are not consistent with the

guidance found in analogous commercial nuclear industry documents and in fact often

degrade the Order's requirements. In general, many safety analysis reports in the

complex do not currently meet the requirements of DOE Order 5480.23 or the

implementing standards. While the commercial nuclear industry standards can

provide a model for DOE's approach to safety documentation, their verbatim

adoption is not possible, because of the diversity of DOE facilities, their age and

. 10 -
condition, and the state of their records. The challenge is for DOE to accelerate

development of a meaningful set of-safety documents for its facilities.

Those defense nuclear facilities coming under the control of the Office of

Environmental Restoration and Waste Management (EM) for clean-up, site

remediation, or decontamination and decommissioning will have sets of Orders and

standards (many just being developed) different from those of production facilities.

Even though the Board has emphasized the importance of determining the status of

compliance with requirements in existing Orders and safety standards, EM elected

to develop more encompassing RIDs first, rather than to perform preliminary self

assessments for compliance with the existing DOE Orders. EM asserted that its

decision was based on the more limited number of DOE Orders relevant to the

functional areas of importance to EM, and the numerous sources for environmental,

safety, and health requirements for EM's facilities _. environmental statutes,

regulations, consent decrees, and court decisions.

The Board has accepted this approach in principle. However, the Board has

communicated its expectation that the safety requirements which are to be the

framework for EM activities will be clearly defined and will be made mandatory for

both DOE line managers and support contractors.

Although some O&M contractors operating EM's sites and facilities had

developed RIDs by the end of 1993, neither DOE nor the O&M contractors had

made those RIDs mandatory through contract modifications and had not developed

implementing procedures. Furthermore, once the procedures that implement RIDs

are written and approved, the Department and its contractors must ensure that they

are properly used and complied with by workers on the line. This process may prove

to be especially difficult for EM, because the EM staff has limited experience

translating standards requirements and guidance into meaningful procedures and

practices.

2. Safety Aspects of Design and Construction of Defense Nuclear Facilities

a. Systems Engineering

Congress explicitly set forth in the legislation establishing the Board that: "The

Board shall review the design of a new Department of Energy defense nuclear facility

... During the construction of any such facility, the Board shall periodically review and

monitor the construction ... to ensure adequate protection of public health and

safety." This provision recognizes that the design, construction, operation, and

decommissioning of defense nuclear facilities form a complete life cycle for defense

nuclear facilities which form a single complete system. These elements and the

manner of their interaction are described by a process called systems engineering.

. 11 .
Each element depends on and is linked to the others. If this is not recognized, the

end result can be a facility that is inoperable within desired safety and economic

envelopes. Facilities have been constructed within the DOE weapons complex that

have not displayed recognition of this. The elements of this life cycle system are as

follows.

Facility design is initiated and controlled by a mission statement that describes

the purpose of the facility, the process or processes that will be used to accomplish

the mission, and the justification of the mission. Conceptual design and design bases

are prepared which outline the basic configuration, the process systems that constitute

the facility, and the safety requirements (Codes and Standards). If a facility is a

component of a larger complex, the int~rface requirements (input and output) are

defined and controlled. Then a series of progressively more detailed design iterations

are prepared that ultimately lead to documents (drawings and specifications) used for

construction and operation. The design bases serve as the underpinning for the

requirements of construction, as well as the starting point for development of conduct

of operations.

Construction is initiated by executing the content and instruction in the

drawings and specifications, and then assembling the structures and components of

the systems accordingly. This is accomplished according to the requirements of the

design. Once startup and testing are complete, operational requirements identified,

operational procedures readied, and personnel trained, the facility is then ready to

operate.

Operations embody using the facility systems to achieve mission requirements

in a manner consistent with the design ~afety envelope and the operational safety

requirements derived from the design bases. Once the facility has fulfilled its mission

and is no longer required, decommissioning begins.

Decommissioning is the process of emptying a facility of feedstock, the

disassembly of the components of the systems within the facility, and the removal of

the structure that housed the facility. This is done using a systems engineering

process that maintains a facility safety envelope, consistent with the changed mission,

until the decommissioning process is complete. It also requires that special

requirements be developed to handle and dispose of any waste products resulting

from actual dismantlement.

The above discussion demonstrates that the mission and life cycle of DOE

defense nuclear facilities may be thought of as a straight forward system. Had the

existing facilities been developed and operated in accordance with these principles

of systems engineering, many of the safety issues and concerns that the Board is

currently addressing would not exist. However, the weapons complex was not

- 12 -
constructed nor has it evolved using these principles. Consequently, many safetyrelated concerns and issues at these facilities result from the lack of development of

the complex as an integrated whole. Using a systems approach, any action related

to one part of the system must be evaluated for its potential effect on the other parts

of the system. Examples of such actions are those described above and include

design, construction, maintenance, operations, and decommissioning. The activities

which comprise these processes or actions are linked and are interactive. The Board

has encouraged, through several separate sets of recommendations, that DOE employ

a systems engineering approach to addressing the numerous technical issues facing

the nuclear weapons complex.

One of the most influential parts of the systems approach is the effect that the

adequacy of the design has oit the safety of facilities. The Board continues to devote

attention to the design bases of defense nuclear facilities. This attention reflects the

conviction that properly conceived and executed designs provide a defense-in-depth

and the foundations for safe operation and decommissioning of facilities.

Previous Annual Reports to Congress have discussed the technical assessments

conducted by the Board and its staff to evaluate the safety bases for operations at a

number offacilities. During 1993, extensive reviews were undertaken of the adequacy

of seismic and systems engineering designs at the H·Area Waste Tank Farms, the

Defense Waste Processing Facility, and the Replacement Tritium Facility at the

Savannah River Site. Examinations are currently being continued of the design

adequacy of existing facilities at the Savannah River Site, the Hanford Site, and the

Idaho Chemical Processing Plant for safe storage of spent nuclear fuel, and the

facility modifications necessary to store additional spent fuel in these existing facilities.

The Board issued its Recommendation 92-4 in 1992, urging adoption of a

systems approach in the project for new high level nuclear waste tanks at the

Hanford Site. In February 1993, DOE submitted an implementation plan for Board

Recommendation 92·4. The Board rejected the plan, noting that the systems

approach and systems engineering for the Tank Waste Remediation System (TWRS)

at Hanford, which were called for in Recommendation 92-4, could be considerably

strengthened through appropriate requirements in the implementation plan. During

the past year, the Board has worked with DOE to ensure that the revised

implementation plan properly addresses the systems approach. Prior to the end of

1993, considerable progress had been made in the development of an adequate plan.

Implementing the needed actions will involve modification of long-standing practices,

such as segregation of the design processes, construction, and operation of facilities.

Many DOE facilities previously managed by the Office of Defense Programs

(DP) are being transferred to DOE's Office of Environmental Restoration and Waste

Management (EM). The status of these facilities needs to be well·characterized to

• 13 -
determine which measures are required to ensure safety during a state of operation,

standby, or decontamination and decommissioning.

b. Seismic and Other Hazards Mitigation

The Board continues to devote significant attention to reviewing the adequacy

of design bases of defense nuclear facilities. A significant portion of the review of

design bases encompasses subject areas associated with mitigation of natural and man

made hazards. Included are effects due to seismicity, wind, tornado, and flood, as

well as potential hazards resulting from processes utilized, and materials contained,

in facilities. These hazards are often the most significant threats to the safety and

integrity of a facility. '

During 1993, part of the Board's review effort was focused on the design

adequacy of facilities to resist natural and man-made phenomena at a number of

facilities across the weapons complex. Review of H-Area Waste Tank Farms at the

Savannah River Site (SRS), the fuel basins at the Idaho National Engineering

Laboratory (CPP-603, CPP-666), the Chemistry and Metallurgy Research Laboratory

(TA-3) and the Plutonium Facility (TA-55) at Los Alamos National Laboratory, and

the Materials Staging Facility at the Pantex Plant were either begun or continued

throughout 1993.

Review of the design adequacy of the Replacement Tritium Facility (RTF) at

the Savannah River Site was completed. Questions were raised concerning seismic

ground motion and structural and geotechnical engineering. The Board could not

concl'ude that the RTF would adequately resist extremes of seismic ground motion

without its design limits being exceeded, due to the potential for liquefaction of soils

directly beneath the main building. However, the facility was considered to pose an

acceptable risk after it had been established that the tritium inventory in the facility

would be limited.

The Board initiated review of analyses that DOE and its contractors

performed to assess potential aircraft crash accidents for certain DOE defense

nuclear facilities. The review and evaluation indicated that the methodologies

employed in these studies are not always consistent. Areas of inconsistencies noted

include assessment of the probability of an aircraft crash, aircraft impact analytical

methodology, and analysis of the consequences of the crash. The Board is closely

examining the accident analyses covering possible aircraft crashes at the storage

magazines at the Pantex Plant. This review will continue in 1994.

Comparison has been made of the characterization studies of seismic ground

motion performed at the Savannah River Site, the Idaho National Engineering

Laboratory, the Los Alamos National Laboratory, and the Rocky Flats Plant in

- 14 -
previous years. The Board has concluded that the methods used to characterize

ground motion may not be appropriately conservative for use in evaluating the safety

of existing facilities and the design of new facilities. This topic will be the subject of

continued review and discussion in 1994. The interest of the Board in seismic issues

is motivated by the fact that among the natural and man-made phenomena, seismic

events can have wide-ranging consequences. This observation was recently

reconfirmed by the extensive area of damage associated with the Northridge,

California, earthquake.

c. Other Systems Engineering Activities

In addition to the Recommendations discussed above, eight of the

Recommendations issued in earlier years have dealt with systems engineering

concepts, improved design basis knowledge, or enhancement ofsafety through design

improvements or modifications. These eight include: 90-3 (Safety at the Hanford

Waste Tanks); 90-5 (Systematic Evaluation Program at Rocky Flats Plant); 90-6

(Criticality Safety at Rocky Flats Plant); 90-7 (Safety at the Hanford Waste Tanks);

91-2 (Closure of Safety Issues at the K·Reactor); 91-5 (Power Limits for K-Reactor

Operation); 92-4 (Multi-Function Waste Tank Facility at Hanford); and 92-5

(Discipline of Operation in a Changing Defense Nuclear Facilities Complex).

While not directly tied to specific Board recommendations, several activities

have been initiated on a broad basis to review other issues related to systems

engineering, design bases, and safety enhancement. The issues covered include: (l)

spent fuel handling by DOE; (2) treatment of waste and other chemical processing

matters; (3) methodologies for storage of special nuclear material; (4) storage of

tritium; (5) methods used for safety analyses and for risk-based analyses and

prioritization; (6) practices for planning work so as to maintain exposures as low as

is reasonably achievable; and (7) approaches for decommissioning and

decontamination.

3. Recruitment, Retention, Education, and Training of Qualified Technical

Personnel

a. Recruitment, Education, and Training

The technical capabilities of DOE and contractor personnel have been an ongoing concern of both the Congress and the Board for a number of years. The

United States Senate Report accompanying the Board's enabling legislation states

that the "Board is expected to raise the technical expertise of the Department

substantially...." The health and safety of the public and workers rest on a properly

trained workforce accomplishing tasks in a formal, deliberate fashion in accordance

with reviewed and approved procedures. Implementation of effective training and

- 15 -
qualification programs and disciplined conduct of operations are essential to

establishing a technically competent work force. As a result, many of the Board's

recommendations have stressed training and conduct of operations.

Recommendation 90-1, the first formal Recommendation promulgated by the

Board, called for implementation of effective training and qualification at the

K-Reactor at the Savannah River Site. DOE action resulted in a successful training

program. During 1993, the staff of the Replacement Tritium Facility at the Savannah

River Site used the lessons learned at the K-Reactor and subsequently became the

first DOE facility to have a fully accredited technical training program. However, in

most other cases, DOE has not extended this proven approach to other defense

nuclear facilities at the Savannah River Site or to facilities at other sites.

Assessments in 1992 at the Hanford Site, the Pantex Plant, non-reactor

facilities at the Savannah River Site, the Y-12 Plant at Oak Ridge, and the Rocky

Flats Plant clearly demonstrated the need to strengthen training of technical

personnel. As a result, Recommendation 92-7 proposed that DOE take strong

actions to improve qualification and training at those sites. DOE's initial

Implementation Plan, submitted in June 1993, was determined by the Board to be

unacceptable as a means for achieving the needed improvements.

DOE did not correct the deficiencies in this Implementation Plan until the

initiatives of Recommendation 92-7 were embraced by an even broader-based Board

proposal (Recommendation 93-3) for improving recruitment, retention, education,

and training of DOE's technical personnel. Previous Annual Reports have

emphasized the imponance of attracting and retaining technically educated and

experienced personnel to provide the management, direction, and guidance essential

to safe operation of the defense nuclear facilities. Nevenheless, in recent years there

has been little noticeable improvement in the scientific and technical expertise in the

defense nuclear facilities complex.

A significant cause is a major handicap imposed on DOE in the recruitment

and advancement of technically-qualified personnel to positions of responsibility.

Unlike other federal agencies which rely upon technical competency, such as the

Nuclear Regulatory Commission, the National Science Foundation, and the Board,

DOE does not have excepted appointment authority. It is seriously encumbered by

antiquated Civil Service restrictions that discourage bright, technically-qualified

persons from being initially hired and subsequently promoted to positions of

responsibility.

The lack of sufficient numbers of qualified technical personnel in DOE's

oversight and line organizations is a serious issue. In some instances, the Board has

provided a level of technical review for DOE that goes beyond the traditional bounds

. 16 .
of external oversight. This has occurred for a variety of reasons, including failure of

DOE's internal oversight and line personnel in many instances to detect and correct

safety problems as they arise. It also has adverse consequences for the Board, which

has a limited number of staff. The ability of the Board to meet its responsibilities

and to expand its coverage are directly related to DOE's performance in taking

prompt and effective remedial action on safety problems which DOE itself identifies,

or which are called to DOE's attention by the Board. The Board is sensitive to the

need to ensure that its resources are not used as a substitute for DOE's personnel

and capability, both in line and internal oversight organizations. Those organizations

must be the first and second lines of defense for detecting and correcting safety

problems. If the Board's personnel must make repeated assessments of a facility or

activity in order to identify problems or to ensure that needed improvements are

made, the Board's ability to fully execute its responsibilities may be limited.

Recommendation 93-3 urged DOE to take dramatic action to attract and

retain scientific and technical personnel of exceptional qualities. The

Recommendation addressed concerns of the Board regarding the technical

capabilities of personnel within the Department, both at Headquarters and in the

field. Among the steps the Board urged were the following DOE initiatives:

1. Establish the attraction and retention of scientific and technical personnel of

exceptional qualities as a primary agency-wide goal.

2. Take the following specific actions promptly in the interest of achieving this

goal.

a. Seek excepted. appointment authority for a selected number of key

positions for engineering and scientific personnel in DOE

programmatic offices, in other line units, and in the oversight units

responsible for the defense nuclear complex.

b. Establish a technical personnel manager within the Office of the

Secretary to coordinate recruitment, classification, training, and

qualification programs for technical personnel in defense nuclear

facilities programs.

3. Develop a broad-based DOE program for improving qualification, education,

and training of technical personnl:1 including:

a. Review the performance appraisal system for technical employees for

its effectiveness in determining basic pay, training needs, promotions,

reductions in grade, and reassignment/removal.

- 17 -
b. Review and improve programs for training and assigning technical

personnel. (This activity would be coordinated with actions taken, or

planned to be taken, in response to Board Recommendations 90-2, 91-

6, 92-2, and 92-7).

c. Explore with the Secretary of Defense the possibility of assigning to

DOE defense nuclear facilities activities a number of outstanding

officers with nuclear qualifications who may now be surplus to DOD

needs.

d. Establish initiatives designed to take advantage of skills of marginal

technical performers and 'retrain them.

e. Expand HeadquarterslField personnel exchange programs for highly

qualified junior technical staff to promote understanding of all aspects

of technical issues including their resolution.

Finally, the Recommendation called for a baseline and continuing assessments

of DOE's technical personnel initiatives by groups internal and external to DOE.

The Secretary of Energy accepted Recommendation 93-3 on July 23, 1993. A

verbatim copy of Recommendation 93-3, as it appeared in the Federal Register, is

contained in Appendix 1 to this report. Because of the importance the Board

attached to the Recommendation, the Board established a task group of senior staff,

chaired by the Board's General Counsel, to work with DOE's staff in the

development of an adequate implementation plan.

To address several overlapping clements of Recommendations 92-7, which

covered qualification and training of technical personnel, and Recommendation 93-3,

the Secretary proposed, and the Board accepted, that a single Implementation Plan

be developed for these two important and inter-related Recommendations. After

extensive joint effort by the DOE and Board task groups, DOE submitted a

comprehensive combined Implementation Plan that was accepted by the Board on

November 5, 1993. All initiatives covered by the Implementation Plan are scheduled

to be completed by December 1995.

Some of the actions recommended by the Board in Recommendation 93-3

were completed before the close of 1993. A senior and broadly experienced DOE

technical management expert was named to coordinate all of the technical personnel

initiatives and to manage implementation of the plan. The Secretary issued a policy

statement emphasizing the important link between technical competence and safety

at defense nuclear facilities. Unfortunately, DOE did not move expeditiously enough

to request Congressional authorization for excepted service appointment authority for

key technical personnel during 1993. The Board has informed the principal

- 18 -
committees in Congress of the need. This Board Recommendation is a priority for

1994, and is consistent with the President's commitment to correct deficiencies

existing in the government personnel system identified during the National

Performance Review. Persistent and strong personal involvement at the highest

levels within the Department will be required to ensure that the sweeping reforms

embodied in the Secretary's implementation plan for Board Recommendation 93-3

are achieved.

For these technical personnel initiatives to work, DOE must clearly define and

delineate the various roles and responsibilities for safety within the defense nuclear

complex. During the past year the Secretary instituted a major reorganization of the

Department. As DOE implemented these new arrangements, it became evident to

the Board that nuclear safety responsibilities among the many organizations involved

require more explicit written delineation than has been provided. The Board also

brought the need for such definition to the attention of DOE and has been told that

it is being developed.

The Board and its staff continued making assessments of existing training and

qualification programs at defense nuclear facilities during 1993. The Board's

observations and staff reviews were often forwarded to DOE pursuant to the Board's

Policy Statement Number 2, which governs transmittal of technical information to the

Department of Energy in these circumstances where a Board recommendation is

inappropriate. For example, many of the deficiencies in training and qualification

observed during a July visit to the F-Area of the Savannah River Site, transmitted in

a Board letter to the Assistant Secretary for Defense Programs, had been observed

in earlier reviews. The lack of corrective action was cause for concern, particularly

in view of the approaching re~tart of the facilities. DOE and its contractor thereafter

initiated significant improvements in the deficient programs.

In a letter from the Board to the Principal Deputy Assistant Secretary for

Defense Programs dated July 6, 1993, the Board transmitted information regarding

technical reviews at the Pantex Plant conducted during March and June 1993. The

Board noted that the Pantex O&M contractor's training and qualification programs

for maintenance and technical support divisions lacked uniformity and that progress

in improving these programs varied noticeably among the involved divisions. The

Board also found a lack of proactive line management and asked for a formal report

from DOE indicating its plan for corrective action. Thereafter, DOE and its

contractor committed to accelerating the schedule to correct the deficiencies.

As shown by these two examples and the results of several other reviews

conducted in 1993, inadequate progress was being made in effecting broad·based

improvement in training and qualification across the complex. In September, the

Board urged the Secretary's continued and direct leadership in timely and effective

- 19 -
implementation of needed improvements. Shortly thereafter, DOE committed to the

wide-ranging Implementation Plan for Recommendations 92-7 and 93-3 noted above.

A key element in DOE's ability to ensure proper training, qualification, and

conduct of operations by its contractors is the assignment of Facility Representatives

by DOE. A Facility Representative is assigned to each major facility, or group of

lesser facilities, to oversee the day-to-day conduct of operations there. These

individuals are DOE's primary contact with the contractors, and they playa vital role

in ensuring adequate protection of public health and safety at the defense nuclear

facilities.

The Board had noted and informed DOE that the Facility Representative

Program lacked centralized control and that qualifications, duties, and responsibilities

of the representatives varied from facility to facility, even at the same site.

Recommendation 92-2 addressed the need for a comprehensive analysis of the

Facility Representative program and for establishment of a formal program of

training, qualification, and definition of duties and responsibilities. In April 1993, the

Secretary forwarded a plan to review the status of existing programs and develop:

(1) a plan to establish and maintain an effective program at each field organization;

(2) recruitment and retention techniques and incentives; (3) training; and (4) a

standard for the Facility Representative program.

Subsequently, in August 1993, DOE issued DOE-STD-1963-93, Establishing

and Maimaining a Facility Representative Program at DOE Nuclear Facilities, to

provide guidance concerning selection, training, qualification, coverage, duties,

responsibilities, and authorities of the Facility Representative. In the first quarterly

status report of the Action Plan for Recommendation 92-2, the Secretary reported

the results of a review of the current status of Facility Representatives at each

defense nuclear facility, and committed to completing all proposed actions by May

1994.

DOE's Technical Standards Program has issued various documents which

amplify DOE's Orders 5480.19 and 5480.20, Personnel Selection, Qualification,

Training, and Staffing Requirements at DOE Reactor and Non-Reactor Nuclear

Facilities, and which provide valuable recommendations and suggestions for

implementing requirements established by the Order. Guides have been issued for

two-thirds of the chapters in DOE Order 5480.19. Numerous guides have also been

prepared to provide information concerning the conduct and evaluation of various

aspects of training and qualification programs. Although issuance of these guides is

commendable, the Board's staff has found during site visits that DOE field

organizations and contractors are often unfamiliar with the DOE-SID Guide series

and have failed to implement programs of quality comparable to that of the ones set

·20·
forth in the guidelines. The Board intends to stress the implementation of these

guides in its facility reviews in the forthcoming year.

The shift of several of the defense nuclear facilities toward environmental

restoration, and the resulting abruptly changing missions of these facilities, present

new and formidable challenges to DOE in developing and maintaining effective

training, qualification, and operational programs. Many of the DOE Orders and

standards were developed for facilities engaged in long term processing or reactor

operations. Developing specific programs for facilities engaged in short-duration,

singly performed operations, such as the Fernald Environmental Management

Project, will require careful planning and innovative approaches. Moreover, in some

cases, such as at Building 0771 at the Rocky Flats Plant and the Hanford Site

Plutonium Finishing Plant, the lack of a well-defined mission has prevented

implementation of an effective training program. The Board and its staff will

continue their vigilance of DOE's training, qualification, and operational programs,

particularly those that are rapidly changing. For example, the Board is currently

conducting an expanded review of performance in regard to conduct of operations

across the complex to determine additional actions required to improve the quality

of compliance in this critical area.

b. Retention of Critical Technical Expertise

The Board has been concerned with the loss of unique talents from DOE and

the contractor organizations operating defense nuclear facilities. This concern is

particularly acute for the weapons laboratories and the facilities involved in assembly,

disassembly and testing of weapons, where budget pressures and other constraints are

leading to severe erosion of the talent pools on which much of the weapons program

has rested for many years. In' Recommendation 93-6, issued in December 1993, the

Board urged DOE to:

• develop a formal program to identify the skills and knowledge needed

to develop safe weapons dismantlement and modification procedures

for all remaining nuclear weapons, and to safely conduct nuclear

testing;

institute a practice whereby personnel losses from the complex are

reviewed to assess their impact on required safety-related capabilities;

• develop means to ensure continued access to necessary capabilities

through the use of personnel retention, new hires and consulting

arrangements, programs to document the knowledge of highly expert

personnel, and the development of detailed procedures to guide people

who will follow;

- 21 -
develop an integrated program to maintain nuclear weapons testing

expertise at the Nevada Test Site (NTS); and

• reevaluate the traditional reliance on administrative controls to ensure

nuclear explosive safety at NTS, given the ongoing loss of personnel.

A verbatim copy of Recommendation 93-6, as it appeared in the Federal Register, is

contained in Appendix 1 to this report. The Secretary of Energy accepted

Recommendation 93·6 on February 2, 1994.

The Board's concern for maintaining vital facilities and expertise to conduct

criticality experiments resulted in issuance of Recommendation 93-2 on March 23,

1993. A verbatim copy of Recommendation 93·2, as it appeared in the Federal

Register, is contained in Appendix 1 to this report.

4. Safety Aspects of Conduct of Operations

a. Engineering Safety Through Improved Conduct of Operations

"Conduct of Operations" entails the formal control of facility systems and the

performance of reviewed and approved procedures in a deliberate manner, using

proper communications. The basic requirements for proper Conduct of Operations

are set forth in DOE Order 5480.19, Conduct of Operations Requirements for DOE

Facilities, supplemented by other DOE Orders and guidance documents. The Board's

staff observed only limited progress toward implementation of these directives at

many facilities and has noted a general lack of understanding and commitment to the

concepts set forth in DOE Order 5480.19 by DOE's managers and contractors.

The Board has directed a significant portion of its resources to monitoring

conduct of operations at the Pantex Plant, because of the key role that site plays in

the disassembly of weapons and the accompanying risks to health and safety of the

public and workers. Late this past year, the Board sent a letter to the Assistant

Secretary for Defense Programs describing deficiencies observed in conduct of

operations at the Pantex Plant. The Board requested a formal report covering:

(1) an evaluation of conduct of operations at Pantex; (2) an evaluation of practices

at other sites to upgrade conduct of operations and their suitability for Pantex;

(3) availability of personnel with appropriate conduct of operations qualifications and

experience at contractor and DOE offices; and (4) an evaluation of the effectiveness

of actions by DOE to implement improved conduct of operations at Pantex. The

Board also requested a report of corrective actions resulting from these evaluations.

A satisfactory response from DOE has yet to be received.

- 22 .
b. Readiness of Facilities to Operate

One of the Board's earliest activities was to review preparations for the

planned resumption of plutonium processing at the Rocky Flats Plant.

Recommendation 90-4 urged DOE to conduct comprehensive Operational Readiness

Reviews (ORR), on a facility-by-facility basis, prior to resumption ofsuch operations.

Details of that Recommendation are found in the First Annual Report to Congress.

The Board closely followed the implementation of the Operational Readiness

Review process for the first facility to resume plutonium operations at the Rocky

Flats Plant, which was Building 559, an analytical laboratory. The Board determined

that DOE's review had been conducted prematurely. Because thi: Board realized

that DOE's first Operational Readiness Review at the Rocky Flats Plant would be

used as a model for future ORRs, the Board insisted that the ORR for Building 559

be performed in a manner that adhered closely to the DOE Implementation Plan for

Recommendation 90-4. Therefore, the Board issued Recommendation 91-4, calling

for DOE to complete the Operational Readiness Review for Building 559 only after

known safety deficiencies had been corrected or were appropriately near closure, and

only after the contractor had issued a Readiness to Proceed Memorandum requesting

approval for resumption of plutonium operations. The follow-on Operational

Readiness Review for Building 559 was completed in January 1992. As discussed in

the Board's Second Annual Report to Congress, the Board determined that DOE had

adequately implemented Recommendation 91-4, and a model for subsequent ORRs

had been developed. The mission ofthe Rocky Flats Plant was subsequently changed

from production to cleanup, and the Board determined that the actions taken by

DOE and the contractor to implement Recommendation 90-4 for the limited

plutonium processing operatigns proposed for Building 707 were adequate. See the

Board's Third Annual Report for a discussion of the 707 restart effort.

The lessons learned at the Rocky Flats Plant on ORRs, however, were not

initially implemented at other facilities in the complex. For example, in early 1992,

the Board and its staff conducted reviews of selected safety issues related to

plutonium-238 processing operations at the HB-Une at the Savannah River Site,

where there had been repeated safety-related shutdowns following resumption of

processing in July 1991. The Board determined that both the Operational Readiness

Review conducted for the HB·Line by the SRS contractor, and DOE's readiness

review, had been premature, limited in scope, and inadequate. As a result, the Board

issued Recommendations 92-1 and 92-3, recommending that the contractor and DOE

conduct adequate Operational Readiness Reviews prior to resumption of operations

at HB-Line, in accordance with previous Board Recommendations. The contractor

and DOE subsequently conducted adequate reviews.

- 23 -
DOE took an important step in defining requirements for Operational

Readiness Reviews (ORRs) applicable to all defense nuclear facilities in issuing

"Approval for Restart of Facilities Shutdown for Safety Reasons and for Startup of

Major New Facilities," Secretary of Energy Notice, SEN·16B-91. Following issuance

of these requirements, the Board and its staff monitored the preparations for and

conduct of additional Operational Readiness Reviews (ORRs) at several defense

nuclear facilities. In many instances, improvements were noted. However, it was

observed that several key aspects of the review process were not being consistently

implemented.

The Board concluded that DOE lacked effective standards for the conduct of

ORRs throughout the complex. DOE ditectives and guidance needed improvement,

particularly in specifying both the required features of a satisfactory ORR and the

occasions when an ORR should be performed. A,:cordingly, the Board issued

Recommendation 92-6 on August 26, 1992, urging DOE to develop effective

standards to govern the ORR process, including specific criteria for determining when

ORRs are required. DOE committed in its 92-6 Implementation Plan, dated January

1993, to develop a new Order providing requirements for the Operational Readiness

Review process and a supporting DOE Standard giving detailed guidance for

implementing the requirements. The Board conditioned acceptance of DOE's

Implementation Plan on receipt and approval of DOE's new Order, and standards

for conducting ORRs being developed under the Plan.

In September 1993, DOE completed the new DOE Order 5480.31, Startup and

Restart ofNuclear Facilities. The Board reviewed the Order, and determined that it

provides a clear and effective set of requirements to govern the ORR process. As

of December 1993, DOE was completing ,development of standards (DOE Stallllard,

Planning and Conduct of Operational Readiness Reviews (ORR), DOE-STD·3006-93,

November 1993) to provide additional guidance for implementing requirements of

DOE Order 5480.31.

In early 1993, the Board and its staff reviewed DOE's new Environmental

Restoration Management Contractor (ERMC) approach to operation of defense

nuclear waste storage, treatment, disposal and site decommissioning/restoration. At

the Fernald Environmental Management Project (FEMP), the ERMC contractor had

committed to conduct a readiness review required by DOE·Fernald (DOE-FN) prior

to start-up of the Uranyl Nitrate Hexahydrate (UNH) stabilization project. However,

a lack of technical vigilance on the part of DOE-FN allowed the ERMC contractor

to start operations without either conducting the required readiness review or

informing and obtaining approval to start the operation, from either the DOE-FN

manager or the DOE Headquarters project office. This disregard for the overall

readiness process was a key factor leading the Board to issue Recommendation 93-4.

- 24 -
A verbatim copy of Recommendation 93-4, as it appeared in the Federal Register, is

contained in Appendix 1 to this report.

In Recommendation 93-4, the Board called for DOE to "establish a clear

process with an appropriate set of requirements and clear definitions of the line of

authority for approval to start the UNH stabilization project. The set of

requirements should identify the type and scope of readiness reviews DOE will

require for the start of the UNH stabilization runs."

Recommendation 93-4 also addressed the broader need for closer

management and direction of ERMCs. That portion of the Recommendation

addressed the approach DOE needs to undertake to better control the diverse

activities of its contractors. These elements were triggered by the lack of sufficient

numbers of competent, trained headquarters and field personnel assigned by DOE

to technically manage ERMCs, as shown by safety problems encountered and not

properly resolved at the FEMP. The Board was also concerned that future ERMC

contracts might be signed before DOE develops internal capabilities to carry out the

necessary technical management and oversight responsibilities. In light of the

apparent lack of such planning by DOE, Recommendation 93·4 urged DOE to

develop and implement a technical management plan for Fernald, and for all future

ERMC contracts, and to delineate the features of an acceptable technical

management plan. It further asked that DOE consider the inclusion of a technical

management plan in other DOE contracts as those contracts come up for amendment

or renegotiation. On August 6, 1993, DOE accepted the Board's recommendation

and, in its Implementation Plan, committed to meet Recommendation 93-4 fully.

In January 1993, staff members of the Board reviewed the DOE "Operational

Readiness Evaluation" (ORE) at the Pantex Plant for the Preparation for Disposal

(PFD) of retired W-79 warheads in Building 12-84. The ORE Team would not

recommend commencement of W·79 PFD operations because of deficiencies in a

number of areas, including safety analysis and associated safety limits for Building 12-

84. The Board agreed with the ORE team's conclusion, and also noted deficiencies

in the conduct of the ORE itself, including failure to evaluate the technical and

managerial qualifications of personnel in the DOE field organization and the

inadequate assessment of the status of compliance with Orders. These observations

were forwarded to DOE for consideration in a letter from the Board to the Acting

Secretary of Energy dated January 21, 1993.

In March 1993, staff members reviewed the application of the ORR process

to the Reclamation Relocation Project in Building 9204·E at the Oak Ridge Y·12

Plant. This review led the Board to conclude that many of the features of an ORR

set forth in Recommendation 92-6 had not been covered by the contractor's ORR.

Therefore, the Board, by letter dated April 21, 1993, requested DOE to provide an

- 25 -
evaluation of the processes used in the ORR at Y-12 as contrasted against the

Recommendation 92-6 Implementation Plan, and to provide any planned corrective

actions. DOE and the contractor subsequently committed to upgrading the ORR

process at Y-12 and to conduct future ORRs in a manner consistent with Board

Recommendation 92-6 and with the Order being developed by DOE.

In 1993, the process of establishing readiness to operate at the Savannah River

Site was examined for: (1) a "special unload" in the tritium facility; (2) the initial

startup of the Replacement Tritium Facility (RTF); (3) "cold chemical runs" at the

Defense Waste Processing Facility (DWPF); and (4) preparations to restart the

F-CanyonIFB-Line. In general, the Board found deficiencies in the implementation

of the readiness review process similar to those noted at other sites, a lack of rigor

or suitable independence, and the use of ORR-type reviews as adjuncts to

preparation by management for restart of the facility. As a result, the Board

provided written comments to DOE on the readiness reviews for the special unload,

RTF, and DWPF. DOE acknowledged the deficiencies and expanded portions ofthe

reviews or performed them anew.

The Board and its staff conducted several assessments of the readiness to

increase the fabrication rate of "'PuO, pellets in the TA-55 Plutonium Facility at the

Los Alamos National Laboratory (LANL). The Board communicated the results of

those assessments to the Assistant Secretary for Defense Programs in a letter dated

June 21, 1993. A large number of the pellets are needed to support the manufacture

of Radioisotope Thermoelectric Generators for NASA's Cassini Project. These

reviews led the Board to conclude that deficiencies in maintenance of containment

by the gloveboxes, and in procedures for the maintenance, were not being adequately

addressed. These deficiencies allowed degradation of glovebox integrity to occur,

resulting in repeated cases of contamination of personnel in TA-55 during early 1993.

In addition to these deficiencies, the Board's staff noted the limited scope of the

readiness reviews for this project and inadequacies in the hazards analysis. In

September 1993, the Board noted these issues, and, by letter to the Assistant

Secretary for Defense Programs dated September 10, 1993, requested that DOE

consider an enlarged review of the readiness of TA-55 to proceed with production

for the Cassini Project. Also, the Board noted that only six Orders of a possible fiftyone safety Orders were assessed in preparation for Cassini production. During

preparation of another plutonium facility for operations to support the Cassini Project

(the HB-Line at the Savannah River Site), a more complete set of DOE Orders was

assessed for compliance. Consequently, the Board, in a letter to the Secretary of

Energy dated December 29, 1993, requested a report within 30 days from DOE

discussing DOE's evaluation of Order compliance at LANL and the rationale for

having assessed compliance with only six safety-related Orders. The same letter also

asked DOE to evaluate whether an Unreviewed Safety Question existed at TA-55

- 26 -
concerning its emergency power generator. At the close of 1993, these issues had nOl

been resolved.

The Board has noted the development of a manual at the Savannah River Site

for the use by line management in assessing facilities. This manual, titled Operational

Readiness Functional Area Requirements, WSRC-SCD-4, is a compendium of

requirements associated with DOE's Orders and industry practices. Use of this

manual should permit a thorough, structured self-assessment by line management

prior to the arrival of an independent ORR team to verify readiness to operate a

facility safely.

Nuclear testing at the Nevada Test Site is currently subject to a moratorium.

However, the President has publicly stated that testing may be required in the future,

and therefore DOE has been directed to take steps necessary to prepare for

resumption of testing, pending a decision on the matter. In Recommendation 93-6,

the Board urged that DOE develop and institute a program for maintaining expertise

in operations key to the safety of nuclear testing at NTS. The Board considers that

an overall review of the integrated test activities at NTS would be required to confirm

readiness for safe testing, should a decision be made to conduct another nuclear test.

DOE has indicated that in the next few years there will be numerous startups

and restarts of defense nuclear facilities. Examples include:

• At the Pantex Plant, DOE is expanding the interim storage of pits in

Zone 4, and a DOE ORR is scheduled for early 1994. DOE is also

preparing new weapon assembly/disassembly bays in Building 12-104A

and a new SP.ecial Nuclear Material Component Staging facility in

Building 12-116.

At the Savannah River Site, F-CanyonlFB-Line restart of separations

operations is currently planned for early 1994. Thereafter, ORRs are

being planned for the Defense Waste Processing Facility and the InTank Precipitation processes for processing high level radioactive

wastes.

At the Rocky Flats Plant, DOE has not authorized resumption of

limited operations in Building 707 to stabilize plutonium-bearing

residues pending completion of an Environmental Assessment. The

ORR for Building 707 was completed in November 1992. DOE has

informed the Board that it will assess the readiness of Building 707 to

safely resume operations in accordance with the requirements of DOE

Order 5480.31. Additionally, within the next two years, DOE intends

- 27 -
to conduct solution stabilization processing in Building 771 using a new

stabilization process, necessitating an ORR prior to startup.

• At the Hanford Site, readiness reviews are planned for the K-East

Basin fuel re-encapsulation efforts.

• The Hydrogen Fluoride process for converting uranium oxide to

uranium metal is scheduled to be restarted at the Oak Ridge Y-12

Plant. Subsequently, the restart of material processing in 0-Wing in

Building 9212 is planned.

• The startup of the Device Assembly Facility is planned for late 1994 at

the Nevada Test Site.

At the Idaho National Engineering Laboratory, readiness reviews are

planned for the restart of the de-nitrator at CPP-601 in early 1994.

• DOE is considering restarting the Omega West Reactor at the Los

Alamos National Laboratory.

Modifications to the Pulse Reactor Facility and Annular Core Research

Reactor at the Sandia National Laboratories are in progress. A new

facility, the Radioactive and Milled Waste Management Facility, is

being readied for operation in 1995.

The Board will closely monitor the readiness reviews to ensure that they will

be conducted by DOE in conformance with the requirements contained in newly

issued DOE Order 5480.31, Startup and Restart of Nuclear Facilities, and the tenets

of Recommendation 92-6.

5. Safety Aspects of the Assembly, Disassembly, and Testing of Nuclear

Weapons

During 1992, after Congress extended the Board's jurisdiction to include

facilities involved in the assembly, disassembly, and testing of nuclear weapons, the

Board and staff visited all of the nuclear weapons sites to become familiar with

operations and conducted a public meeting on August 20, 1992, in Amarillo, Texas,

related to the assembly and disassembly of nuclear weapons at the Pantex Plant.

Deficiencies identified during these visits were brought to the attention of DOE

establishing a basis for further detailed assessments. Those actions are detailed in

the Board's Third Annual Report to Congress.

- 28·
In 1993, the Board's second full year of cognizance over these facilities, the

scope of the technical reviews was expanded. Public hearings were held in Oak

Ridge, Tennessee, to discuss safety matters related to the Y-12 Plant, and in Los

AJamos, New Mexico, to address safety issues associated with the Los AJamos

National Laboratory. Technical reviews identified a need for improvement in

numerous safety-related areas, both facility-specific and complex-wide. The most

notable reviews were in the areas of utilization of standards, safety assessments,

operational readiness reviews, material disposition, and training and qualification of

personnel.

As a result of its reviews of issues at weapons assembly,. disassembly, and

testing sites, the Board developed and issued three Recommendations during 1993.

Recommendation 93-1 specifically addressed the use of DOE Orders and standards

at facilities that are involved in the assembly, disassembly, and testing of nuclear

weapons. The provisions of that Recommendation were presented in detail

previously. Recommendation 93-6 urged DOE to ensure that access to essential

safety-related nuclear weapons expertise was retained within the defense nuclear

facilities complex.

The Board's concern for maintaining vital facilities and expertise to conduct

criticality experiments resulted in issuance of Recommendation 93-2 on March 23,

1993. This recommendation asked DOE to take actions to retain facilities and

technical capability to perform critical experiments. The ability to perform critical

experiments can be an important part of ensuring the safety of activities in support

of disassembly of nuclear weapons and site decommissioning and remediation.

Recommendation 93-2 was accepted by the Secretary on May 12, 1993; DOE's

Implementation Plan was submitted on August 10, 1993, and approved by the Board.

The Board and its staff will monitor DOE's use of critical experiment capability to

ensure the safety of weapons-related activities.

In addition to the Recommendations issued in 1993, a number of previously

issued Recommendations formed part of the bases for Board reviews at the nuclear

weapons facilities in 1993. Foremost among these were 90-2 (Standards), 91-6

(Radiological Protection), 92-6 (Operational Readiness Reviews), and 92-7 (Training

and Qualification).

As stated earlier, one important focus of the Board during the past year has

been the status of Order compliance and utilization of standards. Information on

deficiencies observed in the programs at Y-12, NTS, Pantex, and the AJbuquerque

Operations Office was communicated to DOE. Discussions between the Board's staff

and DOE's staff resulted in an agreement to upgrade the quality of Order compliance

programs at all nuclear weapons facilities.

- 29 -
Recommendation 91-6 and DOE's Radiological Control Manual were used as

the bases for assessments of radiological protection at the Pantex Plant, Los Alamos

National Laboratory, and the Y-12 Plant. These reviews identified deficiencies of

certain dosimetry systems at Pantex and in the contamination control practices at the

Y-12 Plant. DOE developed corrective action plans to address these deficiencies, and

the Board's staff is closely monitoring their implementation.

The Board's staff reviewed DOE's preparations to operate facilities at the

Pantex Plant, the Los Alamos National Laboratory, the Mound Laboratory, and the

Y-12 Plant. As a result, a number of deficiencies were identified and communicated

to DOE. The operational readiness review process at all DOE facilities is presently

being upgraded to meet the requirements of newly issued DOE Order.5480.31,

Startup and Restart of Nuclear Facilities. This Order, with an associated new DOE

standard, was developed as one of the corrective actions under DOE's

implementation plan for Board Recommendation 92-6. The Board's staff is closely

reviewing all planned and on-going readiness reviews to ensure that the requirements

of DOE Order 5480.31 are properly applied.

Recommendation 92-7, along with DOE Order 5480.20, Selection, Training and

Qualification of Personnel at DOE Nuclear Facilities, formed the basis for reviews of

the training and qualification programs at nuclear weapons facilities. Detailed

reviews at the Pantex Plant resulted in two Board letters. The first was to the

Secretary of Energy on April 13, 1993, and the second to the Deputy Assistant

Secretary for Defense Programs dated on July 6, 1993, which required DOE to report

on its efforts to upgrade training and qualification of both contractor and DOE

personnel at the Pantex Plant.

The Nuclear Explosives Safety Study (NESS) process, outlined in DOE Order

5610.11, is the primary method by which DOE evaluates the safety of various

operations involving nuclear explosives. A six-month review ofthis process conducted

by the Board's staff, including attendance at a majority of the NESS's performed

during 1993 at NTS and Pantex, led to the Board's establishment of a reporting

requirement addressing the following observations communicated to the Secretary of

Energy in a Board letter dated December 8, 1993:

The process depends extensively on the knowledge of the individuals

presently involved. This dependence has led to a somewhat informal

approach to evaluating nuclear explosive safety, characterized by

frequently inadequate technical documentation and late receipt by

NESS members of important technical input documents.

. 30 -
Formal guidance to ensure that the NESS process will properly analyze

and document all risks, including both detonation and plutonium

dispersal, is lacking.

• The current approach to, and schedule for, risk assessments in support

of the NESS process is questionable; and DOE's plan to integrate risk

assessment insights into the NESS process is not clear.

• There are few specific documented requirements on the qualifications

necessary for various participants in the NESS process. Although a

majority of the present participants are very experienced, without a

systematic and comprehensive program for the selection, training and

qualification of personnel, it is unclear whether the next generation will

be adequate.

During early reviews of weapons dismantlement operations, the Board's staff

noted that procedural compliance practices were inadequate in some respects. This

issue was brought to the attention of the Secretary of Energy in a Board letter, dated

June 8, 1993. In addition, it was noted that changes to the procedures had been

made without proper involvement of the cognizant weapons design laboratory.

The Board discussed these concerns with senior representatives of DOE. As

a result of the discussions, DOE determined that a disciplined review of

dismantlement procedures and practices was required. The Department decided to

expand the "qualification evaluation" procedure already delineated in existing DOE

directives to cover the dismantlement process. The resulting Qualification Evaluation

for Dismantlement (QED). process has ensured that a detailed review of a

dismantlement program is performed prior to its initiation. The QED process

assesses the adequacy and correctness of disassembly procedures, and verifies that

all safety considerations have been ascertained for potential impact on disassembly

operations. The QED process, as a minimum, reviews the following functional areas:

(1) nuclear and high explosives safety; (2) industrial safety and hygiene;

(3) environmental protection; (4) process and disassembly engineering; (5) quality

assurance; (6) radiological protection and health physics; and (7) formality of

operations. Immediately following establishment of the new QED process, QED's

were performed for the four major programs for weapons dismantlement ongoing at

the Pantex Plant at the time the Board's concerns were identified.

. 31 .
6. Safely Managing Special Nuclear Material, Waste, and Residues

a. Accelerated Waste Characterization

The Board believes that accelerating the pace of the program for

characterizing the contents of Hanford's high level nuclear waste tanks is important

to nuclear safety. This view is shared by other experts, including a "Red Team"

appointed by DOE, which reviewed the waste characterization program for the

Hanford Tank Farm (DOE-EM, July 1992, Independent Technical Review of

Hanford Tank Farm Operations). Characterization is essential for ensuring safety in

the near-term during custodial management and remedial activities, and also in the

long-term for advancing the development of permanent solutions to the high level

waste problems at Hanford.

The wastes in the Hanford tanks differ markedly from tank to tank. Without

timely characterization ofthe wastes, the nature of the risks associated with the tanks

cannot be fully assessed and, where necessary, mitigated. Further, until the

characteristics of the wastes are known, final methods for monitoring, retrieval,

transport, and treatment of wastes now in tanks cannot be realistically planned.

Therefore, the Board issued Recommenclation 93-5 on July 19, 1993, which

strongly criticized the overall direction and timeliness of the program to characterize

tank wastes at Hanford and called for a comprehensive reexamination and

restructuring of the program to accelerate characterization, strengthen technical

management, and expedite chemical and physical analyses. The Recommendation

called for completion ofsafety-related sampling and analysis of watchlist tanks within

two years, and of the remainder of the tanks by a year later. A verbatim copy of

Recommendation 93-5, as it appeared in the Federal Register, is contained in

Appendix 1 to this report. The Recommendation also called for the waste

characterization program to be integrated into the systems engineering for the Tank

Waste Remediation System (TWRS) being implemented under Board

Recommendation 92-4. The Implementation Plan for Recommendation 93-5 was

submitted to the Board on January 21, 1994.

b. Spent Fuel Storage Basins

During 1993, the Board and its staff conducted two major reviews of fuel

basins at various DOE sites. One of these reviews focused on safety at the spent fuel

basins at the Hanford Site, the Savannah River Site, and the Idaho National

Engineering Laboratory. The other reviewed structural integrity and seismic

capabilities of selected basins. These review efforts will continue in 1994.

- 32 .
Also during 1993, the Board highlighted to DOE the weaknesses in actions by

DOE to develop a systems engineering plan to address the spent fuel problems, and

noted that actions at INEL to address problems with severely corroding fuel elements

were neither timely nor in accordance with proper procedures. DOE responded by

preparing a systems engineering plan for the spent fuel program and taking corrective

actions at INEL Because of the number and severity of these vulnerabilities in spent

fuel storage, the Board views the matter as having high priority, and will continue to

evaluate DOE's spent fuel management plans.

c. Radioactive Residues of Weapons Production

Several DOE sites have significant quantities of plutonium stored in the form

of scrap, unfinished weapon components, and intermediate materials such as

solutions, unpurified oxides, and other compounds. When weapons production was

under way, these materials were rapidly recycled through the production facilities.

Because production of weapons has ceased, however, the materials are simply being

stored at most sites.

The Board is concerned with the stability of some of these stored materials,

because many forms of plutonium are chemically unstable, some even pyrophoric.

If the materials are poorly packaged or stored in inappropriate environments, there

is a possibility of fire or explosion. Large quantities of plutonium are stored in lessthan-optimum forms, and many sites have lost, or are susceptible to losing, the

operational capability to stabilize plutonium materials. Even repackaging unstable

plutonium compounds is becoming difficult to accomplish at some sites. Many of

these materials, particularly those with high plutonium content, were never intended

to be stored for extended periods. The most serious problems arise from the

possibility of generation of hydrogen, spontaneous fires, and leakage from the storage

containers.

Large amounts of production by-products containing recoverable quantities of

plutonium have been stored at the Rocky Flats Plant for many years, awaiting

processing. The Hanford Site, the Savannah River Site, and the Los Alamos National

Laboratory also have significant quantities of plutonium in forms that are unstable

or could become so. However, the plutonium storage situation at these three other

sites is not as problematic as at the Rocky Flats Plant, partly because those sites have

maintained more extensive operational capabilities in plutonium handling and

processing.

DOE does not currently have adequate standards for long-term storage of

plutonium in forms other than encapsulated weapon components. A draft standard

covering fairly long-term storage of plutonium metal and oxide is currently being

- 33 -
developed by DOE and it may address part of the need. The Board will continue to

follow this matter closely.

7. Decontamination, Decommissioning, and Restoration of DOE Sites

A recent GAO report, "Cleaning Up Inactive Facilities Will Be Difficult,"

states that DOE expects that over 7,000 facilities will be slated for decommissioning

and decontamination (D&D) during the next 30 years. No major progress has been

made by DOE in final D&D of its current facilities under the Office of

Environmental Restoration and Waste Management. Because of the large volume

of work, the broad range of hazards involved, and the large expense anticipated,

D&D projects must be prioritized. DOE has yet to make significant progress in this

prioritization effort.

The Board concluded that no driving force exists within DOE to actually

perform D&D other than attempting to maintain old facilities in a surveillance and

maintenance mode. Walkdowns of facilities at Hanford, Mound, and Savannah River

Site indicate that, in general, facilities are deteriorating rapidly and could present

significant hazards to future D&D workers, although the Board has not found that

D&D issues pose any imminent danger to the general public. DOE has made little

headway in the preparation of standards for D&D for specific types of facilities, such

as reactors, reprocessing facilities and separations plants.

m. FORMAL SAFETY AND HEALrn INVESI1GATIONS

In late 1992 and early 1993, the Board combined its investigative, deliberative,

and compliance actions to close issues raised through the Board-directed investigation

of the HB-Line at the Savannah River Site. During that period, a significant

percentage of the resources of the Board's entire legal and technical staff were

utilized to follow the ORR process and to assess closure of safety issues that the

Board and the ORR process had identified. An open meeting, briefing, and hearing

held in mid-December, 1992, in Aiken, South Carolina, covering the contractor's and

the Department of Energy's ORRs, were followed by closed meetings conducted by

the Board on December 17, 1992, and January 5, 1993, to consider safety issues

related to the HB-Line. The Board subsequently obtained a commitment from DOE

to complete assessments of compliance with Orders at the HB-Line. Reporting

requirements were imposed on DOE with status reports being filed in March and

June of 1993. The Board's legal and technical staff continued to follow the progress

on such assessments at the HB·Line, including on-site reviews of the status of Order

compliance in December of 1993. By the close of 1993, the assessment of

compliance with Orders had not been completed by DOE.

- 34 -
During 1993, legal and technical teams conducted investigations of health and

safety issues at several defense nuclear facilities pursuant to 42 U.S.c. §2286b(b).

Investigations were conducted at the Oak Ridge National Laboratories, the Hanford

Site, the Savannah River Site, and the Los Alamos National Laboratory. One

investigation resulted in a referral to the Depanment of Energy's Inspector General.

Also, the Board directed the General Counsel to investigate DOE's monitoring of

radiological exposure of DOE employees, the Board's staff, and the general public

throughout the complex.

IV. CLOSED BOARD RECOMMENDATIONS

During the first fdur years of the Board's operation, DOE completed

implementation of, or otherwise closed, ten sets of Recommendations issued by the

Board. The following list includes those Recommendations which the Board has

determined are closed. The list also indicates the portions of previous annual reports

to Congress which discuss activities related to those Recommendations; if the

Recommendation was closed by action other than full implementation, that

information is given parenthetically.

Rec. No.

90-1

90-3

91-1

91-2

Operator Training at Savannah

River Facilities Prior to

Restan of K, L, and P Reactors

Safety at Single-Shell Hanford

Waste Tanks (superseded by

90-7)

Strengthening the Nuclear

Safety Standards Program for

DOE's Defense Nuclear

Facilities

Closure of Safety Issues Prior

to Restart of K·Reactor at the

Savannah River Site

- 35 -

Annual Repon to Congress

First Annual Repon, February

1991, pp. 3·4; Second Annual

Repon, February 1992, p. 16; Third

Annual Report, April 1993, p. 13

First Annual Repqrt, February

1991, pp. 5-6, Second Annual

Repon, February 1992, pp. 18-19;

Third Annual Repon, April 1991,

pp. 14-15

Second Annual Report, February

1992, pp. 2-4; Third Annual

Repon, April 1993, p. 10

Second Annual Report, February

1992, pp. 4-5; Third Annual

Report, April 1993, pp. 10-11
91-3

91-4

91-5

92-1 &

92-3

92-7

DOE's Comprehensive Readiness Review Prior to Initiation

of the Test Phase at the Waste

Isolation Pilot Plant (WIPP)

DOE's Operational Readiness

Review Prior to Resumption of

Plutonium Operations in

Building 707 at the Rocky

Flats Plant

Power Limits for K-Reactot

Operations at the Savannah

River Site

Operational Readiness of the

HB·Line at the Savannah River

Site

Training and Qualification

(consolidated with 93·3

for implementation)

Second Annual Report, February

1992, pp. 5-6; Third Annual

Report, April 1993, p. 11

Second Annual Report, February

1992, pp. 6-10; Third Annual

Report, April 1993, pp. 11-12

Second Annual Report, February

1992, pp. 10-11; Third Annual

Report, April 1993, p. 12

Third Annual Report, April 1993,

pp. 2-4

Third Annual Report, April 1993,

pp.8-9

V. INTERNALBOARDMANAGEMENTINITIATIVES, LITIGATION,AND

PUBUC HEARINGS

A PERSONNELRECRUITMENT.INCLUDING 1HEINTERN PROGRAM

The identification and hiring of professional personnel with outstanding

qualifications are critical to the successful accomplishment of the Board's mission.

As of December 31, 1993, the Board had hired 94 full-time employees

including a full-time Site Representative at the Department of Energy's Pantex

facility, Amarillo, Texas. During 1993, the Board reviewed 1,563 applications for

employment and conducted 38 sets of interviews. This activity is necessary to recruit

highly-qualified employees with exceptional scientific, engineering, or legal

backgrounds who can effectively carry out the specialized work required.

With the excepted appointment authority granted by Congress, the Board has

been able to achieve progress in hiring high-quality engineering and scientific

personnel to address the health and safety questions associated with the design,

construction, operation, and decommissioning of DOE's defense nuclear facilities.

This excepted appointment authority has enabled the Board to significantly

- 36 -
strengthen its ability to compete with other excepted Federal agencies and the private

sector for the talent to properly perform its mission.

The Board has been able to hire outstanding technical talent with extensive

backgrounds in nuclear, mechanical, electrical, chemical, structural, and metallurgical

engineering and physics, using a nationwide recruiting campaign. As an indication

of the Board's technical talent, 22 percent of the staff hold degrees at the Ph.D. level

and 70 percent have degrees at the Masters level. In addition, almost all technical

staff members, except Interns, possess practical nuclear experience gained from duty

in the U.S. Navy's nuclear reactor program or the civilian reactor industry. Four

other senior members of the Board's staff have law degrees (JD), as well as degrees

in a technical specialty. Both the Board and staff include persons experienced in

environmental impact assessments and regulatory processes. In 1993, the Board

successfully recruited personnel with extensive weapons experience. A number of

staff members completed special courses in weapons design and construction. This

expertise was supplemented by outside experts with extensive experience with

plutonium processing and weapons assembly and disassembly. The Board plans to

continue its aggressive program to attract and hire additional technical staff with

backgrounds commensurate with the Board's public health and safety responsibilities.

In September 1991, the Board initiated a Technical Intern Program designed

to aid in the recruitment and development of the nation's top engineering graduates.

The Board has conducted extensive recruitment and interview programs each year

since then to locate interns with superior academic accomplishments in an

engineering discipline and other attributes that indicate the potential for effective

performance. There are currently nine interns in various phases of the program: one

intern in a first-year assignm~nt at Board Headquarters; seven interns in the secondyear, graduate-education phase at Cornell, the University of California·Berkeley,

Purdue, and the University of Illinois; and one intern completing a third-year

assignment at a nuclear power plant. The recruitment and selection methods used

have proven very effective based on the outstanding academic and on-the-job

performance of interns. Board staffing projections include the recruitment of three

technical interns in 1994.

B. PUBLIC HEARINGS, PUBLIC COMMENT, AND INTERACTION wrrn

BOARD

During 1993, Board Members traveled to defense nuclear sites on 21

occasions, where they met with contractors, DOE representatives, members of the

public, labor unions, and public interest groups. The Board conducted seven public

meetings, hearings, and briefings at various sites throughout the country. The Board

made extensive efforts to include and inform the public of Board activities in 1993,

as follows: .

- 37 -
Individual Written Notices of Public

Meetings, Hearings,and Briefings

Individual Written Notices of Board

Recommendations to the Secretary of Energy

Responses to Inquiries from the Public

and News Media

C. UTIGATION

1,476

1,179

293

1993 brought the successful resolution of the Sunshine Act litigation initiated

by the Natural Resources Defense Council (NRDC) and Energy Research

Foundation (ERF) in 1992. In that litigation the NRDC/ERF challenged the Board's

interpretation of its enabling legislation providing for public availability of Board

recommendations "after receipt by the Secretary of Energy" or the President in

appropriate cases. 42 U.S.c. section 2286d(a); g(3). At the request of the Chairman,

the Attorney General reappointed the Board's General Counsel and his Deputy as

Special Attorneys to the United States Attorney General, which allowed

independence in handling the continuing litigation.

On July 24, 1992, the D.c. Circuit Court of Appeals decided that the Defense

Nuclear Facilities Safety Board's enabling statute required closed Board meetings on

recommendations for the President or the Secretary of Energy regarding health and

safety issues at DOE's defense nuclear facilities. NRDC/ERF v. Defense Nuclear

Facilities Safety Board, 969 F.2d 1248 (D.C. Cir., July 24, 1992). The court concluded

that, under the plain meaning of the .Board's enabling statute, which contained

specific public access provisions, the Board's discussions on recommendations could

be held in closed meetings consistent with the Government in the Sunshine Act,

5 U.S.C. §552b (1988).

Petitioners chose to petition the Court of Appeals for rehearing, with a

suggestion that the rehearing be conducted en banco That petition for rehearing was

denied on October 9, 1992. NRDC/ERF v. Defense Nuclear Facilities Safety Board,

No. 91-1199 (D.C. CiT., October 9,1992). In accord with the Board's bill of costs, the

Court of Appeals awarded costs to the U.S. Government against the Petitioners,

Natural Resource Defense Council and Energy Research Foundation. Those costs

were paid in 1993.

The Petitioners then petitioned the Supreme Court for a writ of cerriorari

seeking to overturn the D.C. Circuit Court of Appeals' decision. The Board's Office

of General Counsel prepared draft opposing briefs and worked closely with the

Solicitor General's Office, which filed the final Brief For the Respondent In

- 38 -
Opposition. On May 17, 1993, the Supreme Court issued its Order denying the

petition for the writ of certiorari to the Court of Appeals for the D.C. Circuit, thus

successfully concluding the litigation, by allowing the Board's position to stand.

D. OFFICIAL SITE VISITS BY BOARD MEMBERS AND BY STAFF

From the establishment of the Board in October, 1989, through December 31,

1993, Board Members, its staff, and its contractor experts had collectively made 473

site visits to DOE's defense nuclear facilities. In 1993 alone, 173 site visits were

made to DOE's defense nuclear facilities by Board Members, its staff, or its

contractor experts. These visits focused primarily on selected facilities that both the

Board and DOE consider to be most pressing in light of DOE's mission, primarily the

Savannah River Site, the Pantex Plant, the Hanford Site, the Rocky Flats Plant, the

Idaho National Engineering Laboratory, the Oak Ridge Y-12 Complex, the Los

Alamos National Laboratory, and the Nevada Test Site.

The Board reviewed firsthand the health and safety issues at each of these

sites. In 1993, the Board Members made 21 site visits to DOE's defense nuclear

facilities conducting these reviews. During these visits, the Board gathered the bases

for its recommendations to the Secretary of Energy and monitored the

implementation of recommendations that have already been made.

VI. PLANNED FOCUS OF BOARD ACTIVITIFS IN 1994

Changes in the nuclear defense complex have had, and will continue to have,

a significant impact on the Board's oversight mission. Although production was still

the primary mission of the I'lUclear weapons complex at the time the Board was

established, Congress gave the Board a broad statutory mandate to oversee DOE's

defense nuclear activities. In late 1991, Congress expanded the Board's purview to

encompass the assembly, disassembly, and testing of nuclear weapons. The Board's

oversight activities have been influenced by several major changes in the complex,

including: (1) the interruption of materials production throughout the complex in

1989, due in large part to safety concerns; (2) DOE's subsequent attempts to resume

limited nuclear operations at some of these sites; (3) abandonment of restart

activities at many facilities, due primarily to arms control agreements reached in the

early 1990's; and (4) the determination that many of these facilities are surplus to

DOE's future mission.

It is tempting to conclude that the reduction of weapons production activities

at DOE facilities means that safety oversight can also be reduced. The reality is that,

to the contrary, there is a need to increase that scrutiny. Simply put, the process of

"shutting down" many defense nuclear facilities compounds existing hazards ofstoring

and handling nuclear materials with new hazards of cleaning up the facilities. If
safety systems are not properly maintained, and other precautions taken, these

facilities can pose an increasing risk to health and safety. The Board is statutorily

required to oversee DOE's efforts to ensure adequate protection of public health and

safety during the entire life-cycle of DOE facilities under the Board's jurisdiction,

including the decontamination and decommissioning of these facilities.

Many of the issues arising from these changes in the defense complex involve

operations and processes that are new to the nuclear weapons industry; others are

more long-standing. All of them have broad, as well as specific, health and safety

implications that linger throughout the complex. Among the long-standing matters

is the relatively poor record of DOE in its self-regulating efforts, DOE and its

contractors have not fully embraced the necessity for conducting nuclear operations

in accordance with safety standards, Orders, and other requirements designed to

protect public health and safety. Despite four years of persistent effort by the Board

and its staff, DOE and its contractors have not even identified all of the Orders and

other requirements applicable at many defense nuclear facilities, let alone enforced

compliance. In similar vein, DOE and contractor personnel are often inadequately

qualified or trained for the technical challenges they face. DOE and its major

contractorsface increasingly severe problems in recruiting and retaining well-qualified

personnel. This in turn has an impact on the Board's mission, since the Board and

its staff must provide technical advice and oversight in instances where DOE line and

oversight organizations should have anticipated and corrected problems without

Board intervention.

This environment -- long-standing problems overlain with new activities --

presents potential public health and safety concerns different from those previously

encountered in the operation of the complex. For example, aged and degraded

equipment can pose significant safety concerns at facilities slated to remain

operational or required to be operated for clean-up. Corrosion ofspent nuclear fuel

stored in basins that were not designed for long-term use is becoming a major issue.

Chemical and radioactive wastes continue to accumulate. These wastes and the

untreated radioactive residues from production processes may become more

hazardous through time. Thus, an increasing number of potential problems are

surfacing, some of which may be greater in severity than those encountered in five

decades of production operations.

To successfully operate in this new environment, DOE must adopt a systems

approach. Systems engineering includes the intellectual control and integration of all

disciplines throughout the system life cycle in a manner so as to ensure that all user

requirements are satisfied. Incorporating the principles of systems engineering can

help assure that all factors involving worker and public health and safety, as well as

environmental concerns, are integrated into the program. The Board's staff will

expand efforts to evaluate DOE progress in implementing the systems approach.

- 40 -
Protecting the health and safety ofthe public, and especially of on-site workers

because of their proximity to the hazards involved, becomes more challenging as

additional defense nuclear facilities make the transition from production, at the same

time that other facilities remain in operation or are restarted. This challenge is

illustrated by the breadth of subjects requiring Board scrutiny during 1993. The

number and severity of activities required in protecting public and worker health and

safety could easily grow as defense nuclear facilities cease production operations and

enter the transition, decommissioning and decontamination, and remediation

processes. The significant issues in this area include:

•

•

•

•

•

the necessity of! operating obsolete or shut-down processing facilities for

short periods to, remove in-process radioactive or hazardous materials;

surmounting technical problems associated with existing high-level

radioactive waste storage tanks;

design and construction of new facilities for interim and long-term

storage of wastes;

,

elimination of corroding spent fuel, even though facilities normally used

to process the fuel are shut down; and

the need for safe decommissioning and decontamination of a number of

major nuclear facilities.

In the weapons-related areas, the technical challenges facing DOE and the

Board will change as DOE's plans for the complex change. Major weapons-related

issues requiring continuing attention include:

• the need to safely disassemble 20,000 or more nuclear weapons;

• the requirement to design and construct nuclear weapons storage

facilities to accommodate both safety concerns and possible independent

international verification, as well as to provide substantially increased

capacity for the safe storage of weapons-grade plutonium, enriched

uranium, and other nuclear materials removed from weapons; and

• the necessity for DOE's reconfiguration of the weapons complex to be

planned and conducted in accordance with health and safety principles.

One of the biggest technical challenges and uncertainties results from the

physical condition of facilities in the nuclear weapons complex. As facilities age and

less attention is paid to their maintenance and upkeep, their condition will degrade.

- 41 -
As key operating personnel depart, knowledge of facility and weapons designs and

contents will erode, and safety will be reduced. The potential for detonation, fires,

and corrosion hazards increases as chemical compounds become more unstable.

Existing radiological hazards may become worse as certain radionuclides (e.g.,

americium) "grow" into nuclear materials due to radioactive decay, and as unknown

or uncharacterized radioactive contamination is discovered in the decontamination

process. During dismantling of facilities, workers are likely to come in contact, often

unexpectedly, with radioactive and chemical hazards that have been inaccessible for

many years. Contaminants may be driven into the environment by the dismantling

process or by exposure to the weather. Shutting down a defense nuclear facility can

actually increase the risk of dispersal Qf radioactivity through material degradation,

action of natural phenomena, fires, or\inadvertent nuclear criticalities.

A recent General Accounting Office report confirms that many of these

technical challenges exist and will persist. The report, dated June 25, 1993, states

that, "Inadequate maintenance and DOE's past emphasis on production over

environmental cleanup are presenting several problems for DOE's inactive facilities

program. ... [S)ome of DOE's aging facilities have been abandoned with hazardous

materials still in them, have not been characterized, or have been only partially

decontaminated..." The report states futther, "Many of the Department's inactive

facilities are in poor physical condition and present serious risks to individuals who

work in and around them," and notes, "...[DOE) agree[s) that the report accurately

portrays the poor condition of many of the Department's currently inactive facilities

[and) the potential risks that these facilities present for workers' health and safety..."

The report concludes that, "...inactive facilities can present real dangers to workers

in and around them and ... the way [DOE) closes and maintains inactive facilities will

influence the ... dangers of cleaning them up."

I

The political, economic, and social environment facing DOE is no longer

stable or predictable. In some aspects, they are unknown. Each of the technical

challenges is also marked by uncertainty. By their very nature, decontamination,

decommissioning and clean-up operations are rarely as routine or predictable as

production operations. These missions will require longer-range planning and

budgetary commitments than DOE has historically undertaken. Indeed, the issues

reflect national policy decisions that have yet to be made.

A COMPLEX-WIDE SAFETY ISSUES REQUIRING PRIORITY

ATfENTION IN 1994

Within the broad context depicted above, the Board plans to place high

priority focus in 1994 on a number of complex-wide safety issues. These include the

need for the Board to;

- 42 •
• Continue to urge development and implementation of safety-related

orders, standards, and guides; assess their adequacy; and ascertain

compliance

• Insist on DOE's adoption of a systems approach in projects and

programs

• Closely pursue DOE's upgrading of technical capabilities and expertise

• Instill continued improvement in conduct of operations by DOE and its

contractors

, • Oversee the safe dismantling and storage of weapons and weapons

components

• Ensure preparation for, and indefinite safe storage of, plutonium-bearing

materials

• Actively pursue DOE's program for resolving ongoing safety issues

associated with corrosion and storage of spent fuel

• Ensure that DOE pursues excellence in the radiation protection program

• Oversee the safe handling and disposition of waste materials and the

control of releases to the environment

B. SITE-SPECIFIC SAFETY ISSUES

The Board plans to place a high priority on the following site-specific safety

issues in 1994:

Fernald:

• Scrutinize the safe stabilization of uranyl nitrate hexahydrate solutions

Hanford Site:

• Closely pursue DOE's actions to clean up corroding spent fuel in the

K-East Basin

• Insist on accelerated characterization of high level waste in tanks, as an

integral part of systems engineering for Hanford

- 43 -
Idaho National Engineerinc Laboratory:

• Oosely assess DOE's upgrading of ICPP fuel basins and associated safety

bases

• Monitor the disposition of remaining reprocessing solutions at the Idaho

Chemical Processing Plant and review DOE's actions for safely storing

calcined wastes

Los Alamos National Laboratory:

• Assess compliance with D~E Orders

• Review the development by DOE and the Laboratory of site seismic

criteria, evaluations of specific structures and systems, and plans for

upgrading seismic resistance" of facilities

Nevada Test Site:

• Continue close scrutiny of the Nuclear Explosives Safety Studies process

• Critically review the design and safety basis for the new Device Assembly

Facility, existing assembly areas and defense radioactive waste disposal

activities

Oak Ridge Y-12 Plant:

• Closely follow upgrades to radiological controls and readiness review

practices instituted under two separate Board reporting requirements

Pantex:

• Ensure that the Safety Analysis Reports being developed for facilities

without them and upgrades to existing Safety Analysis Reports are

technically adequate

• Conduct technical design reviews of, and oversee preparations for,

upcoming dismantlement programs and facility startups, including

Operational Readiness Reviews, Nuclear Explosive Safety Studies, and

Qualification Evaluations for Dismantlement

- 44 -
Rocky Flats Plant:

• Urge DOE to take aggressive action to treat and store plutonium-bearing

residues and solutions

• Oversee the safe start-up oflimited operations planned for Buildings 707,

771, and 371

Savannah River Site:

• Oversee actions to maintain disciplined operations at F-Canyon and FBline, where sedously degraded conditions exist

\

• Urge DOE to make a systematic review of the high level waste complex,

with emphasis on reassessing the development needs of the Defense

Waste Processing Facility

- 45 -
\

, APPENDIX A
Fedor.1 Register I Vol. 58, No. 17 I Thursday. January ~8. 1993 I Noti"". 6389

DEFENSE NUCl.EAR FACltmeS

SAFETY BOARD

standard. UlUluUon In Def......

NucIoor FaclnU.a

AGENCY: Der_ Nuclear Faclliti..

Sor.ty Board.

ACtIoN: Notioo: re<:oll\OlOodation•.

suw.IAllY: Tho Deronse Nuclear

FaclIIU.. Safoly Board (Boucl) has mad•.

• .-mm.~datioo to tho Socrotoly or

Energy pun.....t to 41 u.s.c. 1:l.86a

ooncomlns Standanls Utilliotioo In

Def.nse Nuclear Facilities. Th. Board

""luests public oomrnoole on this

recommendaUon.

DATES: Comments. data. views, or

_rgumenU conalminsthis

recommendation Ire due on or be£ore

March 1,'1993.

I.DOAESSES: Send cornmenU. dat•. views

or arguments concerning this

teCOmmtlnda\ion to: Defense Nuclear

FadllU.. Seroly Boan!. 615 Indi",,"

Avenue. N\'Y.• suite 700. Washington,

DC 10004.

FOR FURlltER tHFORMATlON CONTACT:

. Kennet.h M. Pusateri or Carolo JCouncil. at the oddress above or

telephon. (102) 20H400.

Ollled: January 25. 1~9),

I~ T. Coe",..ay.

C!to,'NnQn.

DalCld; , .. nuAry 21,1993

Sovat.1 of the Doan::l',

tt:Commendation!l havo emphll$i1l\d tho

importance of an offoctive program of

standards utiliUl\lon in defonse nucllX'r

(acilitie$. By so doing. tho Boord has

sh()v.'n thot it ODnslders tho de1nilud

roview of ongoing 0p~f8tions for

complienee with OOE Orders (and

oppliceble COn$OnslU stondardsJ as 8n

essenti,1 measuro In ossuringlhat

deIenso nucl~Qr facilities ore king

operntod in a safe manner.

The Board hns noted signHic.mt

progrM.$ by DOE In tho i$$uonce of now

end revised nucleu .cafoty orden tMt

more explidlly delineate roquiuunents

in liuch arees as: unreviewod saruty

q",dsUon determinations. technical

"ftlty requirementJ:. nuchNlr sofety

analysis repons. design requirements

and nuclear aiticaUly Nfely. Howevor,

the Board'.. ongotng review of the use of

Itendards In defenS(l"n"c!e.1'" facilities

has disclosed II number of po1enllal

Inc::onsi~encl8s In the manner in which

DOE Orders reloted to nuclear ...rety are

applied at (.dUtles thet produce end

prooe$$ flSSile materials. reillth;e to

tho.. radll,les th.l ....mbl.

db..ssemble. and test nUclea; weapons.

Th. Boord no'o.lb.at DOE 0«1... dltre~ntiltebetweeq auc1...,. l4I(oty Clnd

"nuclear explos..lve ..rety.·· (the laUer is

donned by DOE Order 5610.11. Nucle.,

Explosiv. Soroty): how.ver. the Boo«l

considers that certain besie "fety

principles opply 10 tho handling 01

fissile materiels. regardless ofthe (orm

that the material I. in.

For example. a number of orders

ndated to nuclear safety are expUcilly

.><clud.d frorn applicabUlty to racilities

Ihal ....mbl•• di_blo end I..,

nuclear weapons, while olhers are

appliOlblo only 10 "nuclear recilltl~$.·

(.. dofined by DOE Ordor 5480.S. Sorely

or ~ucloar FeciliUo.). Tho... that .pply

to Duclel' racilities do not necessirily • ~ply 10 raciliU.. thot ....mbly.

disassemble a,:,d test nuetoar \Yoepon$:.

In other technlcal ....s, such IS quenty

nsurance, essenUaUy dIfferent

programs havo been put in piece (ie.,

DOE-A!. diro<.1i••• QC-1 and QC-2. e.

opposed 10 DOE Ordor 5100.6CI.

The Do&J is committed to ensuring

tbe Itn'el Qf S3(ety USURnoe 8t those

facilities that assemble, disauemblo and

tfJ:51 nuclear wt)apona is at I08!;t as

rigorous as that roquirod ,t other

d~renso nuclear facilities and 1he1 it CDn

be mOQSurod to compare with Ihe level

of sarety usuranoe prOVided to tho

public 8nd silo wQrkors by commercial

nuclear m,terial prooe:ssing facilitiO$.

The ,bo\'O being recognb.ed. the Ooerd

roc.ommands that:

1. OOE r-Qview its list o( onfers e.nd

dirocHves rel3ted to nucloar safety e.nd

dclormine th~ that apply to facilities

and operflions th,t assvmblo.

diAA."M.lmlllo and lost nucloill'" weapons.

2. DOE ov.h.lete the levol of nuciCNII'"

safoty t)ss,urance providod by the ord~rl

end diroctives appliGl!lble to facHitios

Ih31 assemble. disassemble and lOst

nuclellr w~.pons end compare it to the

Il:vcl of S3~ety aSSUnlnc:e provided by

ooE Otders and diredivt1.5 epplic:able to

olher [)()f. dofon$:e nuclear facilities..

J. OOE develop a plen (or addressing

CIIY: dol'iciancie.s found by the lbovo two

ruvleW$.

... PriOrity be given by ,OOE to

completing sito-wide order complWloo

review$ at faciliUes that assemble

disassemble and tost nuclear wNpons;

wllh special emphasis plaOtSd Q,n tho

Penlox Plant..

Jot. T. Coowa"

Oroirmon.

Appendix-Lellt:r to ActinS Secretary

orEnel!1

J;lInuary 2t. log).

Ms.. Undl. C. Stuntz. ActiD& Secretary of

Energy. WuhingtoD. DC 20sas. .

OCIir Ms. Stunlz: On Jt.nu.&ry 21. IOG3. the

Deren" Nudur FacllUlu Slfoty Board In

wilh 4Z U.s.C nI5ll(S). •

unanimously .pproved fl m-ndtUoa IJ- J which. is endOMd (ot your comlderaUoa.

Rocommendation t13-t deals with Sianduds

UliliuUoD ia DertoN Nudear hcIlitlet.

42 U.s.Co 2186<I(a) nqullet tho BoOrd. aft... rocelp' b)' you. 10 pn>mpU,_ ibis

..,onmmtlnd'tiou avallibl. to lbotI pubUc in

Ih. Ocpartmont of f.fIertY·. npoa.al pubUc

readina f'OiOlU. The Board bclllewf the

I"COOtnmendatioti contains no lafomwUon .

which is cluslfi~ or othawbe nstridcd. To

tho exlent IhlJ mc:omcn.nd.lloA doa DOl

indueS. lnfonrW..ioa nistrict..J by I)()B under

Ibe Atomic EnOTU Act or 19$4, 42 U.s.C

21til-68.... UNIoded. pleue 1tnn88 to "'-ve

~his ~eo4Ition promptly plaoed on file

In yOW" RlJ1o.u1 public ....dia! rooms. The Board will publish thi. recocrweadaUon

in lhe Ftderel kqlstef.

Sincerely.

John T. Conway.

Choinnon.

If'R Doc. \13-2.084 Filed 1-21-93: 0:45 ami

IMl.UHG <:oof
16654 Fedoral Itegiaer I Vol. 58. No. 59 I 1Ueeday,'March 30. 1993 I NoUcoa

DEFENSE NUCt.EAR FAClUTlES

SAFETY BOARD

[Rocommtndadon_I

The Hood for e,lUc.1 Experlm.nl

Copobliity

AGENCY: Dof.nso Nuel.er racllUJ.s

Saf.ty Boord.

ACTlOIl: NoU,,!,:nccmmaodaUon.

6UMroWlY: Tho Dofon.. Nuelaor

FodIIU.. Safety Boord (Boordl bu mado • rocommaDdaUon to tho Socrotuy of

En"lD' p~1 In 42 U.s-c. 2286a

canc:ornln8Tho Need for CriUcaI

Experlmenl ~pahlUly. Tho Boord

nquosts public commonts on thls

rocomlD4lDdaUon.

DAns: Comments. data. views. or orgumenll ClOIlooming thJs

recommendation..,. due aD or before

,,"prll Z9, 1993,

ADDRESSES: 5eDd comments. data, views or orgumonll concornlng this

rocoJDlD.ndaUon 10: Dofonso Nucleor

FaclliU.. S.f.ly Boord. 6Z5lndlena

AVlnue, NW•• suite 700. Washington.

DCZOO04.

FOR FURrnER INFORI,\ATlON CONTACT:

K.nnoth M. Pu..I.rl or ~Io J.

Council••1tho oddre.s obo•• or lolopbon. (ZOZ) ZOlHi400.

Il.alod: March 25, 1093.

Job T. Coaw.y.

Qto;rmon.

The Need for Crilicol Exp.rimenl

Copabilily

Datod: March 23, 1993.

The ond of tho lntem8lional

competition in manufacture of nucle8r

weepons, and the tr8nsillon to 18.J'88

lCIle dllllW1tllng of Duclur WNponl.

heve seoerated tt.roD8 PI"8U'\1IW to

reduce the d,fen•• nuclear budget and

to clOie down many deroDM nuclear

faclUUN and opol'tiUon... At the lan1e

Ume. th. development or fl.rm plan.l ror

• Complex 21 10 "rYe future DUclev

defenao "Mdt hu .lowed.n ... treDdl

I..d 10 0 posslbiUty thai copablUU.. and

fun,etlOI1O nooossory lor atrrODland

fuluro needs could bo I.nnlnalod a1on8

with th... DO longer requbed. Ono of

th_.lmpotUDl for tho o.oldan"" or corII\D typos or accldonts.1s IUpport of

Duclear criUoollty control

Bocouoo oftho Importol>oo of o.oldlng

alUcaUty occIdo.lI. tho Boord ....Iully

foU..... tho 0lil0 of alUco1lty control 01

DOE'o 010...Dudoor faclUU..Thtl

Inlotpo\ boo boon nlelonl" Boord

mom"",, and otoJrbe.. nvIowocl

p_01 tho PonIOX Pion\. Th. Boord

boll_It 10 Importanllo malnllin •

aood bose oflnfonnoUoll for criUcality control. covoring tho phyolcoloUuaUDns

thol will bo .nCOUDtoi.d In handling

and &lOring fWI0n0blo malorlalln tho

future, aDd to elllUN nla1DioS • CIOmmwUty ofindividuals competonlln

pracllclng tho control.

In tho COW1O ofretrenchm.nl or lis

.eU.IU.. In roooni yoo.no. tho

Doportmenl ofEno'SY end III

p..odoooioor aaoncl..be..tormInalocl

UN of.u boll ono of(IiSODOn! purpose

faclUU..for conduetlng Deutron cholnIMcUng critlca1 oxporlmenll with

fWIonAb1.lIlIIorlol Tho resoarch al

th_ faclllU..bad oortocl prognmmoUc

purpcllO& ofelivone DOE Prtlll'lD". IS

weU u layins .8OIlOI'OI experlmo.ta1

bosls for practicesthal.n.......verting

criUcallty acddonls. Th. Boord It

InfOl1lltd thatth... 1s now .Itrong

possIbilIly thol tho lost DOE Cacllily

capoblo ofsononl pwpooe alUcaI

exporllDODli will bo Ibul elOWllIn tho

Door futuro. elue 10 1acIr. of funding. This

possIblUly orlsos boca.... DO mglo

program oftho OoporUD.nl bu en

o..rrldlng Dood for this remaln1n8

faclllly.1 tho l.oI Alunoo NoUonal

Laborolory.end th...foro DO Iinglo

program om"" Is mollvotocllo pro.ido

llilinoncialsupport In this perlod or

budget strinsoncy. A cortaIn

=.r,lscancy fod by 10m. yoers or om &om alUcalllY occldonls ...ms Olso 10 underli. thl. ~Ibillty.

Th. Boord absolV.. th.1 tho art end

scionce of Duclear alUcollly control

ho•• three prindpallngntdlool•. Th.

lirsl is-fomillorily with r.eton thot

contribute to achieving nuclear

crlticollty. end tho pbys.l<:ill bohov;or or systems et end n68r criticality', This

funiliarity is developed in individuals

only I.hrough working with critical

systems. It cannot be Impmod sololy

tbrousb l.ornlnS theory end WiDg

computer cod.... The MCXNId it

theoreUetl Wlde..-lADdina of DGutron

mullipUcatJon pi 0: 1M

lD aitica1e.nd

.ubaitica1 Iy.tamt. leacllng to

p..dletablUly oftho alUcol 0101. or. .y...m by m.lhoda \hot UN theory

bonclunarbd O8aln" aood and w.1I

ch.....ct.rlzed alUcal experlm.nts. Th.

thlrd Illhorough famlllorlly or nueloor

alticallly onglnoon with tho lim two

Ioctoro. obtolDocI tbron8b •lOund

progro.m of 1ro1nlnH th&llndoctrinol•• th.1D In tho oxj>orlmont.oland

theoreUcol upectl.

Th. Boord bu revlowod tho ctoluo of

bonchnwldng tho th-..tIca1 mothodo

ofalUcallty control opiDot exloUng

alUcaI .xporlmonll and bu fOUlld thlt

lbero ... notable feU..... ofthOOl'Ollcal

onaIyolllo llOCDUIlt for tho ....111 of 0

number or exporlmODlL It 10 Dol kaowa

whoth.r thJs clllCNpeaq roouIli &om

Inldequate Ilucloor data uooclln tho

onolysls or &om IDodoquata care In

conducing tho oxportmonlilUld

rocording th.1r physical f..\1iros. Both

Iocton could conlrlbul.. 1n odditJon,ll

IOOnu thll on tho .....thorelDly bo

I smoll Don-conoorv.U..blu In ..oroll

proclietlons oflb. theoJy.1n IpllO or th•••hortcomlngo. CIODNmlllsm In

mothoda u.oed 10a...lop the UtDllIlo bo

.ppllocl during handling and 1101080 of

fission.blo matortal """"" to bevo loci 10

adequate ..roty Ia_I yoo.no. Tho

Boord boli....that In th.lnlotelt of

conUnuocl..roty It 10 ItnportiUll to clear

up tho exIcUng cilsaepaDdu. wblch ore obsllcl.. 10 canftdent undorsWldlng of

alUoolily control To elo 10 will require

conduct of furthc DOIltroD c:boln.

roacUng alUcal oxperllDODlI targeled II

tho malor 00lIIC00 oftIIoaapancy

bolw..n tho theory and tho

oxporlmo.lI. IS _U u carelullUlolysh

oftho experlmont&.

Finally. tho Boord boll.... thot tho"

10 no go......l..thai tho phyolcal

clrcumstonces of banclllng end 5\0118.

of lisslonabl.IDIlorlolIn tho fulure wlll

always be found In tho _1m of

bonclunorl:ocI theory. 1111. polnl is

ospoclolly importanl UIldor

dn:umstoncos thai wtll exist for.

number of yean to come. with

Inaeulng omounll of fisslon.blo

mol.ri.llo bo 110M In ••orioly or ch.mlcal end physical forms. This does

nol appeer 10 bo an opproprlilo Um.lo

.limln.l. In obillly 10 ensure th.l.uch

Ictlvlti.. will bo &eo of alUcallly

h.zard. For ..rOly pwpooos II wl1l bo

necessary to relaln th. cop.bllily 10

perronn oxperiments under conditions

not foros"n at this time. This copability

once lost wouId be most difficult to

roproduC<l, end II could be

eprroxime.tod only at groat cost and
Foderal RogIolor

I VoL 58, No..50I Tuo&day. March 30, ·}0037 NotlOO8 16655

al\.r substAntia! tlma, detarring auch

development eyaD If it were neodtd

bedly.

For.n the .bove roe.tODI. the Board

bellova. that conUnuation or an

experimental program or geDeral

pwposo aitlcaloxperimenlo I.

nece"ary ror continued Mfety in

bandling and stori08liasloDabla

moterial. It is needed to improve the

be,sis 10' the mathodolO8Y.lt Ia Doodad

as part 01 tho p"""'" of properly

aducatlng aitlcahty controlongtnoon. II

i. Doodad to on.uro.tha capoblllty of

answaring criticality quoatlooo with now and previously ..ooud>od f..ture•.

Thenfo.. tho Boord IOCOIIlSDODdt that:

1.Tho DeportmODt of&>.'llY ohould

..tolD 110 prognm of genoral p~

critlcaloxporlmaDta.

2. Tbla P"'8'U' ohould ponnally be

dinctod olODg lin..IOUafyingtho

objecli... oflmprnYlDglho information

bolO undoslytns predlctlOD Dfcriticality.

and sorvlngln education Df tho

C01I\munlty ofcriticality onglnoon.

3. Tho IOOUlla and ..soUrt:OO 01 tho

aitlcallty prognm ohould be used tD

OngolDg daportmantAI prognm. who..

Duel... criticality would he an

Important CODCOSIl.

IobA T. CoD_y.

OCllnnc:IILI

ApPC"'I~c:etU' 10Sotawt..,. otE;wq;y

Much 13. 1093. 1lIo __

I R.O·lAaIy.

SocmIuyof~,

Wulil.._DC20S85.

Dear MaclaJDa SocIOIary: OIl Ma«h 23.

11113. tho Dolt...Noel_PodUtIot Safoty _.In_cowith 42 u.s.c.

22161{$1. "oa·'_'OIy appmvod R..........daUOO 8W wbldllo _ for

your c:ouw..Uou. P'CXW'"-ond,tkta 13-2

dooIa with n.. Need for.QltlcaI BJcporlmaot

Copobtllty. 42 U.s.c. 2216d{.) nqultat tho _. aft..

.-Ipt by you. '" _pUy_ thls

I'IcOCIUlwn,datloaa..u..bl. to tIM pabUc In

tho DeparWootofEooraY' nsk>GOI public _1II-'1lIo_ bol_ tho

._odatloo_ ...... ao In_tloo

wblch ls duIIfIod or_ .._ad.To

tIM ,IdeDI lb.lt I"COO'm.ndtUoo doet Dot

Iocl.dalolormatloo _adby DOH Wld"

tha "'0IDIe EootzyM olll1$4. 42 U.s.c. 2tet~. u ameoded. pi.... to bav.

thb rocollllllOodatloD p<OIIlptly JH-d OD 81.

10 your '"Sional public nadln&"-"

n.._ will p.bllob thb

teCOCDJ:Deodatloo in tho FttdaraJ ..........

SIoconly.

John T. Conway.

Ooinnon.

Eocloluro

tPR. Do<:. 91--1213 Plied 3-2;-gJ; 8:45 ami

alUJHQ COOC

\
.·edenJ Register I Vol. 58. No. 245 I Tbwsday. December 23. 1993 I Notices 68123

DEFENSE NUCl.EAR fACIUTlES

SAFETY BOARD

(Roconvnondallon ~l

Molnlolnlng·Acce•• IO Nucle.r

Weopono Expertloe In lho Delen...

Nudeor ","cllille. Complex

AGEHCY: Derense NuclNf Facilities

Sarety Board.

Acnott: Notice; rt!lCOmmeDdaUon.

suuw.nT:Tho oafenso Nudoor

FIdUti..Sarety Boord (Boord) has modo

a teeomme.udatJoD to the Secretary of

EDorgy J>W$UOO110 42U.s.c. 2286a

dooliug with molalalolug _ 10

nuclear weapons expertiM in the d.re... auc100r fodllU.. complex. Tho

Boord ~uosll public commoDlI on this

recornmeudaUon.

DATES: Comments. data. views. or

ugwoonll coDCIrotng tbls

recummeodatioD are due OD or before

Jon...., 24,,1994.

ADllRESS£S: SeDd commanls, d.lo.

vi at ugumenls coDCOtDlag this

recom daUon 10: Dofa.... Nucloor

FodUIi..sOIoIy Boord, 625 Indiona

Avonue.NW.• Suite 700. Washington,

DC 20004--2901.

FOR FIIIltlIElIIHFORMAllOH COHTACT:

Konnoth M. Pusoteri oc Carolo J.

MOJBan••t the .ddres.s .bove or

1010pbono(202) 208-6400.

Dated: n.cerober 20. 1993.

JobD'l'.CoGw.y.

Oo&rmon.

DaloeS: Doetmber 10. 1993.

The ongoing redUctiOD in size of the

stockpile of nuclear weapons end the

rel.ted mansos in the defonse nuclear

complex have. numbor of Stlifety·relatod

consoquence,. The Board bas oddressod

$Ovenl ofIlJ sets oC recommendation, to

such problem eroos. induding 92-5.

which concernod discipline of

opel'1lltion:t in a changing doConso

nudear f.cilitios: cQmplo.lt. and 93-2.

which stelod e c:ontinuod nood for

GIIpabi.lity to conduct O"i1l<:ol

exper1~nl'_ We wbh now to drew

allenlion to lhe need to ",tein cccos:! 10

e-peblllly.nd apturo the uniquo

knowledge of lndlvidual~ who h.ve

beon eDS.ged for many ye&n In certain

critical de((\I~ nuclear 6ctJvitin.ln

order to .void futUTe ...Cety problem. In

these and nl.Ied Idh1tiea.

Tho IIrot aiticol ""'" ~ulrlng

continued aa::eu to doputlng personnel

is 1M disassembly o( nud..,. W6tpons

01 Ibe PllllulilO, ... activity I,h.o, will

oontlnuelor a Dumber or y-.n.. The

lecond II tho \eltlng or nudOlf

expl...t_ .. tho Nevada T.... Si... III

octl.lIy p_t1y...bjact 10 •

monlori...... no-wt, tho Pnoldent,lD

_bllobl.oglbat DlOnlortum,lOld th.t

be has nlAblod the poosIbiUly oIlal.,

.....mplloa oIloiSUUl,h.ollo Doodad.

ond lbol bo .xpocto !bo Doplrlmool or

En0'V.lo.moIDlaiD. copobiUty 10

nsumo 10IliDg. III NOdiOD to the """,nl

a.1....~dl.... bohas

lDJlN<:lod tho Doportmenl oI·ED0'SY \0

taka oteps-..,.10JH01>O" 10<

recumptloa. pmc;l1Dg a dedatoa ..to

wboth..fJutL....., tho Navad. T....

511. oboWd be coodudod.

A bolonllo1 omounl of

docu WioD edals OII!bo deslgn ODd

..rely UJH!dO ofaudoor_pouo th.,

wII1ha..io be dlaaoallod ot PODtoJt.

nlllofOlllllU""

~I

.._1101 lot tho

prosram oad Io...ad In

lhal.p"'lJ1UD. E¥ea eo. the.~ has

polDted OIIt Ibol II Is ....lmportoD.. fot

oofely _toloyol••IadI..duoU

&om th. dodp Iobcml'orl.. of Los

AIamoo, U __, ODd Soadlo III

revl... ofdoWlod dlamoatlomoal

proood..... oad opodoIlzod prvoodwos

....pon\llos to.c.';~lDI.nooun_d III

th. <:lllUto8of UomODL TbU

pncllco has boon IIlItiAlad. oad II hu

olrwdy boon....'" be ..10110 ufoty oscurollOO In lbo dlsmanllomenl

p~osIgo lndI..dulls &oon tho

Iobo..,orI.. Dlost Doodod III CD<looctiOD

with dlsmont , of.sPOd6c

....pan ....11> who hod booo .dJ.o

In thooriglaal doslga oflbol ....pon.

nay ....(,oU..od 10 possoso

IOfornl.UOII DOl recordod In

documenttUoo. f\&da al f"NSOlU for

.paclfic design r..lutos, and panona!

knowlodgo of any problom. th.t b••o .rUeD dunoS dootga. fabrlcaUon, and

"ocItpll. IIIe. MODY 01 tho remaining

Indi..d...1s with thl. bo~d....

baing lost &om tho 1)"\0"'. bocau.. or the Univorslty of California', rocont

,..,tiremont lDoeDti~. plann6d leyolIs by

coolrocton. and DOE down,h:lOSllld

retiremont.. Some moenl movO" to

r. revent or diecountga use of t1)tirod

ndh1dunb u cooruhants compound

the p:oblem; t110y eroct b9nien that

could prevont lIoCC'OSS (0 th(t needed

Ol(portiM.

Similu ptoblflnu .h;o 1l11s.e In

cor..nection with matntelnfng c.epobilily

for tesOna of nucl8V explosives at the

Nevada Tost Sito. On tho .ssumptJon

Ibot tho testi.ng moratorium will

conUnue. we fore," an lrnpelnnent of

capebility to ensu,.lhe .afr.y oft..... ir

oatiooal prioritiet call for recumptJon or

testing at 50me futu", time. Tbb

Impeimlonl will 00C\lI both through

nduct.ion In competence thet natw1llly

roll.... wbon • blghly lkilled opa..tlon

lJ do( conducted owr a Ions l*iod of

tiOlO, ond through '-of.killod ...d

uperionood pe........LTho '-of

oIdllod pohOOIlo( will be oopoclally

troubling boa...!bon haslIodiU"""Uy

boon. blgh dogm> ofdOl:: DO

odmlnlstnli..ClOnllOls or "'..y In

lostiDg or nuclear explosive devioel at

tho N...da Tosl Sito. Propor.xorclse 01

those administraU•• controls tequl..res

consid...bl. boc:lc8round III post

motbods orI... emplacemonl ODd lost

condua. and extensive lnatitut10nal

Olemo')'. . The 8oI.n! 1"'CDp1tM the

DopartDlanl'. orro,," 10 d....lop. -..odpil.llowatdsblp· prosram

focusod 10 aarore lbo conUDuecloor..ty

IIId relioblUly of Geldod w..pou. 10

......... molotonoaco ofloboralory

cIo..lopmanl copebWl)', ODd to . Umllod produdioo copabiUl)', Our ......

of concoro compw-Ilb_ DOOOIOOl'J

.ClIv1Ii.., bul .... focuoed InIlood on

ODIuriag th., copebiUly Is molalo1aod to

conduct lost\llg opentlooo IOrely Ifthey

mull be dODO. oa3 thol.1I futuro

dlsmenU.manl.clMU.. COD be

complotod IOrely. Although II m.y be

rel.Ii..ly SlnIghtIorwonl to moInWn

tboso copeblUtiOi III lbo DOU l.tDl,

....uriaS tholr...llobl\lIy 510:ro ,.....

In tho fuluro OIOy be.ory difficult.

\D .ooonIlllOO with th••bo..

ClOD"""", tho Boord rook.. the following

ncoauneDdatloM:

(1) Thll • form.1 process bo ItOrtod 10

Identify tho olJlI. end mowlodge

nooded 10 cInolop 01' ...rUy IOf.

dismantlement or lDodifiadoa

prooodum .pocIfic 10.11 remolnlng

Iypo. of u.s. DUcloor _pons(..urad,

lnective. neerve. and enduring stockpile

Iy"omo). Indudod .Dlong tho ,1<1110 ...d

lcaowlodge ohould be tho .bl\i[y 10

cooduct relevant sarety .nelyses..

(2) That. similar rormal pl'OCOS3 be

storlad 10 Idonllly tho .kllls and

knowlodge needed 10 ..roly conduct

nucloar ttming operatJOTl:! 8' thfl Nevada

Tust Silo. including the processes of

assembly/disassembly. on-$110

Ifllns porte.Iton. InMinior\lomptacomont.

nnning end firing. timing end control,
68124 Fedel'M.l Regh.teT I Vol. sa. No. 245 I Thursday. Decem.ber 23. 1993 I Notices

and po.s:t·$~ot op~ratioDS. Included

o.mong the d:1H,-e..nd btowledg" should

be tho ability to conduct fl!IOnnl sdOly

an81y~.

(JJ Thot. preetice be institutod of

revtewing the (Hll'SOfloelloSSoes ot tho

DuciMt "".pon. I.boratorles and tho

Nevada Test Site. u well &5 thl!l louo$

ofk.ey persofUlol &om DOE's own ,tdC

engaged to Duclear defense ad.ivitJes.to

UCBrtain which 01 the skills end

knowlodr. .,., p",jectod 10 be IoSI

throtod> <.pm"", 01 personn.l.

(4) '!'bal OOE end II> d.ren.. ooel....

cootnldon negotlate the continued

...lloblUly (thIOu~h m ...Uon. hlrln~.

........1tlnR. etc.) 01 th_ penonn.1

echodulocllo deport whose .l1lls.nd

bowlodr he... been determlaod 10 be . Impo<teollD eocordeDoo with the .bert.. (5)1he1 Jl'08"IlIIObe 11l1UeIod 10

obteID from tIMNe expert penc>DIlel (.nd

10 NOOnI) the .. yet lIDdocul1lenlod

e1iec:dote1 technlceJ IDI0000000UOII thai

would be 01 velu. ID .ugm<mUng the

l.moleol b_led~ODd expertise 01

p,,"*,«.--nel.'lhb .bould be

d.... e1lh« prior 10 d.portwe 01the

NtlrtoIt penc>DIl.l ..oltortly OJ-ner.

(e)""1 prooed""" f... llle

cliseueuibly ofweepon"'Y"'1n1 be .....Iopod while the pem>DIIol with

oyst.ln-specllic lIXpOrUse On the orlglnel

=~_lofthew..pon"''''oIi!l UkewlM. anelyoes of the

poodW\lly 01 baenI from desnd.Uoo

olnmelDlaSlluclear.....pons with tiDlO

obou1d be expedited. wbile tltese

Ind1v\duela .......IIoble.1D oddiUon.

the ........1 pet\idpeUoo of design

1oborelory upoN In the IIlely aspeets

ofcllooaemhly of....po... 01 the Penlo~

Sil. obou1d be strengthenod.

(7) 1bet• program be doveloped end

1DoIliutod. for molDlel.niDs o.pertl.. ID ~tl....key 10 lIfoly oflIucleor

lesI1DS at tbe.Nevoda Test Sil•• to .n...",

that U looting Ie ""UI1lad .1 eny lulwe

tImo, It COlI be perfotlnod witlt "",wilo

lltoty. p-n,1e componenl> ....tIt_

ocUvlU.. end lIXpOriiJIooll thel would

be pemUltod witlt1D UIIliI.Uons or

~U..liolna dlscussed. f....X&lDplo:

Hycln>nucl.... I..... bocI:drillinslor

Uotoplc.n.lysil of....du.. lrolD old

<bots. end _ IlIeiudins s'ep. in

preperot101l for ,..... up 10 actual

ompl.ocorno.\'

(e) Clven Iho loss ole.perioncod

personnel. that a detennioliion be mede u to w~rtnldllional dependenco on

administrative controls to ensure

nuclear explosive safe1y al lhfl N(lvoda

Test Site. would be adequeto &nd

.pproprlete If nuclear testing should

rosumed at • later time. U mey tHJ found

QOOK'ary to dovolop an approach for

en3uring nud06.1 "xplQsive safoty In tho

tasting progJ'llm thtlt Is loss do~ndol\C

On the performance of highly

expeMenced personnel. such lIS through

the UH ohngineered s.efeguards simile.,

to lhose used In fielded weepons as part

of the uming And firing. and timing tuld

control.ystems.

Jobu T. CoDway.

OlainnoJ\.

Dectrnbot 10. 1993.

Th. HoDOtlbl. Haul R. O'Leary. S~lfll")' of

Eoeqy. Wasblostoa. DC 20513

Oeu sec:ret"Y On December \0,

tM3. the Dofout NudearFKilitl•• Safely Boerd.1a__wlth 12 U.s.c.

22$61(5~ ".I.'_·dy.ppn7"ld Rec:omnMDdetloa u-&.h.k:b is 4oclosed for

your__Dda,loo03-6

doob wItb MoIaIllalaS _ ..Nuclear

Wee_lbpocliN Ia tho Delonselludeor

FodUdooComplex.

42 U$.C. zzaed(11 roqub.. the Board••n.. rooolpi ",,...,Io........uymoko \hit _OdOUOO o..u.b1... the pubUc I.

the~IofBno<p'I••1' public ...dlllll-'IbeBoerdbol_tile ............-_..Iaoaolafanl>a'ion

which IId,selGed arotMrwbt restricted. To

tho _1hII,- ndoUoa doos DO<

Include IoloralatIoG _adby DOE utIdor tho_~/odoft9S4 ••2U.s.C.

2161...... u a.w. pI.... UTan8f' 10 have

IhlI i r UOO IJCompdJ plamd OD fil.

Ia yourftIIooal POhlIc nodlllS IQOmS,

no a-..s wtII POhlltb thlt

.If( d,!Ion fa the Fedmal aq,ltttt,

5_ty.

JohaT.O>ewey.

C/lolnnoL

lFR Doc. ~t3S1 FIled t2-22-93; e,,' oml

IilWNG COOI. ..........
Federal R"l;ister I Vol. 56. No. 143 I Wednesday. July 26. 1993 I Noliees 40409

DEFENSE NUct.EAR FACIUTlES

SAfETY BOARD

~ommenclltJon93-6)

Hanlord W.ale T.nb CllarIclerlzalion

Sludle.

AGEHCY: DefenSl!ll Nuclear f.cilities

Sofety Boord.

ACT\()f(: Notice; r600mmend.Uon.

SUMMARY: The nefense Nuclol!

F.cllill.. Sofaly Boord (Boord) has mid.

• nconuueodaUon to the Secretary of

Ena'1lY pUl'$ullltlo 42 U.S.c. 2286a

concerning lmpfOvements in the wasle

charact.rizalion program for the high

1...1wast. slorag.lIIlk. at the HlIlrord

SiI•. Th. Board requ.sts public

comments on this NCOmQ\endation.

04TES: Comments. dele. views. or

arguments oonoeming this

recommendation are due on or before

Augusl 27. 1993.

ADDRESSES: Send commonu. data.

view., or ugumentl ooneeflling this

reoommendaUon to: DefeoH Nuclear

FaclliU.. Sofely Boerd. 62S Indillli

A'.nu•. N\'!. Sulto 700. Washington.

DC 20004.

FOIl AlATHER INfOIIUATlOIl CONTACT;

Kannoth M. Puslleri or Carol. J.

CouncU. at the address above or

telephone (202)208-6400.

Dated: 'uly 21. 1993.

lou. T. CoDW.,..

OaJnnon.

Huford W..te Tank. CbaraCltlriutioa

Sludiet.

Dttod: July 19. 1993.

Sinoa its beginning almost four,ea"

080. tha Board hu ...Isned one 0 ItAI

bighe'l prioriU.. 10 osaurence 01 eafely

.t tho high le••l DUel..,. wasto storage

lIIlks alth. Hanford Sit•. Th. Board

eddre...d two ofItO letAI of

recommendationl (9G-3 e.nd 90-7) to

potential bazards auocieted with tanb

containing fenocyenlde compounds and

pointlild to the noed for ectJOI1 In

connection with tank. 101-SY, which

periodically vonll Oammabte mixtures

or nitrous oxide ,and hydrogen g~s. In

Recommendetion 9O-7.lhe BO&rd

emphasized the wgont Deed for more

rapid and complete sampling and

analysts orte.nk wutM. The WAstes in

the Henlord tanka diff.r morl<edly Irom

lIIlk to l4Dk. IdenUficeUoo ol.,blt

.peclficelly is In each lAnk u ..sential

and UJ1lODL Withoul timely

chal'eterizaUoQ of the wastes. the

notun! 01 th. risks usocl.ted with the

IlIlks cenoot be fully ....ssed and.

when neousary. miOgated. Further.

untilth. ch....ctorUtlcs ofthe wast..

are known. flnoI melbodo lor lAIDk weste

monitoring. retrI••al. transport, IIld

tre.tm~nl CODDol be ....Ii.Ucolly

esla~lisbed.

1'h. Boord hu ...peeledly .xpressed

ils dismay.t the.contiDued slow n.te of

conduct of thia charact.rization prognm

and has wgod a _'orrol. of prograss.

Allasl count only 22 oftho 177 looks

on the .U. ho•• been ..mpled. Only

tow- of those M.II'lpled. were among the

54 tanka on the _Ich list oftonks thot

generate tbe gnHItelt qr.ty concerns.

Th. Dumber of.....pl.. per lIIlk

continues to be In.ufficient to provide

.dequal' ch.ractorlz.alion of the full

tank. While the published .chedul.. lor

sampling and 8JUl1,.io proml..

improvement. th., .tem optimistic

when viewed eg&1nst the record to date.

TIley .ppurlO presenl wish.. fathor

than IU.Udpated ect1viU8S.

Two ..ts of problem••ppear 10 be

principel contrlbulora 10 the .Iow peco

o( charocterization of the contents of the

lIIlks. Th. first ua complox 01 facto"

ading to impede ICC8$C to th,inlenon

01 tho Wlks and '_01101 aample.

of their conteutl. The MOODd b the

exhaustIve.et of l'DM.SW1tmeuts made

on each sampl•••Iong with limltaUono on loboraloly cepebilily for compleUog

theM moa.suremenlS. The Boud Dotes

th.t mMSuremeDlI made for safety

purposes do Dot necessarily receive

priorily o..r thOle done for other

......,ns.1tICb so ..U.foetlon ollormel

EPA·relaled requirem.nis lor 6nll weste

dioposillon.

The Board believes thllt acx:elonting

the poco of the prognm of

chancterlzing the contents ofH-.nford'j

high level nuclear waste tanks is

Importanllo nuel..,. ..Iely althis

important defense sltEl. This view is

aharod by oIherexperIAI. including

OOE's own ·'Red Team". wbich

reviewed the wade dtuacloriation

program lor the HlIllord Tank Farm

lDO&-EM. July 19Q2,lnd.pend.nt

Technical Review of Honford Tank

Fann OpeRUOns). OJulieteriution is

8$.$4JnUal for ensuring safety in the D8IU'

tenn during custodial managoment IlIId

remedial ,ctivitlos, end also in the long

term for ad~.ndng the developmont of

pennAntnt solutionJ to the higb level

waste problemt .t Hanford.

10 addition to the matter of

ecx:eleretion and reprioriUUltion orthe

sampling schedules.th. Boord to alse

concerned ohoulthe sampling .rrort

111811. The Boord not•• thet a I'OOItllly

..loosed DOEIRL audil (DOE-RLIOPA

Audit 93-02. April 1993) ofthe

..mpling program. reyealed aignlficant

",·ee.knes.sos in the control. me.n.agement.

IIld lechnicellmplementoUon ofcore

I8llIpling.laboraloty, end SUpportfDg

aoU.llles.

Becouse th. failure 10 .igorously

punuo tonk wAllo chorocterlzatioD

nl... lmporWll health ODd ..Iely

IUllO•• DOE Deeds 10 tAlk< .etlon 10

ecceie"t. ADd .....ngth.n th.

1I\8I1egomenl ofthe cb.araderizatlon

effort to elllW"e adequate proted.ion of

public hoelth and '!Ifety.

There£o",. the Bo&rd recommends thlt

DOE:

1. Undertake a ODmprehensive

nJexami",aUon and nS1J'Uduring of the

charee:toriuthm effort with the

objectives of accelerating samrling

schedules.strengthonlng lechnlcal

me..n.~mtlDlof the errort, IUld

completing ..1.ly.relaled sampling end

1Il.lysl. of w.lch Ust tonka within a

lorget ptl.lod of Iwo y...... and tho

remainder of the tanks by a )·.u later:

a.ln accordanou with the .hove. give

priorily in theschedul. oftanks 10 be

sampl.d to tho w.,ch list tanks and

oth... with Id.ntified ..rety probl.ms.

and priority to the chemical anaIy,"

provldiog Iofo"".I100 ImpcKlllltlo

enlurlng ..f.ly In the n..,. term during

the period of custodiel mOD08emooL

Other an.ly.... required by atotut.. IUch .. the ReIOUJCI Couervetion and

Roco••ry Act prior 10 50lt disposition

ofthe wute. should Dot be cause fo"r

deloy of..fety·...latocl aD.lyaeo. 10 moot

cesoo. anll1y... Deeded for long-t.rm

dispo.lllon m.y be postPODed u.oUI

more prusing &afety-nlated anllyS8s .... completed.

b. R.eelWllln~ protocol. for gaining

.cce"lo th.1enks for sampling with lb.

objeetl•• of.impllfylng documonl.llon

and epproVllI ~ulrem.nts.

c. Increase th. Ieborotory copecity .nd

acUviUes dAdiated to tenk s&.nple

on.ly.ls:

(I) Expedit••rrorIAI to oblaln anti begin

utilizing addiUODaI sampling and

alUllytlcal equipment now being
40410 Federol Regisler I Vol. 58, No. 143 i Wedoesday, July 28. 1993 I Notice.

procured. and the tla.iDing of ~rsonnol

needed tor An "nlmged th.n:tugb-put

ape.cHy.

Iii) Explore ovollobllity ood ull~ty of

labontory I6MOM on- &nd ofJ-1iiite. aut;.b

.. Hanrord'. Fu.1 M41.ri.1o ODd

ExamlnoUoD Fecilily and th. INEl. ODd

LANI. laborelorio•• for .cc:ol....ti.1lj; th.

waste chanlderiul100 effort.

2. IoIAlgroUl the c:lw..cl.r4eliOD oltOri

Inlo the oyd.... ooglnooriog .ffort ror

the Took Wid. RBmedloUoD Syst.m: o. Schedule tank oomr.llDg ooD.lstonl

wllb ODglneerlng and p anoIog ror

removAl. pre-treatment., .nd vltrificetion

oflb. tank wut... b. Critlcolly .XOlIIID'.th.1m of

ch.mlcal lyooo do 00 .....pl.. to

_bUsh th n 1beoded to

HUSfy safety requhmneDu.

Co SIJeDgtheD lb. mODogolbO.1 ..d

CODduct orthe oompllog operellob••

Appendll-TronamlltO' leiter 10

Sec:nrtIIry 01 Enorgy

'uly 10. 1993.

n. Hooonbio Hu.ol R 0·.....",

S«m4ryof1ln<oJy, WcWaJopon. DC 2058$.

!lou s....tory O'Loo.y. Oa luly to, '003,

th. Defe.... Nuclou PecUltl..Safwty 8ovd.

I. ocoordaooo ..lth'2 u.s.c. 22...(S),

UMDlmoudy:::''1od Recoil1nlendaUoD 93-

5 which it.n for con.ideratioG.

RMGommtlod.Uolli 03-6 deals wUh HllnfonS

Wut. Tanb O\ancteritaUoD StudlM.

4.2 U.S.C 2286d(1) requlnl tb. Board••fter

nQIIlpt by you, to promplly mab thb

l'tlQOrJ:UnOadltk»a, ."lIable 10 the public in

the Deputmol1l of EMqy". regiQlUll public

roodlllll ......... nolloord bol_ Ill.

recommendalioD. oontillu: no LDlotm,UOQ

which b cla"Ified orothorwiso nftrieted. To

the extClolthll ncommond.UOD doe. not

Include InformatlOD mtbided by DOE under

th. Atomic Eoergy Ad of \954,'" U.S.c.

2161~8. as amended. pi... 1tfU188 to btve

tbit ncommopdaUoa promptly pllKlltd on fil'

10 your rogk)nll public nMIdlns rooms.

Th. Boud will publbh tbJ.

recot'tU'D4lod.tioa in lbo f"-.l l.esiI1•• SiRotnly.

Jot'ln T. Conway.

Chairman.

'fR Ooc. 93-179040 FlW 7-:1:7-413: 8:4$ Ul)

......... """"--..0
Federal Regisler I Vol. 50. No. 1Z0 I Thursday. June Z4. 1993 I NOliees 34247

ERMC c:ontr-ador to Slart operations at

the UNH proloctin Apr-il 1993 without

t1} conducting a DOE-FNarequired

readiness review and withoul (2)

informins and obtaining tho approval or

either thtl DOE-FN memogor or the DOE

headquarters projoct orrico to st~rt tht;1

operation.

Most recently, incid(lnts invol\ling thu

improper Irandor or UNH solution into

• treGtment system 5ump. and the

resultant releose or approximately 30

gallons or UNIi solution to the

en\lironment. have again shown how

inedequate procedures. inadequate

knowledse ofsyol.m••nd prooodures on th. port of operolors••nd .boonoo 01 on .pproprlolelovel of dlscipUn.ln Ihe

conduct or operations an conmbutelo

unsefe operatl.ons. These incidents were

logged In DOE'. OOCUITIn~ nportlng

.ytI.m in ",ports ORo-WMCOfMl'C-l993-00Z7 AND ORo-WMCX>-

fMl'C-l993 -0028. _peell"ly.

Furth.rmo",. tho Boord hu noled recent

.v.nlS .1 olbe, focIlIU... under Ih.

cognlzonoo ofEM. Including the

DelenM W.ste Prooossing F.cllily.t

SRS .nd Ih. U..nlum Oxld. Pllnt.1

Hanford. th.llppeorto Indlcelo

fund.monlelsof'ly problems _ulllng

from delocti.e dtoclplln. of op.rallons.

The Incld.nts .t F.mold Ind II olhor

sUos.llken logether. 1100 IUggost thlt

DOE's lechnicollllODOgeDMInl end

oversigbl struelure for ERMC COnln":'" oro In need of upgredlllg. M tho d.fen•• nucleor compl.x moves mon ..pldly

towonllnna-Ie"" lIa..go.

environmental restoration. and cleanup. new contndora .1 other Illos will be

engaged using the ERMi.~roach.•s I.

being UMd .1 Fernlld. upon

oboerv.lions orthe F.mold projec!.the

Baud hoo concern at.mmlng from

heelth end .fety conslderaUons thol: (1)

DOE m.y nol hive oufficlllli numbers of

compet.nl.lnlnod heodquorlors .nd

field pe..onn.lto tecbnlcolly monlgo

ouch COoInCll. end (2) contncU may be

nogoUated ",d .Igned hefon DOE has

developed 1n1.....1plono on how 10

corry OUllllleclmlCollllODllgomonl.nd

overslghl nspclnslblllU... Th. BoenIls.•won thol you beve

recenlly ennounood InlU.Uves 10 ",form

DOE conlnd rn.nsgemenL Th... lnit,l.lIves .", directed lorgely II more .lTectlv. finlnclal menagem.nt .nd

prog.-m Implem.ntaUon. The Boord

would .ncouroge.ln Ihelnle",sto or

public end worke' hoolth .nd ..fely.

th.1 the planned nvlew of conlnldlng

mechanlsms and pradi08s also

oncompo.. Ihe DOE technlcel direction

and ovorsight structure. Tho Boord

believes that competence ond

errceti\leness in technical aspects of

rnenagement are essenUal to assure that

FOR FURTtf.ER INFORMAnOH COHTACT:

Kenneth M. PU$;1«~r1 or cerolo J.

Council. at the address above or

telephone (202) Z08~'00.

Dated: June 21. 1993.

John T. Coaw~y.

Chairman.

DOE'. Management and Direction of

Environmental Reslorallon

Man_sement Conlr.ces

Oat~d: Jun•. 16. 1993.

The 80Ird and Its starr have boen

monitoring the ~ffort$ of the Department

01 Energy IOOE) In technlcolly

m.noslnglh. Uronyl NII..le

H.xohyd.-:e (UNH) oI.bllluUon p,ojecl

.1 the Femold Envlronm.ntal

ManagolllOllt Projoct .Inoo DOE bog.n

p.."",Uonsr... opo.-IlonlllosllngIn

·eorlY\1992. Tho stabllluUon projecl WIS

IntUo\ed oftoT the UNH IOlullon w.s docllNd WIst. In 1991. The purpose of

tho projoCllo 10 p_tho UNH Inlo • nller cob f~ Inlerlm hUcl.., west.

oIoro8o omIl. pending fin.1 disposition. In .ddlUon 10 mointalnlng • focus on th.lochnIcoloopocto .lTocting sofoty.1

Fernold. the Boon! bes • high Inlerestln

DOE's use ofllS Il.wEnvironmenl.1

Rosto.-Uon Monogom.nt Conlnlctor

(ERMC) .pproach 10 dofmM nueloo,

wolle atange. \lalm.nl. dlsposel••nd

0111 docommlulonlngl""loroUon .1 this

0IIo.1lxporIon<» acqulred.1 Fernald con provo v.luobl.lo tho Deportmonl end

Its fulure ERMCs for defoDM nuclear

011... Of portIculor Inl_10 tho BoenI

10 how. undor thl••pprooch. DOE Ind

the ERMC will enswe .doqu.le

proteClllJll ofthe hoolth end sofoly 01 Iho

public end lb. onsll. worbrs Involved

In at_end processing ofnueloor

WIst••1Fernold.

n... Boon\·.II.1Thu visited Fernold

10 nvle..lb. UNH stablllzoUon projecl

In fi" oepuat. oocoslons oInoo Morcb

1992. Topics for nvI_ hov.lncluded

locbnlcol monogomenllUrODgomenlS,

opo.-tor tnInIng.lIsrt·up lest pIon•• ndlotlon pcoIoctIon, nitrogen dioxide n'-.and lhelesUng ofsystem

operoblUIJ.Th. BoenI forwanled

oboerv.UIJIlO &om tho Morcb 1992

Fomold vIoIllo tho hlslslont _ory

fo' Envirollln.ntal Roslo..Uon end

Wottl Monogomenl (llM-l) In .Ietl.r

deled luly a. 1992, Observ.Uons from • .talTUip In April ofthis yeo' we",

forwonled 10 EM-lin. leller doled MlY

11.1993.Those revl.wIII Fornold h.ve

shoWll weokn...... In DOE's lechnical

dirtlCllon 01 conlroClo,perlormonoo. Iho

contractor's conduct of opent.tions, and

tho level 01 knowledge of personnel.

With respeello Ihe firsl weakneSS, a I.ck 01 technical vigilim", on tho port 01

DOE-Fernald (DOE-fN) eUowed tho

~:The Def.nM Nucloor

FeclliU.. Saf.ly Boon! (IIoen!) hu ....d. • ncommondeUon 10 tho Seaeloly of

EneIaY pursuonllo 42 U.s.c. Zza60

_oornlng heelth end ooIely feclo.. usocl.led with DOE'I IIIUllgeDMInl end

dlnlcilon ofEnvironmenl.1 Reato..Uon

Mon.gomenl ContncU. The Boon!

request. public comment. on thl.

recommend.Uon.

OATES: Comments, data. views. or

argum.nts conoornlng thl.

recommendation are due on or before

July 26. 1993.

AOORESSES: Send commenls. d.lo.

views. or.arguments concerning this

recommendation to: Defense Nucloar

Facilities soroty Board. 625 Indiana

Av~n\le. NW.,luito 700. Washlngton.

DC 20004.

DOE'I Manogemenllnd Dlrectlon of

Environmentot.ftestonotlon

Management Conlnlell

AOEHCV: Def.nM Nuclear F.c1l1ti•• SafetyBaud.

ACllOH: NoUoo: recommend.Uon.

DEFENSE NUCLEAR FACILITIES

SAFETY BOAAD

,'-
34248 Fed.ral Register I Vol. 50. No. 120 I Thursday..June 21. 1993 I Notices

Appendix-T"~U.ILett" to Stlcrew'y

.It:nav

)Ghat T. eonw.y.Ctalnnln

h.l. Easonboqjer. VI.,. Ololnnan

John W. Cnawrord. Jr.

I_ph I. DlNu.no

HaUo<1 fohn Cec:ll Kouts

Dor.... Nod....faclllll.. SaIOlyBoonl

625 IndlaDa A..n\tO. NW•• Su.lte 700.

W.sbIJli1<>a, DC _(202)_00

JUD. 16. t99'.

The Ho"""'bIe HuollL O'Louy,

SeaelGtJ' Of£nerBY. Washln"on. DC20585.

.Doar Seorew)' O'Leory: 00 ,..... t8, .tIlI3.

lho Dar.... Nuclear facllllies Sac"y Boonl.

In a=rdanoo ..lib 42 U.s.c. 22GGa(51.

uMnlmou.lyapproved R.Ic:ornmnda'km 13-

4 ..hkl> 1s.1lClofod lor your.....1d...tIoIl.

Rooomrn.odalloo U ..... cIool. wllh boallb lOci

salol, ladon usodated wllh DOE's

lnan.l8Oment ud. dlrectlou of Ea"lroomantal

Rostorsllon ManapnentCon_

4t U.s.c. 22ll<l(.) ""Iulrestho Boonl••nor _ipl by you. to promptly~. this __tion .YI1labI. to tbo public I.

th.IlepartmIO' oIlls>o!8Y"1e81ooa1 public ...dlna ........The BoaR! bel_ tbe

nc:omtDIndatioa ClOn~bu no tnformlt&oD

which b dualf..ci or otberwlN restricted. To

Ihe edent thlt: f. tnelItioa does not

Includ.lnlormatlon r<lSIrIClod b,!lOB under .h. h.omlc Ilno1zJ Aetol.oSt. 42 U.s.c.

2161-48, U UMndecl. plo..e arnn,. '0 bave

Ihl. ncommendlUon promptly pl.oed on me

io )'Our f'e81onal rubllc fOlding rooms. The Board wll pUblbh Ihl'

recommendation In the federal Reststcr.

Sinccnly.

John T. Conwl!ly.

Choinnon.

IFR Ooc. 93-14894 Fliod 6-23-93; 8:45 8m)

IlrlUHO COO£

stebilizetion runs. Por tho type and

scope of the reviews. consideration

should bo given to the standards set

forth in phivious Ooard

I'"9COmmendetions on this subject (1.0.

9o--t. 9'-3. 9 ....... 92-1. 92-3. and 92-

6) and eccounl for the known safety

consider8tlons for this opcT8tion. ntis

process should also includo

identification of the appropriate DOE

officiel(s) responsible for ensuring that

public and worker health and "fety are

edequatoly protected and ror giving final

start-up IIpproval.

6. DOE Immodi•••ly eslobli,h • group

ollachnlcally quelifiod Facilily

Representatives It Femald to monitor

tho ongoing .d.i.ltI.. DC d.lly

operations at the alt•. DOE'.

"Culd.lin.. for Establishing and

M.lnl.lnlng a Facillly Rep.....ntatl••

Progrlm at DOE Nuclear FadllUes.ft

issued In Morch. t993. may be a usalul

basis lor quickly estebllshlng such.

program al F.rnald.

'OM T.Conw.y.

Qloirmon.

Fernald. the technical nllmagemenl plan

Ihould bo developed end implemented

expoditiously. For futu~ ERMC

contrtlcts. such a plen should be readied

prior to contractor selection. I!lnd should

be implemented at the initiation of

contracted servlal$_

2. Each pion for technical

manegement of contreeted services

include as 8 minimum:

(8) A clear statement of fund ions I!lnd

R:sponsibUiHes of those in OOE

assigned the tlSk of technical direction.

monitoring. or oversight of Ute

con\r<lctod .rrorts, both .t headqu.<1o"

and the nlennt OpeRUonl offices:

(b) Definition oflbolechnlcal.nd

m.nagerla1 quallficallons ""Iuir<ld DC

1lOE'.IOchnicalmanagemantst.IT.,

eacb mret of....ponalbl. DOE line ond

ovenlRllt unlll; lei IdentificaUon oftha principal

Inlerfacaa wilb lb. non·lechnical DOE

personn.llnvolvod I. \be con\r<lel

ma~ment.

(dlldenUficaUon. by n....... DC Ih. key

lechnlcal penonn.lselecled 10 perlorm

the ""Iulsiteledu>lcal dir<lcllon.

monitoring, end OY8rsl~t funC1ions;

Ie) IdenUficaUon oC pollci... preelices.

orders. and other key i.sIn1ellons that

rep.....nl. basic framework 10 be used

In DOE lodinl.... managem••t ofthe

ClO1IIr<lelor In enauring public and work

safoly IIld adequot. environmenl.1

protection: and

(I) A detailed p_mto .nsure

oompllaoce wlib .ppllcablo Slalut..ond

DOE Ord....'standards, rul... dIIaClI....

and other ""Iulremonts related 10 public

and workersarety and .nvlronmental

prolection.

3. DOE consid.r lb. Inslihts g.lned

from addQ!lS$\ng nocommend.llons 1

end 2 abo•• for ERMC conlr<lcls In

pursuing iii. broader Inlti.ti_ for

",fonnlng amlr<lel manage...nl you

recently announced.

To Us\sI.DOE In .....lvIng Ih.

broad.MluecI safoly Issues.dd",SSld in

the previous recommlndations. the

Board r<lCOlDDlends thol\be following

addlUonal aetJons be taken.t F.rn.ld:

4.D08 headquarters ",..pllle.n

IndT.:nd.nl ",view oflb. recenl

Ind .nts at F.m.ld,ldenllfylng tho rool

causes for Ibose Incidents and the

correctl•••dloos ""IUIr<ld lo ...mody

Ih. und.rlylng problem•• and lrensl.to

Ih. F.mold findings Inlo lessons

loomod .ppUcabl. 10 othor Cacilities. 5. DOE esl.blish. cleor process with

an appropriate set ofrequirements and

cloer definitions of tho line or authority

(aT epprovol to start the UNH

stablHution project. Tho set of

requiroments should idenlify the typ('

ond scope of readinoss reviews DOE

will require for the stert oflho UNH

contract .5ervicl(Is ore provided In a managor which meets health and safoty

ob;(Ietivvs,

The Board believes !.hat DOE should

rurmali7.E1 and Gtrengthen its technical

"1anaBoment of ERMC contracts. A

straightforward step tow....d achioving

this objective Is fOJ DOE to dovelop. in

parallol with tho drafting and

negotiation of 8 new contract. 8 scparato

documont which will provide detailed

project and technical managoment plans

ond allocato qu.lified technical

personnel to manago that contflct at

both HQ ••d tho fiold location. Such a

plan would In .lTect be a Iunellons ond

rosponsibllltios documonl. II would loy

out fMnasement e~ltlons for those

auisnod \be lechnlcal monllorlng.

dlnlcllon. aod o.ersighl oftho

conlnclod ..moo•. and Id.nllly the

inlOrf.OB$ with othar DOE ",souroes

manoalng tha non-tochnical aspec:ts oC

the cootnct. The contftdor would

normally not be .Uowftd to commence

opelallons In.ol.lng radlOlellve

malorial. until DOE', pIon for lechnlcal

managemonl oC sit••d.i.1tles has been

put Into effect. this means, among other

things. thol lb....l••ant DOE sll••nd

beadquarters offices have been

adequatoly SlalTed with qu.lified

persons 10 pro.ld. competonllechnlcal

d1laClion. guldanca••nd o....lght ofthe

=Ir<lelo<', operellons.1n additlon. lb.

nrindpl.. contllnod In .pplicabl.DOE

<MI... aod In p....ious Board

t'ICOmmeadations on such topics as

DOE facility " ntlll (92-2),

o"""'U.n.l din I.ws (92-6).

and \JaInlng (92-7) should be

incnrpo...lod, wh.... 'ppropriot., Into

DOE's plan.

Sudl.d.anca planning f.r lechnlcel

management ofERMC contracts would

h...lb. following ben.nc1.llmpacts:

11)Tim.ly Id.ntification and

commitment.fadequototechnlcal

resources to manage new centreds and

proJects: (2) uf front Identification for

DOE tonica managen of expectations

deri.lng from DOE ruponslblllU.s for

protection of health .nd saf.ty of

work... and lb. public: .nd (3)

essuranca Ib.t DOE', technical lin.

manegem.nl and ..C.ty ove..ight

0I8lDIzaUons.... In.ol..d early in11>.

contnetlng process.

In summory, the Board beli•••s thet

impro.emenl oC DOE's cop.bllily 10

.provld. technical manogement .nd

ove..lght 01 ERMCs across 0 board front

Is necessary to ensure edoquate

prolection oCthe public health ond

"Coly. The",lore. the Boord

recommends that:

1. DOE devolop 6nd implement a

tdolcel managoment plan for Fornald

,wd .11 future ERt..1C Contracts. For
federal Register / Vol. sa. No. 106 I TuesdlilY. JW\o 6. 1993' I Noticc!s 32109

DEFENSE NUCLEAR FACIUTIES

SAFETY BOARO

IR_9~1

Improving DOE Technical C.pobllily In

Ilelenae Nuclear F8dlltle. Prog....m.

AGENCY: Dol..... NIic1.... F.clliU..

Sallty Iloud.

AC1lON: Notice: recommeadation.

_n..nef.....Nudov

FaclliU.. Safely Board (lloonI) .... m.d.

.I'OOOIIlIIIeIIdUan 10 tho saa.Luy 01

Enorgy P\llOlWlt to 42 U.s.c. 2286.

amcomlns Improvlos DOE TocIwical

Capobilily In Dor..... Nod.... F.cllili.s

n.. Board roquosts public

comments on this recommendation.

OATES: CoDUQents. data. views. or

ugwtIeots conc:enl.inB this

IeCOlIlIIUIIldaUon on duo 011 or·boro...

July e. Il1G3.

AIIOAESSE': send commen\S. data. views

or ugwtIeots """coining this

recommendation to: Defense Nuclear

FaclliUes SalltyBoard. 62S indiana

Avenu•• NW_ sull. 700, WuhI"8Ion;

DC 20004.

AlII RlRTHElIlICf<lRloIAnoH COHTACT:

1CeDIIeth M.PuAtlIri orCarol.,.

Cow>dl, at the .ddres$ above or

t.l.phon. (202) :ziIs..6l00.

Dot.of, , .....3. 1",.

JollaT.Coo"." QloIrmon. .

DOE TechalcalCapability in

Del NucJeuFadUii..

Dolo& , 1. t1Hl3,

EfIocI1ve functloalo8 01any

orpnizatiOll, wbechorIn~rinl. lOCtor or SOft'1lID'III\, II Y

d.pend.nt upon ~. copob UI. 01

poopll and thl ...y th.y are guided and

dlployed. Nowh_1s this alpend.ncy

mare auclaJ than iii tho Dopartmlnl or

·En.rgy'. (DOE)·dllollso nud....

complex. wh.... tho potlnUl1 huaros

inherent in nuclear materials

production, prooossiag. and

monulocturillg roqui;' hlgb qualily

lechnicol.xporUsolo "'.... public and

work.ersafety.

Nuclear weapons doyolopment end

production have progreiSed ovor tho

years (rom early erforts of a small group

of higbly tatontod. lngonioU$

individuals in sdonli£ic laboratorios to

employment of lhouso.nd$ of workers in

induslrilll·typ~ production

onvironmonlS. While tho nationol

rosponse to lodey's changing

inlemationfll scenD is resulting in down·

sizing of the nuch:lar- stockpile and a

change in mission or many of tho

dofense nuclear facilities. the need

remains for continuing vigilance to

protect public and worker health and

safety. In bct. • case can be made for the

need for greater vlglt.nco now

throughout the weapons complex

bocouse or: increased rlsI: 1equipmIni

mishaps in ag.d IocIUU loss 01

IXisUn& lochnicol exporUso Ihtough

.IIriUOlllDd downslzlng, and • reduood

Incllnotloo lor ,oUllS 1DgIn.." and

sci~tlststo SIIlnYOlvedIn tho lIuel....

_poll$liold..

NoverthelesS, th.I...101 sci.ntllic

ODd lochnlcol experUso Irt Ibl DOE·or

det.lISO nucl.... IocIUU.. ond operotlons

bas been doclilllng. Th. Dor......

Nucl..r FaciliUes Sor"y Iloard In its

lUI three OlInu.1 ...ports has o~erved

th.l:

• • • lhe ..ott Important aDd tu-roochIas

problem ,«ectio« the safety of DOE defeDH

o_lIdIIlles..lila d1t6<:ully 10 .1ItId1o&

oed 10lIIoI"8.,..-...1who an .dequaiely

queUliod by tducelloollld

expeM to pf'O'flde tha klDd of

INIrw.aemeol. dlndlon..ad SUldanOll

esseDt1a1 0_ to pl. OJ*'UoD of DOE"I deCeAJe lIdIItIes. . ,

Thl Board""; lIot boo:t a1on. In

coUIns .ttoOUOIl to the problllll.

CoJllP'OSSlonai porooptIon oftho lIeed 10

upgred. DOEteeboIcoI export1s.11

ovIdoot In tho Baud'sODIbUDs . \ogIaIIUOlI. Tho """" fa.r aueh upgrading Is lurtlior UlIil.r•.,....cl:by USISSIlIlnts

madl by. nUDibor ofolber group. over

tho past decadl, os thl .ttached ."""rpts

from Ib.ir reports Indicolo.

A reputaUan for teehnlcoI """"lI.nco

Is • atroos.ltraetiOll for tallnted

Individuals. OrgOllizaUOllS with strong

Iochnical mlsslollS commDllly dt. .

locImkal._UllIco os. goal towatcl.s

which llIIDogtlllOlltshlN14 SUI....

HowtMlr,sustalnocl.load.nhIp

amp....is ond d.Uberatl .ctlans....

required Utho rooIily of tochnlcal

l_lI.nco Is 10 be .ChiIVed.

Actions by th.1loud. such a.

recommendations and public bearings.

htIYe result&<! in some efforts on the part

or cert.in DOE organlutlon. and Mil<O

C:Onlne:tof$ to upgrado existiQg steff and

recruil bettor quaUlied personn.l.

However. such efforts havo f10t boon

coordaDllted DOE·wido and have been

w.lI short of the noed. Th. Boord

believes tJlet·o mo" aggressive. broad·

ba...cd. and wcll-<;oordinated progftl,m

directed 81lb(l enbanc~ment of t.he

technical capabilities o( the OOE staff

should be defined and implemented.

The Board recognizos tho difficulty

.ny ongoing orgeni~tion faces in

daveloping programs targeted at

up,:::radinC compe!cnc:o 01 stAff. Such

cfforts rarely succeed without s(rong

endorsement. invol\'ement. and

cuidane;., by tho orgnnintion's top

management and without L~e impetus

provided by objective appr.isal$ made

by outside. independent exports.

FW1her. tbe sheer lize. dHTering

requirements. And dispersion of DOE

st.ffcomplicates both the prob1em end

the solution. Nonotheless. Ute strong

correlation between technical

e"""Uenee OlId assuranco of public

h..llb and wily ""mpeis this Boord 10

thel DOEgive high priority 10 tho

probl.ai of.ttractlng and rotalolilg

lechllicol persoDD.1 willi .xcaptlanol

qu.U8catiallS. Mor••poclli","lly tho

Baud """,mmends thot DOE:

1. EstabU.b thl attrilcUon and

reLention orJdenU5c: entltechnleal

personnel of exce~onltqualities as a

prilllary aglllcy.wldl gool.

2. T.\e lb, following specific actions

promptly in tho Inl.resl or .chi.ving

this goal.

L'Seek excepled 'ppointm.nt

.utharlly lor ...Ioct.a numbor or key

poslUons for engineering -.nd scient.L6.e

ponDDD.11rt DOE programrooUc officos.

In other lin. UlIits, and In tho overslgbl

units ....pollSibl. lor tho d.l.lISIlIuel....

complax.

h. Establish. technical ponDDDol

maoogor wlthilIthe Ollico 01 tho

SocroLuy to cocirdlDal. rtCruItmOll\,

duoi8cotlOll, tra1D.IDJl, and quo1lllcaUoll

programs for tocbDIe&l pelSODlI.11n a.rense lIucleor UciIlU..Prograll\S.

3. DovaIap. broadly hUed program,.

g1~g consldl..Uo!' 10 thl followlllg:

L·DOE1lItomalIrtlU.Uv..

(I) Dowlop.set oflIlutUlUy

.upporUve sctlon. which DOE could

tak., wlthilI _ngparsow>.1

Otructures,lci OlIhuco capiblUtI••.

MouunsIbol could bo collSldl...d

Includ.:

C.) Plan ond .xecul. I syst.m lor

using .IIriUon to bolld lechnical

co~blUly.

Ih) Ravi.w tho PltfOrmaooe appraisel

.yst.m lor leclmicallmployoos lor lIs

eUectlveness in determining baslc pay.

traioiDg heeds. promotioDs. r6duCtions

in grade. and reasslgnmentlreinove1.

(c) Review and improve programs ror

In<ining and .sslgnlng lechnlcol

personnel. {This activity would M

coordinated with actions takan. planned

to be laken. in response to Doard
nll0 federal Regisler I Vol. 58. No. 108 I Tuesday. Juoe 8. 1993 I Notices

Rocommcn~tions90-1, 91-6. 92-2.

and 9Z-7.}

(d) Explaro with tho SCCrtl'o'Y of

Defense the possibility of aS1:igning 10

DOE dOrODSe nuclear facilities aeti",itiOl;;

o numoor of outstanding oCfico~ with

nucloa.{ qualification, who muy no"' be

surplus to 000 Doods.

(v) Establish initiativtlS desigo~ to

ta~e lldvBl'lttl.g8 ofskills of marginal .

tcchnial pe:r(onners and retrain them.

In Expand Headquanorslfiold

pononn.toxchanC. progum.' 10' highly

qu.Ufied IWlior technical st.llto

promote understanding of .1I.~pect.s of

tocbn!catlssueslocludillg thol,

resolution.

b. Ind.pondeot Ext....1Assessments

(1) U..respec:ted,lndopondeot. extamaI__tio..ouch ..the

NaUoaal1Weat:llCouilc!I oftho

NaUow Academy ofSc:Ieooos. and 0..

Natioaa1 Academy ofPubUc

I\dmlnlstreUon to assess DOE"I oDgoing

and planDed acti.... direcled al

attraC11D8 and ..aIDIll8 ~OODel witb .....og lecImIca1 capahiUti.. and 10

lUke recodUXleDditions for

enbA"O"D1ents. Such as:ses.sment could

include:

(a) Go_anl·wid....dlor DOE

peISODDOtrecruI1Inent and development

policiesmel pnction that may be

ellecUv. Inducemeolll to gaverum.nt ...,,1....

lb) CoII\porioon of DOEm.thods 01

bulld1lls. qua\lfled """'Dleal ataff with

qualllieaUnns COIIlpanbl.\O thOM of

other gov&r1IIZIOnt agencies wltb

pndom!-"t'ocboleal misslooo.

Co DOElntemalAIS ro«ltt

(1) Parliarm an JiHI.pth ........ent of

educaUow aad uperIonce

nqulrem....ofby positions and

develop beth.short-term and Ioag-t.nn

plan for by'ponoon.1 devolopment.

Sucb .......ment could Include:

(a) Id""Ufieatina oJqualifications

(education and exportanea) nqubed In

key posItlons (ebcm GS-1411n DOE

Heedquaroa and 6.ldClIllanlzetlons

.with l'<lSPOIISIb!Uti.. for _Iyconylng

out the clef...... nuclear prognm.

lb) Evalualion of1Dcwnbtin.. for their

abIlity \0 meetsuch qualification

.,uinlmc... c) Evaluation of cunnI avalLablUty

withID DOE of fully '1uaUfted penonnel

10 fill tho.. positions.

(2) Develop aa action plan to meet

needs thu.s Identified.

fob.a. T. Couw.,.

ChojlTDdn.

Appeodt.-t..nert. ~tUfof EneraY

funClI.l99J.

The Hooonroble Huel R. 01..ocuy.

Scaotaty OrED~. \'Yasbingtoft rx: 20S0S.

Our Soat:t.ary O'Leuy; 00 'une I, \993.

the OCfenso Nuclear P_dlltJes Safety 8oud.

in IoCCOrd.1\OI with 42 U.s.c. %Z86a{~).

unanimoudy approYed, RJooommea.datioll gJ.-

J oN bic.b iUDC~oscd (or)"OUt CIOAsl.dc:.n.tioQ..

ReconullcndltlOu g3-3 deals witb.lmproving

OOE Technical C.pabitity iQ Defcll$~ NUf;Iu,r

rae-IIIlles rt'rogrllnu.

41 U.S.c. 2286d(al ~uire:s Lhe OQud. loner

receipt by you. 10 pfGmplly roake this

roconuncndatl"n 'vall.bl. to the public 11'1

Ihe Der,~.mCOI at EPOfIY'. resknl.a1 public

rAdiq rooms. Th. 80vd bel...... the

recc)(:unendatloo c:ool.&i.u DO lAfomu:l1oa.

which is du.sJfied Of otHIwu. ratrided. To

the extent th1s teOOmPW'MbtiOA doa not

include lDformalioll ralricted by DOE UDdCl

the Alomic EDet&r Ad. of IOSI. 42 U..$.c.

211'........ ameAde4. plo&M maQlelO U"'O

thia i dlnoa P'~~plaoed. 011 rue

i.JOW' ......... 1lUl>11c IODDIS.

wIII plablltb uu.

III thoor roolenl ........ S y.

/DlmT.COoway.

QoUmon.

Ilnclorun

I.cfcraIc.I)oot'U:taU IdaadfJtrl& DOE T<dmIcaI .....oad._

I. "ASofdT" _·o/~,./

EMrgNudoor 1I<oa<t«>." OOBlUs-<1OO•• Uan:.a, 11$1'

AD ............~_,tolbo

lock01adoquaIaaU...u.loy DOll IIoaclquateni·_1.._. "'tho Duel...

..rely upecli 01 iU _IIItha lad. or

nffidtPl iIIumber1 or~shJ1 competODt

todul1C11pooplo III Hoodoia<pJI1Ztt1aoswllb...-0If0ty

l'OSpo1lSibI1Ill'le1d0IIl00 0IpDlrI1.... .ba -._ uu.1ock.

1. Nalioaa/Ib;-udo e-.:IIlteparu

ReodotI. n.

.. "S4/«T,-", ..Noilaaal.1""hlJtI,/eIIM-- ij 2941. CIIallll1_ " tho

Iloputmo,j~ balb a aa41ll111

6.[d~......iJed_...l1noly

OClIII COD""""" to IdoatIfyAfoty..,..,.".

.ud \0 NCO'iII Ml tppIOpda\lt fldkms.1Il

port boca_tho imbOloaOo III toe:IlIllcoI

eapobWUu ODd -""'"""-tho

m._ODd DOll_isofoulIlcIeat

mopllad. la pncIuda DOIl_

coeDpi' b I" bOB bhuh t In tho

opentlolloltbe p,,,d..,lI••lI_.n •

ClOIDIillUee" . _tit that tbe Det*bDt:a1

""'..... ODd Jl'OpOdY-'!ID tho-....

&ad ta"'I"""'""1 la........thot..r.

.perolIaa II bolas &Uo1Dod.

b. "So/dyIu...olllwr DOIlTest <tAd

~oa." NCllional Acodemy

Preu. .SU.

The sultabUitY01 the P1oU"8IOOE

olpDIZltkJoatJ UQ.DgeDI,ot II undlllTDined

by abMDOlli of adequate atatt 1D; tM DOE

liD' men'8lDODt,.bo ani IOPhLtUcated on

Nfety mad opm-aUooal mattm· • ·.In

elTaet.. tb••,lIeDl ,.UN I&lmori exclusivel, 00

the skills &Od compotellOl ofthe COlltnelOrs.

c. "TIle NucC«u Wccpons Complex.:

Managementlor Hcolth. Safety. dnd me

Environment." Notional Acoddmy Press.

1989.

Conslanl allen lion must bo paid to the

maintenance and improvemen' of technical

ClPll.bilities. Contortod cHorts, 1m needed 10

rCCl'\Jit comre\CI\IICCnl\ical pOIs-onnel at all

Icyels; and 00£ must rnll.ln:ain an

cnyironmCtll fOr the retention (If emplo)'ccs

tJy pwy[d1rtS challonging aSliisnmcnlJ.

mcanirtr;rl,ll participation in decisiOrt making,

;'jolt prnfcssionlt advanCenulitt. Suong

'r<lining proRnllms arc "«CUll")' to build a

culture ill ,... hich hoalth. safely. and

envirOllmental consider<ltions ate leen as an

integrAl COMponent of operations,

J. Sccrt:(ory ofEnergy LeHer 10 the President.

Ckc~mber 10. 1991

.. .. .. The lecllnlcal knowledge and .kills

of many DOe raaGlgcn and employoes are

no' sufOclent to do lbelr lobs.

4. S. Conf. Rep. No. 232 (to occomptJny S.

l08S). lDOlh Cons.• lit San. IU'l}

n. Boud Is oxpec:tod ,.ratse the

.ecIlulCllI expedlso 01 tho DoputJDeot

lubslUlltlllly. to assist aDd monitor the

continued. dl!¥ol~t ofDOE"stn'oma1 ~H OIpQlatloD.o and to pfOvlde

independent advice to ~e Secntll'}'.

S. A.dv~~ CDaur';ttee Dn Nuclror FocUity

So/~ty (-Ahrome CDmmiftn") Utler 10 the

Secretoryo/J:netIY. Man:h 24. '''9.

We ~nd that you atnwnUoe

milR&8emeot to make ntSpoo.t\bUlUes clear.

!hoI you pu' kaawlO<1seabl. peopl.lo Un.

poslUollS ofrtSpOGJibUlty. Ud that you siva

lbem aUlb.rlty. 'IbIs IIlmportonl lor u ....._ 01 ouel_..!ely. Sol.m, tho

1lOE". probl.... wiD 19qIIUe uppe'

manqc.mont and OpeRtlDg penoaaellO

work tOStlthetdosely aad efffJdively.This

wUl not be poulble tr OM ItIfflPU.Jt work

throu.sh bua.rs ofpeople who are 'Dot

techA1cal1y mropeten-'

6. "Hoz=h Mead: ",~a"""up

lVorloer HeoIrIt GIH! Sofety'" liteNud"'"

WOOpallS C'.Dmp/""" Off"'" o/Todmology

Aa-......~.99J

EM· • • laCb adequate aumben of

quaUUad .taIlto _lop occupatlanol bea1lb

and sar.ty prctgrt.mllUlted to EM UDe

0l*ll.tloOt: aDd h.. UtUe Qpiclty 10 assess coatractar's perfannaaCllID bNlth and ..r..,.

matleh.

nollOE omce or Euviroam.o~sarety

&Ad Health (EH) cSoea not have C1DQU8b

quo1l6od staff..moollar_In""" operaUODS.

IFR tloc. U--134n filed ....7...3: .:45..,1

.......<00<-.-...