NINTH ANNUAL REPORT

TO CONGRESS

DEFENSE NUCLEAR FACILITIES

SAFETY BOARD

FEBRUARY 1999
John T, Ccnw;r,y. O\.JirmiJn

AJ. Eggc:nbc:rgcr. Vice Chairman

Joseph J, DiNunno

Herbtl1 John Cecil Kouts

John E. MilnSrlC1d

DEFENSE NUCLEAR FACILITIES

SAFElY BOARD

625 Indiana Allenue. NW. Suite: 700. W"shinglon, D.C. 20004-2901

(202) 208-6400

February 26, 1999

To the Congress ofthe United States;

The Defense Nuclear Facilities Safety Board (Board) is pleased to submit to Congress its Ninth

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

advice and recommendations to the Secretary of Energy regarding public health and safety issues at

Department of Energy (DOE) defense nuclear facilities, and to the President if necessary.

During the Board's nine years of operation, DOE has been subject to numerous changes in its

top leadership. Seven Secretaries or Acting Secretaries have served in that cabinet position. Also six

different Deputy or Acting Deputy Secretaries (a seventh has been nominated) have been in office and

seven Under or Acting Under Secretaries have filled that office. Notwithstanding the inevitable

disruptions and uncertainties that accompany such changes, DOE personnel responsible for nuclear

weapons and defense nuclear facilities and their contractors, including the National Laboratories,

continued to move steadily forward in DOE's progranl for improving safety management.

As required by statute, the Board's report summarizes activities during calendar year 1998,

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

problems.

While much has been accomplished, more needs to be done. TI,e Board has played a vital role

in this upgrade effort and in maintaining the pace ofthe path forward. Many ofDOE's missions entail

dIe use of hazardous materials. We support Secretary Bill Richardson's strong commitment to the safe

handling of d,ese materials and his support ofintegrated safety management in protecting the health and

safely of dIe public, workers, and the environment.

The Board's core efforts during 1998 focused on institutionalizing sound integrated safety

management practices and dteir implementation in design, construction, operation. and

decommissioning of defense nuclear facilities. Priority attention and effort wete devoted to activities

involving the greatest risks to public healdl and safety. TItese are reported in detail in this report.

;;John0f"ft~1 .fu':way

Chaimlan

~f ~J;w".tD t1J;S~;~J ~~o Member

Respectfully submitted,

~.~ Vice-Chairman

Herbert J. C. Kouts

Member
v

PREFACE

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

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

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

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

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

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

during the period covered by the report;

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

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

Board; and

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

facilities.
vii

EXECUTIVE SUMMARY

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

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

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

been increasingly evident at defense nuclear facilities.

DOE’s defense mission associated with stewardship of the nation’s nuclear arsenal

remained a prime effort during 1998. In addition, DOE continued to emphasize its ongoing work

to stabilize hazardous materials remaining from previous operations and the decommissioning and

decontamination of highly contaminated nuclear facilities. The Board gave priority attention to

DOE’s safety management of these major DOE activities.

Highlights of the Board’s principal efforts in each of these areas during 1998 were as

follows.

Complex-wide Health and Safety Issues

! Staff reviews, interactions with DOE, and the Board’s public meetings helped DOE

make progress in the implementation of sound integrated safety management (ISM)

programs at priority facilities and sites in response to the Board’s Recommendation

95-2:

– As a result of the Board’s December 1997 reporting requirement upon DOE, DOE

and its site contractors evaluated the status of ISM at facilities beyond those

initially selected for priority implementation under Recommendation 95-2. Many

sites reported that a beneficial outcome of this effort was that it revealed areas

needing improvement.

– At the Board’s urging, authorization agreements for the original 10 facilities

considered priority under Recommendation 95-2 were developed and signed; an

additional 43 facilities have been added to the priority list. In all, 44 agreements

have been signed. The Board commends DOE for this progress.

! During the past year, the Board has maintained its momentum toward accomplishing

congressional mandates to review and evaluate the content and implementation of

standards related to the design, construction, operation, and decommissioning of

DOE’s defense nuclear facilities, and to recommend to the Secretary of Energy those

specific measures that should be adopted to ensure that the health and safety of the

public and workers are adequately protected. The Board’s staff formally reviewed 45

new or revised DOE safety directives and supporting documents. As a result of the

Board’s reviews and interactions, DOE substantially improved the content of those

safety directives.
viii

! The Board and its staff conducted specific reviews of DOE organizational documents

(e.g., Manual of Safety Management Functions, Responsibilities and Authorities,

DOE M 411.1-1); DOE’s efforts to recruit and retain safety management staff of

exceptional quality, education, and experience; and operations at DOE Headquarters

and in the field. Examples include the following:

– The structure of DOE’s program for responding to the Board’s Recommendation 

94-1 failed to identify cross-cutting authority and resources to provide adequate

direction for the program. In response to a December 1997 letter from the Board

on this subject, the Deputy Secretary assumed responsibility for resolving

complex-wide integration issues.

– The Board’s reviews revealed that the safety roles, responsibilities, and interfaces

between DOE and its contractor for the Capability Maintenance and Improvement

Project at Los Alamos National Laboratory (LANL) in New Mexico were not

clearly defined. In response to the Board’s December 1997 reporting requirement

on this matter, DOE and LANL management initiated key organizational changes

and have made a commitment to resolve the issues identified by the Board.

– In January 1998, with the Board’s support, DOE’s Richland Office was granted

authority to hire 25 additional well-qualified technical personnel, including

excepted service billets.

! The Board’s staff provided oversight and technical assistance to DOE in identification

and assessment of the effects of the possible introduction of suspect/counterfeit parts

and semiconductor devices in national security and other applications. For example,

the staff:

– Spurred DOE to thoroughly inspect and technically evaluate possible applications

of suspect/counterfeit semiconductor devices in applications which could

compromise safety in national security applications.

– Provided the impetus for DOE to formalize and institutionalize procedures for

notifying activities of the possible introduction of suspect/counterfeit parts into

DOE applications and to evaluate the technical consequences of possible

nonconformances.

– Spurred DOE to formalize responsibilities for matters relating to suspect/

counterfeit parts.

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

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

ensuring public health and safety at DOE’s defense nuclear facilities.
ix

! Reviews conducted by the Board and its staff determined that line management’s

resolution of health and safety issues raised during evaluations by the DOE Office of

Independent Oversight was often unresponsive or incomplete. The Board’s

Recommendation 98-1, Integrated Safety Management, called on DOE to take

additional action by establishing clearer lines of authority and responsibility for

resolution of the safety findings of its internal, independent safety organization. In

November 1998, DOE accepted the Board’s recommendation and at year-end was

working to develop an associated implementation plan.

Management and Stewardship of the Nation’s Stockpile and Nuclear Weapons

Components

! The Board assisted DOE in improving the safety of Enriched Uranium Operations at

the Y-12 Plant in Tennessee which led to the resumption of initial operations in

support of a high-priority national security task. The Board helped DOE in upgrading

system designs and in improving identification of safety controls, implementation of

controls, and coordination between operations and maintenance personnel.

! The Board determined that the overall program of work planning and safety planning

that had been developed by DOE for nuclear explosive operations at the Pantex Plant

in Texas, partly in response to the Board’s Recommendation 95-2, had been structured

in such a complex manner that it was beginning to be undoable. As a result, the Board

issued its Recommendation 98-2, encouraging DOE to seek simpler and more

pragmatic ways of providing the necessary assurance. These were to ensure that the

responsibility of line management in DOE and in the contractor’s organization would

function properly, with the responsibility for safety flowing with the responsibility for

the work. DOE is progressing with changes in accordance with the Recommendation.

! In response to a 1997 Board initiative, DOE identified and implemented many

additional protective measures to prevent or mitigate the threat of lightning to nuclear

explosives at the Pantex Plant. These improvements included bonding metallic

penetrations to facilities, installing surge protectors, and providing other electrical

isolation.

! During the last year, the Board placed considerable emphasis on the safety

management program at the Chemistry and Metallurgy Research (CMR) Facility at

LANL. As a result, LANL reorganized its line management structure, revised the

facility safety management system, and completed a rigorous activity resumption

process. CMR is now operating with greater assurance that safety requirements are

being met.

! The involvement of the Board and its staff throughout 1998 in resumption activities at

the Plutonium Facility at Lawrence Livermore National Laboratory in California

spurred DOE and the laboratory to improve the facility safety management process
x

 significantly. Most specific operations resumed after implementing improvements such as

upgraded procedures, improved safety controls, clarified responsibilities for safety functions and

systems, and upgraded training of employees responsible for handling nuclear materials.

! The Board’s ongoing effort to improve the safety of nuclear weapon dismantlement

operations continued in 1998. The W69 dismantlement program, the first operation to

undergo the full Seamless Safety process (developed in response to Recommendation

93-1, Standards Utilization in Defense Nuclear Facilities), exhibited not only

significantly enhanced safety features, but also an accelerated productivity rate. The

last W69 nuclear weapon was successfully dismantled on October 21, 1998, well

ahead of schedule. The Board also supported the safe start-up of the W79 nuclear

weapon dismantlement operations in June 1998 by helping to identify and resolve

several safety issues concerning the flammability of the solution used to dissolve high

explosives, controls for the hot water heating system, ignition sources (particularly

electrostatic discharge), combustible loading and fire protection, documentation of

controls, and change control.

! In 1998, DOE responded to an earlier inquiry from the Board concerning the

suitability of the bays in Building 12-64 at the Pantex Plant for certain nuclear

explosive operations by declaring that the W69 campaign would be the last nuclear

explosive operation for these bays, other than weapon staging in sandbag bays. The

bays in Building 12-64 are the oldest bays used for nuclear explosive operations in the

DOE complex, and they have been determined to have some potential safety and

operational deficiencies.

! In December 1997, the Board issued a classified report, Surveillance of Nuclear

Weapon High-Explosive Operations at Pantex, which emphasized that DOE should

consider making improvements in some elements of the surveillance program, such as

increasing the high explosive sampling frequency for weapons awaiting dismantlement. 

In 1998, noticeable improvements were observed in the surveillance program in some

of the areas highlighted in that report.

Hazardous Remnants of Weapons Production

! The Board’s Recommendation 96-1 questioned process safety at the In-Tank

Precipitation Facility at the Savannah River Site (SRS) and urged DOE to defer

operations until more thorough research could better demonstrate the safety of the

process. In 1998, the results of this research (which had been closely monitored by the

Board) led DOE to stop preparations for restarting this facility and to pursue

alternative technologies. The Board’s staff is actively monitoring the screening and

selection of these alternative processes, to confirm that a technically sound and safe

process is selected.
xi

! In response to a series of Board Recommendations (94-1, 94-3, 97-1), DOE has

committed to the stabilization and safe storage of a broad spectrum of radioactive and

chemically unstable residues and transuranic materials. At the Board’s request, DOE

developed a revised implementation plan for Recommendation 94-1 to reflect current

priorities. Some of the schedules presented in the revised plan remain unnecessarily

drawn out, and the Board will continue to apply considerable effort to ensure DOE

attacks these problems aggressively and remediates hazardous conditions as

expeditiously as possible. Under the close safety oversight of the Board, DOE has

begun correcting hazards in the following areas:

– At the Rocky Flats Environmental Technology Site, drained and processed the

remaining solutions stored in tanks; stabilized the first 2 metric tons of plutoniumladen salt residues; repacked more than 4 metric tons of plutonium residues into

robust pipe overpack containers; and made significant safety improvements to the

structure, systems, components, and operations at the site’s principal plutonium

storage facility (Building 371).

– At SRS, restarted the HB-Line to begin stabilization of plutonium scrap; restarted

solvent extraction operations in H-Canyon to stabilize spent nuclear fuel; started

repackaging plutonium metal in the bagless transfer system in the FB-Line; and

completed the dissolution of Taiwan Research Reactor spent fuel and the SRS

inventory of plutonium-bearing sand, slag, and crucible residues in F-Canyon.

– At Hanford, conducted an extensive program review to identify alternatives for

improving the plutonium stabilization schedule at the Plutonium Finishing Plant. 

This activity was undertaken in response to a reporting requirement that was

issued by the Board in 1998 after reviews by the Board’s staff and public meetings

held by the Board determined that DOE was not aggressively pursuing means to

accelerate Hanford stabilization activities.

– Completed initial site assessments to begin characterizing the hazards of uranium233 storage at Oak Ridge National Laboratory (ORNL), Idaho National

Engineering and Environmental Laboratory, and Los Alamos National Laboratory;

initiated construction of characterization facilities for uranium-233 at ORNL; and

issued a draft version of a safe storage standard for uranium-233.

! DOE has made substantial progress in the sampling and characterization of the highlevel waste tanks at the Hanford Site, in response to the Board’s Recommendation 

93-5, Hanford Waste Tanks Characterization Studies, and continued active Board

oversight. Of the 177 tanks, 139 have been sampled and analyzed, leading to a

significantly increased understanding of tank safety issues. In particular, the hazards

arising from potential burning of flammable gases within the waste are much better

understood, and upgraded controls to prevent and mitigate such burns have been

implemented.
xii

! The Board and its staff continued to spur improvement in DOE’s design and

construction projects through reviews of the early stages of the work. Examples of

the results of such reviews include the following:

– Shortcomings were identified in the Spent Nuclear Fuel Project at the Hanford

Site, including a hydrogen explosion hazard in a battery room; the lack of sound

project management; and an inability to address emerging technical issues in a

timely manner, which was delaying the removal and stabilization of the

deteriorating fuel. Continued Board pressure through correspondence, project

reviews, and public meetings led DOE to address safety hazards, streamline the

project’s organization, and resolve issues associated with the design and

fabrication of the primary containment vessel for spent fuel storage.

– The scope of the geotechnical investigation for the proposed Actinide Packaging

and Storage Facility at SRS was found to have insufficient coverage for the final

siting. In January 1998, the Board successfully encouraged DOE to expand the

scope of the investigation in order to confirm design inputs and resolve other

safety issues associated with the condition of the soil at the site.

!. Reviews by the Board’s staff of DOE’s readiness to perform hazardous operations led

to improvements by DOE at several facilities. For example:

– The Board’s staff completed reviews of the Waste Isolation Pilot Plant (WIPP)

and evaluated its readiness to operate safely. These reviews contributed to

improvements in the formality of conduct of operations and in the quality and rigor

of the WIPP safety basis. Based on these reviews, the Board transmitted a letter

to the Secretary of Energy on June 3, 1998, stating its belief that: (1) WIPP can

be operated safely, and (2) start-up of waste disposal should commence as soon as

practicable, so that the backlog of transuranic wastes at defense nuclear facilities

can be dispositioned.

– The Board and its staff identified issues regarding the readiness to perform

hazardous work in several facilities at the Hanford Site. Though improvements in

Operational Readiness Reviews (ORRs) by the contractor and the DOE-Richland

Office were observed by the Board’s staff, more progress was seen to be needed. 

This observation led the Board to issue letters in April and June 1998, alerting

DOE to the problem.

! During 1998, the Board led DOE to improve the safety of deactivation of former

defense facilities by applying the tenets of ISM. For example, the Board’s staff:

– Identified vulnerabilities in Building 9206 at the Y-12 Plant, including the 

potential for a chemical reaction or explosion, inadequate characterization of

contamination in the ventilation systems, and the potential for spills of highly

enriched uranium during a natural phenomenon event. As a result, DOE
xiii

developed a plan for eliminating or reducing the backlog of combustibles and to

determining actions needed to reduce vulnerabilities associated with the highly

enriched uranium.

– Identified issues regarding the readiness to perform hazardous work in the 233-S

Plutonium Concentration Facility at the Hanford Site. While improvements in

contractor and DOE-Richland personnel were observed during the past year as a

result of staff interactions, more progress is needed in this regard.

This Annual Report also contains a summary of the Board’s response to a provision of the

National Defense Authorization Act for fiscal year 1998 that required the Board to prepare a

report and make recommendations as to the future role of the Board should Congress consider

legislation for the external regulation of defense nuclear facilities (see Section 1 of this report). In

its response, the Board concluded that external regulation of DOE defense nuclear activities could

have an adverse effect on national security, would increase operating cost, and would have little

or no improvement in safety or DOE’s credibility with the public.
xv

TABLE OF CONTENTS

Section Page

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

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

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

1.3 External Regulation of DOE’s Defense Nuclear Facilities ................ 1-7

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

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

2.2 Institutional Safety Management Framework and Implementation ......... 2-4

2.3 Raising DOE Technical Competence Complex-wide ................... 2-21

3. MANAGEMENT AND STEWARDSHIP OF THE NATION’S STOCKPILE

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

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

3.2 Stockpile Stewardship of Nuclear Weapons .......................... 3-13

3.3 Defense Programs-wide Topics ................................... 3-17

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

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

4.2 Stabilization of Spent Nuclear Fuel ................................ 4-9

4.3 Storage of Hazardous Materials ................................... 4-11

4.4 Waste Management ............................................ 4-15

4.5 Deactivation and Decommissioning ................................ 4-20

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

5.1 Personnel Recruitment .......................................... 5-1

5.2 Official Site Visits by Board Members and Staff ....................... 5-2

5.3 Inquiries into Health and Safety Issues .............................. 5-2

5.4 Public Interaction with the Board .................................. 5-4

5.5 National Partnership for Reinventing Government Objectives ............. 5-5

Appendices

A. BOARD RECOMMENDATIONS 98-1 AND 98-2 .......................... A-1

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

1. INTRODUCTION

CONTENTS OF THIS SECTION

Section 

Page

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

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

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

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

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

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

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

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

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

1.3 EXTERNAL REGULATION OF DOE’S DEFENSE NUCLEAR FACILITIES ..................... 1-7

1.1 BACKGROUND

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

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

October 1989 with the swearing in of the charter Board Members, three of whom continue in

office. To help ensure adequate protection of the health and safety of the public and workers, the

Board is empowered to oversee DOE’s programs for management of the health and nuclear safety

of defense nuclear facilities. The Board believes its greatest imperative is to ensure that DOE

safely carries out its mandate to maintain the nation's nuclear weapons stockpile.

1.1.1 Board Responsibilities

The Board is responsible for independent oversight of safety management by DOE of all

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

numerous nuclear weapons while maintaining the remaining weapons in the stockpile in a safe and

reliable condition, and in the conduct of research to ensure the continued safety of DOE's

stewardship of the stockpile. DOE also pursues safe disposition of fissionable material removed

from dismantled weapons and of hazardous material remaining in facilities that abruptly ceased

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

are associated with characterization, stabilization, and safe storage of special nuclear materials;

facility deactivation; and safe handling of radioactive wastes.
1-2

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

and analyze facility and system design, operations, practices, and events, and make

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

public health and safety. In making recommendations, the Board must consider the technical and

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

Congress if implementation of a recommendation is impracticable because of budgetary

considerations. If the Board determines that there is an imminent or severe threat to public health

and safety, it must transmit its recommendations to the President and Congress, as well as to the

Secretaries of Energy and Defense.

1.1.2 Powers of the Board

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

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

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

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

of defense nuclear materials and attendant nuclear waste streams, while providing adequate

protection of worker and public health and safety. Congress was aware that the safety policies

and standards issued by DOE needed upgrading, and that operations by DOE and its contractors

had in the past left extensive residual contamination in buildings and their environs. Congress also

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

the continued development of DOE’s internal Environment, Safety and Health organization.

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

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

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

contractors at defense nuclear facilities to give the Board their full cooperation.

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

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

law explicitly directs the Board to review and evaluate the content and implementation of health

and safety standards, including DOE's Orders, rules, and other safety directives pertaining to the

design, construction, operation, and decommissioning of defense nuclear facilities. The Board is

also required to recommend to the Secretary of Energy any specific measures, such as changes in

the content and implementation of those standards, that it believes should be adopted to ensure

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

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

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

protection of the health and safety of the public.

1.1.3 Avoidance of Interference with DOE Functions 

The Board recognizes that DOE must perform its essential national defense work without

unwarranted delay. The Board has been able to keep its safety reviews synchronized with DOE 
1-3

activities by timely assignment of its staff to monitor and review work involving design,

construction, or preparations for readiness to operate, operations, and decommissioning. The

technical staffs of the Board and of DOE and its contractors frequently resolve technical issues

that arise during these reviews without the need for formal action-forcing measures by the Board. 

If the Board identifies safety issues that must be resolved before work may proceed, it can, and

frequently does, formally define those issues and recommend that they be resolved by DOE. In

the case of operations at the Rocky Flats Environmental Technology Site (RFETS), Congress

required that before plutonium operations are resumed in specified buildings, the Board must

determine to its satisfaction that DOE’s response to specific recommendations by the Board

adequately protects public health and safety.

1.1.4 Formal Mode of Communication

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

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

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

considers to be advisable solutions and as required by law are made public immediately after

receipt by the public. The Secretary may reject a recommendation, requesting the Board to

reconsider. However, to date no Secretary has found cause to do so. Following the Secretary’s

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

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

planned actions have been completed. To date, the Board has issued 38 sets of recommendations

containing 174 specific recommendations. DOE has completed the majority of these

recommendations and is making progress in implementing the remainder.

1.1.5 Nature of the Board’s Work

The Board's primary function is to assist DOE in upgrading its program for safety

management of its defense nuclear facilities. The integration of work planning and safety planning

is a fundamental objective. The Board remains closely attuned to the planning and execution of

DOE’s defense nuclear programs, gathering information from a broad range of sources. These

sources include, but are not limited to:

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

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

Board, its staff, and competent technical experts;

! Public meetings at Board Headquarters and in the field; and

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

that are placed on the public record.

The Board has optimized its resources by assigning Site Representatives to five highpriority defense nuclear sites. In addition, extensive travel by the Board and its technical staff to
1-4

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

mission.

In order to remain better informed about DOE’s activities and initiatives, the Board also

receives regular briefings by senior DOE officials. Information obtained by the Board from these

briefings is used to keep the Board’s oversight activities synchronized with DOE’s priority

programs, to gauge progress being made on safety, and to monitor upgrade programs to which

DOE has committed.

Based on the information gained through the above sources, the Board chooses from the

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

observations and to promote appropriate DOE corrective actions. These action-forcing

mechanisms include the Board’s recommendations to the Secretary of Energy (in the case of an

imminent threat to public health and safety, recommendations would also go to the President and

Congress), requests for reports from DOE, public meetings or hearings, technical exchanges and

issuance of technical reports, investigations, and testimony to congressional committees. In

addition, the Board often transmits reports prepared by its staff to DOE, thereby sharing the

staff’s observations and findings.

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

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

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

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

counterparts to ensure that the staff is able to brief the Board on the status of safety issues and

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

and initiatives. This type of direct interaction conserves federal resources by ensuring that DOE

and the Board understand each other’s positions in depth. This understanding, in turn, permits

the Board to focus its recommendations, letters, requests for information, and public meetings and

hearings on the most important health and safety issues to be addressed. It averts the waste of

resources of both DOE and the Board on false starts and contention over easily resolved sideissues. In many cases, the simple exchange of ideas is sufficient to motivate DOE to take

appropriate actions without the Board having to make formal recommendations.

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

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

[NRC], the General Accounting Office, Office of Management and Budget [OMB], the

Department of Defense [DoD], and Environmental Protection Agency [EPA]), as well as outside

agencies (e.g., National Research Council and National Academy for Public Administration). 

Such interactions facilitate the exchange of knowledge, experiences, and factual information on

matters of mutual interest with regard to the safety of DOE defense nuclear facilities.

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

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

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

open forum have proven to be a powerful, cost-effective tools for advancing the Board’s nuclear
1-5

safety initiatives. The Board held eight public meetings in fiscal year (FY) 1998, each of which

involved substantive interactions with senior DOE officials.

1.2 BOARD’S STRATEGIC PLANNING

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

requires federal agencies to develop strategic plans. These strategic plans are to include

articulation of the agency’s mission statement and goals, as well as proposed methods to achieve

the goals. The first edition of each agency’s five-year strategic plan was to be submitted by the

end of September 1997. Furthermore, starting with FY 1999, agencies are required by GPRA to

submit annual performance plans to OMB that establish target levels of performance for program

activities. 

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

actual achievement can be compared against the targets. Agencies will be required to report their

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

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

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

goals. 

1.2.1 Board’s Planning Goals

The Board has developed seven general outcome goals that describe the intended effect or

consequence that will occur as a direct result of its oversight activities. Using its action-forcing

powers, the Board seeks to effect the following goals:

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

assured.

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

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

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

technically and economically feasible measures to address these hazards.

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

established that incorporates recognized good nuclear safety practices and allows for

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

DOE’s hazardous defense nuclear facilities.

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

hazardous work associated with defense nuclear facilities.
ISM is the means by which DOE is institutionalizing the process of incorporating into the planning and 1

execution of every major defense nuclear activity involving hazardous activities those controls necessary to ensure that

environment, safety and health objectives are achieved.

1-6

5. Integrated safety management (ISM) programs will be implemented for operations at

defense nuclear facilities, with processes and controls tailored to the hazards involved.1

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

standards.

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

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

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

FY 1999 and beyond. The Board focuses its actions on those activities and facilities that have

reached a development stage that is best suited to constructive safety oversight, and on those

operations where safety improvements have the greatest potential for risk reduction. 

1.2.2 Board’s Strategic Plan

In accordance with the requirements of GPRA and OMB’s guidance, the Board issued its

first strategic plan in September 1997. That plan discusses the Board’s mission and Congressional

mandate, the nature of the Board’s work, the Board’s planning assumptions and external factors

with potential impact on planning, and the oversight principles and general goals under which the

Board’s oversight mission is conducted. In addition, the plan identifies the Board’s three strategic

areas of concentration for the period of FY 1997–FY 2002 to be: 

! Complex-Wide Health and Safety Issues;

! Management and Stewardship of the Nation’s Stockpile and Nuclear Weapons

Components; and

! Hazardous Remnants of Weapons Production.

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

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

aggregate, will support the implementation of the Board’s general goals, as noted above. As

required by GPRA, the Board and its staff further refined their planning efforts for the FY 1999

and FY 2000 budget requests to produce measurable performance goals that, when executed, will

demonstrate progress toward the Board’s strategic objectives in each focus area, and

consequently toward its general goals. The first GPRA-required performance reports, addressing

each agency’s FY 1999 performance goals, are due to the President and Congress by March 31,

2000. 
1-7

During each annual performance reporting period, it is anticipated that DOE’s mission and

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

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

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

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

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

support of the general outcome goals.

In addition to DOE mission/schedule changes and the emergence of new safety concerns,

there are other external forces that have the potential to influence the Board’s execution of its

strategic plan and annual performance plans. In particular, if a major accident or other

safety-significant event occurs at a DOE facility involving special nuclear material, the Board’s

oversight priorities will be changed substantially. This priority shift may require an expeditious

reallocation of resources and a substantive revision to the Board’s performance planning goals,

and potentially may impact the Board’s strategic plan objectives and action plans. 

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

concentration.

1.3 EXTERNAL REGULATION OF DOE’S DEFENSE NUCLEAR FACILITIES

On November 18, 1998, the Board issued Report to Congress on the Role of the Defense

Nuclear Facilities Safety Board Regarding Regulation of DOE’s Defense Nuclear Facilities. 

That report responded to a requirement in the National Defense Authorization Act for FY 1998

that the Board prepare a report and make recommendations to Congress as to what the role of the

Board should be in the event that Congress considers legislation for external regulation of nuclear

safety at DOE defense nuclear facilities. The Board’s responses and supporting analysis

considered information from both the NRC and DOE.

Based on available information, the individual experience of Board Members, and current

analyses, the Board concluded that:

! Congress made the correct decision in 1988 when it adopted the recommendation of

the Senate Committee on Armed Services for national security reasons to maintain

responsibility for nuclear safety of DOE defense activities with the Secretary of Energy

and to establish the Board as an independent advisory agency, not as a regulator.

! The most serious problem with any external nuclear regulation of DOE’s defense

program would be a potential for adverse effects on national security. Delay is a

commonly encountered consequence of a regulatory process. The Secretaries of

Defense and Energy and the directors of DOE’s national laboratories are on record

that significant delay in the conduct of DOE’s weapons program could have serious 
1-8

national security implications, including causing other entities to doubt or question the

credibility of our nation’s nuclear deterrent.

! While respectful of the views of those seeking change in the regulatory regime for

DOE contractors, the Board believes such action is hardly justified by the costs likely

to be incurred for any benefits that might accrue. This is particularly true for defense

nuclear facilities because the costs include the real potential for undue intervention and

delays that could effectively block interminably the construction and operation of new

facilities or the upgrades of existing ones that are needed either for safety reasons or to

support the national security mission. The potential for increased vulnerability of

defense nuclear facilities to litigious proceedings and extended delays needs to be

recognized as a potentially serious cost.

! There is no basis to assert that cost savings or even cost-neutral results are achievable. 

On the contrary, it is generally recognized that transition to external regulation of

DOE nuclear safety will require a cost increase.

! Considerable complications—legal, technical, and fiscal—would accompany any

attempt to change the Atomic Energy Act to require DOE defense nuclear facilities to

be subject to external nuclear safety regulation. 

! DOE’s credibility with the public improves when it performs its responsibilities in a

safe, efficient, and creditable manner, not when additional government regulatory

agencies are layered on it. DOE has made notable progress with regard to

cooperation and openness with the public, particularly in the formation and utilization

of local citizen advisory boards.

The Board’s accomplishments during the 9 years since its establishment clearly

demonstrate that there are ways of achieving enhanced safety objectives without adding

unnecessary regulatory layers and processes. Based on its review of the factors that would attend

the external regulation of defense nuclear facilities, the Board concluded in its report to Congress

that it does not believe additional external regulation of defense nuclear facilities is in the best

interest of our nation.
S. Rep. No. 232, 100th Cong., 1st Sess. 10 (1987).

2

2-1

2. COMPLEX-WIDE HEALTH AND SAFETY ISSUES

CONTENTS OF THIS SECTION

Section Page

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

2.2 INSTITUTIONAL SAFETY MANAGEMENT FRAMEWORK AND IMPLEMENTATION ........ 2-4

2.2.1 Board Reviews of DOE Directives and Related Documents .............................. 2-4

2.2.2 Complex-wide Integrated Safety Management Upgrades ................................ 2-8

2.2.3 Site/Facility-Specific Integrated Safety Management Upgrades ........................... 2-14

2.3 RAISING DOE TECHNICAL COMPETENCE COMPLEX-WIDE ............................. 2-21

2.3.1 Implementation Status ............................................................ 2-21

2.3.2 Upgrading of Criticality Safety Expertise ............................................. 2-22

2.3.3 Facility Representative Program .................................................... 2-23

The Board devoted a substantial portion of its resources during 1998, as well as in

previous years, to advising and assisting DOE in the effort to upgrade its internal safety

management program. This effort was focused on:

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

directives;

! Implementing standards-based safety management programs that integrate work

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

workers, and the environment in a holistic way; and

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

technical competencies of DOE’s workforce.

2.1 SAFETY MANAGEMENT UPGRADE PROGRAM

In establishing the Board in 1988, Congress in its Conference Report stated that, “The 2

Board is expected to raise the technical expertise of the Department substantially and to assist and

monitor the continued development of DOE’s internal ES&H organization, and to provide

independent advice to the Secretary.”
2-2

Every Secretary of Energy with whom the Board has interacted since 1988 has stressed

the importance of performing DOE’s missions safely. However, with respect to defense nuclear

facilities under the Board’s oversight jurisdiction, the Board observed during the intervening years

that DOE’s program for achieving this objective had been marked by (1) the uncoupling of work

planning and safety planning; (2) the development of separate protective programs for the public,

for workers, and for the environment; and (3) the use of separate programs for nuclear safety and

for chemical safety (hazardous and toxic materials). This situation is not unique to DOE as

evidenced by the substantial number of single-sector safety programs that regulatory agencies

have required and the commercial industry has developed. Examples of these various initiatives

for the different sector protection programs being implemented in DOE include:

Worker Protection

! Voluntary Protection Program

! Enhanced Work Planning

! DOE Chemical Safety Program

Environmental Protection

! ISO Standard 140001

Public Protection

! Total Quality Management

! Emergency Planning and Community Right to Know

! Responsible Care (Chemical Manufacturers Association)

! Integrated Emergency Management

! Quality Assurance

Given that the source of the hazards that all these programs are intended to address is

frequently the same, addressing those hazards in an integrated way appeared to offer substantial

benefit. Toward that end, the Board recommended in 1995 (Recommendation 95-2, Safety

Management) a restructuring of DOE’s safety management program to provide a more effective

and integrated way for DOE to discharge its responsibilities for protecting workers, the public,

and the environment. In support of this recommendation the Board issued DNFSB/TECH-16,

Integrated Safety Management, which set forth a vision of what integrated safety management

could offer.
2-3

Integrated safety management strives to provide a single safety management program

rather than the multiple, unintegrated programs listed above. It is a structured, comprehensive,

common sense approach to “doing work safely.” Through ISM, the Board encouraged DOE to

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

workers, environment—and to administer them as an integrated whole. The Board recognized

that DOE’s missions involved widely varying degrees of risk and hazard and that a “one size fits

all” requirements approach would not succeed. By combining work planning and safety planning

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

environment, however, DOE can address any type of hazard that is encountered in the defense

nuclear complex.

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

collaboration with the Board, provided in April 1996 an implementation plan for moving forward. 

Her successor, Secretary Peña, reaffirmed DOE’s commitment to the integrated safety

management concept and issued DOE Policy 450.6, Secretarial Policy Statement Environment,

Safety and Health, making the implementation of the concept a requirement for all DOE’s

hazardous activities in the complex, nuclear and otherwise. In 1998, Secretary Richardson

reinforced these earlier initiatives by issuing strong statements in support of DOE’s continuing

efforts to upgrade its safety management program.

The basic tenets of ISM were expressed in the implementation plan for Recommendation

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

management functions and seven guiding management principles.

Core Safety Management Functions

1. Define the scope of work.

2. Analyze the hazards.

3. Develop and implement hazard controls.

4. Perform work within those controls.

5. Provide feedback and continuous improvement.

Guiding Principles

1. Line Management is responsible for safety.

2. Clear roles and responsibilities must be articulated.

3. Competence must be commensurate with responsibilities assigned.

4. Balanced priorities must be set.
Forty-five directives and supporting documents were formally logged and reviewed by the Board’s staff. In 3

addition, informal comments on a substantial number of early draft documents were furnished by the Board’s staff to

their DOE counterparts, who were authors of those documents. 

2-4

5. Safety standards and requirements must be identified.

6. Hazard controls must be tailored to the work being performed.

7. Operations must be authorized.

These functions and principles are to be applied universally and systematically in the

management of all hazardous activities, large or small, with control measures tailored to the

specifics of the hazards involved.

The following sections present the progress DOE and the Board are making in upgrading

DOE directives, institutionalizing ISM, implementing ISM at facilities in the complex, and

establishing a growing number of specific sets of control measures (authorization agreements) at

most major DOE sites.

2.2 INSTITUTIONAL SAFETY MANAGEMENT FRAMEWORK AND

IMPLEMENTATION

In the Board’s enabling statute, Congress directed the Board to review and evaluate the

content and implementation of standards related to the design, construction, operation, and

decommissioning of DOE’s defense nuclear facilities, and to recommend to the Secretary of

Energy those specific measures that should be adopted to ensure that public health and safety are

adequately protected. Congress anticipated that the Board would be instrumental in helping DOE

develop appropriate and operationally meaningful safety standards, and in ensuring their

incorporation into clear and consistent requirements for DOE management and contractors. 

2.2.1 Board Reviews of DOE Directives and Related Documents

DOE directives set forth requirements and guidance for the way DOE and its contractors

are to perform activities throughout the entire facility life cycle; they are key inputs in the

development and implementation of ISM programs at DOE facilities and sites throughout the

DOE complex. The Board's reviews and those of its staff focus on whether the requirements and

guidance in these directives are sufficient to adequately protect the health and safety of workers

and the public.

In meeting its enabling statute during 1998, the Board reviewed numerous new or revised

DOE safety directives. Extensive reviews conducted by the Board's staff during this process led 3

to substantial improvements in the content of a number of those directives, examples of which are

as follows:
2-5

! Rule 62 Fed. Reg. 2482. A significant milestone in the institutionalization of safety

management programs, as the Board urged in Recommendation 95-2, was DOE's

publication of a final rule (62 Fed. Reg. 2482) that, among other things, includes two

new DOE Acquisition Regulations (DEAR) clauses related to ISM. These clauses are

48 CFR § 970.5204-2, Integration of Environment, Safety, and Health into Work

Planning and Execution, and 48 CFR § 970.5204-78, Laws, Regulations, and DOE

Directives. Key features of these clauses are requirements for information that

contractors for major acquisitions must provide for DOE approval. These include 

(1) a list of the general DOE requirements that apply to the contracted work, and (2) a

description of the ISM system (ISMS) the contractors agree to deploy. The Board

focused on these two elements in 1998. 

! DOE Guide 450.4-1, Integrated Safety Management Guide. During 1997, DOE

issued Guide 450.4-1 which was developed largely as a result of DOE's initial

experience in implementing ISM at priority facilities. The Guide was developed to

assist DOE contractors in describing and implementing ISM. It also provides

guidance to DOE line managers tasked with oversight of the contractors’ ISM

programs. The Board worked closely with DOE through the development of this

guide. Updating of the Guide is a continuing process that benefits from the additional

experience being gained from ISM implementation across the DOE complex. The

Board has continued to work with DOE in the updating effort by reviewing the

revisions to ensure that the document will continue to be effective and comprehensive.

! DOE Order 251.1, Directives System, and Manual 251.1-X, Directives System

Manual. As a result of reviews by the Board’s staff and extensive interactions

between DOE and the Board during the latter part of 1997, DOE revised Order

251.1A, Directives System, and Manual 251.1-1A, Directives System Manual. Mutual

agreement with DOE on the revised versions of both of these directives was achieved

early in 1998. 

! Revision of DOE Order 430.1A and DOE-STD-1120-98 to cover

Decontamination & Decommissioning. The Board provided substantial input into

the revision of DOE Order 430.1A, Life Cycle Asset Management, and the

development of DOE-STD-1120-98, Integration of Environment, Safety, and Health

into Facility Disposition Activities. These efforts concluded an 18-month period

during which the Board’s staff worked closely with DOE to develop a standard that

comprehensively addressed methodologies for safe deactivation and decommissioning

of nuclear facilities, consistent with the functions and principles of ISM.

! 10 CFR 835 and Associated Directives. In November 1998, DOE published an

amendment to 10 CFR Part 835, Occupational Radiation Protection. DOE’s primary

authoritative source for requirements on occupational radiation protection. This final

rule corrected minor errors in the first version of the rule (issued in December 1993)
2-6

 and clarified certain issues. The Board’s staff reviewed and commented on various

versions of the proposed amendment through one-on-one communication and

interaction with DOE staff, and in some cases by Board correspondence. These

activities led to needed improvements in health and safety requirements.

! Directives Associated with Safety Analysis. DOE-STD-3009-94, Preparation

Guide for U.S. DOE Nonreactor Nuclear Facility Safety Analysis Reports, was issued

in 1994. The guidance provided in that standard was inadequate to ensure that

consistent and appropriately comprehensive safety requirements would be developed

for existing facilities, or for new construction and major modifications. In response to

comments from the Board and its staff, DOE prepared an appendix to the standard and

revised the implementation guide associated with DOE Order 420.1, Facility Safety.

! DOE-HDBK-XXXX-98, Design Considerations Handbook. When DOE Order

6430.1A, General Design Criteria, was replaced by DOE Order 420.1, Facility

Safety, a significant amount of general design guidance from the old Order was

transferred to the associated implementation guide. During 1998, the Board’s staff

aggressively pursued with DOE the need to ensure adequate scope and content for the

Handbook. DOE’s final resolution of comments from the Board’s staff occurred in

December; issuance of the Handbook is expected in 1999.

! DOE-STD-3XXX-98, Stabilization, Packaging, and Storage of Plutonium-Bearing

Metals. A pending revision of DOE-STD-3013, Criteria for Preparing and

Packaging Plutonium Metals and Oxides for Long-Term Storage, is intended to cover

a wider range of materials and to be simpler to implement, with reduced thermal

stabilization requirements for oxides, more flexibility in test methods for verifying

oxide stabilization, and less restrictive limits for the temperatures of plutonium metal in

storage. As a result of suggestions from the Board, DOE has developed additional

technical support for the proposed requirements, has made revisions to the standard’s

scope and requirements, and is requiring more testing of the behavior of metals stored

at elevated temperatures.

! Draft DOE Order 461.X, Defense Programs Packaging and Transportation, and

DOE Limited Standard DOE-DP-STD-XXXX-YR, Defense Programs Onsite

Packaging and Transportation. In October 1998, the Board’s staff provided

comments to DOE regarding these two documents, noting inconsistencies between the

draft Order and the existing DOE Order 460.1A, Packaging and Transportation

Safety, which is applicable to hazardous materials in general. DOE Order 460.1A

requires at least an equivalency with Department of Transportation hazardous

materials regulations; the draft Order appears to lower this expectation. In addition,

the draft standard generally lacks appropriate criteria and implementation guidance. 

At year-end, these issues were still pending resolution.
2-7

! DOE M 411.1-1A, Safety Functions, Responsibilities and Authorities (FRAM).

Following receipt of a proposed revision to the Level 1 (corporate) FRAM in October

1998, the Board’s staff provided its comments to DOE in November, observing that

the proposed revision did not incorporate several of the Board's earlier comments. 

Most notably, the revised Level 1 FRAM did not clearly require that subtier

documents for DOE (headquarters and field office) incorporate the health and safety

responsibilities of DOE personnel in applicable DOE Orders, including certain older

Orders being canceled. At year-end, these issues were still pending resolution.

! DOE Order 442.X, Employee Concerns Program. DOE Order 442.X, Department

of Energy Employee Concerns Program, provides protection to DOE and contractor

employees who report health and safety problems to appropriate officials. During its

review of this Order, the Board’s staff suggested that the draft Order include explicit

provisions to implement the DOE policy of “zero tolerance” for reprisals against those

who raise concerns and urged that, in light of recent court decisions, the Order include

provisions necessary to enforce settlements arrived at under 10 CFR Part 708, DOE

Contractor Employee Protection Program.

! Other Directives and Related Documents Reviewed. In addition to the directives

and related documents discussed above, the Board’s staff reviewed a significant

number of directives for which either the comments were minor in character and

adopted by DOE prior to publication, or the review was completed late in the year and

response was pending at year-end. These included:

– DOE Order 400.XDMD, Safety of Accelerator Facilities

– DOE Order 414.1, Quality Assurance

– DOE Order 420.1, Facility Safety, and Guide 421.1-1, Criticality Safety Good

Practices Guide for DOE Nonreactor Nuclear Facilities

– DOE Guide 420.1-X, Implementation Guide for Non-Reactor Nuclear Safety

Design Criteria and Explosives

– DOE Order 425.1, Startup and Restart of Nuclear Facilities

– DOE Order 435.1, Radioactive Waste Management

– DOE-STD-1066-97, Fire Protection/Design Criteria

– DOE-HDBK-1089-XX, Guidance for Identifying, Reporting, and Tracking

Nuclear Safety Noncompliance, and related guidance

– DOE-STD-3007-93, Guidelines for Preparing Criticality Safety Evaluations at

Department of Energy Non-Reactor Nuclear Facilities
2-8

– DOE Guide 426.1-1, Recruiting, Hiring, and Retaining High-Quality Technical

Staff

– DOE Policy 426.1, Federal Technical Capability Policy for Defense Nuclear

Facilities

2.2.2 Complex-wide Integrated Safety Management Upgrades

Several key indicators for gauging progress in implementing ISM have been identified as a

result of the Board's reviews:

! Incorporation of the DEAR clauses into contracts.

! Establishment of a DOE/contractor mutually agreed-upon requirements base as the

foundation for the ISM program. 

! Development of an ISMS Description that explains how the contractor will safely

manage its hazardous activities.

! Performance of a DOE ISMS verification review.

! Establishment of work-specific safety control measures for high-hazard operations

(i.e., authorization agreement).

 Each of these areas received Board attention in 1998, not only at the 10 priority facilities

called out in the implementation plan for Recommendation 95-2, but also in the 43 facilities

designated in the Board’s December 23, 1997 letter as “follow-on” facilities.

DOE Acquisition Regulations Clauses

During 1998, the Board confirmed that all major maintenance and operation contracts at

sites with defense nuclear facilities have been modified to incorporate the key provisions of the

DEAR requiring a description by contractors of the ISMS they agreed to deploy. DOE plans to

release an additional DEAR clause in 1999, 970.5204-XX, Conditional Payment of Fee or

Incentives, that calls for the establishment of performance measures relating to ISM

implementation and the establishment of an awards fee structure regarding those measures. The

Board will work closely with DOE on implementing this new clause that the Board views as an

important reinforcement by DOE of its commitment to safety management.

Selection of Contractual Environment, Safety, and Health Requirements (List A/List B)

The DEAR clauses require contractors to use DOE-approved processes for determining

appropriately tailored sets of environment, safety, and health standards, practices, and controls to

govern hazardous work. Once approved by DOE, the resulting requirements become binding

contract terms. During 1998, the Board reviewed the application of the DOE-approved Work
2-9

Smart Standards (WSS) process at the Lawrence Livermore National Laboratory (LLNL) and the

Los Alamos National Laboratory (LANL). These reviews identified areas where improvements

were needed, including the need to update DOE's guidance to bring the process more into

consonance with ISM principles. The staffs of the Board and DOE are working towards such

improvements. 

System Descriptions

The Board has followed the development of ISMS Descriptions, required by the DEAR

clause. These documents describe how the contractor will integrate ISM into work practices. 

Only the Savannah River Site (SRS), the Y-12 Plant, and RFETS have had their ISMS

Descriptions approved by DOE. All other sites are developing their Descriptions or have

submitted them to DOE for approval. A key step in their approval by DOE is the completion of a

verification review.

Verification Reviews

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

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

urging, DOE established a protocol for performing verification reviews, and in February 1998,

issued the Integrated Safety Management Systems Verification Process Team Leader’s

Handbook (DOE-HDBK-XIX-98, February 1998). As with the Integrated Safety Management

System Guide, DOE G 450.4-1, this initial version of the Handbook is scheduled for revision in a

year to reflect additional lessons learned from the ISMS verification process.

There are two targets of verification reviews:

! The site-wide upgraded safety management infrastructure, and

! The state of implementation at hazardous facilities where agreed-upon safety control

measures are to be clearly established.

During 1998, the Board’s staff observed and constructively critiqued all DOE verification

reviews conducted at defense nuclear facilities, including RFETS, SRS, Pacific Northwest

National Laboratory, Sandia National Laboratories (SNL), the Y-12 Plant, the Pantex Plant, the

Hanford Site, and the Waste Isolation Pilot Plant (WIPP). In a March 1998 letter, the Board

informed DOE of important lessons learned that merited consideration as future verification

review approaches were developed.

These verification reviews, led by senior technical staff of DOE and supplemented by

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

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

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

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

all sites have a considerable site-wide safety management infrastructure in place, but all can
2-10

benefit from more manual-capture of good practices for planning and performing hazardous work. 

Such upgrade efforts are under way. (Site-specific status is reported in Section 2.2.3)

The Board has observed that verification reviews have improved, but the Board continues

to find areas for further improvement, especially in team composition and qualification, review

scope, and timing of the reviews. The Board intends to continue its oversight and constructive

advisories on DOE’s verification reviews in 1999.

Authorization Agreements

The Board has assigned great importance to the timely execution of authorization

agreements covering hazardous work at defense nuclear facilities. An authorization agreement is

a documented agreement between DOE and a contractor incorporating a statement of work to be

done and the contractor’s proposed means for conducting the work safely. An authorization

agreement includes appropriate limits on safety-related parameters and activities and sets forth

key terms and conditions under which the contractor is authorized to perform the work. Some

restrictions may be identified as administrative controls, and specific technical requirements

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

and practices contractually binding. Authorization agreements (similar to the licenses of

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

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

work place, or mitigate the consequences of an accident if one should occur. 

To assist DOE and its contractors in developing authorization agreements, the Board

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

Activities (April 1998). In addition, Board Members and individuals of the Board's staff

presented associated technical discussions at various meetings, participated in DOE workshops,

and discussed authorization agreements at three public meetings. As a result of these and other

efforts, more than 40 facilities or major activities are operating within the bounds of signed

authorization agreements. This accomplishment by DOE is a notable outcome of the ISM effort

and a substantive measure of successful implementation. It is particularly noteworthy that all 10

operating priority facilities that require authorization agreements have been approved. As

presented in Table 1 below, 43 authorization agreements have been approved. This represents a

substantial fraction of the authorization agreements that remain to be set in place for defense

nuclear facilities. If this pace is maintained, authorization agreements for all operational Hazard

Category 1 and 2 defense nuclear facilities and much of the ISM infrastructure should be in place

at all defense nuclear sites by the end of 1999. Table 1 provides the current status of

authorization agreements for these 53 facilities (10 priority and 43 follow-on).
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 Table 1 - Status of Authorization Agreements (AAs) for Priority Facilities and Follow-on Facilities

PRIORITY FACILITIES Approval Date/Status AA in

Place

DEFENSE PROGRAMS

Lawrence Livermore National Laboratory

1 Superblock:

Building 332, Plutonium Facility implement Yes 6/97

Building 334, Weapon Design & Testing Facility No Not required for B334 and

B331, but LLNL will develop

Building 331, Tritium Facility No as ISM is implemented

Los Alamos National Laboratory

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

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

Oak Ridge

4 Y-12:

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

Bldg. 9206, Enriched Uranium Chemical Processing No 6/99

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

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

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

Bldg. 9215, Special Nuclear Materials (SNM) Processing & Yes 5/15/98

Fabrication

Pantex Plant

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

specific weapon activity,

not for the facility. See

follow-on facilities list.

Hanford Site

6 K Basins Facility Yes 9/24/98

7 Tank Farms Yes 7/24/98

Rocky Flats Environmental Technology Site

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

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

Savannah River Site

10 Canyons

F Canyon Yes 9/9/97

FB Line Yes 9/26/97

H Canyon Yes 8/1/97

HB Line Yes 3/19/98
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Table 1 - Status of Authorization Agreements (AAs) for Priority Facilities and Follow-on Facilities

(Continued)

FOLLOW-ON FACILITIES Approval Date/Status AA in

Place

DEFENSE PROGRAMS

Lawrence Livermore National Laboratory

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

facilities.

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

facilities.

Los Alamos National Laboratory

3 TA-18, Pajarito Laboratory No 2/99

4 TA-16, Weapons Engineering Tritium Facility No 2/99

5 Defense Nuclear Activities at TA-15, Dual Axis Radiographic Not Applicable - Under

Hydrotest Facility Construction

6 Defense Nuclear Activities at TA-53, Los Alamos Nuclear Scattering No 2/99

Center

Nevada Test Site

7 Abel Site, Area 27 (to be replaced by the Device Assembly Facility, Yes 1/14/99

Area 6)

8 U1a Complex Yes 1/14/99

Oak Ridge National Laboratory

9 ORNL: Material Storage (Building 3019) No 9/99

Pantex Plant

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

11 Building 12-104A, Special Purpose Bays (New - not operational) No 3/99

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

13 Weapons Programs

W56 No Spring 1999

W69 Yes 7/97

W76 No FY 99

W78 No FY 99

W79 Yes 7/98

14 Paint Bays (Bldg. 12-41) No 3/99

Sandia National Laboratories

15 Sandia Pulse Reactor Facility No 3/99

Savannah River Site

16 Tritium Facilities

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

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

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

Tritium Reservoir Loading/Unloading Facility (233H) Yes 8/26/97
2-13

Table 1 - Status of Authorization Agreements (AAs) for Priority Facilities and Follow-on Facilities

(Continued)

FOLLOW-ON FACILITIES Approval Date/Status AA in

Place

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

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

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

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

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

ENVIRONMENTAL MANAGEMENT

Hanford Site

17 Waste Encapsulation and Storage Facility No 3/99

18 Plutonium Finishing Plant No FY99

Idaho National Engineering and Environmental Laboratory

19 Underwater Fuel Storage (CPP-603-A) No 3/99

20 Irradiated Fuel Storage Facility (Dry SNM Storage) (CPP-603-B) No 3/99

21 New Waste Calcining Facility (CPP-659) No 3/99

22 Underwater Fuel Storage (CPP-666) No 3/99

23 Radioactive Waste Management Complex No 3/99

24 Unirradiated Fuel Storage Facility (CPP-651) No 3/99

Nevada Test Site

25 Radioactive Waste Management sites in Area 5, Area 3 and the TRU Yes 1/14/99

Pad

Oak Ridge National Laboratory

26 K-25 (East Tennessee Technology Park) HEU Remediation

Deactivation)

27 Depleted Uranium Tailings Yes 11/30/98

28 Material Storage (Molten Salt Reactor Experiment) No To be determined

Rocky Flats Environmental Technology Site

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

30 Building 776, Manufacturing Bldg. No Anticipated 2/99

31 Building 559, Analysis Laboratory Yes 3/1/98

32 Building 774, Waste Processing No Anticipated 2/99

Savannah River Site

33 FA-Line No No plans to operate.

34 HA-Line Yes Covered in H-Canyon AA

35 235-F Yes 12/15/98

36 Defense Waste Precessing Facility Yes 10/6/97

37 ITP/ESP Yes 7/16/98

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

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

40 K-Reactor Basin Yes 9/17/97

41 L-Reactor Basin Yes 9/17/97
2-14

Table 1 - Status of Authorization Agreements (AAs) for Priority Facilities and Follow-on Facilities

(Concluded)

FOLLOW-ON FACILITIES Approval Date/Status AA in

Place

WIPP

42 Waste Isolation Pilot Plant No Draft AA prepared in July

1998. AA will be

completed after legal

challenges to facility startup have been resolved.

NUCLEAR ENERGY

Idaho National Engineering and Environmental Laboratory

43 Advanced Test Reactor No 3/99

Feedback and Improvement 

A key function for achieving the objectives of ISM is feedback on operating experience to

improve the safety of operations. During 1998, the Board focused considerable attention on

DOE’s efforts to implement an acceptable feedback and improvement function. In March 1998,

the Board requested from DOE information about its feedback and improvement programs. 

Among the specific topics on which the Board sought more information was the status of safety

assessments performed by contractors, by DOE line managers, and staff members responsible for

independent oversight from DOE’s Office of Environment, Safety, and Health (EH-2). The

Board was particularly interested in the disposition of a list of specific assessments by EH-2,

including obstacles posed by line organizations to effecting response.

Interactions between the Board and DOE on this topic, which included a public

information session on June 24, 1998, led to (1) an agreed-upon set of initiatives volunteered by

DOE to strengthen its feedback and improvement program and (2) the Board’s Recommendation

98-1, advising DOE to establish clearer lines of responsibility and authority for resolution of

findings of its internal, independent safety organization (EH-2). The Board and its staff will

continue to work closely with DOE in 1999 as it improves its feedback and improvement

programs.

2.2.3 Site/Facility-Specific Integrated Safety Management Upgrades

During the past year, DOE has been working to fully implement ISM at the priority

facilities designated in DOE's implementation plan for Recommendation 95-2. These facilities

were selected because of the importance of their mission or because they involved especially

hazardous work. As noted earlier, they also serve as pilot facilities for the implementation of ISM

across the defense nuclear complex, with the expectation that lessons learned at each of 
2-15

these pilot facilities will make it possible to accelerate implementation in the remaining follow-on

facilities.

The Department of Energy Strategic Plan explicitly states that DOE will “implement ISM

Systems at DOE’s ten priority facilities and in all major management and operations contracts in

FY 1999.” Throughout 1998, the Board urged DOE to continue its efforts to define and operate

in accordance with explicit control measures at the priority facilities, and also expand its efforts to

include all high and moderate hazard defense nuclear facilities.

 Although the key indicators previously discussed show DOE is making progress

implementing ISM, there still is a need to provide insight into the quality and effectiveness of the

ISM programs involved. The Board and its staff have focused considerable resources on

determining whether the requirements established in each contract are reflected in safety

management processes or implementing procedures used in specific work activities covered by the

ISMS. The staff has also continued reviewing whether the facilities are implementing the ISMS

adequately. In general, the Board has found that most facilities have at least basic elements of an

acceptable ISMS in place. However, much work remains to be done to embed the functions and

principles of ISM deeply into the planning and execution of work at all levels of the organization

in order to achieve the goal of enhanced safety for the public, workers, and the environment.

In general, more progress has been made in upgrading safety management programs for

individual priority facilities than in modifying site-wide requirements, manuals, and procedures at

sites where priority facilities are located. On the other hand, the site-wide ISMSs are progressing

ahead of the development of facility-specific ISM programs at the follow-on facilities. This

finding was neither surprising nor disturbing; in fact, it reflects the priorities the Board has

encouraged. The following Sections provide specific insight into the progress at each site.

Pantex Plant, Texas

Pantex has taken positive actions to develop an ISMS in response to DOE’s requirement

to do so. As described earlier in this report, these actions represent an upgraded program, not a

drastic course change. The Board’s staff observed the conduct of ISMS verification reviews

completed by DOE in September 1998, and provided insights to the verification review team

leaders as the review progressed. The DOE team concluded that in general, the ISMS established

for each of the two major Pantex missions—high explosives operations and special nuclear

material storage—was sufficiently well defined and executed, but could still be improved. The

team also concluded that the processes for executing safety management functions for the Pantex

mission of nuclear explosive operations required further definition in the ISMS Description and

implementing documentation. For example, improvements were needed in the flowdown from

safety requirements to plant directives and/or plant standards and manuals. In addition, the team

identified inconsistent execution of the ISM functions for nuclear explosive operations. 
The Phase I Verification review is a DOE review of the contractor’s site-wide safety management 4

infrastructure (i.e., functions, responsibilities, system description requirements, procedures, policies, and manuals of

practice). The primary goal of the review is to provide a recommendation to the DOE contracting officer as to whether

the contractor’s safety management plan should be approved. The purpose of the Phase II review is to verify that the

contractor’s ISMS Description submitted to and approved by DOE is in place at the site, facility, or activity. 

2-16

The DOE verification team recommended that DOE and the contractor complete their

ongoing effort to formally define the processes unique to nuclear explosive operations that are

intended to provide an evolved system of safety management, and that the ISMS reviews be

repeated for the nuclear explosive mission area after an appropriate implementation period. In its

final report in October 1998, the team acknowledged that participation by the Board’s staff

contributed to the success of the review.

 

Y-12 Plant, Tennessee

In early 1998, the Board’s staff worked closely with Y-12 personnel as they began to

define needed elements of an upgraded safety management program. These efforts resulted in

substantial progress toward implementation of ISM in support of restart of enriched uranium

operations (EUO) at Y-12. Subsequently, the Board and its staff observed DOE’s efforts in

performing a combined Phase I/Phase II verification review at the Y-12 Plant as a whole, ending 4

in September 1998. The DOE verification review team found the ISMS Description to be a good

road map to the Lockheed Martin Energy Systems (LMES) implementing manuals and

procedures. However, the team noted that the ISMS was in the early stages of implementation.

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

to ensure a mature and consistent implementation of ISMS at Y-12. The team recommended that

the Y-12 Site Office Manager schedule a subsequent verification of implementation at selected

facilities after the site-wide program at Y-12 had time to progress.

Los Alamos National Laboratory, New Mexico

The current contract between DOE and the University of California for managing LANL

became effective October 1, 1997. DOE’s Work Smart Standards process was used to identify

the safety standards and requirements that the university and DOE agreed to as terms of the

contract. Based upon these requirements, LANL has proceeded systematically and aggressively

to develop implementing procedures and manuals of practices tailored to the needs of its

laboratory activities. The Board through its oversight role has endeavored to assist the

laboratory’s commendable efforts. Toward this end, in December 1997, the Board noted the

absence of project management requirements such as those in DOE Order 430.1A, Life Cycle

Asset Management, and the inadequacy of the chosen requirements relating to natural phenomena

hazards. DOE was so advised.

In response, DOE and LANL instituted a continuous improvement process, referred to in

a June 1998 letter from the Board to DOE. As a result, DOE and LANL are identifying project

management requirements that need to be added to the contract. Some contractual changes have
2-17

 been made, including the addition of the section of DOE Order 420.1, Facility Safety, concerning

natural phenomena hazard mitigation, and the addition of DOE Order 4330.4A, Maintenance

Management Program.

Senior management of the Technical Area-55 (TA-55) Plutonium Facility has played a

leadership role in the development of the institutional site-wide infrastructure. This was done

largely by a pace-setting application of the tenets of ISM in structuring a facility-specific safety

management program for activities to be conducted in TA-55. In 1998, TA-55 reviewed its

safety management program to effect improvements that would make its directives more

consistent with the new institutional requirements. Moreover, TA-55 has developed and is

implementing comprehensive safety control measures set forth in an authorization agreement

approved by DOE. The Board applauds this achievement.

Lawrence Livermore National Laboratory, California

LLNL has long operated under a safety management program based upon safety

requirements specified by rules and contract terms. The laboratory reflected these requirements in

its Health and Safety Manual and its Environmental Compliance Manual. However, in the early

period of the Board’s oversight of LLNL’s weapons-related activities, the Board and its staff

noted that there was no formal mandate that these manuals be used to plan and perform work, nor

was there a clear correlation of work practices and procedures with the safety requirements

specified by contract. Early attempts by LLNL to address what appeared to be significant

shortcomings revealed the need to better select from DOE’s generally applicable requirements

specified by contract those requirements most suitable for laboratory-type activities and the

research environment. The laboratory was challenged by the Board to do so. As LLNL

undertook this challenge, the Board and DOE developed the concept of ISM (DOE Policy 450.4),

with its core framework built around the five functions and seven principles enumerated earlier

that can be universally applied to integrated work planning and safety planning for any potentially

hazardous activity.

While continuing to operate its nuclear facilities under its current contractual safety

requirements, LLNL is moving to transition its management programs to the ISM framework,

tailoring its program to best fit a laboratory environment. During the past year, this effort focused

on:

! Resumption of nuclear operations in the Superblock facilities after systematic

reassessment of all hazardous activities under way there, and affirmation of the 

adequacy of safety measures.

! The systematic review of safety standards and requirements and selection of those

deemed most appropriate for performing the laboratory’s weapons-related missions.

 
2-18

Nevada Test Site, Nevada 

DOE faces a unique challenge in tailoring a safety management program to the functions

and principles of ISM for the Device Assembly Facility (DAF) and subcritical experiments at the

Nevada Test Site (NTS). These operations are conducted, and even managed, by national

laboratory personnel who are not under contract to DOE-Nevada. This makes it difficult for

DOE-Nevada to enter into contractually binding agreements with the laboratories regarding safety

expectations. The operations at DAF and for subcritical experiments are conducted under a

memorandum of understanding. One aspect that mitigates the current difficulties at NTS is that

the hazardous activities conducted by the laboratories at NTS are discrete and relatively

infrequent such that they can be controlled through an activity-specific ISM approach. The Board

and its staff have reviewed this approach during assessments of DAF and subcritical experiment

operations. These operations are conducted in accordance with DOE-Nevada Orders that reflect

the functions and principles of ISM. The NTS program for safety management of experiments to

be conducted at the site will be assessed by an independent DOE team in early 1999. The Board’s

staff will interact with the participants.

Sandia National Laboratories, New Mexico 

In 1998, the Board's staff continued to assess safety management improvements at SNL

and at the Sandia Pulsed Reactor Facility (SPRF). In October and November, the Board's staff

observed DOE's SNL site-wide combined Phase I and Phase II ISMS verification review. DOE

found that the ISMS Description for the entire institution had not been fully developed. It is

anticipated that most of the corrective actions will be completed during 1999. The Board's staff

will continue to monitor SNL's progress in this area. 

On the other hand, the DOE review team found that, in general, SPRF has a welldeveloped Safety Analysis Report and a defined set of safety controls. A rigorous experiment

proposal and review process ensures that the safety basis of the facility is maintained for all

reactor operations. The Board’s staff agreed with these findings. During a visit by the Board’s

staff, SPRF managers acknowledged that some difficulties exist with integrated control of the

work of all personnel at the site. The staff also noted substantial improvement in the DOEKirtland Area Office Facility Representative program previously assessed during a staff review in

1996.

Savannah River Site, South Carolina

SRS has implemented one of the more mature ISM programs in the DOE complex. The

Board worked closely with SRS during the development of the integrated safety management

system for the site and during its first DOE verification review, which served as the pilot for

verification reviews elsewhere across the DOE complex. SRS updated its ISMS Description in

1998 according to the provisions of the DEAR clause, and DOE approved it on June 3, 1998. 

The priority Environmental Management facilities at SRS and most of the follow-on facilities now

have authorization agreements in place. SRS deserves considerable credit for its success in this

endeavor.
2-19

In 1998, the Board’s staff evaluated whether it was appropriate to conduct Phase II

facility-specific ISM program verification reviews using SRS’s existing Facility Evaluation Board

(FEB). The staff observed the pilot facility-specific verification review at the Defense Waste

Processing Facility. The Board’s staff agreed with DOE’s assessment that the FEB is a viable

mechanism for performing facility-specific verification reviews, provided that the FEB process is

modified to specifically include the ISMS fundamentals, additional team training is provided on

ISMS verification techniques, and continued DOE oversight is applied. In 1999, the Board

intends to continue to observe and critique SRS’s management self-assessment activities and the

actions taken to resolve issues identified by these reviews. 

Rocky Flats Environmental Technology Site, Colorado 

At RFETS, ISM is a site-wide process focused on work activities. Many of those

activities are unique, one-time efforts; therefore, focusing on individual work activities is

appropriate. The site historically has had difficulties with identifying hazards and safety controls,

and incorporating those controls into work procedures. These functions showed marked

improvement this past year. The Board’s staff has continued to encourage RFETS to define and

implement more rigorous safety controls for the activities performed.

During 1998, the Board’s staff observed DOE verification reviews for activities in

Buildings 371 and 771 at RFETS. The team concluded that activities at both facilities can be

conducted safely and noted that many of the procedures required to safely perform the mission of

site closure were in the process of being revised and formalized. 

As a result of the DOE verification review, revised work control procedures were

implemented to bring most aspects of safety management under a single work control document. 

The Board’s staff has reviewed this document and believes it can help improve the identification

and implementation of safety controls needed for work activities, and should partially address

weaknesses in ISM mechanisms noted by the DOE verification team. Additionally, RFETS had

developed an acceptable ISMS Description for the site. Following the verification review, DOE

approved this ISMS Description, signifying its agreement with the contractor’s plan for

conducting work safely at RFETS. RFETS has made substantial progress in implementing ISM at

the site, and the Board commends RFETS for this effort.

In 1999, the Board’s staff will continue to assess preparations for and conduct of work

activities, and to encourage the continued rigorous application of ISM as described in the site’s

ISM Description.

Hanford Site, Washington 

Several processes are in place at the Hanford Site for identifying and controlling work and

hazards as part of ISM implementation. These processes provide a minimum level of safety

necessary to accomplish work at the site; however, many are not institutionalized to ensure their

consistent use. The Board’s staff observed ISM verification reviews for the Spent Nuclear Fuel

Project (SNFP), the Pacific Northwest National Laboratory, and the Tank Waste Remediation
2-20

System (TWRS). In addition, the Board’s Hanford Site Representative conducted detailed

reviews of ISM implementation in work control systems within SNFP and TWRS. Through

face-to-face feedback and formal letters, the Board prompted DOE and its contractors to make

improvements in ISM implementation, particularly in work control and job hazard analyses. 

Particular improvement is required at the activity level, where job hazard analyses are performed

inconsistently at the various facilities. 

Waste Isolation Pilot Plant, New Mexico

The Board and its staff have been following closely the efforts to open WIPP. In 1998,

the staff observed the ISMS verification review for WIPP. Based on the results of these reviews,

it appears that ISM implementation at WIPP is adequate. An ISMS Description has been

submitted by the contractor for DOE approval. The DOE Carlsbad Area Office is expected to

issue an authorization agreement in 1999.

Idaho National Engineering and Environmental Laboratory (INEEL), Idaho 

INEEL is in the early stages of implementing ISM at the Idaho Nuclear Technology and

Engineering Center (formerly the Idaho Chemical Processing Plant), at the Test Reactor Area,

and at the Radioactive Waste Management Complex. On April 22, 1998, the Board forwarded to

DOE a staff report on the INEEL work planning process and ISM implementation. The existing

work control and planning process, which contains some elements of ISM, appeared to be weak. 

DOE’s Type A investigation into a worker death at INEEL confirmed this finding. In an October

1, 1998 memorandum to all DOE employees, the Secretary of Energy stated that the “accident

could have been prevented had we effectively implemented the principles of Integrated Safety

Management.” A Board member visited INEEL to review its plans for accelerating

implementation of ISM and to offer guidance and advice with respect to its upgrade efforts. In

1999, the Board will observe the ISMS verification review and work closely with DOE to see

ISM implemented at all INEEL facilities under the Board’s purview.

Oak Ridge National Laboratory, Tennessee

In 1998, the Board and its staff reviewed the implementation of ISM at the Oak Ridge

National Laboratory (ORNL) to confirm that lessons learned from Y-12 would be shared with

follow-on facilities, including the Molten Salt Reactor Experiment and Building 3019; and

depleted uranium tailings not only at Oak Ridge, but also at Paducah, and Portsmouth. At the

Board’s public meeting in September 1998, the Board’s staff reported on the results of its review

of the implementation of ISM at these facilities. Overall, progress has been slow. ISM has not

been fully implemented at the institutional level or in the facilities. ORNL is developing ISMS

Descriptions, but firm plans for verification reviews are not complete. Several facilities have

authorization agreements based on existing safety management programs; however, they will

require updating following ISM implementation.
2-21

2.3 RAISING DOE TECHNICAL COMPETENCE COMPLEX-WIDE

2.3.1 Implementation Status

Accomplishment of DOE’s missions in a manner that protects the health and safety of

workers and the public depends heavily on the technical qualifications of DOE personnel who are

assigned safety-related responsibilities. Congress, the Board, and other external agencies have

emphasized a need for raising the technical competence of both federal and contractor personnel

in the defense nuclear complex. In June 1993, the Board focused DOE’s attention on this issue

through issuance of Recommendation 93-3. An implementation plan was provided by DOE in

November 1993. DOE had made measurable progress on several aspects of its 93-3

implementation plan, including (1) development of a standardized technical qualification program

for approximately 1,800 federal employees, (2) identification of 251 senior technical safety

management positions required for continued safe operation of defense nuclear facilities, and (3)

acquisition of excepted service hiring authority for an additional 200 positions beyond the 200

positions allowed under the DOE Organization Act.

By early 1997, however, many of the specific commitments in the implementation plan for

Recommendation 93-3 had not been met or had not achieved the desired effect. Missions,

resources, and personnel constraints affecting DOE had changed considerably since 1993. As a

result, the Board requested in a letter of April 1997 that DOE revise its 93-3 implementation plan

to reflect revised DOE initiatives and provide more realistic milestones. DOE commenced

working with the Board toward this objective in mid-1997. However, progress stalled in the

summer of 1997 when a reduction in personnel was seriously threatened in response to reduced

FY 1998 funding levels proposed by Congress. DOE informed the Board that a number of

technically qualified DOE employees hired in response to Recommendation 93-3 might be

terminated to comply with regulations governing reductions in force. The final FY 1998 budget

levels for DOE, however, allowed major reductions in force to be avoided. 

In an October 1997 letter to DOE, the Board stressed that DOE needed to prepare in

advance to avert the loss of technically competent safety personnel in the face of likely future

budget reductions. The Board stressed that while DOE must comply with government

regulations as they affect downsizing, it is also essential to preserve the technical expertise needed

to perform those functions that protect public and worker health and safety. Any actions to

preserve technical expertise should include staff in key health and safety positions at defense

nuclear facilities, competent personnel in senior technical safety management positions (identified

during the implementation of Recommendation 95-2), and critical technical expertise developed

under the DOE Technical Qualification Program in response to Recommendation 

93-3. Progress in this area is discussed further below.

In the ensuing months, the Board and its staff worked closely with DOE managers in

developing a revised implementation plan for Recommendation 93-3. In May 1998, the Secretary

of Energy submitted a revised plan, which was subsequently accepted by the Board in June 1998. 

This plan focused on line management ownership for development and preservation of DOE’s

essential technical capabilities. 
2-22

Using its revised implementation plan, DOE had formed a panel of senior line managers to

ensure successful implementation of efforts to recruit, develop, deploy, and retain technical

capability at defense nuclear facilities. Regarding concerns about the effects of downsizing on

technical capabilities, most of the DOE organizations with responsibility for defense nuclear

facilities had completed an interim workforce analysis. Based on this interim analysis, the panel

identified approximately 740 critical technical positions, including 175 Senior Technical Safety

Managers and 201 Facility Representatives, and took administrative action on nearly all of these

positions to reduce the potential impact of further downsizing. Additionally, workshops on

administrative flexibilities in the recruiting, hiring, and retention of high-quality technical staff

were conducted in the field and at Headquarters by panel members in the fall of 1998. In

December 1998, a new DOE Policy on Federal Technical Capability and a DOE Handbook

entitled Recruiting, Hiring and Retaining High Quality Technical Staff: A Manager’s Guide to

Administrative Flexibilities were issued through the DOE Directives System. Throughout this

period, the Board and its staff closely followed the functions and deliberations of the line

management panel and provided comments on the development of the related DOE policies,

procedures, and processes. 

The Board is aware of the difficulty of the task it has asked DOE to accomplish in the face

of potential reductions in total manning levels. As a result of such downsizing activities, however,

the need to preserve and improve DOE’s pool of unique technical expertise becomes all the more

imperative. The senior management of DOE recognizes the importance of recruiting and

retaining highly qualified staff, and the Board sees in DOE’s 1998 efforts added impetus toward

such ends. The Board intends to follow closely the leadership and actions of DOE’s senior

management in developing and preserving the key DOE technical expertise required to ensure

safety. 

2.3.2 Upgrading of Criticality Safety Expertise

In its implementation plan for the Board’s Recommendation 97-2, DOE committed to

developing criticality safety training requirements and qualification standards for technical

personnel at defense nuclear facilities. DOE made meaningful progress in 1998 toward defining

the technical competencies for a comprehensive nuclear criticality safety qualification standard. 

Throughout the past year, the Board's staff has been providing feedback on the development of

this functional-area qualification standard. DOE is on a satisfactory path forward. 

DOE also made adequate progress this year in conducting the basic hands-on criticality

safety training at the Los Alamos Critical Experiments Facility. However, an expanded training

course is late in both its development and implementation, in part because of a suspension of

operations at the facility. The Board's staff will continue its oversight and constructive critique of

this program. The funding of the program rests on shaky grounds, because the benefits are DOEwide, and support of the activity is not a mission objective of any single Program Secretarial

Officer.
2-23

2.3.3 Facility Representative Program

A significant contribution to the safety of DOE defense nuclear facilities is made by

Facility Representatives (FRs), who are required to have detailed knowledge of their assigned

facilities and the daily operations conducted therein. The success of the FR program is largely the

result of major improvements recommended by the Board in its Recommendation 92-2, DOE’s

Facility Representative Program at Defense Nuclear Facilities. The Board considers

Recommendation 92-2 to be one of the most successfully implemented Board recommendations.

Since closure of Recommendation 92-2 in 1996, the Board’s staff has continued to

monitor the operation of FR programs across the complex. The Board’s actions in 1998 led to

improved FR programs at the Fernald Environmental Management Project and at WIPP.
3-1

3. MANAGEMENT AND STEWARDSHIP OF THE NATION’S STOCKPILE AND

NUCLEAR WEAPONS COMPONENTS

CONTENTS OF THIS SECTION

Section Page

3.1 STOCKPILE MANAGEMENT OF NUCLEAR WEAPONS ................................... 3-2

3.1.1 Pantex Plant .................................................................... 3-2

3.1.2 Y-12 Plant ..................................................................... 3-8

3.1.3 Los Alamos National Laboratory ................................................... 3-11

3.1.4 Savannah River Site Tritium Operations ............................................. 3-12

3.2 STOCKPILE STEWARDSHIP OF NUCLEAR WEAPONS ................................... 3-13

3.2.1 Lawrence Livermore National Laboratory ............................................ 3-13

3.2.2 Los Alamos National Laboratory ................................................... 3-14

3.2.3 Nevada Test Site ............................................................... 3-16

3.3 DEFENSE PROGRAMS-WIDE TOPICS .................................................. 3-17

3.3.1 Recommendation 93-1/Nuclear Explosive Safety Study Corrective Action Plan .............. 3-17

3.3.2 Collection and Analysis of Safety-Related Information .................................. 3-18

3.3.3 Status of System-Specific Weapon Safety Specifications ................................ 3-18

3.3.4 Weapon Surveillance Program ..................................................... 3-19

The Board has a unique role in overseeing the safety of operations in the DOE nuclear

weapons complex. These vital national security activities include assembling, disassembling, and

verifying nuclear components; conducting research and experiments in connection with stockpile

stewardship; and providing replacement components and materials. A major thrust of the Board’s

oversight has been to review and assess safety management programs for these activities to ensure

that they are conducted in a manner that adequately protects public health and safety.

The defense nuclear complex has changed considerably since the charter Board Members

were appointed in 1989. As a matter of national policy, production of new weapon systems has

stopped, and dismantlement of a large fraction of the nuclear weapons stockpile is under way. 

With the Administration's commitment to the Comprehensive Test Ban Treaty, all underground

testing of nuclear weapons has ended as well. 

Existing nuclear weapon systems are likely to remain in the nation's stockpile longer than

in the past, potentially much longer than their original design lifetime. It will be necessary to

ensure that nuclear weapons within DOE custody remain safe. In the absence of underground

nuclear testing, alternative means to confirm the safety and reliability of weapons throughout their

life cycle are being developed. DOE's strategy for dealing with this challenging new 
The Stockpile Stewardship and Maintenance Program, U.S. Department of Energy, Office of Defense 5

Programs, May 1995.

3-2

mission is embodied in its Stockpile Stewardship and Management Plan. This plan provides for 5

continuation of the ongoing defense missions at eight DOE sites, and includes appropriate

adjustments consistent with post-Cold War national security policies. 

The facilities for assembly and disassembly of nuclear weapons were constructed in the

period between the late 1940s and 1960s, and they are now quite old. DOE is refurbishing

facilities intended for continued use and is changing the functions of other facilities. DOE’s plans

also call for construction of some facilities with enhanced experimental capabilities at the nuclear

weapons laboratories. Manufacturing capabilities at some existing plants are to be maintained,

but their capacity will be reduced. The last tritium production reactor was closed a decade ago at

SRS, and DOE has initiated a project to secure a new source of tritium that will likely require new

defense nuclear facilities at SRS. In addition, a limited capability for manufacturing components

of plutonium pits is planned for a weapons laboratory.

DOE must also institute Life Extension Programs for specific weapon systems. Life

Extension Programs will likely result in increased activity at the Pantex Plant and the Y-12 Plant. 

The Board accordingly posted a full-time Site Representative at the Y-12 Plant in June 1998. 

Board Site Representatives have been located at the Pantex Plant since July 1992. 

3.1 STOCKPILE MANAGEMENT OF NUCLEAR WEAPONS

Stockpile management is a term used by DOE to describe the industrial aspects of

maintaining the nuclear weapons complex. A program of research and development to develop

improved ways of ensuring safety and reliability in the absence of underground testing of nuclear

weapons has also been started; this is called stockpile stewardship. Activities at the major sites

with defense nuclear facilities that are engaged in stockpile management activities are discussed

below.

3.1.1 Pantex Plant

The Pantex Plant, located outside Amarillo, Texas, plays a central role in the stockpile

management program. Operations at Pantex include the assembly, disassembly, and surveillance

of nuclear weapons. Pantex also serves as an interim storage site for strategic reserve plutonium

removed from retired weapons.

Recommendation 98-2, Safety Management the Pantex Plant

In response to the Board’s Recommendation 93-1, DOE had developed and began

implementing an upgraded work planning/safety planning process, called Seamless Safety for the

21 Century (SS-21), to guide the development of safety bases, procedures, and tooling for st
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nuclear explosive operations at the Pantex Plant. The SS-21 process has yielded excellent results

where it has been used, by integrating safety planning and work planning for dismantlement

operations. However, the SS-21 process has been executed for only a few programs because of

its reported complexity and labor-intensive requirements.

The SS-21 process was meant to ensure that surveillance and dismantlement of nuclear

weapons take place in an orderly fashion that profits from input by all appropriate organizations. 

This process is relied on for assurance of safety at all stages. In 1998, the Board observed that

the process was so cumbersome that it could not be followed simultaneously for all the types of

weapons to be dismantled or surveilled at once, and the assurance of safety had begun to suffer. 

Recommendation 98-2 was issued in response to this observation. It called for redesign of the

management process to simplify it and to reinstitue line responsibility for actions, which had

suffered in the existing process. The recommendation was not prescriptive; it proposed that DOE

and the Pantex contractor develop the new system.

The Board believes that line management must control and be responsible for the safety of

hazardous operations. However, the roles, responsibilities, and accountability for nuclear

explosive operations at Pantex have been weakened. Nuclear Explosive Safety Study Groups

were found to be regularly imposing specific remedies for safety deficiencies they identified, rather

than charging line management to develop and resubmit appropriate corrective actions for the

work its workforce was ultimately to execute. This situation compromised the role of the Nuclear

Explosive Safety Study Group (NESSG) as an additional review body, independent from line

management. Furthermore, an effective process for change control by line management, related

directly to the approved safety basis, did not exist. 

Specific Weapon Programs 

W69 Dismantlement Program. The W69 is the retired warhead from a short-range

attack missile. The W69 dismantlement program was the first nuclear explosive operation to

undergo the full SS-21 process. The Board and its staff conducted an extensive review of the

proposed W69 dismantlement operation in 1997 and found it acceptable for start-up, while

identifying a number of areas meriting further improvement. DOE’s successful resolution of the

W69-specific safety issues, including those identified by the Board, resulted in approval by DOE

of the first authorization agreement for a nuclear explosive operation. This integrated work

planning/safety planning program resulted in installation of a series of added engineered safety

features for lightning protection and fire protection. The W69 dismantlement program proceeded,

with enhanced safety, in a highly efficient and productive manner. The last W69 was successfully

dismantled ahead of schedule in October 1998. The W69 dismantlement operation has been

widely characterized by both DOE and the Board as the best nuclear weapon dismantlement

process designed and implemented to date.

W56 Dismantlement Program. The W56 is a retired Minuteman II warhead. The full

SS-21 process was also employed in the development of the W56 dismantlement operation. The

Board and its staff closely reviewed preparations for this major dismantlement program, 

including the identification and on-the-floor implementation of safety controls derived from the 
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SS-21 process. A review of the Hazard Analysis Report (HAR) for the W56 conducted by the

Board’s staff revealed relatively few issues and determined that the analysis was methodical and

generally comprehensive. The HAR initially identified numerous specific controls to ensure the

safety of the operation. When the results of the HAR were fed back to the process designers,

they were able to improve the procedures and tooling. For example, lifts (which provide the

opportunity for accidental drops that threaten the high explosive in the weapon) have been

eliminated, including crane lifts of the warhead in any configuration. In addition, the tooling used

in dismantlement has been designed to better protect the weapon and its components by removing

or reducing hazards wherever possible.

In 1998, the Board’s staff questioned how the W56 dismantlement program intended to

identify, implement, and preserve the important controls that are relied upon to prevent

inadvertent detonation of the high explosive components in the weapon. In the original drafts of

the Activity-Based Control Document, there was little to differentiate these vital controls from the

many other safety controls identified for the W56 dismantlement operation. In response to this

issue, DOE revised its approach and committed to clearly identifying the controls most important

in this respect, defining the bases for these controls, mandating appropriate requirements to

maintain the functionality of these controls, and dictating actions to be taken should a control be

compromised. This effort represents a real improvement in DOE’s management of nuclear

explosive operational safety, since it contributes to the preservation of those controls most relied

upon to prevent a high-consequence accident.

The Board’s staff observed the Nuclear Explosive Safety Study (NESS) for the W56, as

well as a Readiness Assessment for the W56 that was completed in December 1998. The

common purpose of these two different forms of readiness reviews by panels of experts is to

assure DOE that the contractor is ready to begin work safely. Briefings to the NESSG were an

improvement over those in earlier studies, as they were appropriately interspersed with physical

demonstrations of the dismantlement procedures by the Production Technicians (i.e., the hands-on

operators). The importance of adding such realistic demonstrations has been noted repeatedly by

the Board and its staff, since it allows the reviewers to make better associations between the

assessed hazards and actual operations. At year’s end, Pantex was working to address several

important issues raised during the W56 NESS and Readiness Assessment. The Board and its staff

will continue their oversight of these safety planning activities. Start-up of the W56

dismantlement program is expected in early 1999. 

W79 Dismantlement Program. The W79 is an artillery-fired atomic projectile. The

dismantlement operations for the W79 began in April 1998 after a year of Readiness Reviews and

demonstrations of the process, tooling, and equipment. Design and development of the W79

dismantlement process started before the concepts of SS-21 and current expectations for a

weapon system had been completely formulated in a HAR. Therefore, the W79 process was not

designed to the full SS-21 requirements.

The Board and its staff positively influenced the identification, review, and resolution of

several potential safety issues related to W79 dismantlement. These issues were related to the

flammability of the dissolution solvent, safety controls needed for the hot water heating system, 
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potential ignition sources (particularly electrostatic discharge), combustible loading and fire

protection, lightning protection, the review process, documentation of controls, and change

control. In response, a DOE-led project team solicited an independent peer review of the safety

of the systems for dissolution of the high explosive, improved the safety controls for the hot water

heating system, and revised dismantlement procedures to address the remaining issues.

The Board and its staff also reviewed and provided feedback on the NESS, Safety

Evaluation Reviews, and Readiness Reviews for the W79. When the NESSG and review teams

appeared to lack technical expertise in specific areas and to accept presentations without adequate

questioning, the Board’s staff posed additional questions. Overall, however, the work

planning/safety planning process for the W79 was an improvement over previous reviews. Issues

identified by the Board were satisfactorily addressed.

W62 Disassembly and Inspection (D&I) Program. The W62 is an enduring stockpile

warhead used in the Minuteman III missile system. The NESS authorization for dismantlement

and inspection of the W62 expired in 1997. DOE decided to revalidate the expired W62 NESS in

June 1998 (i.e., use of the same tools, controls, and procedures previously used), rather than

pursue a tailored SS-21 approach to develop an improved set, which would then be the subject of

a new, full-scope NESS review. The revalidation process is allowed under the DOE nuclear

explosive safety Orders, but sometimes it is not advisable from a safety perspective. The Board

noted that, at this stage, the W62 was one of those cases. This observation was a principal reason

for issuance of Recommendation 98-2. As of the end of 1998, DOE had agreed that an additional

hazard analysis and other actions will be needed to support safe D&I operations for the W62. 

These actions include reviews of the W62 authorization basis, a walkdown of the W62 operations,

and development of a HAR and an Activity-Based Controls Document. 

W87 Life Extension Program and D&I Operations. The W87 is an enduring stockpile

warhead used on the Peacekeeper missile system. Throughout 1998, DOE has been preparing to

begin a life extension program for the W87. A HAR for Life Extension Program (LEP)

operations that will take place at the Pantex Plant has been completed, and safety controls have

been identified through a HAR and an Activity-Based Control Document. The W87 LEP First

Production Unit is anticipated in early 1999.

In a November 1998 letter to DOE, the Board identified several issues associated with

planned W87 LEP operations. One of these was the need to designate clearly the most important

controls that are relied on for preventing inadvertent detonation of the high explosives. There

was little in the initial draft documents to differentiate these controls from the many other safety

controls identified for the W87 LEP. Additionally, the Board’s letter noted that the authorization

basis for the ongoing W87 D&I operations was not based on a documented hazard analysis. 

As a result of interactions with the Board and its staff, DOE has decided to include the

W87 D&I operations within its ongoing hazard analysis and identification of controls for the W87

LEP operations. This will provide the W87 D&I program with a documented safety basis. 

DOE efforts to evaluate and improve the W87 hazard analysis and the set of controls are being 
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strengthened and can be improved even further when the final HAR and the Activity-Based

Controls Document are issued. 

Additional Pantex Safety Management Issues and Advances

Throughout the year, the Board and its staff identified or followed up on a number of

additional matters that pertain more generally to the safety of weapons system operations at the

Pantex Plant. The discussion that follows highlights actions taken by the Board to address these

matters.

Facility Selection. Bays at Pantex available for dismantlement operations involving

conventional explosives in proximity to nuclear materials are of different vintages. The older

ones, in general, were built to less stringent seismic design requirements and less quality control

on bonding of the reinforcing steel. The latter affects the capability of the structure to divert

lightning strikes to ground, should they be experienced. Because explosives safety is highly

dependent upon exclusion of energy sources, nuclear explosive operations involving older, less

safe systems should be carried out in the most robust and safe facilities. The Board observed that

the relevant safety features of the bays did not appear to have been considered in the selection of

the facility for performing dismantlement.

In a letter dated August 8, 1997, the Board questioned the selection of the older bays in

Building 12-64 for the W69 dismantlement campaign. The Board specifically observed that this

building has weaknesses compared with other facilities at the Pantex Plant that might have been

chosen for such dismantlement activities. DOE’s response, in February 1998, was that the

process for facility assignment used prior to the introduction of current procedures did not

evaluate the relative hazards of operations against the preventive and mitigative capabilities of

facilities. Accordingly, in early 1998, DOE and Mason and Hanger Corporation (MHC)

developed a formal procedure for facility selection that more appropriately addressed safety

considerations. DOE has continued to make improvements in facility selection as further lessons

have been learned. DOE has subsequently completed the nuclear explosive operations in Building

12-64 (except for weapon staging) and is now considering the possible modification of these bays

for less hazardous operations, such as pit repackaging. 

Upgrades of the Site-wide Basis for Interim Operations (BIO). Initiatives of DOE and

MHC to upgrade the Pantex BIO, which began in 1997 primarily as a result of the Board’s urging

during the last several years, continued in 1998. The Pantex BIO contains analyses of common

operations at the Pantex Plant, identifies hazards from a facility perspective or hazards that are

common to more than a single weapon system, and demonstrates that work can be done safely. 

The safety basis will remain interim until systematic safety analyses have been completed for all

activities and an ISMS has been fully developed. With technical input from the Board and its

staff, DOE switched to a plan for upgrading the site-wide BIO in a modular fashion by subject

areas (lightning protection, on-site transportation, fire protection, etc.), rather than defer

implementation of new controls and safety improvements until all analytical work has been

completed and approved. Updating the BIO in a modular fashion ensures that additional safety
3-7

improvements will be made in the most expeditious manner. Examples of the Board’s activities

related to the BIO upgrades are as follows: 

! Lightning Protection—In 1997, the Board requested that DOE prepare a technical

report addressing a comprehensive analysis of the hazards posed by lightning to

nuclear explosive operations at the Pantex Plant and the controls necessary to prevent

and mitigate those hazards. In response, DOE established a project team to address

the lightning protection issue. DOE and MHC have already begun to identify and

install additional protective measures, including electrically bonding metallic

penetrations, surge protectors for communications circuits, transportation carts that

are effective at mitigating lightning hazards during movement of nuclear explosives,

and isolation requirements to prevent electrical energy from being inadvertently

applied to explosive circuits.

! On-site Movements of Nuclear Explosives—The Board and its staff have

emphasized the safety of weapons movements at the Pantex Plant. With the aid of the

Board and staff discussions, DOE and MHC have come to recognize that this activity

is one of the least well analyzed nuclear explosive operations at Pantex. Work on the

on-site movement module of the BIO is now one of the highest priorities at the plant.

Pit Storage at Pantex

Integrated Pit Storage Program Plan. The Board continues to evaluate the safety

implications of projected long-term storage of plutonium pits at the Pantex Plant. From an ISM

standpoint, the proposed pit storage system at Pantex can be viewed as a combination of

interrelated barriers to radioactive release (i.e., the pit cladding, the container, and the facility) and

associated controls needed to maintain these barriers. However, for most pits the pit cladding is

the only reliable confinement since the containers are unsealed and subject to corrosion, and since

current storage facilities lack confinement features. On December 31, 1997, the Board formally

transmitted to DOE its report DNFSB/TECH-18, Review of the Safety of Storing Plutonium Pits

at the Pantex Plant, urging that activities recently initiated to improve pit storage be completed in

a thorough and well-considered manner. The Board emphasized that accomplishing this would

necessitate attention by high-level DOE management, logical development of an integrated

program plan, and sensible allocation of resources.

During 1998, DOE proceeded with activities aimed at improving pit storage conditions,

including the development of a pit storage specification and the selection of MHC’s AL-R8

Sealed Insert as the preferred storage container, replacing the existing container (the AT-400A). 

Qualification of the AL-R8 Sealed Insert is ongoing, with repackaging scheduled to begin in

March 1999 and end in 2004. 

Development of the Integrated Pit Storage Program Plan (IPSPP) has proceeded in

parallel with the AL-R8 Sealed Insert development. The first draft of the IPSPP was issued in

November 1998. The Board found that this draft plan incompletely defines activities needed to

repackage pits into the AL-R8 Sealed Insert, and indefinitely defers discussions related to the
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systematic integration of pit storage activities to a future revision. As of year’s end, these issues

had not been resolved.

Special Nuclear Material Component Storage Facility (Building 12-116). Building

12-116 is a new Pantex facility for consolidated storage and nondestructive testing of strategic

reserve components (pits, reservoirs, and secondaries). Construction was largely completed in

1993, but operations did not start until 1998. The protracted period before start-up resulted from

a shift in the facility’s primary mission—from staging pits for weapon assembly to providing

longer-term storage of strategic reserve components. This shift led to roughly a five-fold increase

in the intended pit inventory. To accommodate this increase, DOE plans to load the building in

phases to increase the number of pit vaults from two to four and nearly double the effective

stacking height of container pallets.

During 1998, the Board reviewed the progress toward start-up. In August 1998, the

Board issued a letter to DOE forwarding its staff’s observations on the DOE Operational

Readiness Review (ORR) of Building 12-116. The Board noted the need for improvements in

planning, operations, and authorization basis controls; better maintenance of safety systems;

identification of safety controls for components with safety-related temperature restrictions;

improved planning for future upgrades; and designation of pit containers as safety systems. The

Board observed that many similar issues had been identified in its letter of December 1997

transmitting DNFSB/TECH-18. The Board and its staff intend to follow closely and

constructively critique the efforts of DOE and MHC to resolve these issues, and their planning

and progress in implementing the required work.

3.1.2 Y-12 Plant

The Y-12 Plant, near Oak Ridge, Tennessee is designated as the site for conduct of the

secondary component and weapons case fabrication mission. The Y-12 mission also includes

fabrication, surveillance, inspection, and testing of weapons components.

Enriched Uranium Operations Restart

Enriched Uranium Operations at the Y-12 Plant involve a system of metallurgical

operations (casting, rolling, forming, and machining), waste processing operations (thermal,

solution, and wet chemistry processes), and metal production operations. EUO, like other 

nuclear activities at the Y-12 Plant, was suspended by the contractor in 1994 following the

identification of numerous criticality safety problems. Since that time, Y-12 has been working to

resolve the fundamental safety issues identified in the Board’s Recommendation 94-4,

Deficiencies in Criticality Safety at the Oak Ridge Y-12 Plant. At the beginning of 1998, all

nuclear facilities except those unique to EUO had resumed normal operations. The restart of the

metallurgical operations, designated Phase A1, and waste processing operations, designated

Phase A2, was planned in 1998. Y-12 successfully started Phase A1 in June 1998. Restart of

Phase B metal production operations is planned for 1999. Resumption of these operations,

conducted in Buildings 9212 and 9215, is needed to support high-priority national security

missions. 
3-9

Phase A1. During the first part of 1998, the Board and its staff evaluated Phase A1

preparations for restart. In a January 1998 letter, the Board identified several design and

equipment deficiencies related to electrical and fire protection systems, such as emergency

lighting, instrumentation and control systems, and dry vacuum systems. Additionally, the Board

identified a lack of appropriate identification and implementation of safety controls for the

ventilation systems and the system for detecting water in the casting furnace. The following are

examples of Board/DOE interactions that led to safety upgrades.

! Fire Protection—The Board and its staff found that the method by which action items

from Fire Hazards Analyses (and other external reviews and audits) were tracked and

dispositioned was inadequate and ineffective. Resolution of the findings significantly

improved fire protection safety for the facilities. 

! Ventilation Filtration Systems—The accident assessments in the BIOs for Buildings

9212 and 9215 rely heavily on filtration in ventilation systems operating at peak

efficiency to mitigate postulated exposures from credible accidents. A review by the

Board’s staff found that appropriate controls to ensure preservation of the capability

of the ventilation systems’ filtration had not been identified. In response, DOE and

LMES identified new surveillances of the ventilation system to test appropriate

operating parameters, and included them as key safety basis controls. 

! Emergency Lighting—The adequacy of emergency lights and the status of

compliance with the Life Safety Code had not been verified, even though compliance

with this standard is assumed in several accident analyses. In response, DOE and

LMES installed new emergency lights in Buildings 9212 and 9215.

! Dry Vacuum Systems—A review by the Board’s staff of the systems used for

removing particulates in various areas revealed that safety interlocks could be

bypassed and that a single failure of one relay could prevent any of the three safety

interlocks from shutting down the system. In response, DOE and LMES redesigned

and modified operations of the dry vacuum systems to resolve these issues. 

Efforts to address the fundamental safety control issues discussed above coincided with

the desire of both DOE and LMES to complete required ORRs on a predefined schedule. The

ORR conducted by LMES for Phase A1 was started prematurely in March 1998, with numerous

safety issues not resolved, safety controls not fully implemented, and equipment not fully ready. 

These deficiencies were recognized by LMES’ ORR team, which suspended the ORR. After 6

weeks of additional preparations, LMES’ ORR and later DOE’s ORR were successfully

conducted. 

ORRs by both the LMES and DOE resulted in findings indicating continued deficiencies in

the identification and the implementation of safety controls and preparation of procedures. The

nature of the findings, along with clear problems with the LMES process for addressing

findings/issues from various assessments, was such that both ORR teams recommended

independent verification of the development and completion of corrective action plans for the
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ORR’s prestart findings. After this period of erratic preparation for restart, Phase A1 operations

were resumed in June 1998 and continued to support DOE operations through the remainder of

1998.

Phase A2. In a June 1998 letter to DOE, the Board identified issues such as the need for

systematic assurance that all safety basis controls be identified and implemented, and that issues

be properly closed prior to conducting an ORR. The Board believed that resolving these issues

would aid restart preparations and improve the safety of the EUO operations in Phases A2 and B. 

In response, DOE and LMES committed to several improvements for the Phase A2 and Phase B

restart, including more deliberate, disciplined preparations for restart.

The Board and its staff reviewed the preparations for restart of Phase A2, including a

detailed review of controls. The Board issued a letter to DOE in October 1998 forwarding staff

observations. In particular, the staff identified numerous differences between National Fire

Protection Association (NFPA) codes and the way in which a furnace was installed, tested,

operated, and maintained. In response, LMES performed a rigorous review of adherence to the

NFPA codes and identified even more noncompliances. By the end of 1998, LMES had

addressed the identified noncompliances through several equipment and procedural modifications.

The Board’s staff observed the ORRs conducted by LMES and DOE for Phase A2

operations in October and November 1998, respectively. Overall, the conduct of operations and

readiness demonstrated for these ORRs were much improved as compared with the ORRs for

Phase A1. Phase A2 operations were resumed in December 1998.

Phase B Restart Preparations. Metal production in Phase B includes chemical

recovery/extraction, conversion, and reduction operations to produce enriched uranium metal

from a number of material forms. In mid-1998, LMES proposed preliminary plans indicating that

an ORR might not be performed to confirm the readiness of the Phase B activities. This would

have been counter to the requirements of DOE Order 425.1, Startup and Restart of Nuclear

Facilities, calling for ORRs for restart of such activities after an extended shutdown. The Board

noted this issue in a letter to DOE in June 1998. In response, DOE informed the Board in July

1998 that an ORR will be performed to confirm the readiness of these operations.

Y-12 is in the process of constructing a new anhydrous hydrogen fluoride (HF) delivery

system to support metal production. HF is an extremely corrosive gas, and a sound pressure

boundary in the HF delivery system is critical to worker and public safety. After a DOE Facility

Representative from the Y-12 Site Office discovered defects in completed welds in the HF 

system pressure boundary, the Board’s staff called attention to this breakdown in weld quality

assurance on the HF system. Additionally, the staff found that the process hazard analysis

performed for the HF system was ambiguous and was not used in the process to design

engineered features; safety controls were not systematically developed with an appropriate level

of detail. 
3-11

The Board presented these observations on the HF system in a letter to DOE in August

1998. Subsequently, DOE and LMES decided to perform field radiographic inspections of

completed HF system welds to ensure proper weld quality. DOE and LMES also decided to

perform a new hazard analysis of the HF system to ensure that proper safety controls are

identified. In December 1998, DOE initiated field radiography of HF system welds. Of the first

four welds radiographed, one was defective and required replacement. This weld had passed the

previously required inspections. Short of this radiography, a failure of this pressure-containing

weld could have occurred upon placing the HF system into service. 

Control of Maintenance Activities

At the Y-12 Plant, most maintenance activities, including maintenance on safety systems,

are accomplished by the Facilities Management Organization—an organization distinct from the

operations management organizations, such as EUO. In early 1998, the Board found that there

was a lack of operations management awareness and control of the maintenance of safety systems

at the Y-12 Plant, as evidenced by several off-normal events or occurrences. These were viewed

by the Board as symptomatic of a fundamental problem with control of maintenance at the Y-12

Plant. In June 1998, the Board issued a reporting requirement to DOE, asking that DOE review

these occurrences, identify the root causes, and determine corrective actions. In August 1998,

DOE and LMES responded with actions to address the root causes and identified corrective

actions that should substantially improve operations control of maintenance of safety systems.

Overall, the Board has been favorably impressed with the receptivity of both DOE and

LMES to constructive critiques of their work planning/safety planning and the progress being

made in effecting a continuing upgrade program.

3.1.3 Los Alamos National Laboratory

LANL has a unique mission as compared with other nuclear-weapons-related research and

development laboratories—to provide a small-scale capability for producing pits for enduring

stockpile weapons to replace existing pits taken out of service for destructive testing or other

reasons. This mission is related to stockpile management, even though activities at DOE’s

weapons laboratories usually emphasize stockpile stewardship. 

The Capability Maintenance and Improvement Project (CMIP), as originally conceived,

was intended to develop the capability to manufacture pits at LANL. In a December 1997 letter

to DOE, the Board identified weaknesses in the manner in which technical project management

for CMIP was being conducted. Those weaknesses included a lack of adequate safety design

criteria; the need for technical personnel experienced in the management of major projects that are

complex and hazardous; and the need to implement suitable technical project management

processes. The Board requested a report providing an evaluation of actions aimed at improving

project management for CMIP. Subsequently, DOE began to redefine the CMIP mission and the

near-term development of a limited pit manufacturing capability at LANL, now being called

Transition Manufacturing and Safety Equipment. DOE and LANL have acknowledged that the
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project management problems identified by the Board were systemic and extended to several

other stockpile management projects at LANL in addition to Transition Manufacturing and Safety

Equipment. DOE committed to addressing these issues and correcting the associated deficiencies

that impact both DOE’s and LANL’s ability to effectively manage and execute major projects.

DOE’s response, in June 1998, identified corrective measures to be implemented by the

Nuclear Construction Projects Office within the Albuquerque Operations Office. The plan’s

provisions included the development of a technically competent organization that is responsible,

has authority, and is accountable for safe execution of projects. From May to October 1998, the

Board and its staff met with DOE to review the implementation of these commitments. 

Significant improvements were observed in project management by DOE and LANL at the senior

management and project levels. Although DOE’s plan was not fully implemented at year-end, the

revised strategy for technically managing major projects at LANL is sound. The Board will

continue to closely follow DOE’s and LANL’s efforts and to provide advisories as appropriate to

assist LANL in its attempts to upgrade its project management capabilities and performance.

3.1.4 Savannah River Site Tritium Operations

The tritium facilities at SRS, located near Aiken, South Carolina, are vital to support the

nation’s capability to replenish certain weapons components with tritium gas and to process and

store the gas. Tritium, a radioactive isotope of hydrogen, has a relatively short half-life 

(12.3 years) and must be replaced periodically. Tritium was last produced in the K-Reactor at

SRS, which was shut down in 1988. DOE does not have current capability to produce tritium,

but is planning to acquire this capability.

Tritium Production Options

On December 6, 1995, the Secretary of Energy issued a Record of Decision announcing

that DOE would pursue a dual track on tritium supply alternatives: (1) the use of a commercial

light water reactor, and (2) the development of an accelerator system. On December 22, 1998,

the Secretary of Energy selected the commercial reactor alternative as the primary alternative and

indicated that development and design of the accelerator would continue as a backup alternative.

During 1998, the Board and its staff communicated comments directly to DOE and its

contractor on the safety aspects of the preliminary design of the tritium extraction facility, which

will be used to extract tritium from special rods irradiated in a commercial reactor. This facility

will be built within the existing tritium complex at SRS, and will be operational by 2006. The

Board and its staff have focused their safety reviews of the accelerator alternative mainly on the

tritium-producing target, which is expected to have a high inventory of radioactive spallation

products. The Board expects to continue safety-related reviews of the tritium extraction facility

in 1999, to ensure that appropriate engineered safety features are incorporated in the final design. 

Key design features associated with safety of the accelerator itself will be reviewed as the design

evolves.
3-13

Ongoing and Existing Tritium Operations

The Board and its staff have dedicated substantial effort to overseeing the safety of the

installation and start-up of new tritium activities at SRS for surveillance testing of tritium

reservoirs. In 1998, the Board’s staff reviewed the design and safety analyses for the

environmental conditioning chambers. These chambers subject tritium reservoirs to conditions

they may experience during deployment. In response to issues raised by the Board regarding the

likelihood and consequences of accident scenarios involving explosion of tritium, DOE improved

the safety analyses and supporting documentation for operating these chambers. Through further

staff interactions, the formality of readiness was significantly strengthened. Several safety issues

were identified, resulting in fire protection upgrades, pressure protection improvements, and

enhanced operating procedures to support safe operations of the environmental conditioning

chambers. 

In 1995, the Board called DOE’s attention to the possibility that certain natural

phenomena could cause an adjacent ventilation stack to fall on Building 217-H, which houses a

large number of filled tritium reservoirs and hydride storage vessels. Such an event could cause

release of large quantities of tritium. As a result, DOE and Westinghouse Savannah River

Company (WSRC) designed and installed highly invulnerable encased safes (HIVES) in the Vault

of Building 217-H. These safes are designed to maintain their structural integrity in the event of

collapse of either the building or an adjacent ventilation stack. Installation of the HIVES has been

completed, and all reservoirs and hydride storage vessels in the 217-H Vault were to be located in

the HIVES by early 1998. However, the Board’s staff noted that a large number of reservoirs

were still being stored in the old-style storage cabinets in the 217-H Vault. As a result, DOE and

WSRC committed to eliminating storage of reservoirs outside of HIVES by March 1999. 

Additional HIVES have been installed, and WSRC is now on schedule to meet its commitment.

3.2 STOCKPILE STEWARDSHIP OF NUCLEAR WEAPONS

Stockpile stewardship is the term used by DOE to refer to activities carried out in the

absence of nuclear testing to assure confidence in the safety, security, and reliability of the

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

combination with future non-nuclear test data and aggressive application of computer modeling,

experimental facilities, and simulations. Activities at the major sites engaged in stockpile

stewardship are discussed in turn below.

3.2.1 Lawrence Livermore National Laboratory

LLNL, located 45 miles southeast of San Francisco, California, is a DOE nuclear 

weapons research and development laboratory. It provides technical expertise to support

stockpile stewardship and management, including consultation on the surveillance and

dismantlement of LLNL-developed nuclear weapons. Its most significant defense nuclear
3-14

facilities are in the Superblock complex, e.g., the Building 332 (B332) Plutonium Facility and

Tritium Facility.

Resumption of Operations at the Plutonium Facility

LLNL halted operations at the B332 Plutonium Facility in July 1997 as a result of

concerns with safety management, criticality safety, and conduct of operations. 

Throughout 1998, the Board and its staff reviewed efforts and activities to upgrade the

safety management program at the B332 Plutonium Facility and the remainder of the Superblock,

as part of efforts to restart this facility. The Board’s staff reviewed and assisted in the

development of the Plutonium Facility Resumption Plan, and reviewed and provided feedback on

efforts and activities to resume operations. In general, the staff’s efforts were focused on

assisting the nuclear facilities in developing and improving programs and procedures for the

identification of hazards and implementation of controls for operations and storage of special

nuclear and radiological materials.

The resumption of operations in B332 was an evolutionary process. The process resumed

operations in stages, provided for iteration of improvements in work practices in subsequent

work, and gradually developed standing work practices. The process required rigorous

compensatory measures to ensure that the work was thoroughly defined, hazards were identified

and analyzed, controls were identified and implemented, workers were trained and qualified, work

was executed as prescribed, and lessons learned were fed back into the process. The

compensatory measures included consistent review of the work descriptions, hazards, and

controls; verification of readiness to begin work; performance of work as prescribed; 

maintenance of controls; and review to ensure that the full scope of operations for an activity was

effectively demonstrated before the workstation was approved for further operations. The

combination of increased laboratory management attention, DOE mentoring and assistance, and

strong oversight by the Board has resulted in most of the activities in the facility being restarted

with substantial safety improvements. Moreover, this effort has not diminished support to

important missions, such as stockpile stewardship and material disposition. 

3.2.2 Los Alamos National Laboratory

LANL, located in northern New Mexico, is the DOE weapons laboratory with the largest

number of defense nuclear facilities and weapons-related activities. It is the main site for ongoing

research and development on the means for certifying the safety and reliability of nuclear weapons

in the absence of nuclear testing. As noted earlier, it is also to be the location of DOE’s limitedscale manufacturing capability for replacement pits for nuclear weapons.

Chemistry and Metallurgy Research Facility. CMR has had a long history of 

problems relating to safety management. In the fall of 1997, LANL chose to temporarily 

suspend operations at CMR. On February 2, 1998, responsibility for operating CMR was

transferred to the Nuclear Materials Technology Division, which also manages the TA-55

Plutonium Facility. CMR was subsequently restarted, following extensive review of safety
3-15

management for each of its activities. The CMR safety management program is being patterned

after the TA-55 ISMS where possible, and it is still under development. Basic safety management

functions are in place to ensure that work can be performed safely. A BIO for CMR was

approved by DOE on August 31, 1998. Technical Safety Requirements for CMR have been

drafted and are expected to be finalized shortly.

TA-18, Pajarito Laboratory. In May 1998, a member of the Board’s staff attended the

LANL Safety Review Committee’s review of operations at the Pajarito Laboratory, which is the

only hands-on nuclear criticality safety training facility in the DOE complex. The review

uncovered numerous deficiencies. The Board’s staff member noted some additional issues that

underscored the need for improved conduct of operations. On August 12, 1998, LANL placed

TA-18 in a stand-down mode as a precautionary safety measure following a criticality safety

violation and other recent safety infractions. Based on its own subsequent review, LANL

correctly identified the root causes of safety issues at the Pajarito Laboratory as inadequacies in

the work planning aspects of ISM (define work, analyze hazards, develop controls, and implement

controls) and in formality of operations. DOE’s Los Alamos Area Office has been interacting

extensively with LANL to improve safety management at this facility. The Board’s staff is

continuing to monitor the development of the ISM program at the Pajarito Laboratory.

Hydrodynamic and Dynamic Experimentation

Experiments for studying the performance of nuclear weapon components are to be

conducted on mockups of the components and on simplified structures in specially designed

vessels. LANL has been planning a series of such tests to compare the performance of aged

weapons components with that of new ones. The Board has been reviewing documentation and

plans for the ORR to verify that rigorous controls are in place before testing proceeds. In

November 1998, the Board issued a reporting requirement to DOE in order to stimulate better

planning, thus ensuring that sufficient time and expertise will be available to conduct the necessary

technical reviews prior to start-up.

Seismic Hazard at Los Alamos National laboratory

For several years, DOE has been actively evaluating the seismic hazard at LANL. A major

milestone in this effort was completion of the Woodward-Clyde seismic hazard report in February

1995. One issue identified by the Board resulting from the Woodward-Clyde investigation was

that the seismic capabilities of the nearby Pajarito fault were not adequately understood because,

in contrast with two other nearby faults, geologically recent (i.e., Holocene, or less than 10,000

years ago) movements on the Pajarito had not been evaluated. These three faults, known

collectively as the Pajarito Fault System, are close to LANL and are the main contributors to the

seismic hazard at the site. As a result, the seismic hazard projections at LANL are extremely

complex to account for incomplete data and a high reliance on expert opinion. To address this

issue, DOE initiated additional field investigations to identify the expected Holocene movements. 

Complete results are expected in 1999, and the new information should lead to a more robust

assessment of the LANL seismic hazard. 
3-16

Another seismic-related matter raised by the Board is the possibility that the Rendija

Canyon fault (another of the three faults) extends into the LANL Technical Areas and could pose

a potential surface rupture hazard during an earthquake. To address this uncertainty, LANL

initiated a program to survey the mesa side walls and possibly identify recent fault displacements. 

While results from this survey have eliminated the concern for TA-55, they now point to the

possibility of the fault trending toward TA-3, particularly CMR. A further bore-hole investigation

supported the existence of two small, closely spaced, faults under CMR. Human activity and

disturbance of the area will make it exceedingly difficult to determine the seismic capability of this

fault.

The Board’s staff and consultants are interacting regularly with DOE and its contractors

on these matters.

3.2.3 Nevada Test Site

Underground testing of nuclear weapons is no longer being conducted at NTS. However,

NTS is required to maintain readiness to allow resumption of underground testing within a certain

timeframe if required by the President to do so. In 1993, the Board issued Recommendation 93-

6, which addressed, among other things, the need for DOE to retain access to and capture the

unique knowledge of individuals who have significant experience in nuclear testing, and the need

for DOE to identify and preserve the knowledge necessary to resume testing operations safely. 

Since 1993, DOE-Nevada and the weapons laboratories have made substantial progress toward

completing commitments under Recommendation 93-6.

Device Assembly Facility

DAF is a new facility at the Nevada Test Site. In previous years, the Board closely

monitored preparations for start-up of DAF, ensuring that many elements of a satisfactory ISM

program were in place. DAF successfully started up in 1998 and has supported several activities

related to the subcritical experiments. The Board and its staff reviewed these activities and found

them to be well within the authorization basis for DAF operations. The Board continues to

monitor operations planned for the DAF. 

Subcritical Experiments

DOE’s subcritical experiments program is a vital materials research component of its

stockpile stewardship and management program. Subcritical experiments involve devices

containing both high explosives and special nuclear material. The experimental configurations are

designed, however, to preclude the possibility of nuclear criticality.

During 1998, the Board and its staff reviewed the proposed operations for the

STAGECOACH, BAGPIPE, CIMARRON, and CLARINET experiments. The Board called

DOE’s attention to a number of specific matters with regard to the hazard analyses prepared for

these experiments and emergency management. At the encouragement of the Board, LANL
3-17

updated the bounding hazard analysis for the U1a Complex, where subcritical experiments are

performed, to address the hazards during these operations.

The Board has encouraged DOE to take actions to capture lessons learned from each

experiment to continue to enhance the safety of these experiments.

3.3 DEFENSE PROGRAMS-WIDE TOPICS

3.3.1 Recommendation 93-1/Nuclear Explosive Safety Study Corrective Action Plan

For several years, the Board has worked with DOE to improve the directives governing

the safety of nuclear explosive operations. In implementing the Board’s Recommendation 93-1,

Standards Utilization in Defense Nuclear Facilities, and the Nuclear Explosive Safety Study

Corrective Action Plan, DOE has produced a revised and expanded set of safety-related Orders,

standards, and guides that, taken together, significantly improve the definition of what DOE

expects of its contractors to ensure the safety of operations. The implementation of the 

452-series Orders and the development and implementation of the SS-21 process have yielded

excellent results where they could be applied, by integrating safety planning and work planning for

dismantlement operations. The following discussions outline DOE’s progress during 1998.

Implementation of Nuclear Explosive Safety Orders

In July 1998, DOE notified the Board that many of the requirements of the Orders had, in

fact, been implemented for the Pantex Plant. The 452-series Orders were added to the MHC

contract in May 1998. One of the DOE-Albuquerque supplemental directives, which provides

operations office direction for implementing the Orders, is in final draft form; several other

supplemental directives are nearing completion. DOE-Nevada and the national laboratories plan

minimal additional efforts to implement the nuclear explosive safety Orders at NTS, primarily

because of the absence of any ongoing nuclear explosive operations there. The safety analysis for

test preparation and the training and qualification of personnel for those tasks would be included

in the three-year preparation time to conduct a nuclear test.

Headquarters Roles and Responsibilities

DOE has assured the Board that all necessary actions will be taken to ensure that its

Office of the Deputy Assistant Secretary for Military Application and Stockpile Management

(DP-20) is able to carry out its responsibilities under the new directives. DOE has agreed to

ensure that any adjustments to DOE Headquarters staffing will not result in inadequate staffing

related to the nuclear explosive and weapons surety function. To this end, DOE will utilize

technical support contractors, certified in accordance with the requirements of the DOE standard

for NESS, to support the NESS process; national laboratory personnel who have been detailed to

DP-20; and excepted service appointment authority.
3-18

Hazard Analysis Report Standard

Publication of a DOE standard providing guidance on the preparation of HARs for nuclear

explosive operations was one of the last DOE commitments in response to the Board’s

Recommendation 93-1. DOE published this important standard in January 1999, after

incorporating changes responding to a substantial number of comments from the Board and its

staff. This standard is referenced in the revised set of DOE nuclear explosive safety Orders and

defines an adequate set of operation-unique controls to ensure the safety of nuclear explosive

operations.

3.3.2 Collection and Analysis of Safety-Related Information 

Board Recommendation 93-6

In 1993, the Board noted that individuals possessing essential weapons information were

being lost from the defense nuclear complex in large numbers. To address this concern, the Board

issued Recommendation 93-6, Maintaining Access to Nuclear Weapons Expertise in the Defense

Nuclear Facilities Complex, which urged DOE to capture safety-related design and operational

knowledge from these individuals. In response to this recommendation, Defense Programs (DP)

initiated several programs for preserving and archiving information at the nuclear weapons

laboratories, NTS, the Pantex Plant, and the Y-12 Plant. In April 1998, DP initiated a weapons

complex-wide assessment of existing programs for preserving and archiving knowledge. The

scope of this assessment went beyond the safety focus of the Board’s Recommendation 93-6 to

include preservation of all critical weapons program data and information.

In late May 1998, senior DP management briefed the Board on the assessment’s

preliminary findings and recommendations. The preliminary findings validated many of the

concerns expressed by the Board in 1997. In particular, the assessment revealed that there was

“no comprehensive, strategic plan in place to deal with the capture of data, information, and

knowledge.” The recommendations called for the establishment of strategic policy and plans for

“enterprise-wide information management.” As of the end of 1998, a Nuclear Weapons

Information Management Strategic Plan for Defense Programs had been drafted, and a senior

manager responsible for information management policy, plans, and priorities had been appointed. 

On December 22, 1998, the Board received a letter from the DOE Assistant Secretary for

Defense Programs, which stated that “the strategic plan and the appointed senior manager’s

involvement will meet the intent of the Board’s Recommendation 93-6 and allow it to be closed.” 

Based on review of the strategic plan and the information to be provided in early 1999, the Board

will determine whether DOE’s program management strategy for knowledge preservation

resolves the remaining issues still impeding the closure of Recommendation 93-6.

3.3.3 Status of System-Specific Weapon Safety Specifications

Weapon Safety Specifications are intended to record the hazards of each existing nuclear

weapon, including historical information and interviews with current and retired program 
3-19

personnel. These documents, developed in response to a Board initiative, are vehicles for capture

and channeling of the knowledge of laboratory personnel into the hazard analyses for each

weapon system and use of that knowledge to increase the involvement of design agency

personnel in the efforts to ensure safety at Pantex. By the end of 1998, DOE had completed

WSSs for all weapon systems, with only one WSS not yet formally released. In addition, DOE

has decided to enhance the utility of the WSSs by asking the design laboratories to specify, 

where possible, the weapon response expected if a weapon is exposed to specific abnormal

environments.

3.3.4 Weapon Surveillance Program

Weapon surveillance is the responsibility of DOE’s Albuquerque Operations Office. The

weapon surveillance program has two major components—the Core Surveillance Program and

the Enhanced Surveillance Program. These programs assess the viability of the nuclear weapon

stockpile through sampling, testing, and analysis. The purpose of the Core Surveillance Program

is to discover defects, if any, in the safety and reliability of weapons systems and to verify

compatibility of DOE and Department of Defense weapon system interfaces. The purpose of the

Enhanced Surveillance Program is to develop cutting-edge methods and models that can be

incorporated into the Core Surveillance Program, and increase DOE’s ability to predict the effects

of aging on weapons in order to determine whether these effects will impact weapon function or

safety. The Board is monitoring these activities to confirm that safety issues are given adequate

attention in both programs.

DOE surveillance programs are focused, in part, on ensuring the continuing performance

and safety of the explosive components of nuclear weapons. In early 1998, the Board issued a

report to DOE entitled Surveillance of Nuclear Weapons High-Explosive Operations at Pantex,

which raised concerns about the sampling frequency for the selection of components for testing

and the process for initiating detailed investigations based on preliminary surveillance findings.
4-1

4. HAZARDOUS REMNANTS OF WEAPONS PRODUCTION

CONTENTS OF THIS SECTION

Section Page

4.1 STABILIZATION OF LEGACY MATERIALS .............................................. 4-2

4.1.1 Plutonium ..................................................................... 4-4

4.1.2 Enriched Uranium ............................................................... 4-7

4.1.3 Uranium-233 ................................................................... 4-7

4.1.4 Special Isotopes ................................................................. 4-8

4.2 STABILIZATION OF SPENT NUCLEAR FUEL ............................................ 4-9

4.2.1 Hanford Site ................................................................... 4-9

4.2.2 Savannah River Site ............................................................. 4-10

4.2.3 Idaho National Engineering and Environmental Laboratory .............................. 4-11

4.3 STORAGE OF HAZARDOUS MATERIALS ............................................... 4-11

4.3.1 Plutonium Storage Facilities at the Savannah River Site—Actinide Packaging and 

Storage Facility and K-Area Material Storage ......................................... 4-11

4.3.2 Building 371 at the Rocky Flats Environmental Technology Site .......................... 4-13

4.3.3 Uranium Hexafluoride Storage ..................................................... 4-13

4.3.4 Hazardous Chemical Storage ...................................................... 4-14

4.4 WASTE MANAGEMENT .............................................................. 4-15

4.4.1 High-Level Waste ............................................................... 4-15

4.4.2 Low-Level Waste ............................................................... 4-19

4.4.3 Transuranic Waste ............................................................... 4-19

4.5 DEACTIVATION AND DECOMMISSIONING ............................................ 4-20

4.5.1 Activities at the Rocky Flats Environmental Technology Site ............................. 4-21

4.5.2 Activities at the Hanford Site ...................................................... 4-23

4.5.3 Activities at the Y-12 Plant ........................................................ 4-24

4.5.4 Activities at the Miamisburg Environmental Management Project ......................... 4-24

4.5.5 Deactivation and Decommissioning Standards ........................................ 4-25

As DOE attempts to close facilities and sites that are no longer needed for weapons

production, it is faced with many new challenges. Myriad activities must be accomplished safely

to ensure adequate protection of the public, workers, and environment. The Board has

consistently encouraged DOE and its contractors to undertake these activities in a methodical and

controlled manner; that is, they must understand the hazards presented by the activity and

materials involved, control those hazards, perform the work using appropriate safety controls, and

learn how the activity could be performed better. These are fundamental tenets of the Board’s

Recommendation 95-2 on Integrated Safety Management. 
4-2

Following the shutdown of many nuclear weapons production facilities in the late 1980s,

much of the special nuclear material in the complex—most at the Rocky Flats Environmental

Technology Site, the Hanford Site, and the Savannah River Site—was not stored in conditions

considered safe for the long term. For example, solutions of plutonium remained in tanks and

bottles at RFETS and the Hanford Site where they happened to be located when shutdown orders

were given. In addition, at SRS, the Hanford Site, and INEEL, spent nuclear fuel was in transfer

basins not designed for long-term storage. Although DOE had tentative plans for correcting some

of these conditions, there was no sense of urgency regarding the need for stabilization and

repackaging of those materials for safer storage.

In Recommendations 94-1, 95-1, 96-1, and 97-1, the Board urged DOE to take action to

correct the storage problems in a timely manner, recognizing that unsafe conditions would

become worse with time. Since then, DOE has taken action to mitigate some of the most

immediate concerns, but much of the material has yet to be stabilized or packaged for long-term

storage or ultimate disposition. This need to stabilize unsafe material is seen by the Board as

having the utmost urgency.

During the processing of material for stabilization, packaging, and storage, the

fundamental tenets of ISM must be satisfied. Such control remains essential as DOE facilities no

longer needed for the weapons mission make the transition to deactivation and decommissioning. 

In many cases, greater hazards, particularly to workers, arise during deactivation and

decommissioning of these facilities than existed when the facilities were in operation.

In the discussion that follows, the Board reemphasizes the importance of stabilizing and

packaging legacy materials on an expedited basis and providing the necessary resources to

accomplish this objective. This is not a matter of preference; rather, it is an issue of public health

and safety that must be dealt with aggressively. The Board intends to assist DOE in this regard

through its strong focus on the safety of defense nuclear facilities and activities and through its

analysis of issues deserving high-priority attention.

4.1 STABILIZATION OF LEGACY MATERIALS

The Board issued Recommendation 94-1 in May 1994, stating, “The halt in production of

nuclear weapons and materials to be used in nuclear weapons froze the manufacturing pipeline in

a state that, for safety reasons, should not be allowed to persist unremediated.” At the time,

fissile materials and related materials required treatment on an accelerated basis to be converted 

to forms more suitable for safe interim storage, and it was even more unclear how these materials

should be dealt with for the long term. The Board expressed concern with the then current slow

pace of remediation, and stated its belief that additional delays in stabilizing these materials

would be accompanied by further deterioration of safety and unnecessary increase in risks to

workers and the public. DOE accepted the Board’s recommendation on August 31, 1994, and

submitted its implementation plan on February 28, 1995. DOE broadened the scope of its

response to propose safe interim storage of additional liquids and solids containing fissile
4-3

materials and other radioactive substances in spent fuel storage pools, reactor basins, reprocessing

canyons, and processing lines.

Significant risk reduction and material stabilization were accomplished during the

following two years, and much of the plutonium solutions, special isotopes, and plutonium

residues have been stabilized by the end of 1998. However, stabilization of about 8 metric tons of

plutonium metals, 6 metric tons of plutonium oxides, and more than 200,000 liters of uranium

solutions has not yet been started. Stabilization of spent nuclear fuel is in progress at the SRS

canyon facilities, but has not yet begun at the Hanford Site, which accounts for more than 90

percent of the 94-1 inventory. Additionally, substantial quantities of americium, curium, and

neptunium at SRS remain to be stabilized. In late 1997, it was apparent to the Board that the plan

for most of the remaining stabilization activities was outdated and needed to be revised to ensure

an aggressive but realistic path forward.

In December 1997, the Board requested that DOE develop and submit a revised

implementation plan. During the preparation of this revision, the Board raised many questions

about the impact of proposed changes and compensatory measures being taken as a result of the

proposed delays. In addition, the Board considered that some proposed delays were not justified

by the evidence provided. As a result, DOE delayed submittal of a revised plan, and instead, on

September 2, 1998, provided the Board with an update to show progress toward completing a

revised plan, as well as the current status of Recommendation 94-1 actions and DOE’s then

current estimates for completion of those actions. 

In a letter dated October 8, 1998, the Board expressed concern about the rate of progress

in stabilizing the remaining materials. The Board’s letter indicated that, to be meaningful, the

implementation plan needed revision to provide aggressive paths forward for the remaining

materials and mitigation of the risks caused by continued delays. During the last quarter of 1998,

the Board engaged DOE management on several significant open issues requiring resolution to

support a necessary and acceptable revision. Only after sustained, intensive, interaction by the

Board and its staff did the issues get addressed and resolved. In particular, development of a plan

for stabilizing the plutonium-containing materials at Hanford’s Plutonium Finishing Plant (PFP)

required repeated Board attention. On December 28, 1998, a revised implementation plan for

Recommendation 94-1 was issued by the Secretary of Energy. The revision provides the

following:

! Plans and schedules for the completion of remaining stabilization activities;

! Specific commitment dates for completion of stabilization activities; and

! Assessment of the safety risks associated with delayed stabilization activities and 

compensatory measures being taken to minimize those risks.

In particular, DOE’s revised plan for stabilizing the plutonium-bearing materials at the

PFP at the Hanford Site represents a significant improvement to DOE’s September 1998 

technical update. It provides more aggressive recovery schedules; reflects an enhanced
4-4

understanding of the technical logic and safety risk associated with each activity; and plans for the

preparation and execution of major activities in parallel.

Most of the questionable material is scheduled to be stabilized before the end of 2003. 

Depending on DOE’s success in accelerating the operation of the HB-Line at SRS to stabilize

plutonium and neptunium solutions in H-Canyon, some activities may continue for a few more

years. Additionally, construction of the Actinide Packaging and Storage Facility (APSF) at SRS

may be delayed for as much as two years, which will result in corresponding delays in the

stabilization and storage of plutonium metals and oxides.

The success of the 94-1 program is dependent on aggressive execution of the activities

defined in the revised implementation plan, which will ensure timely stabilization of the remaining

nuclear materials covered by the recommendation. The Board will continue to closely monitor

these activities to ensure that DOE management provides the resources and commitments needed

to accomplish the actions in the revised plan on schedule. 

4.1.1 Plutonium 

Plutonium Finishing Plant 

Throughout 1998, the Board urged DOE to restart plutonium stabilization at PFP and to

plan for meeting Recommendation 94-1 commitments in a timely manner. PFP has a relatively

large inventory of plutonium-bearing materials in unstable forms and packaging exhibiting

degradation. The Board intends to exert pressure on DOE to get these materials safely stabilized

using demonstrated technologies on an aggressive schedule.

Fissile material handling at PFP had been halted in 1996 because of repeated instances of

poor conduct of operations. In April 1998, fissile material movements for laboratory and vault

operations were finally approved, but plutonium stabilization had not yet been restarted. This lack

of progress led to increased Board scrutiny, which has led to some improvements. The Board

issued letters to DOE on April 15, 1998, and July 13, 1998, containing requirements to report on

key problems at PFP. Problems included the lack of aggressive recovery plans for meeting

Recommendation 94-1 commitments, the need for a properly scoped Operational Readiness

Review to ensure the safe restart of plutonium stabilization operations, and the need to consider

more aggressive risk reduction through accelerated stabilization options. At year-end,

stabilization had not yet been restarted.

While response has been slow, the Board appears to have stimulated change at PFP. For

example, PFP initially had failed to supply meaningful input for the proposed change to the

implementation plan for Recommendation 94-1. As a result of pressure from the Board, the

facility chartered a team in November 1998 to develop such input. In addition, in November and

December 1998, PFP carried out a focused Operational Readiness Review to verify the plant’s

ability to safely handle and stabilize plutonium oxides in muffle furnaces. This process did start up

in early 1999.
4-5

In early 1998, the PFP contractor decided to defer thermal stabilization activities for

plutonium oxides and metals until 1999. The Board was not satisfied with this slow approach,

and communicated its concerns to DOE. As a result, the PFP contractor now intends to

implement several of the Board’s suggestions for accelerating stabilization activities during 1999. 

These include completing the installation of three additional muffle furnaces for thermal

stabilization, restarting the prototype vertical calciner to continue development work and to

stabilize some plutonium solutions until the production calciner is operational, and pursuing an

alternative precipitation process used at RFETS for stabilizing impure plutonium solutions. The

Board has also stressed the need to stabilize plutonium-bearing polycubes, which are a high

hazard for plutonium dispersal. The PFP contractor now intends to reestablish interactions with

LANL to procure a pyrolysis unit during 1999 for polycube stabilization.

Stabilization of Plutonium Metal and Oxide 

In Recommendation 94-1, the Board urged DOE to place plutonium metal and oxide in

storage configurations that meet DOE’s standard for long-term storage (DOE-STD-3013). The

Board and its staff have continued to actively follow each site’s preparations for stabilizing and

packaging plutonium metal and oxide to this standard. Some progress on stabilizing plutonium

metals and oxides is continuing. However, little progress has been made in packaging material to

DOE-STD-3013, and delays in construction of the APSF at SRS will further delay DOE’s

progress in this area. DOE has continued efforts to make the requirements of the long-term

storage standard less rigorous. The Board has discouraged such attempts and has insisted that

DOE provide strong technical bases for the adequacy of any proposed changes to the standard.

DOE is procuring automated systems for packaging material to meet the long-term

storage standard. A prototype unit was procured for RFETS. During 1998, DOE had mixed

success with this prototype. Operation of the packaging system was successfully demonstrated,

but difficulties with the stabilization system led DOE to decide not to install this portion of the

unit. Manual stabilization furnaces are planned to be used instead. The prototype unit was

accepted by DOE, and post-acceptance testing has begun and is expected to continue into 1999. 

The Board’s staff plans to continue its oversight of this testing, as well as preparations for

installation of the system in 1999. The Board’s staff has actively encouraged DOE to incorporate

lessons learned from the prototype unit into the procurement of follow-on units for SRS, LLNL,

and the Hanford Site. 

DOE had considered not packaging material at RFETS and the Hanford Site to meet the

long-term storage standard before shipment to SRS for extended storage. The Board did not

believe this was the best option for safe storage of the material. In part because of involvement in

this issue by the Board and its staff, DOE has now decided to package the material to the

standards specifications before shipment. 

Stabilization of Plutonium Solid Residues 

Since the Board issued Recommendation 94-1 in May 1994, DOE has made progress in

reducing the risks and uncertainty associated with “possibly unstable” residues. Of particular 
4-6

note is progress being made at RFETS. On January 29, 1998, the Board wrote to the Secretary

of Energy, encouraging DOE to revise its plans to emphasize timely removal of solid residues to a

final repository, rather than stabilizing most residues. The Board noted that the more hazardous

residues have now been treated and are relatively benign for the near future, and that expeditious

burial of low-risk residues at WIPP without further processing would satisfy the intent of

Recommendation 94-1. Based upon the results of the RFETS residue characterization program,

DOE expects many residues to be reclassified from high to low risk. To resolve plutonium

dispersibility issues under the Board’s Recommendation 94-3, DOE plans to repack dispersible

residues into more robust containers (e.g., pipe overpack containers) pending their shipment to

WIPP.

After years of preparation, residue processing and repacking began at RFETS in 1998. 

Pyro-oxidation of high-risk salts began in January 1998, after the Board had determined that this

operation could be safely started. Approximately 2 metric tons of high-risk salts was oxidized in

1998. Multiple process lines also began repacking ash, dry, and combustible residues in

compliance with the Interim Safe Storage Criteria; more than 4 metric tons of these packaged

materials is now awaiting shipment to WIPP. RFETS modified its combustible repacking strategy

after the Board’s staff identified packaging configurations that did not comply with the Interim

Safe Storage Criteria. The bulk of the remaining work at RFETS involves repackaging the lowrisk residues into pipe overpack containers, stabilizing a small subset of residues as dictated by

characterization, and ultimately removing the residues from RFETS to support earlier site closure.

The Board has consistently noted that many residues could be better processed at facilities

other than those where they are currently stored. During its public meetings on Recommendation

94-1 in mid-1998, the Board noted that only SRS currently had the capability to stabilize RFETS

sand, slag, and crucible residues and encouraged DOE to stabilize these residues at SRS. During

1998, RFETS repackaged approximately 1.5 metric tons of sand, slag, and crucible residues into

shipping containers. Shipment of this material to SRS for processing began in December 1998

after the residue Record of Decision had been issued. 

Stabilization of Liquid Plutonium Residues 

RFETS has continued to make progress in stabilizing plutonium-bearing solutions. In late

1997, solutions containing high concentrations of plutonium were drained into plastic bottles from

four tanks in Building 771. These bottles, along with similar bottles from Building 771 and

Building 776, were transferred to Building 371 and stabilized using the Caustic Waste Treatment

System. (Reviews by the Board’s staff on the conduct of tapping and draining activities in

Building 771 are summarized below in Section 4.5, Deactivation and Decommissioning.) Liquids

from the last criticality line tank in Building 371 were drained in early 1998 and used to blend

down higher-concentration solutions from Building 771 before processing. In June, tapping and

draining of piping began in Building 371, and five areas were drained during the remainder of the

year. New techniques were also used in 1998 to fix contamination in two highly contaminated

rooms in order to simplify future draining operations.
4-7

4.1.2 Enriched Uranium

The Board’s staff continued its oversight of stabilization and removal of uranium fluoride

gases from the Molten Salt Reactor Experiment at ORNL in accordance with Recommendation

94-1. The successful completion of reactive gas removal (primarily fluorine and uranium fluoride)

from the head spaces of drain tanks and from off-gas system piping reduced the total uranium

remaining in the system from greater than 37 kg to less than 15 kg and decreased the pressure

enough to allow preparations to remove uranium deposits from the Auxiliary Charcoal Bed

(ACB) to commence. Chemical operations required to denature the reactive fluorinated charcoal

in the ACB (the first phase of uranium deposit removal) were safely completed following a review

of the proposed operations by the Board’s staff. The Board’s staff will observe the readiness

review for uranium deposit removal and assess the results in early 1999. Subsequent risk

reduction activities include removal of fuel and flush salt from the drain tanks and

stabilization/conversion of uranium to oxides. 

4.1.3 Uranium-233

Uranium-233 (U-233) is a man-made isotope of uranium whose decay products are highly

radioactive. Most of it is stored at ORNL and INEEL, with a smaller quantity at LANL. The

Board issued Recommendation 97-1 to urge DOE to stabilize its U-233 materials and to provide

for their safe storage. The Board recommended that DOE characterize the U-233, develop a

storage standard, assess the adequacy of current storage conditions, and preserve technical

competency in U-233 expertise. Because most of the U-233 at these sites has not been inspected

for many years, there is uncertainty as to the safety of its current storage condition. Moreover,

because of the high radiation associated with U-233, material handling and examination are likely

to be difficult, requiring protection from both alpha particles and gamma rays.

ORNL, LANL, and INEEL have begun to take actions to characterize their U-233

materials. ORNL is constructing two hot cells for performing inspection and stabilization

activities, has designed a shielded enclosure that will protect workers from radiation during

inspection, and is developing an inspection plan. The Board’s staff reviewed ORNL’s plans and

concluded that continued technical oversight by engineering personnel at ORNL will be required

if the inspection program is to be completed safely and successfully.

During the past two years, LANL has visually inspected the exterior of all containers of 

U-233 at the Critical Experiments Facility (TA-18). No visual evidence of degradation has been

found. In the near term, LANL plans to transfer its U-233 to the CMR facility. Ultimately,

LANL plans to ship all but a small amount of its U-233 to ORNL for long-term storage; the

retained material will be used for research purposes. Most of the U-233 at INEEL is contained in

unirradiated fuel assemblies and buried waste. INEEL plans to continue its current visual

inspection program for the exterior of fuel assembly containers. The majority of the remaining U233 material is buried in retrievable waste mounds and cannot be readily inspected. A sampling of

some unburied waste drums opened to check the condition of the packaging showed minor 
4-8

degradation of the drums. Additional inspections are planned to evaluate the condition of some of

the stored materials.

DOE has completed a technical competency study that identified more than 50 U-233

experts within DOE and its contractors. Much of this expertise is centered at ORNL, where a

number of retirees are actively involved in the U-233 Safe Storage Project by mentoring younger

engineers. DOE also formed a 97-1 Technical Team comprising experts from the DOE complex. 

The DOE 97-1 Technical Team completed several implementation plan deliverables. These

included criteria for determining which U-233 is designated as waste, a study to identify long-term

disposition options for U-233, a report on sites with small amounts of U-233 that can be shipped

to ORNL for storage, and an ORNL Building 3019 Alternatives Trade Study.

On October 2, 1998, DOE issued a proposed U-233 safe storage standard. DOE also

produced a System Requirements Document (SRD) for the U-233 Safe Storage Program in 1998. 

After reviewing the standard, the Board issued formal comments to DOE in a letter of December

14, 1998, stating that DOE needed to strengthen its technical basis; ensure that containers do not

contain significant quantities of plastics and volatile materials; and ensure that the required

attributes of materials, packages, and facilities credited as barriers are adequately specified. 

Furthermore, because of the large number of policy, programmatic, and technical uncertainties

identified in the SRD, the Board considers that document incomplete. In 1999, the Board and its

staff will continue to monitor risk reduction through on-site reviews, review of the U-233

inspections, and review of efforts to complete the U-233 standard.

4.1.4 Special Isotopes

Americium/Curium Solution at SRS 

In Recommendation 94-1, the Board recommended expediting the stabilization of

americium/curium solutions stored in F-Canyon. In October 1997, design and construction

activities were suspended as a result of numerous unforseen complications with the proposed

bushing melter vitrification system. In January 1998, after evaluating alternative stabilization

methods, Westinghouse Savannah River Company concluded that vitrification remained the

preferred stabilization method and proposed restarting design activities after sufficient system

research had been conducted.

A staff review of the project identified several areas needing improvement to ensure safe

and timely stabilization of the americium/curium solutions, including the need for a detailed

research and development plan and schedule, improved project management, pursuit of backup

stabilization alternatives, and mitigatation of ongoing solution storage risks. On July 10, 1998,

the Board issued a letter communicating these observations to DOE, with a 45-day reporting

requirement. In response to the Board’s letter, WSRC made several changes in the

americium/curium project. A more detailed research and development plan and schedule were

issued in August 1998; periodic updates are planned. A new project management structure was

established to improve management focus on the project. Several backup alternatives for the

vitrification process are being researched. Additional safety controls for the americium/curium
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storage tank are being implemented. Design activities resumed in October 1998, and a substantial

portion of the design is planned for completion by May 1999. The Board and its staff continue to

monitor the progress of the americium/curium stabilization project. 

Neptunium Solution at SRS 

SRS has 6,000 liters of neptunium-237 nitrate solution in H-Canyon. A decision on the

method to be used for processing this solution has been delayed until DOE’s Office of

Environmental Management and DOE’s Office of Nuclear Energy develop a memorandum of

agreement formalizing commitments for the stabilization of this solution and its transfer from the

site. Pending resolution of the form and method of disposition, compensatory measures have

been implemented to reduce the risk associated with the material; these measures include a

sampling and monitoring program, cooling system modifications, and preparation of actions in

case deficiencies occur in current storage conditions. The implementation plan for

Recommendation 94-1 committed DOE to stabilizing and packaging the neptunium material by

December 2002. This date was subsequently revised to September 2003 and accepted by the

Board. However, the delays experienced in determining the disposition form and method for this

material appear to have caused a further delay of at least 6 months past this revised date.

4.2 STABILIZATION OF SPENT NUCLEAR FUEL

DOE’s National Spent Nuclear Fuel Program coordinates activities at the various DOE

sites involved in placing spent nuclear fuel into safe interim storage. An additional goal of this

program is to ensure that the canisters used for interim storage can be used for shipment to and

burial at a national repository without repackaging. During 1998, the Board’s staff worked with

DOE’s staff to emphasize coordination of spent fuel storage activities at the Hanford Site, SRS,

and INEEL.

4.2.1 Hanford Site

Deteriorating spent nuclear fuel in the K-Basins at the Hanford Site has the potential to

release radioactive contamination to the environment, posing a threat to the health and safety of

workers and the public. In response to Recommendation 94-1, DOE made a commitment to

remove the spent fuel from the basins, stabilize it, and place it in interim dry storage at the site. 

Initially, DOE planned to initiate spent fuel removal by December 1997 and to complete it by

December 1999. However, in 1997, the Spent Nuclear Fuel Project experienced substantial

delays because of equipment design changes and modifications to the spent fuel stabilization

process. On November 17, 1997, the Board transmitted to DOE its report DNFSB/TECH-17,

Review of the Hanford Spent Nuclear Fuel Project. This in-depth technical and project review

identified deficiencies in the project’s processes and practices for identifying and resolving

technical and safety issues, and noted that these deficiencies could lead to additional delays.

In 1998, DOE outlined corrective actions needed to improve SNFP project management

and ensure the timely and technically justifiable resolution of emerging issues. Additional major
4-10

delays were identified during 1998 as the SNFP developed a revised project schedule that

proposed commitment dates for the start of fuel removal by the end of November 2000 and for

the completion of fuel removal by the end of December 2003.

During 1998, the Board and its staff closely followed project progress in the design, safety

analysis, and construction of the SNFP facilities. During numerous meetings and discussions with

DOE and in a letter to DOE in March 1998, the Board and its staff questioned the design basis for

the Multi-Canister Overpack, which is intended to provide primary containment of the spent fuel

during stabilization and storage. As a result, the design was revised to use more conventional

materials, to provide periodic monitoring during storage, and to require code stamping to

demonstrate compliance with American Society of Mechanical Engineers Code for nuclear

components. 

Additionally, reports documenting reviews by the Board’s staff of instrumentation and

control systems and fire protection for the proposed process facilities were forwarded to DOE in

February and December 1998. DOE’s response to these reports resulted in a reduced hazard of a

hydrogen explosion in the battery rooms and in improved calibration of the electrical protective

devices at the K-Basins. DOE is evaluating additional actions in response to these letters to

further improve safety. The Board and its staff intend to continue to review the SNFP to ensure

urgent reduction of the risks associated with continued storage of the spent fuel in the K-Basins.

4.2.2 Savannah River Site

In a previous technical report issued by the Board (DNFSB/TECH-7, Stabilization of

Deteriorating Mark 16 and Mark 22 Aluminum-Alloy Spent Nuclear Fuel at the Savannah River

Site), the technical rationalization was established for using chemical separation to stabilize the

deteriorating defense-related spent nuclear fuel stored in the basins at SRS. The Mark 31 target

elements had been stabilized in the F-Canyon/FB-Line prior to 1998. During 1998, stabilization

of Mark 16 and Mark 22 spent nuclear fuel elements continued in the H-Canyon. To date, about

147 of 154 metric tons of heavy metal fuel have been stabilized. In its implementation plan for

Recommendation 94-1, DOE made a commitment to complete stabilization by November 1999;

this date was later revised to December 2000. The date continues to slip, and stabilization is now

expected to be completed in December 2001. The Board’s staff considers these operations as

necessary to verify the continued use of appropriate safety measures and to ensure the timely

resolution of safety issues. The Board has placed specific emphasis on the need for DOE to

demonstrate the most technically justified process for stabilization; this emphasis has contributed

to the attainment of measurable progress in remediating the problem of deteriorating spent nuclear

fuel.

A large inventory of non-defense-related, aluminum-alloy spent fuel is also in wet storage

in defense nuclear facilities at SRS. This inventory will continue to increase as additional fuel is

received from off-site research reactors and other DOE sites. This aluminum-based spent fuel

cannot be left in wet storage indefinitely, and will likely require treatment before ultimate 

disposal. DOE is continuing to evaluate alternatives for removing this spent fuel from wet
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storage. The Board reviewed these developments during 1998 and intends to continue to monitor

DOE’s progress, particularly as it affects defense nuclear facilities. 

4.2.3 Idaho National Engineering and Environmental Laboratory 

The implementation plan for Recommendation 94-1 committed DOE to remove fuel from

the CPP-603 Basin, a spent fuel storage basin at INEEL, by December 2000 because of concerns

with underwater spent fuel storage conditions. DOE has met all milestones to date. Most spent

fuel that does not require overpacking has been removed from CPP-603. Approximately 225 fuel

units were removed from the CPP-603 fuel basins during 1998, leaving only 229 units. The

Board and its staff continue to review these activities to ensure that they are performed in a timely

and safe manner.

4.3 STORAGE OF HAZARDOUS MATERIALS

Since ultimate disposition of most legacy materials is many years away, it is important to

ensure that these materials are adequately and safely stored in the interim. During recent years,

the Board has issued several recommendations intended to upgrade storage conditions for these

materials, and the Board continues to review new storage areas and evaluate existing storage

conditions.

4.3.1 Plutonium Storage Facilities at the Savannah River Site—Actinide Packaging and

Storage Facility and K-Area Material Storage

The Board’s Recommendation 94-1 addressed the need to stabilize surplus plutonium

metal and oxide and provide safe interim storage of this material. After stabilization and

packaging, DOE intends to ship surplus plutonium from the Hanford Site and RFETS to SRS and

store it with SRS material in two facilities—APSF and the K-Area nuclear materials storage

project. DOE’s plans are described in the amended Record of Decision on Storage and

Disposition of Weapons-Usable Fissile Materials (August 1998), and depend upon SRS being

selected as the surplus plutonium immobilization site. Numerous reviews by the Board and its

staff have focused on the planning, safety analyses, and design activities for these two facilities.

APSF is intended to stabilize and repackage SRS plutonium by May 2002, in accordance

with the DOE implementation plan for Recommendation 94-1, and to provide safe, secure storage

of special nuclear material for up to 50 years. This project has been subject to shifting project

requirements and increasing scope, including expansion of its mission from storing only SRS

material to storing all surplus material from the Hanford Site, as well as some material from

RFETS. While much progress on design has been made in 1998, the current schedule for

construction, start-up, and operation of APSF is optimistic. 

Because numerous safety issues, as well as DOE’s surplus plutonium disposition strategy,

depend on timely APSF start-up, the Board has closely monitored progress on the design and

construction of this facility. In February 1998, the staff reviewed an early version of the system
4-12

design packages and concluded that more details were needed to assist the constructor,

particularly the identification of codes and standards being invoked and the systems and

components that are important to safety. Also in early 1998, the Board and its staff made

suggestions for improving the robustness of the structural design and confirming design

assumptions. For example, it was known early in 1997 that a soil soft zone existed beneath the

planned footprint of the facility, but by early 1998, this soft zone still had not been adequately

characterized. In February 1998, DOE and WSRC agreed to perform a more comprehensive

geotechnical investigation to ensure an appropriately safe structural design. Also during 1998,

DOE and WSRC increased the design tornado loading and completed a thorough seismic

verification study, following suggestions of the Board and its staff.

Furthermore, to improve confidence in the seismic design and evaluation of SRS facilities,

the Board’s staff and DOE initiated a generic review of ground motion assumptions at SRS. The

questions explored included (1) the magnitude and distance assumptions used to bound the 1886

Charleston earthquake, (2) the historical record of nearby ground motion estimates from the

Charleston earthquake, (3) modeling of the crustal structure for the attenuation of ground motion,

(4) modeling of probabilistic ground motion parameters, and (5) comparison of detailed sitespecific data on the seismic hazard with generic data on national seismic hazard maps prepared by

the U.S. Geological Survey. Considerable progress was made in addressing these issues, and as a

result, SRS has modified design practices for future designs to improve structural performance

under extreme loads. Continuing efforts in this area should streamline the selection of appropriate

seismic design criteria and ground motions, thus ensuring the safe design of future defense nuclear

facilities at SRS.

By the end of 1998, staff reviews of APSF had concluded that there were still open safetyrelated items, particularly for electrical and fire protection systems. DOE and WSRC need to

continue to apply high-level attention to managing the remaining issues. One difficult challenge

will be the installation, start-up, and operation of the plutonium stabilization and repackaging

system, in light of the difficulties experienced at RFETS during start-up of a similar system. The

Board will continue to closely follow progress on these matters.

The K-Area nuclear material storage project started in early 1998 and is an outgrowth of

the APSF project. In early 1998, DOE began to pursue early closure of RFETS, and developed a

strategy dependent upon SRS receiving RFETS material starting in 2000, about 1 year before

APSF is due to be completed. Since APSF would not be ready, DOE began planning to upgrade

K-Area facilities and to store shipping containers of properly stabilized and packaged RFETS

material in K-Area. This strategy takes advantage of extensive upgrades completed in the early

1990s to support K-Reactor start-up. Additional modifications are required for security,

criticality monitoring, and structural repairs. Of particular interest from a safety standpoint is the

planned longer-term use of certified shipping containers to maintain plutonium containment in a

storage environment. The Board and its staff will continue to review the planned K-Area

modifications and supporting safety analyses, as well as progress in APSF design and

construction.
4-13

4.3.2 Building 371 at the Rocky Flats Environmental Technology Site

The Board issued Recommendation 94-3, Rocky Flats Plutonium Storage, to ensure that

the large quantity of SNM at RFETS would be safely stored. The Board recommended that DOE

take a systematic approach to evaluating the suitability of Building 371 for the proposed new

mission of storing the site’s entire SNM inventory, and prepare a program plan for building

upgrades and improvements consistent with the building’s mission. Based on its reviews, the

Board had concluded that activities to prepare Building 371 for this role were neither logically

structured nor sufficiently broad in scope to ensure that the material would be adequately stored. 

In response, DOE determined that upgrades to Building 371's structure, systems, and

components, as well as its safety basis, were needed. The Board and its staff followed DOE’s

progress closely and were instrumental in DOE taking a systems engineering approach to

evaluating and developing upgrades, as well as integrating this approach into project management. 

Without the Board’s proactive interaction, these evaluations would not have been completed in a

timely manner. 

In mid-1998, the Board’s staff had reviewed progress on upgrades, the design adequacy of

several upgrades, and the implementation of a new safety basis for the building. As a result of the

Board’s Recommendation 94-3, the safety basis was upgraded to be adequate for the building’s

mission. However, the staff’s review had also identified the fact that analysis of one upgrade was

inconsistent with accepted industry practice, and analysis of another upgrade functional test

contained errors. Based on this review, the Board suggested that DOE independently evaluate

work packages to ensure that the functional requirements of the upgrades have been satisfactorily

met. DOE completed an independent review, which revealed that in general, upgrades were

satisfactory, but additional controls were needed, and several issues required further resolution.

4.3.3 Uranium Hexafluoride Storage

Approximately 50,000 cylinders containing more than 500,000 metric tons of depleted

uranium hexafluoride from the production of enriched uranium for both defense and civilian

purposes are stored outdoors in carbon steel cylinders at gaseous diffusion plants in Oak Ridge,

Tennessee; Portsmouth, Ohio; and Paducah, Kentucky. In Recommendation 95-1, Improved

Safety of Cylinders Containing Depleted Uranium, the Board recommended that DOE (1) begin

an early program to improve the corrosion resistance of the cylinders, (2) evaluate additional

measures that would protect the cylinders from corrosion, and (3) determine the proper form for

long-term storage of the uranium hexafluoride. 

In response, DOE has taken substantial actions to slow the degradation of cylinders from

external corrosion. Handling, inspection, surveillance and maintenance procedures have been

upgraded, and more than 20,000 visual inspections of cylinders have been performed. Hundreds

of severely corroded cylinders have been measured ultrasonically for wall thickness, and cylinder

recoating efforts are well under way for cylinders with the highest levels of corrosion. A pilot lot

of approximately 2,200 cylinders has been recoated at Paducah, and production programs at Oak
4-14

Ridge and Paducah started up in June 1998 and have recoated about 1600 cylinders to date. 

More than 1,000 cylinders are projected to be completed annually.

In December 1997, in response to a June 1997 letter from the Board regarding inadequate

coverage in the Final Safety Analysis Report of a cylinder handler fire that would cause a rupture

of a cylinder, DOE committed to a new set of controls. During 1998, the needed safety controls

were implemented, including installation of fire suppression equipment. Technical Safety

Requirements were modified to limit the allowable cylinder handler fuel loading, and additional

procedural and maintenance controls were developed and finalized. 

4.3.4 Hazardous Chemical Storage 

The Board’s staff is reviewing the chemical safety programs at all major DOE sites, even

though chemical safety is not specifically under the Board’s cognizance. This is because

unplanned chemical reactions could lead to the release of radioactive material at defense nuclear

facilities, and such incidents are within the Board’s purview. The Board has observed that DOE

has not rigorously followed up on its Chemical Vulnerability Study of 1994 or the Secretary of

Energy’s safety initiatives following the explosion at the Plutonium Reclamation Facility in May

1997. Since the Board’s staff began its chemical safety study, DOE Headquarters has established

a combined DOE/Contractor Chemical Safety Interest Group under the auspices of the Energy

Facilities Contractors Group to formulate chemical safety issues and propose possible resolutions

to DOE for line management action. The Board has expressed concern about the initial lack of

line management involvement in the chemical safety issue. Line management involvement is a

fundamental part of integrated safety management necessary to establish appropriate chemical

safety controls.

The Board has also initiated a dialogue with the Center for Chemical Process Safety and

has encouraged DOE’s ES&H secretarial officers to similarly engage. Operating under the

auspices of the American Institute of Chemical Engineers, the Center has much to offer regarding 

good chemical safety practices.

The Board’s staff has observed deficiencies in the characterization of legacy chemicals and

the incorporation of chemical safety programs into ISM programs at the major sites. For

example, SRS does not have a chemical management program that is integrated with its nuclear

safety program. After meeting with the Board’s staff in October 1998, DOE called for the

establishment of such a program, and followed up on several identified deficiencies in the safety

program. RFETS and the Hanford Site have made progress in incorporating chemical safety into

their ISMSs. The Hanford Site now requires its contractors to use an automated hazards

identification form that helps identify chemical hazards. However, Hanford has not characterized

all of its legacy chemicals, especially those in miscellaneous inactive underground storage tanks,

as required by the Secretary of Energy’s more recent directives.

Two reviews conducted by the Board’s staff at the Y-12 Plant have disclosed weakness in

job hazard analysis procedures relevant to chemical safety. Several facilities contained abandoned

and excess or improperly stored chemicals not addressed in the facility safety basis.
4-15

Acknowledging such deficiencies, the contractor has indicated it would make improvements in

conjunction with the implementation of ISM at the Y-12 Plant. Recently, the Board’s staff noted

some improvement in the storage conditions at the facilities.

Chemical reactions have caused several problems in radioactive waste packaging

operations at the Fernald Environmental Management Project during the past two years. 

Investigation by DOE found that procedures and management systems were not adequate to

prevent the packaging of chemically incompatible wastes together in a single container. After

these events occurred, the Board’s staff held discussions with DOE and the contractor regarding

the root cause of the events and proposed corrective actions. Questions and comments by the

Board’s staff led to improved quality and level of detail of the reviews, and to upgraded safety of

waste management operations. The Board’s staff will continue to follow not only safety

management at Fernald in general, but also the nexus of chemical safety and nuclear safety.

4. 4 WASTE MANAGEMENT

In keeping with the Board’s statutory mandate to ensure the establishment of appropriate

safety standards for DOE’s activities, the Board has emphasized the importance of issuing DOE

Order 435.1, Radioactive Waste Management, to incorporate the safety-related measures of

Recommendation 94-2 and as a replacement for the existing DOE Order 5820.2A. DOE Order

435.1 addresses three major waste types—high-level, transuranic, and low-level waste—and the

safety requirements for design, construction, operation, and decommissioning of associated

facilities. The following subsections address, for each of those waste types, those activities in

defense nuclear facilities essential for the protection of the health and safety of the public.

4.4.1 High-Level Waste

Savannah River Site In-Tank Precipitation Facility 

The In-Tank Precipitation (ITP) Facility was intended as a pretreatment facility for use in

concentrating and removing radioactive fission products from high-level waste liquids at SRS. 

The separated fission products would have been processed at the Defense Waste Processing

Facility. The decontaminated liquids would have been processed at the Saltstone Production

Facility. With the ITP process, chemical and radiolytic decomposition of the tetraphenylborate

precipitating agent occurs, generating substantial quantities of benzene, a flammable and

carcinogenic gas. If the accumulated precipitates were to decompose rapidly, the resulting

benzene release could be very large. Such an event would pose a major flammability hazard. The

Board’s Recommendation 96-1, In-Tank Precipitation System at the Savannah River Site, was

issued in August 1996 to ensure that the hazards associated with the ITP process would be

adequately understood and controlled before the ITP Facility commenced operations. Laboratory

experiments carried out in response to Recommendation 96-1 confirmed the Board’s concerns

and led DOE to conclude early in 1998 that the ITP process could not be operated safely without

significant upgrades to the ITP Facility. As a result, DOE has halted efforts to begin operations at

the ITP Facility, and alternatives to the ITP process are under evaluation. 
4-16

The Board has carefully reviewed the methodology DOE is using to evaluate alternative

waste treatment technologies, as well as the results of these evaluations. DOE began with a wide

variety of candidate technologies and systematically reduced the field to four finalists: small-scale

tetraphenylborate precipitation, nonelutable ion exchange, caustic-side solvent extraction, and

direct grouting of tank liquids without cesium removal. The Board agrees that each of these

options could be carried out safely, but each also has its own strengths and drawbacks. Notable

drawbacks include the need to deal with benzene in downstream facilities for the small-scale

tetraphenylborate option, the large radiological source term of the loaded nonelutable exchange

media, the immaturity of the caustic-side solvent extraction process, and the need for on-site

disposal of large quantities of radioactive cesium for the direct grouting option. DOE has not yet

decided how to proceed from this point, but the Board expects a decision to be made soon. 

Immobilization of high-level waste at SRS remains one of the Board’s highest priorities, and the

Board will continue to review DOE’s efforts to select a safe and effective process to replace ITP.

While DOE considers alternatives to the ITP Facility, the remnants of process testing at

the ITP Facility are continuing to pose hazards. Tank 49, which holds radiologically

contaminated, tetraphenylborate-bearing wash water from ITP process testing, was recently

discovered to generate benzene at rates greater than the authorization basis limits for flammability. 

This problem resulted from inadequate control of the tank chemistry, which allowed conditions

known to be favorable for benzene generation to arise. As a corrective action, the vapor space in

this tank has been inerted with nitrogen, and improved flammability controls are being established. 

Tank samples indicate that virtually all the tetraphenylborate in the tank has already decomposed,

and the benzene hazard should end once the intermediate decomposition products themselves

decompose. The Board has reviewed draft versions of the proposed controls and will endeavor to

ensure that the final controls provide adequate protection for the short period of time during

which the benzene releases are expected to persist. This problem is a clear illustration of the need

to fully understand and control process chemistry in waste treatment facilities. It also provides

further incentive to use caution in pursuing the application of tetraphenylborate precipitation for

high-level waste processing.

SRS High-Level Waste Facilities 

A major upcoming activity at SRS is the 1999 start-up of the Replacement High-Level

Waste Evaporator. This large new facility, located within the tank farms, will be used to

concentrate high-level waste in order to conserve tank space at SRS. The site contractor

recommended to DOE that only a contractor Readiness Assessment be conducted to verify the

readiness of the facility prior to start-up. The Board preferred that the applicable DOE Order,

425.1, Startup and Restart of Nuclear Facilities, be followed. This Order clearly requires a full

Operational Readiness Review, which includes independent verification of readiness for new

nuclear facilities such as the new evaporator. After numerous interactions between DOE and the

site contractor, and the Board’s staff, DOE decided in 1998 that a full Operational Readiness

Review should be performed. The Board believes this more rigorous review will provide better

assurance that the new evaporator can operate safely.
4-17

The Board also reviewed high-level waste operations at SRS. In general, those operations

were found to be conducted in a formal, well controlled manner. However, an effort to add water

to Tank 8 high-level waste in preparation for its retrieval was found to be fraught with problems

not recognized by the site contractor or DOE. Tank 8 is a 1950s-vintage single-wall tank that sits

in a 5-foot-tall steel pan to contain leaks. Preparations for responding to potential leaks from the

tank during the water addition were inadequate. Equipment needed to remove waste from the

tank in the event of a leak was inoperable, the installed transfer jet was located too high above the

waste to be useful, the response procedure was still in draft form, and the amount of water to be

added was sufficient to overflow the leak collection pan. These concerns were identified to DOE,

leading SRS to apply a more rigorous ISM methodology to this activity, which resulted in

significantly improved planning and controls. This incident emphasizes the importance of

continued attention to detail for every nuclear operation, even at sites with strong site-wide safety

management systems and generally good conduct of operations.

Tank Waste Remediation System at Hanford 

One of the most difficult tasks facing DOE is remediation of the more than 50 million

gallons of high-level radioactive waste currently stored in 177 underground storage tanks at the

Hanford Site. The system for storing, retrieving, processing, and immobilizing this waste is

TWRS. The Board considers adequate characterization of the wastes at the Hanford Site to be

the necessary first step in ensuring their safe storage, processing, and disposal. The Board has

issued three sets of recommendations on this subject. Largely at the Board’s urging, DOE has

made substantial progress in the sampling and characterization of the wastes. The Board held a

public meeting at the Hanford Site in August 1998 to discuss this progress. Information provided

at that meeting indicated that a total of 139 of the tanks have been sampled. DOE has completed

the sampling, characterization, and theoretical analysis associated with potentially explosive

organic complexant mixtures, and has since issued a report showing that an explosion or fire

cannot occur. DOE also has implemented a high-volume sampler for obtaining waste samples

needed for designing processing systems in a timely fashion. 

The progress DOE has made in characterizing the Hanford wastes is commendable;

however, continued sampling and characterization of the remaining tanks will certainly provide

additional necessary information. In particular, refined sampling techniques for flammable gases

in the waste will aid in closing the flammable gas safety issue. Continuing to sample for organic

solvents may allow DOE to narrow the number of tanks potentially at risk of an organic solvent

burn. Lastly, additional characterization may be prudent to identify tanks with extreme chemical

characteristics that may make processing difficult. DOE has been advised by the Board that this

information could be useful in designing optimal blending sequences for providing feed for

TWRS.

In 1992, while reviewing the design of one TWRS project, the Multi-function Waste Tank

Facility, the Board found that this project, and indeed the rest of the TWRS, suffered from the

lack of a systematic design process. In Recommendation 92-4, Multi-Function Waste Tank

Facility at the Hanford Site, the Board recommended that DOE establish a systems engineering
4-18

process to ensure that all system requirements, including those necessary for the protection of

health and safety, are considered for all phases of the system’s life cycle.

In 1998, DOE satisfactorily completed all the commitments in its implementation plan for

Recommendation 92-4. As reported in the Board’s 1997 Annual Report, primary among DOE’s

improvements in systems engineering was development and use of the TWRS Program Logic,

which identifies the logical flow of the TWRS efforts, including primary prerequisites,

chronology, and interfaces. The Board recognized this logic as integral to the successful

management of the TWRS and requested that DOE provide periodic updates on its evolution. In

these updates, DOE successfully showed that the logic had been further defined at lower levels

and was having a beneficial impact on the overall progress of the system, including the start-up of

the new cross-site transfer line and initiation of retrieval of high-heat waste from Tank C-106. 

The Board considers the development of systems engineering at TWRS to be a success and

worthy of application to the site as a whole.

Removal of High-Level Waste from Tank C-106 at the Hanford Site

The process of removing about 200,000 gallons of high-level nuclear waste sludge from

the 50-year-old single-shell Tank C-106 and transferring the waste to double-shell Tank AY-102

was begun in late 1998. Tank C-106, the highest heat-generating single-shell tank at the Hanford

Site, required the addition of 6,000 gallons of water each month to cool the waste. The removal

of waste from Tank C-106 reduces the potential for leakage to the environment and eliminates the

monthly addition of water. The waste is removed using a high-pressure liquid jet and vertical lift

pumps to mobilize and remove the waste. This is the first attempt to transfer radioactive waste

sludge at Hanford since 1978. Once the waste has been transferred to Tank AY-102, it will serve

as the high-activity feed for the initial phase of waste vitrification operations planned at the

Hanford Site. 

The Board and its staff have closely followed and reviewed contractor and DOE activities

on the Tank C-106 project, including the Safety Analysis Report and Technical Safety

Requirements. The Board’s staff also evaluated the DOE Operational Readiness Review

completed before waste transfer operations were allowed to begin. Waste transfer operations

began on November 18, 1998, but were stopped after the release of volatile organic compounds

(VOCs) from Tank C-106 exceeded the permit limit. Operations will not be resumed until

process or equipment changes are made to reduce the VOC releases below the permit limit. The

Board’s staff intends to follow the resolution of this issue and the progress of activities toward

removal of the Tank C-106 waste sludge in 1999. 

High-Level Waste Tank Level Rise in Tank 101-SY 

Prior to the installation and subsequent periodic use of a mixer pump in 1993, the waste

level in Hanford Tank 101-SY had been observed to rise as a result of accumulation of

flammable gas in the sludge beneath a liquid supernate layer in the tank. When the sludge had

accumulated enough gas, it became buoyant and rapidly rolled over, resulting in a significant

release of flammable gas to the vapor space in the tank. The mixer pump had been operated
4-19

periodically to stir the waste sufficiently to prevent the buildup and rapid release of flammable gas

in the tank.

In late 1997, DOE discovered that the waste level in Tank 101-SY had risen 2 to 4 inches

during the year. Since then, the waste level has continued to rise. Applying the information

gained from its tank waste characterization program and using the systematic approach developed

in response to Recommendation 92-4, DOE methodically investigated this phenomenon,

developed a plausible explanation, and planned a course of action. DOE concluded that the rise in

waste level is the result of accumulated gas and that there is no credible release mechanism that

could cause the vapor space in the tank to reach flammable concentrations. However, the level

rise cannot be permitted to continue unabated. DOE plans to perform additional characterization

of the tank waste and to transfer a sufficient amount of waste to Tank 102-SY in order to mitigate

the problem. The waste currently in Tank 102-SY must be transferred to the East Tank Farms,

necessitating the first use of a new cross-site transfer line. These activities, in addition to the

planned sluicing of Tank C-106, represent a significantly higher operational tempo at the tank

farms than that executed in the recent past. During 1999, the Board and its staff will continue to

follow this safety issue closely and evaluate DOE’s progress toward its resolution.

4.4.2 Low-Level Waste

Recommendation 94-2 called for a complex-wide review of DOE’s low-level radioactive

waste program to establish the dimensions of the low-level waste problem and identify suitable

corrective actions. Most of the actions proposed in the recommendation either have been

completed or are currently being addressed appropriately. Remaining open actions include

meeting the requirement for “development and issuance of additional requirements, standards or

guidance on low-level waste management that address safety aspects of waste form and

packaging, burial ground siting and performance assessment, facility design, construction,

operation, closure, and environmental monitoring.” This action has been subsumed under DOE’s

efforts to produce a new overall waste management Order (435.1) to replace existing DOE Order

5820.2A. Substantial progress has been made on this new Order; it is expected to be issued in

early 1999. Two additional actions remain necessary for closure of Recommendation 94-2. The

first is the completion, or evidence of satisfactory progress toward completion, of the remaining

comprehensive performance assessment analyses for existing low-level waste burial grounds. The

second is the implementation of an acceptable strategy for meeting outstanding low-level waste

research and development needs. The Board intends to work with DOE toward closing this

recommendation by the end of 1999.

4.4.3 Transuranic Waste

Waste Isolation Pilot Plant 

WIPP, a geologic repository intended for the disposal of defense transuranic nuclear

wastes, was excavated out of a rock salt formation, 2150 feet below the desert surface, 26 miles

east of Carlsbad, New Mexico. The Board has been reviewing the operational safety of WIPP
4-20

since early 1990. After several years of reduced attention to WIPP, reflecting continued

operational delays resulting from various administrative, procedural, and legal obstacles, the

Board increased its efforts in late 1997 in response to DOE’s planned mid-1998 start-up of WIPP

disposal operations. The Board’s staff reviewed WIPP authorization basis documentation, as well

as the waste characterization and certification audit process used by the DOE Carlsbad Area

Office for the storage/generator sites expected to make initial shipments to WIPP for disposal.

In 1998, the Board’s staff evaluated DOE’s Operational Readiness Review for WIPP. 

The Board’s staff also reviewed an emergency preparedness exercise and the safety and reliability

of the mine hoist intended for transport of waste below ground for disposal. Based on these

efforts and on an assessment of past review efforts by the Board and its staff, the Board

concluded that WIPP could be operated safely. The Board reported this conclusion to the

Secretary of Energy in a letter dated June 23, 1998.

DOE expects that the issues causing continuing legal and administrative delays will finally

be resolved in 1999. It is the Board’s intention, therefore, to carefully track WIPP developments,

and conduct reviews to ensure that the readiness to operate safely demonstrated in 1998 is carried

over into 1999 and through start-up of waste disposal operations.

Advanced Mixed Waste Treatment Project at Idaho National Engineering and

Environmental Laboratory 

In December 1998, the Board forwarded to DOE the results of a staff review of the design

for the Advanced Mixed Waste Treatment Project. This project is a privatization effort to

retrieve, characterize, treat, and package a large inventory of low-level transuranic waste that

originated from defense nuclear facilities elsewhere in the DOE complex. The design is in the

early stages. Operations are scheduled to begin by 2003. Preliminary staff reviews indicate that

much of the design to date appears sound, but that more effort is required on preliminary safety

analyses and on identification of structures and systems relied upon to perform safety functions. 

This identification is a key step in the design process since it determines which codes and

standards should be invoked for safety-related structures, systems, and components. A thorough

identification of safety systems early in the design can avoid the significant delay and disruption

that would be required later in the design to correct deficiencies. The Board intends to assist

DOE through its attention to the safe design aspects of this project.

4.5 DEACTIVATION AND DECOMMISSIONING

The Atomic Energy Act requires that the Board review and evaluate the content and

implementation of standards (including applicable DOE Orders, rules, and requirements) relating

to the design, construction, operation, and decommissioning of each DOE defense nuclear facility. 

After DOE determines that facilities are no longer needed to support the weapons program, the

facilities will be deactivated and eventually will be decommissioned for reuse or dismantlement.
 Formerly referred to as the Mound Plant. 6

4-21

The Board has placed emphasis on:

! The need to stabilize special nuclear materials that are unstable residues of the

weapons production program so they can be safely stored until final disposition.

! The initial clean-out of relatively stable, yet hazardous, materials in process lines,

tanks, ducts, and other process equipment to allow contaminated facilities to be

deactivated to a safe standby state.

! The location and characterization of known radioactive residuals after initial

deactivation, to facilitate the planning required by the Environmental Protection

Agency and the states before final demolition and cleanup commences when the

Resource Conservation Recovery Act applies. DOE and EPA have agreed by

memorandum of understanding that decommissioning activities will be conducted as

Comprehensive Environmental Response, Compensation and Liability Act 

non-time-critical removal actions.

An objective of the Board regarding the hazardous remnants of weapons production is to

confirm that DOE is aggressively pursuing the safe deactivation of excess defense nuclear

facilities that pose a high risk to workers or the public. This objective is achieved by assessing the

adequacy of DOE’s risk-based approach for deactivation of excess defense nuclear facilities

through evaluation of work activities. Facilities are selected for review based on a determination

of potential risks to workers and the public. 

During 1998, the Board focused its attention on standards development and deactivation

and decommissioning activities at RFETS, the Hanford Site, the Y-12 Plant, and the Miamisburg

Environmental Management Project (MEMP). The number of clean-up projects selected by the 6

Board for priority attention, using the considerations set forth above, is small relative to DOE’s

total environmental restoration program.

4.5.1 Activities at the Rocky Flats Environmental Technology Site

In 1998, the Board’s staff reviewed the hazard analysis and identified safety controls for

several RFETS decommissioning work packages. In addition, the staff performed extensive

oversight of decommissioning activities to evaluate conduct of operations and radiological

practices. Based on these observations and a series of radiological incidents, the staff discussed

with RFETS the controls required to mitigate the identified hazards. The staff had two general

concerns in this area. First, RFETS tended to rely on personnel protective equipment rather than

engineered controls to eliminate or mitigate the hazards. Second, some of the engineered 

controls in use (e.g., air movers) had not been analyzed to ensure that they produced the desired 

result. Partly in response to these concerns, a multidisciplinary team was chartered at RFETSto

develop a new generation of size-reduction tents with more rigorous engineered controls and 
4-22

analyzed performance. RFETS is also investigating the use of remote size reduction for

contaminated equipment. The Board’s staff intends to follow these initiatives in 1999.

Building 779

Decommissioning activities at Building 779 (the former Plutonium Process Development

Building), a moderate-risk plutonium facility, were approached as a pilot project, with the

objective of applying knowledge and experience gained during this closure to future

decommissioning activities at high-risk facilities at RFETS. Decommissioning of Building 779

began in early 1998 upon approval of the Decommissioning Operations Plan and successful

completion of a management review. During 1998, approximately 90 gloveboxes were

disconnected, size-reduced, and removed from the building. In addition, ducting removal began

in the fall. The Board’s staff oversaw the three readiness reviews conducted for removal of

gloveboxes, implementation of the new BIO, and removal of ducting. The Board’s staff also

reviewed the implementation of an ISMS. In addition to the issues discussed in the preceding

section, the Board’s staff identified potential improvements in pre-evolutionary briefs, air

sampling of the workers’ breathing zone, and qualifications of operations personnel. These items

were addressed by RFETS during 1998. The Board’s staff, in cooperation with EPA and state

authorities, plans to continue its review of Building 779 decommissioning until the nuclear

hazards have been substantially reduced through completion of the removal of gloveboxes and

contaminated ducting next year. 

Building 771 

The Board has identified Building 771 (the former Plutonium Recovery Facility) at

RFETS as one of the highest-priority defense nuclear facilities slated for decommissioning. 

Building 771 contains more than 50 kg of plutonium held up in gloveboxes, ducts, equipment,

plenums, furnaces, tanks, piping, and contaminated rooms or areas. In 1998, as part of activities

addressing Recommendation 94-1, RFETS began tapping and draining the actinide and reagent

solutions held up in piping and tanks. The Board endorses RFETS’s proposal to DOE to remove

the process piping immediately after the system has been drained rather than waiting several years;

this approach is expected to provide efficiency benefits. During 1998, the piping associated with

two reagent systems and an actinide system was removed. Oversight of these activities by the

Board’s staff has consisted of reviews of the hazard analyses and work packages, observation of

two readiness reviews, and observation of the pipe removal activities. These reviews identified

improvements that could be made in the verification and validation of the procedures, the training

of the operators, and line management’s ability to decide when it was time to conduct the

readiness reviews. These matters were addressed by DOE and its contractor as part of the

resolution of readiness review findings.

The Board’s staff also identified several situations in which inadequate radiological

controls were to be used for removing contaminated process piping. As a result of a discussion of

this issue between the staff and RFETS personnel, the radiological controls were strengthened by

requiring the use of more contamination containment, ventilation, and personnel protective

equipment to reduce the spread of contamination and protect the workers against surprise
4-23

hazards. The Board’s staff, in cooperation with state authorities, plans to continue taking an

active role in overseeing the preparations for and conduct of removal of process piping during

1999. In general, these interactions among DOE, State, the Board, and contractors are

proceeding in a commendable spirit of cooperation and unity toward a common goal.

4.5.2 Activities at the Hanford Site

233-S Plutonium Concentration Facility 

The 233-S Plutonium Concentration Facility (233-S Facility) was built in 1955 to expand

plutonium production by further concentrating the plutonium nitrate solution produced by solvent

extraction by the REDOX Plant. The 233-S Facility operated until July 1967, at which time it

was added to the DOE Surplus Facility Management Program as a retired facility. An estimated

1.5 kg of plutonium-239 remains in the process portion of the facility. DOE’s removal action

program calls for dismantlement and disposal of highly contaminated process systems,

decontamination and/or stabilization of the facility, and then its demolition and disposal.

In May 1998, the Board’s staff observed the Operational Readiness Review related to

decommissioning of a portion of the 233-S Facility. The review represented a unique approach to

DOE’s traditional readiness review process and was important for two reasons: (1) the DOE

Richland Operations Office (DOE-RL) review team had been asked to approve readiness for

activities at the 233-S Facility that had not yet been planned, and (2) the 233-S Facility

decommissioning is a pilot project, and thus the readiness process being tested there would likely

be the prototype for future decommissioning projects within DOE. The Board’s review revealed

a systematic problem in the way DOE-RL was implementing its start-up and restart readiness

verification process. This problem was addressed to the Board’s satisfaction in the review team’s

final report and will require that DOE-RL conduct appropriate readiness reviews of

decommissioning activities at the 233-S Facility. The Board’s staff will observe additional

readiness activities as they are performed and will continue to monitor the conduct of the most

hazardous of decommissioning operations.

B-Plant 

B-Plant was built during World War II to process plutonium for nuclear weapons, and 

was later reconfigured to remove strontium and cesium from Hanford’s high-level waste storage

tanks. The deactivation of B-Plant was completed in September 1998. The deactivation 

activities included removal of contaminated organic solvents, decontamination of the canyon,

clean-out of piping and process cells, and installation of a new ventilation system. The

deactivation also involved the decoupling of auxiliary operations and support services provided 

by B-Plant to the adjacent Waste Encapsulation and Storage Facility. During the deactivation

process, the Board’s staff conducted several reviews of the health and safety aspects of the

B-Plant deactivation project, including the continued use of an aged filter train in the exhaust

ventilation system, as well as the design of the new exhaust ventilation system. In part because 

of the Board’s oversight activities, the existing ventilation system was replaced with a new
4-24

 exhaust ventilation system, which has significantly reduced the potential for a radiological release

to the environment.

B-Plant still contains between 100,000 and 1 million curies of residual radioactive

materials. However, these materials have been stabilized to the extent that the facility can be left

safely in a surveillance and maintenance mode, i.e., a non-time critical remediation status,

 for the near term until their final disposition is decided.

4.5.3 Activities at the Y-12 Plant

Building 9206 at the Y-12 Plant contains substantial quantities of material at risk. The

facility is in a stand-down operational status, with no plans to restart operations. The original

mission of the building was the recovery of a wide range of highly enriched uranium (HEU), but

its current use is limited to storage of excess fissile material awaiting disposition. This backlog

consists of more than 2,600 batches of uranium-bearing material in several forms and various

enrichments, with a total net weight of 20,000 kg, with approximately 3,200 kg of uranium-235. 

The material is packaged in cans, vessels, drums, plastic bags, and containers located throughout

the facility in vaults, piping, hoods, and tanks. Many safety vulnerabilities in the facility have been

identified by the Board’s staff and in DOE's HEU Vulnerability Assessment. 

The Board issued a letter to DOE in February 1998, noting the lack of attention that

Building 9206 was receiving even as the hazards and risks continued to increase because of

neglect. Some safety deficiencies raised to management are starting to receive attention, and it

appears that progress toward stabilizing the facility is beginning to be made. In late 1998, the

Board’s staff reviewed the status of deactivation and transition activities at Building 9206.

Accomplishments made since previous staff reviews include removal of some hazardous and

radiological material from storage areas; repackaging of some suspect containers of HEU;

decontamination to reduce radiological and contamination areas; performance of several

Unreviewed Safety Question Determinations to address HEU vulnerabilities; addition of an onsite maintenance crew; and issuance of a draft Deactivation Management Plan. Funding continues

to be an uncertainty in long-term planning; DOE needs to identify the source of the funds required

to move this initiative forward. Of particular concern is the delay in issuance of the BIO and the

Preliminary Hazard Analysis, which are many months behind schedule and affect work planning

and the development of implementation procedures. The Board’s staff plans to continue to

review deactivation and decommissioning activities in Building 9206, and to assess the BIO and

final Deactivation Management Plan when they become available in 1999.

4.5.4 Activities at the Miamisburg Environmental Management Project

The mission of MEMP in Miamisburg, Ohio, is clean-up, environmental restoration, and

private economic development. MEMP was built in the 1940s to produce components for 

nuclear weapons using radioactive tritium. A significant milestone was reached in the MEMP

clean-up process with the safe removal of the last quantity of bulk tritium from the site in

September 1998. Although a small amount of tritium remains in facilities and process 

equipment, the removal of the bulk of the tritium has significantly reduced a potential
4-25

environmental risk. This cleanup of tritium was the culmination of a 32-month project during

which the Board’s staff conducted several on-site reviews of the tritium operations. During the

course of these reviews, the staff identified several potential safety concerns, which DOE and the

MEMP site contractors satisfactorily addressed.

4.5.5 Deactivation and Decommissioning Standards

The Board reviewed and provided substantial input to DOE’s revision of DOE Order

430.1A, Life Cycle Asset Management, and the development of DOE-STD-1120-98, Integration

of Environment, Safety, and Health into Facility Disposition Activities. These efforts concluded

an 18-month period in which the Board and DOE worked closely to develop and issue a DOE

technical standard that comprehensively addresses methodologies for safe deactivation and

decommissioning of nuclear facilities while incorporating the Board’s approach to integrated

safety management. Additionally, the Board worked with DOE to develop the requirements

needed to address safety and health issues associated with the transition from facility operations to

a safe and stable facility configuration while awaiting deactivation and/or decommissioning. The

Board’s staff is continuing to work with DOE in developing the detailed guidance to be used in

implementing the requirements for the Order. It is anticipated that these two documents will be

issued during the first quarter of 1999. 
5-1

5. ADMINISTRATIVE MATTERS

CONTENTS OF THIS SECTION

Section Page

5.1 PERSONNEL RECRUITMENT ........................................................... 5-1

5.2 OFFICIAL SITE VISITS BY BOARD MEMBERS AND STAFF ................................ 5-2

5.3 INQUIRIES INTO HEALTH AND SAFETY ISSUES ......................................... 5-2

5.4 PUBLIC INTERACTION WITH THE BOARD .............................................. 5-4

5.5 NATIONAL PARTNERSHIP FOR REINVENTING GOVERNMENT 

OBJECTIVES ......................................................................... 5-5

5.5.1 Reducing Regulatory Burden ....................................................... 5-5

5.5.2 Excepted Service and Pay for Performance ............................................ 5-5

5.5.3 “No Frills” Approach to Operations .................................................. 5-6

5.5.4 Effective Organizational Structure ................................................... 5-6

5.5.5 Management Continuity ........................................................... 5-6

5.5.6 Information Technology ........................................................... 5-7

5.1 PERSONNEL RECRUITMENT

By law, the Board is authorized to hire up to 150 full-time employees. As of December

31, 1998, it had 5 full-time Board Members and 90 full-time staff. Two Site Representatives are

located at the Pantex Plant, near Amarillo, Texas; two Site Representatives at the Hanford Site, in

Richland, Washington; one Site Representative at the Rocky Flats Environmental Technology

Site, near Denver, Colorado; one Site Representative at the Savannah River Site, near Aiken,

South Carolina; and one Site Representative at the Oak Ridge Site, near Oak Ridge, Tennessee. 

The technical mission of the Board requires staff with multidisciplinary backgrounds and

specialized engineering and scientific knowledge, and with demonstrated competencies in all

major aspects of nuclear safety. The Board's technical staff includes individuals with extensive

experience in nuclear, mechanical, electrical, chemical, structural, and metallurgical engineering

and in physics. As an indication of the Board's technical talent, 25 percent of the technical staff

hold degrees at the Ph.D. level, and an additional 72 percent have masters degrees. Most of the

others, all of whom are college graduates, are technical interns who plan to complete their

masters-level engineering programs within the next year. Moreover, almost all technical staff

members, except interns, possess practical nuclear experience gained from duty in the 

U.S. Navy's nuclear propulsion program, the nuclear weapons field, or the civilian reactor

industry. Three members of the General Counsel’s office have a technical/scientific degree in
5-2

addition to a law degree. Both the Board and its staff include individuals experienced in

environmental impact assessments and regulatory processes. 

Staff expertise is supplemented on occasion by outside experts with special technical

knowledge and extensive experience in the areas of plutonium processing, weapons assembly and

disassembly, and other nuclear operations. Since the limited staff size precludes the ability to

cover all technical and scientific matters by means of in-house specialists, the Board contracts for

specialized technical expertise as needed. Drawing on the work of the Board’s technical staff and

outside experts and utilizing their own considerable specialized knowledge and capabilities, the

Board Members have been able to make technical judgments and to serve as authors of the

Board’s recommendations and related actions.

Through its technical intern program, the Board has continued to recruit and develop a

select group of the nation’s top engineering graduates. Currently, five interns are in various

phases of a 3-year training program encompassing formal graduate school education and on-thejob training. The outstanding academic and on-the-job performance of the five staff members

who have already completed the intern program are proof of the effectiveness of these recruitment

and selection methods. Board staffing projections include the recruitment of at least two technical

interns in 1999.

5.2 OFFICIAL SITE VISITS BY BOARD MEMBERS AND STAFF

From the establishment of the Board in October 1989 through the end of 1998, in addition

to its full-time Site Representatives, the Board, its staff, and its contractor experts have

collectively made 1398 site visits to DOE's defense nuclear facilities. In 1998 alone, 300 such site

visits were made. These visits focused primarily on selected facilities that both the Board and

DOE consider to pose the most pressing safety issues in light of DOE's mission. Where

appropriate, reports on staff visits have been conveyed formally to DOE managers.

During its visits to DOE sites, the Board has reviewed health and safety issues firsthand,

and has gathered information relevant to its recommendations to the Secretary of Energy and their

implementation.

5.3 INQUIRIES INTO HEALTH AND SAFETY ISSUES

During 1998, combined teams of legal and technical members of the Board’s staff closed

37 and opened 10 new inquiries into health and safety issues at several defense nuclear facilities

pursuant to 42 U.S.C. § 2286a. Inquiries were conducted at the Rocky Flats Environmental

Technology Site, Oak Ridge National Laboratory, the Hanford Site, the Savannah River Site, Los

Alamos National Laboratory, Lawrence Livermore National Laboratory, Idaho National

Engineering and Environmental Laboratory, the Pantex Plant, and the Fernald Site. Several of

these inquiries led to significant improvement in practices or conditions that could have 

adversely impacted public health and safety and, in a few cases, affected national security 
5-3

missions conducted at DOE’s defense nuclear facilities. Most of the lessons learned and

corrective actions resulting from these inquiries had application throughout the defense nuclear

complex. 

Through continuing review of DOE’s infrastructure for protecting safety-related

structures, systems, and components from nonconforming or suspect/counterfeit parts, the

Board’s staff discovered a failure in DOE’s response to an interagency alert issued by the

Department of Defense regarding suspect/counterfeit electronic components sold to several

federal agencies, including DOE. Intervention by the Board’s staff provided DOE with legal,

technical, and administrative assistance that enabled DOE to protect potentially compromised

missions and to cooperate fully with actions of DoD and the Department of Justice.

DOE subsequently took effective measures to evaluate and control the future introduction

of suspect/counterfeit parts into applications with the potential to adversely affect worker and

public safety and the safe maintenance of the nuclear weapons stockpile. Specifically, with regard

to the suspect semiconductor devices, DOE identified and technically evaluated the adequacy of

the devices in significant national security applications and provided assurance that the suspect

devices will not compromise the safety or support of the stockpile. 

In response to issues raised by a concerned individual regarding the control of radiological

sources and the use of cargo containers for temporary storage at Rocky Flats, the Board’s staff

conducted an inquiry into practices aimed at controlling radiological sources and the use of cargo

containers for temporary storage. The Board’s staff found no safety hazards associated with the

issues raised by this individual. As a result of inquiries made by the Board’s staff, however,

weaknesses in the control of radiological sources and cargo containers were identified. The DOE

Rocky Flats Field Office and contractors now recognize the vulnerabilities involved, and have

taken actions to institute effective controls on sources, and to both improve controls on the use of

cargo containers for temporary storage and reduce the number of cargo containers at the site.

The Board’s staff also expanded upon the issues raised by this concerned individual

regarding the use of cargo containers by conducting a thorough review of practices and controls

applied to materials removed from buildings being decommissioned at the Rocky Flats

Environmental Technology Site. This review included the use of all temporary storage, controls

on equipment destined for the sites, and controls on parts and tooling to be provided to other

sites. As a result of this expanded review, the Board’s staff found the outdoor storage of lowlevel radioactive wastes to be poorly managed. DOE subsequently directed the contractor to take

actions to improve storage conditions for low-level wastes.

The Board’s staff also found deficiencies in practices used at Rocky Flats for the control

and shipping of parts and tooling that are removed from buildings and are to be provided to other

sites. As a result of the staff’s inquiries, DOE appointed an individual to be responsible for all

aspects of off-site shipments. Additionally, sites that have experienced problems with shipments

from Rocky Flats have now formally identified those problems to Rocky Flats personnel. 
NetGuide and Places to See awards are given to Web sites based on content, presentation, and graphics. 7

These two Web sites help guide users through the Internet and stay on top of the constantly changing Internet

environment.

5-4

5.4 PUBLIC INTERACTION WITH THE BOARD

The Board is sensitive to the need for public involvement in, and awareness of, defense

nuclear safety issues. In its public health and safety reviews, the Board's contacts with the public

are primarily through open meetings and easy access to the Board’s technical documents on the

Internet and in its public reading room. Since 1990, the Board has held 66 public meetings at

sites across the nation and in Washington, D.C. The Board has found these meetings to be a

highly effective tool for encouraging responsiveness on the part of DOE representatives, and for

exchanging information with state and local officials, labor leaders, DOE facility workers, public

interest groups, and area residents. The Board’s public reading room is open to the public every

working day. The staff has received numerous complimentary letters from private citizens, public

interest groups, corporations, and other government agencies on the availability of the Board’s

technical and administrative documents. 

During 1998, the Board conducted five public meetings at its Washington, D.C., office,

and two in Richland, Washington. In addition to these meetings, members of the Board’s staff

have provided informational briefings to local officials, citizens advisory boards, and other public

interest groups in the vicinity of the Pantex Plant, the Savannah River Site, the Hanford Site, and

Rocky Flats Environmental Technology Site.

At three of the Board’s public meetings, the Board, its technical staff, and outside experts

discussed the status of DOE’s implementation plan for Recommendation 95-2, Integrated Safety

Management. Two public meetings were held to examine DOE’s progress on the implementation

of Recommendation 94-1. The two meetings in Richland, Washington, were held to review the

status of DOE’s implementation of Recommendations 92-4 and 93-5.

Notices of the Board’s public meetings are published in the Federal Register and are

mailed to more than 400 organizations and individuals that have requested to be on the Board's

mailing list. In addition, each notice is published in local newspapers serving the communities

near the facility involved, as well as being placed on the Board’s Internet Web site.

As an efficient and cost-effective vehicle for communicating information, the Board’s

Internet Web site has been expanded to include additional categories of information. The site,

located at www.dnfsb.gov, provides among other items the entire text of all unclassified Board

recommendations, biweekly updates of the log of correspondence/documents sent or received by

the Board, trip reports and issue reports prepared by the Board’s staff, weekly Site Representative

reports, and other background information on the Board’s health and safety review activities. The

site has received two awards for its clarity, ease of use, and presentation of information. As of 7

the end of 1998, more than 60,000 visits to the Board’s Web site had been logged.
5-5

In accordance with Office of Management and Budget Bulletin No. 95-01, the Board has

established and includes on its Web site its Government Information Locator Service, identifying

and describing public information resources available and directing users on how they can obtain

this information. 

5.5 NATIONAL PARTNERSHIP FOR REINVENTING GOVERNMENT

OBJECTIVES

The President has directed that all agencies of the executive branch review their individual

legislative mandates and operations as part of a fundamental rethinking of what the Federal

Government should do and how it should be done. This program, under the direction of the Vice

President, is called the National Partnership for Reinventing Government.

The Board believes that as a relatively new agency (formed in November 1989),

unencumbered by years of bureaucratic rules and practices, it has accomplished many of the

streamlining objectives of the National Partnership for Reinventing Government. At its inception,

the Board recognized the importance of carefully structuring an organization that would avoid

layering, promote empowerment, and encourage timely action. The Board has built a strong

organization based on the successful implementation of the following initiatives.

5.5.1 Reducing Regulatory Burden

The Board's policy on regulations is fully consistent with the President's memorandum on

streamlining the bureaucracy. To date, the Board has promulgated only those internal regulations

(rules) required by law and necessary to maintain orderly operations—related to the Freedom of

Information Act, the Privacy Act, the Government in the Sunshine Act, and Organizational and

Consultant Conflicts of Interest. Moreover, in promulgating these regulations, the Board has

written the rules in ways that achieve the statutory purposes without burdening the Board or the

public with inflexibility, or with overly prescriptive requirements that attempt to substitute

excessive paperwork for sound judgment.

5.5.2 Excepted Service and Pay for Performance

The Board successfully argued for, and subsequently received through legislation and

administrative delegations, the means to overcome many of the administrative roadblocks that

have traditionally frustrated change in government organizations. Most prominent on this list of

specific statutory authorities sought by the Board and ultimately granted by the Congress is the

excepted service personnel authority.

 

The pay-banding and pay-for-performance concepts recommended in the National

Performance Review have been operational at the Board for more than five years and have

received favorable review by the General Accounting Office and the Office of Personnel

Management. These concepts have proven to be highly effective in hiring technical talent, 
5-6

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

the job.

5.5.3 “No Frills” Approach to Operations

From the first day of operation, the Board Members have set a standard for having a “no

frills” approach to conducting business. For example, the Board does not employ chauffeurs and

has no government automobiles for local travel of Board Members or staff. Internal directives

have been written to give practical and easily understood guidance in the most simplified manner. 

The Board has converted to the Electronic Time and Attendance Management System for

recording of time and leave. All employees receive their salary checks and travel reimbursements

by electronic funds transfer. The issuance of travelers checks has been eliminated by using ATM

access for travel advances and encouraging all travelers to obtain a government-issued credit card

for travel expenses. Government credit cards are also used extensively by the Board for

telephone calls and miscellaneous purchases. These initiatives have provided good customer

service and reduced overhead costs. 

5.5.4 Effective Organizational Structure

The Board maintains focus on its mission to ensure adequate protection of public and

worker health and safety at DOE defense nuclear facilities. By using matrix management, the

Board has gained management flexibility and avoided the creation of layers of middle management

that could dilute limited staff resources and thereby impede the Board’s ability to perform health

and safety reviews.

Adopting the approach of economies of scale for obtaining needed administrative support

services, the Board has negotiated interagency agreements with the U.S. Nuclear Regulatory

Commission, the Public Health Service, and the General Services Administration to obtain

support for accounting, personnel, and payroll services. Resources that would normally be

diverted to these administrative functions remain dedicated to the Board’s health and safety

mission.

5.5.5 Management Continuity

Under the Board's enabling legislation, the five Board Members are appointed to

staggered five-year terms on a full-time basis. Thus, the Board has enjoyed management

continuity and has not been subjected to the disruption of frequent changes in leadership that has

been experienced by many government agencies. This continuity has permitted the Board to

provide precise and consistent direction in conducting its technical mission and addressing major

policy issues, as well as a degree of constancy and stability for DOE’s upgrading efforts in safety

management.
5-7

5.5.6 Information Technology

To improve communications with DOE field sites and to reduce travel time and expenses,

the Board has installed video teleconferencing equipment at its field locations. The Board has

used this technology for the rapid exchange of information during briefing sessions with multiple

DOE field sites on issues that impact the entire weapons complex. This technology enables the

Board’s Headquarters and field staff to receive briefings from DOE and its contractors with

minimal burden to DOE's staff. In 1998, the Board extended video teleconferencing capabilities

to the Site Representative location at Oak Ridge, Tennessee. 

The Board maintains a high-speed connection to the Internet for all staff members, which

allows technical and administrative staff to communicate via electronic mail with other federal and

state agencies and members of the public. Staff members use their desktop computers to obtain

the latest information on events at defense nuclear sites; to review draft DOE rules and Orders; to

exchange information with professional societies; to perform research on technical and legal

subjects; to access notices, legislation, and legal decisions; and to send draft reports to colleagues

for review. In addition, technical staff on travel and site representatives have remote access to the

Board’s local area network through dial-in communications, and can retrieve and send files,

review electronic mail, and communicate with colleagues at headquarters.
A-1

APPENDIX A. BOARD RECOMMENDATIONS 98-1 AND 98-2

53646 Federal Register /Vol. 63, No. 193/Tuesday, October 6, 1998/Notices

DEFENSE NUCLEAR FACILITIES SAFETY BOARD

[Recommendations 98–1]

Integrated Safety Management and the Department of Energy

(DOE) Facilities

AGENCY: Defense Nuclear Facilities Safety Board.

ACTION: Notice recommendations.

SUMMARY: The Defense Nuclear Facilities Safety

Board has made a recommendation to the Secretary

of Energy pursuant to 42 U.S.C. 2286a concerning

integrated safety management and the Department of

Energy (DOE) facilities.

DATES: Comments, data, views, or arguments

concerning this recommendation are due on or before

November 5, 1998.

ADDRESSES: Send comments, data, views, or

arguments concerning this recommendation to:

Defense Nuclear Facilities Safety Board, 625 Indiana

Avenue, NW, Suite 700, Washington,

DC 20004–2901.

FOR FURTHER INFORMATION CONTACT:

Kenneth M. Pusateri or Andrew L. Thibadeau 

at the address above or

telephone (202) 208–6400.
A-2

 Federal Register /Vol. 63, No. 193/Tuesday, October 6, 1998/Notices 53647

Dated: October 1, 1998. safety management programs. The Board has noted that involved. It is precisely at this interface between the

John T. Conway,

Chairman.

[Recommendation 98–1]

Integrated Safety Management and the

Department of Energy (DOE) Facilities

Dated: September 28, 1998.

 On October 11, 1995, the Defense Nuclear Facilities

Safety Board (Board) issued to the Secretary of Energy

its Recommendation 95–

2, entitled Safety Management. The Recommendation

proposed adoption by the Department of Energy (DOE)

of a concept termed ‘‘Integrated Safety Management’’

(ISM) as a means of improving assurance of safety at

DOE’s defense nuclear facilities. The Secretary of

Energy provided an implementation plan for the

Recommendation on April 18, 1996, which the Board

accepted in turn. In accordance with the implementation

plan, DOE issued its Policy Statement 450.4 to be the

basis for initiation and conduct of ISM at its facilities. 

 DOE and its contractors are making good progress in

implementing the concept of ISM at defense nuclear

facilities. One of the central functions of ISM called out

both in the Recommendation and the implementation

plan is ‘‘feedback and improvement.’’ That function is

exercised both in planning work and establishing safety

controls at the outset, and in subsequent assessment of

the diligence in application and the success in

achievement of safety.

 DOE has established through its directives system its

expectation of actions by both the federal work force and

contractor management in assessing the effectiveness

of its safety management programs as they are

practiced. Such safety assessments include both

observance of work and determination of long term

trends. They are accomplished principally through two

major kinds of assessments for feedback and

improvement.

 · Self-assessment by the contractor of site/facility/activity

programs responsive to DOE Policy 450.5, and parallel

oversight by DOE line managers and facility

representatives responsible for the missions and

contractor performance. This is assessment by line

management.

 · Corporate level assessments by DOE

safety specialists (ES&H), independent of the line,

responsible for capturing and sharing lessons learned,

preparing trend analyses, performing special

investigations and otherwise performing corporate-level

reviews in support of the Secretarial Offices. This is

independent assessment.

 These assessments and the corrective

actions taken in response to them are important

elements of the internal safety management program of

DOE.

 In the course of its oversight of DOE’s

safety management program, the Board has noted

considerable variability in implementation and

effectiveness of the feedback and improvement function

as performed by the numerous federal and contractor

entities. 

There appears to be much collection of 

data (about 30 DOE directives drive the process) but

less evidence of follow-up.

To facilitate a closer examination of the 

matter, the Board in a March 20, 1998, 

letter stated its observations, and requested a report on

how the function was being performed at defense

nuclear facilities. DOE, by letter dated June 3, 1998,

provided such report. The report and the matter in

general were the subject of discussions with

representatives of DOE and its contractors at a public

meeting held by the Board in Washington, DC, on June

24, 1998.

 The outcome of these exchanges to date

has been a mutual understanding of a number of

improvements that are merited. An action plan

presented to the Board in

DOE’s letter of June 3, 1998, proposes to

focus on four areas:

· Accelerating implementation of DOE

Policy 450.5,

· Improving DOE’s tracking and follow-on

processes,

 · Improving DOE’s lessons Learned processes, and

 · Improving implementation of the Functions,

Responsibilities, Accountability Manual (FRAM) relative

to feedback and improvement..

 The Board commends DOE for these initiatives. As

worthy as they are, however, 

they are not, in the Board’s view, sufficient to cover all

aspects of DOE’s feedback and improvement of its

the initiatives for improvement, particularly DOE’s actions Secretarial Program offices and the independent

on findings, are limited to results of oversight by line reviewers of safety performance (EH–2) that DOE’s

operations. They do not address deficiencies in feedback safety management program merits additional

and improvement based on results of independent attention. The need for an institutionalized protocol for 

oversight by the Office of the Assistant Secretary for

Environment, Health and Safety (EH)—more specifically

that of the Deputy Assistant Secretary for Oversight

(EH–2). The purpose of this recommendation is to

address that matter.

 For many years, it has been commonplace 

for DOE’s Headquarters to conduct 

independent assessments of safety management by the

field offices and their contractors, in relation to

performance of DOE’s hazardous work. This parallels a

normal practice of headquarters of commercial

hazardous industries which have multiple product lines

and facilities and which therefore delegate primary

responsibility for doing work safely to officials of a facility

or a product line. But assessment of safety is not

sufficient. To be effective, the constructive criticisms

must be brought to the attention of corporate

management. There they must be evaluated, and course

corrections must be directed, if the benefits of

assessment are to be achieved. This is especially true

where resource issues are involved and allocation or reallocation of funds is required.

 Recognizing that at times there is a need

for Secretarial involvement at levels above

the program offices and the corporate role 

of the independent assessors, in September 1989

Secretary Watkins established the 

Office of Nuclear Safety (ONS), reporting directly to him

as described in SEN–6E–92. That led to Secretarial

review of all findings 

of ONS, and an opportunity for response at 

the Secretarial level if necessary. With the change in

Administration in 1994, this Office 

was assigned to report to the Assistant Secretary for

ES&H, and it was redesignated as EH–2 with direction

by a Deputy Assistant Secretary. In that capacity, EH–2,

according to the DOE Manual of Safety Management

Functions, Responsibilities, and Authorities (DOE

M411.1–1), performs corporate level assessments,

independent of the safety management programs as

implemented by DOE program offices and associated

contractors.

 Evaluations are provided to the Secretary of Energy,

Congress, Cognizant Secretarial Offices, Field Managers

and Contractors. However, under this organizational

arrangement, most of the assessments and findings by

EH–2 are treated largely as advisories. Such follow-up

actions as are taken are no longer subjected to a

deliberative process involving, when appropriate, the

Office of the Secretary of Energy (Secretary, Deputy

Secretary, Under Secretary). Rather, they become

discretionary to lower levels of DOE line management

(such as cognizant Secretarial Officers and Field

Managers). An exception to this general discretionary

pattern occurs when an accident results in death or

serious injury of workers, or threatens the public. For

example, Type A accident investigations require, among

other things, corrective action plans (CAPs), approval of

the CAPs by the cognizant secretarial officer, and

completion of corrective actions subject to independent

verification. These requirements, in DOE Order 225.1A,

Accident Investigations, November 26, 1997, and

supporting guidance effectively close the loop on

accident investigations.

 EH–2 does make a practice of requesting a CAP after

submission of a report on other types of investigation,

and usually receives one from the cognizant party.

Proposed corrective actions in these CAPs are frequently

incomplete and are sometimes only loosely related to

findings in the oversight report. Some CAPs are no more

than commitments to provide a CAP in the future. The

Department of Energy has not identified criteria for

adequate CAPs, nor has DOE authorized EH–2 to

require adequate CAPs which are responsive to

evaluation reports. As a result, problems identified as

accident precursors are not handled with the same rigor

as accidents themselves. The end effect is that

corrective action under the current system is reactive

rather than proactive.

 Nothing prevents EH–2 from elevating

safety issues via its management (Assistant Secretary

for ES&H), but the process of evaluation is now ad hoc,

not institutionalized and protocol driven. There is a

natural tension between those charged with doing work

safely and those tasked by management to monitor and

evaluate how well the doers perform. There is also a 

natural resistance to having to reallocate resources when

deficiencies are found. Such factors cause outcomes to

depend highly on the forcefulness of the personalities

content and treatment of a CAP, and for addressing and

resolving differences are the central points of issue.
A-3

53648 Federal Register /Vol. 63, No. 193/Tuesday, October 6, 1998/Notices

 The Board is of the opinion that the

Department of Energy should take additional action with

respect to its program for improvement of feedback and

safety for defense nuclear facilities by establishing clearer

lines of authority and responsibility for resolution of safety

findings of its internal, independent safety organization. 

Towards such end, the Board recommends that the

Department of Energy:

 1. Establish by policy statement, directives, or other

protocols, the manner in which the Secretary expects

Cognizant Program Secretarial Officers (Assistant

Secretaries) and Field managers to address and resolve

findings of its independent internal corporate

safety organization (Assistant Secretary for ES&H). In so

doing, consideration should be given to direction and

guidance for the following:

 · Establishing authority and responsibility

for conducting and responding to independent oversight,

preparing and approving corrective action plans, reporting on

progress toward timely and adequate closure of findings, and

subsequent closure, including independent verification of

closure.

 · Elevating cases of inadequate or

untimely response to findings to the Office of the Secretary for

resolution.

 · Describing the purpose and content of

corrective action plans responsive to oversight findings (e.g.,

cause identification, actions, to correct immediate problem,

lessons learned, actions to prevent recurrence).

 Scheduling the time frames within which

the evaluation and process activities must

occur.

· Periodically reporting the status of

corrective actions by the responsible entity.

 · Tracking findings and corrective actions

to closure with a system accessible to DOE line management

and the independent oversight organization.

 2. Make explicit the Secretarial Officer or

designee assigned the resolution function.

John T. Conway,

Chairman.

September 28, 1998.

The Honorable Bill Richardson,

Secretary of Energy,

1000 Independence Avenue, SW,

Washington, DC 20585–1000

 Dear Secretary Richardson: On September 28, 1998, the

Defense Nuclear Facilities Safety Board (Board), in

accordance with 42 U.S.C. § 2286a(a)(5), unanimously

approved Recommendation 98–1, which is enclosed for your

consideration. Recommendation 98–1 deals with Integrated

Safety Management and the Department of Energy (DOE)

facilities.

 42 U.S.C. § 2286d(a) requires the Board, after receipt by

you, to promptly make this recommendation available to the

public in DOE’s regional public reading rooms. The Board

believes the recommendation contains no information which

is classified or otherwise restricted. Atomic Energy Act of

1954, 42 U.S.C. §§ 2161–68, as amended, please arrange to

have this recommendation promptly placed on file in your

regional public reading rooms.

 

 The Board will publish this

recommendation in the Federal Register.

 Sincerely,

John T. Conway,

Chairman.

c: Mr. Mark B. Whitaker, Jr.

[FR Doc. 98–26753 Filed 10–5–98; 8:45am]

BILLING CODE 3670–01
A-4

53884 Federal Register /Vol. 63, No. 194/Wednesday, October 7, 1998/Notices

DEFENSE NUCLEAR FACILITIES SAFETY BOARD

[Recommendation 98–2]

Safety Management at the Pantex Plant

AGENCY: Defense Nuclear Facilities Safety Board.

ACTION: Notice, recommendation.

SUMMARY: The Defense Nuclear Facilities Safety Board

has made a recommendation to the Secretary of Energy

pursuant to 42 U.S.C. 2286a(a)(5) concerning safety

management at the Pantex Plant. The Board believes that

opportunities exist to strengthen and simplify the process

by which DOE

designs and develops activities at the Pantex Plant and

independently evaluates the safety of those operations.

The Board believes that DOE should take action to

improve these processes. However, the recommendation

contains Information which is classified and otherwise

restricted. Therefore, only the letter forwarding the

recommendation (which is unclassified when separated

from the attachment) is being published.
A-5

 Federal Register /Vol. 63, No. 194/Wednesday, October 7, 1998/Notices 53885

FOR FURTHER INFORMATION CONTACT:

Kenneth M. Pursateri or Andrew L.

Thibadeau at the address above or

telephone (202) 208–6400.

 

 Dated: October 1, 1998.

John T. Conway,

Chairman.

Appendix—Transmittal Letter to the

Secretary of Energy

DEFENSE NUCLEAR FACILITIES SAFETY BOARD

625 Indiana Avenue, NW, Suite 700,

 Washington, D.C. 20004, (202) 208–6400

SECRET—RESTRICTED DATA

September 30, 1998

The Honorable Bill Richardson,

Secretary of Energy, 1000 Independence 

 Avenue, SW, Washington, DC 20585–1000

Dear Secretary Richardson: On September 30, 1998, the

Defense Nuclear Facilities Safety Board (Board), in

accordance with 42 U.S.C. §2286a(a)(5), unanimously

approved Recommendation 98–2, which is enclosed for

your consideration. Recommendation 98–2, deals with

Safety Management at the Pantex Plant.

 42 U.S.C. § 2286d(a) requires the Board, after receipt

by you, to promptly make this recommendation available to

the public in the Department of Energy’s (DOE) regional

public reading rooms. However, the recommendation

contains information which is classified or otherwise

restricted. Please arrange to have this letter forwarding the

recommendation (which is unclassified when separated

from the attachment) promptly placed on file in your

regional public reading rooms.

 The following is an unclassified summary of the Board’s

recommendation: The Board believes that opportunities

exist to strengthen and simplify the process by which DOE

designs and develops activities at the Pantex Plant and

independently evaluates the safety of those operations.

The Board believes that DOE should take action to

improve these processes.

 Sincerely,

John T. Conway,

Chairman.

c: Mr. Mark B. Whitaker, Jr.

 When separated from enclosures, this document is

unclassified. Document

transmitted herewith contains Secret/

Restricted Data.

[FR Doc. 98–26867 Filed 10–6–98; 8:45 am]

BILLING CODE 3670–01–M
B-1

APPENDIX B. LIST OF ABBREVIATIONS AND ACRONYMS

AA .................................................... Authorization Agreement

ACB .................................................... Auxiliary Charcoal Bed

APSF ....................................... Actinide Packaging and Storage Facility

BIO .................................................. Basis for Interim Operation

Board ....................................... Defense Nuclear Facilities Safety Board

CMIP .............................. Capabilities Maintenance and Improvement Project

CMR ........................................... Chemistry and Metallurgy Research

DAF ................................................... Device Assembly Facility

D&I .................................................. Disassembly and Inspection

DEAR ................................. Department of Energy Acquisition Regulations

DoD .................................................... Department of Defense

DOE ..................................................... Department of Energy

DOE-RL ................................. Richland Office of the Department of Energy

DP ................................ Department of Energy’s Office of Defense Programs

DP-20 ............................... Deputy Assistant Secretary of Energy for Military

Applications and Stockpile Support

EH-2 ............................... DOE’s Office of Environment, Safety, and Health

EPA ............................................ Environmental Protection Agency

EUO ............................................... Enriched Uranium Operations

FEB .................................................... Facility Evaluation Board

FR .................................... Department of Energy’s Facility Representative

FRAM ....................... Manual of Safety Functions, Responsibilities and Authorities

FY ............................................................... Fiscal Year

GPRA ............................. Government Performance and Results Act (of 1993)

HAR ................................................... Hazards Analysis Report

HF .......................................................... Hydrogen Fluoride

HEU ................................................... Highly Enriched Uranium

HIVES .......................................... Highly Invulnerable Encased Safe

INEEL ....................... Idaho National Engineering and Environmental Laboratory

IPSPP ......................................... Integrated Pit Storage Program Plan 

ISM ................................................ Integrated Safety Management

ISMS ....................................... Integrated Safety Management System 

ITP ............................................... In-Tank Precipitation (Facility)

LANL ............................................ Los Alamos National Laboratory

LEP ..................................................... Life Extension Program

LLNL ..................................... Lawrence Livermore National Laboratory

LMES ........................................... Lockheed Martin Energy Systems

MEMP ............................... Miamisburg Environmental Management Project

MHC .............................................. Mason and Hanger Corporation

NESS ............................................. Nuclear Explosive Safety Study

NESSG ...................................... Nuclear Explosive Safety Study Group

NFPA ......................................... National Fire Protection Association

LIST OF ABBREVIATIONS AND ACRONYMS (Concluded)
B-2

NRC ............................................. Nuclear Regulatory Commission

NTS ......................................................... Nevada Test Site

OMB ............................................ Office of Management and Budget

ORNL ............................................. Oak Ridge National Laboratory

ORR ............................................... Operational Readiness Review

PFP ................................................... Plutonium Finishing Plant

RFETS .................................. Rocky Flats Environmental Technology Site

SNFP ................................................ Spent Nuclear Fuel Project

SNL ................................................ Sandia National Laboratories

SNM ................................................... Special Nuclear Material

SPRF ............................................... Sandia Pulsed Reactor Facility

SRD ............................................. System Requirements Document

SRS ........................................................ Savannah River Site

SS-21 .................................. Seamless Safety for the 21 Century (process) st

TA-55 ...................................................... Technical Area 55

TWRS ............................................ Tank Waste Remediation System

U-233 ........................................................... Uranium-233

VOC ................................................ Volatile Organic Compounds

WIPP ................................................. Waste Isolation Pilot Plant

WSRC ...................................... Westinghouse Savannah River Company

WSS ..................................................... Work Smart Standards