FOURTEENTH ANNUAL REPORT

TO CONGRESS

DEFENSE NUCLEAR FACILITIES

SAFETY BOARD

FEBRUARY 2004

ii

PREFACE

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

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

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

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

inform the public.

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

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

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

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

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

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

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

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

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

Secretary must publish his or her decision and reasoning in the Federal Register and must

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

Congress if implementation of a recommendation is impracticable because of budgetary

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

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

Energy and Defense.

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

information, conduct studies, and take other actions such as establishing reporting requirements

for DOE in furtherance of its oversight of health and safety at defense nuclear facilities. The

Board has noted that the use of requests to the Secretary of Energy for detailed reports on safety

issues raised by the Board has regularly resulted in prompt actions by DOE to remedy the

situation.

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

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

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

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

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

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

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

EXECUTIVE SUMMARY

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

nuclear weapons operations conducted by the National Nuclear Security Administration

(NNSA), is a complex and hazardous enterprise. Missions include maintenance of the national

nuclear arsenal; dismantlement of surplus weapons; stabilization and storage of surplus nuclear

materials; disposition and disposal of hazardous waste; and cleanup of surplus facilities and sites. 

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

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

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

public, workers, and the environment.

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

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

report. These improvements are described along the lines of the Board’s four strategic areas of

concentration:

! Nuclear Weapons Operations;

! Nuclear Materials Processing and Stabilization;

! Nuclear Facilities Design and Infrastructure; and

! Nuclear Safety Programs and Analysis.

NUCLEAR WEAPONS OPERATIONS

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

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

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

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

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

As a result of the Board’s efforts during 2003, DOE has taken actions to upgrade the

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

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

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

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

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

consequence of the Board’s work are as follows.
1

 SS-21 is the preferred protocol for weapons assembly and disassembly at Pantex. It is designed to achieve

controlled interactions of the weapon, personnel, facility, tooling, and equipment at all stages of the operation.

vi

Pantex Plant:

! Pits of fissionable material have been repackaged into sturdy containers suitable for

interim storage (Recommendation 99-1).

! The SS-21 process1 for W62 Disassembly and Inspection and for W88 Bay operations

was completed; development of SS-21 processes for other weapons programs (W78,

B83, W87, B61) commenced.

! The Nuclear Explosive Safety Studies (NESS) Process Guide was revised to ensure

better coordination between NESS and readiness reviews.

! Significant deficiencies in the quality assurance of software used to control on-site

transportation of nuclear materials and nuclear weapons were corrected.

Y-12 National Security Site:

! The quantities of combustible organic liquids stored in Building 9212 have been

restricted and further fire protection improvements will be undertaken.

! A conduct of operations improvement plan was developed to correct numerous

deficiencies in conduct and formality of nuclear operations.

! Criticality safety was substantially upgraded by reduction of the amount of fissile

materials stored at the site and by simplifying requirements for material storage and

containers.

! The venting of drums storing depleted uranium chips was undertaken to place the

chips in a safe condition for long-term storage; other actions were taken to verify that

similar storage deficiencies did not exist elsewhere on the site.

All weapons laboratories: 

! The Secretary of Energy (a) affirmed in writing that the highest priority work at these

laboratories has been, and remains, support for the nation’s nuclear weapon stockpile,

and (b) directed each nuclear weapons laboratory to establish single points of contact

for safety issues affecting each weapon to ensure that proper actions are taken.

(Recommendation 2002-2)

Los Alamos National Laboratory:

! Deficiencies in the safety basis and safety controls associated with the new aqueous

processing line for recovery of scrap Plutonium-238 (Pu-238) were corrected.
vii

Los Alamos National Laboratory (cont.):

! Funding for upgrades to the site-wide fire alarm system was restored, reversing a

decision by DOE to eliminate funding from the FY03 budget.

! Deficient work planning requirements are under revision.

Lawrence Livermore National Laboratory:

! Inadequacies in the safety bases for the Plutonium Facility, the Hardened Engineering

Test Facility, and the Material Management Source Vault will be corrected.

Nevada Test Site:

! The capability to safely resume underground nuclear weapons testing has been

markedly improved.

Savannah River Site:

! Errors and omissions in software specifications for safety systems were corrected.

NUCLEAR MATERIALS PROCESSING AND STABILIZATION

The Board’s strategic performance goal for this area is to ensure that DOE’s program for

handling of hazardous nuclear materials and deactivation and decommissioning of unused

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

The Board’s safety oversight activities in this area focus on the stabilization and storage of

nuclear materials, storage and disposition of defense nuclear waste, and deactivation and

decommissioning facilities.

As a result of the Board’s efforts during 2003, DOE has taken actions to reduce or

eliminate risk and improve safety. These actions include stabilizing and improving the storage

conditions of nuclear materials, correcting deficiencies in the formal conduct of operations,

improving the quality of engineered safety systems, and correcting deficiencies in the safety

bases for new and ongoing activities. 

Specific examples of safety improvements in materials processing and stabilization made

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

Hanford Site:

! Safety improvements were made in the Spent Nuclear Fuel Project (SNFP), including 

completion of closure welds on suspect spent fuel containers, refinement of the

controls for hydrogen generated in K-Basin sludges, and tightened safety controls on

fuel transfers between basins.
viii

Hanford Site (cont.)

! Safety controls for retrieving transuranic wastes in earth-covered trenches were

strengthened.

! The safety analysis, content of safety requirements, and rigor in verifying

implementation at the tank farm have all been enhanced.

! Chemistry and corrosion control problems in double-shell tanks controlled by adding

corrosion-inhibiting chemicals.

Rocky Flats Environmental Technology Site:

! Deficiencies in work planning and oversight are being corrected following a

glovebox fire. (Board investigation)

Savannah River Site:

! Deficiencies in ventilation and fire protection systems in the K-Area Material Storage

(KAMS) facility will be corrected.

Fernald Closure Site:

! Corrective actions to improve worker safety were implemented to better train and

protect inexperienced workers.

NUCLEAR FACILITIES DESIGN AND INFRASTRUCTURE

The Board’s strategic performance goal for this area is to ensure that new DOE defense

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

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

recent years, there has been an increase in the number of new DOE projects, with 20 to 30

projects currently in the design and construction phase. As a result of the Board’s efforts during

2003, DOE has taken action to enhance safety in the design and construction of new defense

nuclear facilities. 

Specific examples of safety improvements in facilities design and infrastructure made in

consequence of the Board’s work are as follows.

Hanford Site:

! Potential safety flaws in the design of the Waste Treatment Plant were identified and

investigated.
ix

Y-12 National Security Site:

! Changes were made to improve the foundation design for the Highly Enriched

Uranium Material Facility.

Complex-wide:

! Reliability of High Efficiency Particulate Air (HEPA) filters used in safety

applications was enhanced.

NUCLEAR SAFETY PROGRAMS AND ANALYSIS

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

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

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

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

issues affecting a variety of defense nuclear sites and facilities.

As a result of the Board’s efforts during 2003, DOE has taken actions to strengthen the

technical competence of its contractors, establish and implement safety standards, improve the

quality of engineered systems, and increase the effectiveness of oversight and generic safety

programs such as Integrated Safety Management. 

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

consequence of the Board’s work are as follows.

! Administrative safety controls were strengthened. (Recommendation 2002-3)

! The quality of software used in safety applications was enhanced. (Recommendation

2002-1)

! The operability of vital safety systems has been confirmed; important technical

positions are being filled and personnel given additional training to serve as system

engineers. (Recommendation 2000-2)

! Stronger measures were taken to prevent DOE’s purchase and use of suspect and

counterfeit parts.

! Corrective actions were taken to correct deficiencies in training at NNSA sites.
x

OUTSTANDING SAFETY PROBLEMS OF DEFENSE NUCLEAR FACILITIES

I. The quality of federal oversight in the defense nuclear complex.

DOE is engaged in making major changes in its approach to safety oversight of defense

nuclear facilities. DOE is currently implementing, or is planning, three simultaneous initiatives

that affect its safety oversight of defense nuclear facilities. The sum and substance of this

initiative is to place principal reliance on the contractor to ensure that work is done safely, move

from prescriptive requirements to performance criteria, and decrease reliance on centralized

federal safety oversight of contractor operations. In the midst of this, information developed by

the Columbia Accident Investigation Board with respect to the loss of the space shuttle, and by

the U. S. Nuclear Regulatory Commission in connection with the “near miss” at the Davis-Besse

nuclear power plant, suggests that a weakening of federal oversight of contractor operations can

have dire consequences. In furtherance of its statutory duty to protect the public health and

safety from hazards at defense nuclear facilities and its charge to restore confidence in DOE’s

management capabilities, the Board conducted six public meetings between September and

December 2003. The meetings, which will continue in 2004, are intended to provide a record on

which to assess DOE’s proposals for changing its oversight, contract management, and directives

systems.

During its public meetings, the Board received testimony from representatives of the U.S.

Nuclear Regulatory Commission, the Naval Reactors Program, the Columbia Accident

Investigation Board, the Deputy Secretary of Energy, the Administrator of NNSA, the

Undersecretary for Energy, Science and Environment, selected DOE and NNSA Site Managers,

and senior contractor managers. In addition to the public meetings, the Board invited social

science experts to present in-house seminars to enhance understanding of the causal relationships

between organizational behavior and technical operations of complex, high hazard activities. In

2004, the Board will assess DOE’s oversight changes in light of the information that has been

gathered.

II. Laboratory Support for Weapons Activities. 

The Board issued Recommendation 2002-2 to ensure that safety information developed at

the national defense laboratories is adequately communicated to DOE’s defense nuclear

complex, and to preserve the priority of nuclear weapons projects in the face of competition from

other activities. In 2003, DOE continued its implementation of this Recommendation. An

essential task is the establishment at each defense laboratory of a single point of contact for each

nuclear weapon system. These individuals ensure that safety questions are promptly and

effectively answered and that safety issues are tracked to adequate closure. 

DOE has explicitly directed each NNSA defense laboratory to assume the responsibility

for ensuring that requests for laboratory support to resolve safety issues are tracked and fulfilled. 

Conflicting demands on laboratory resources are not to be allowed to hold up action on requests

for weapon safety assistance. The Board has observed some progress in this area, but it is

apparent that very close scrutiny of the implementation of this Recommendation will be required

for some time.
2

 Configuration Management, Vital Safety Systems, issued March 8, 2000.

xi

III. Safe retrieval, handling, and stabilization of nuclear materials and high-level waste. 

The Board has issued several Recommendations to DOE to expedite the stabilization of

materials in deteriorating storage conditions. Of greatest concern are the spent nuclear fuel and

associated sludges in the K-Basins at Hanford, high-level waste in underground tanks that have

aged beyond their intended design lives at Hanford and Savannah River Site (SRS), and large

quantities of nuclear materials at Los Alamos National Laboratory (LANL) for which DOE has

not presented a complete and acceptable stabilization plan.

DOE still must clear many technological and programmatic hurdles. At the Spent

Nuclear Fuel Project (SNFP) at Hanford, the Board has identified programmatic breakdowns in

engineering, nuclear safety, project management, and oversight. These failings have

substantially delayed the previously planned December 2002 start-up of sludge retrieval and may

result in DOE abandoning the current sludge retrieval process. In addition, these problems have

impeded the removal of fuel from the basins. The Board intends to maintain a high priority for

the oversight of this effort.

DOE’s plan to retrieve and treat high-level waste from underground storage tanks at SRS,

Hanford and the Idaho National Engineering and Environmental Laboratory (INEEL) is subject

to considerable uncertainty. The Board has focused its attention on technical and safety

challenges arising from DOE’s attempts to implement first-of-a-kind technologies for retrieval,

treatment, and disposal of High-Level Waste (HLW).

Finally, significant quantities of nuclear materials remain unstabilized at LANL. DOE

has not made sufficient progress in treating these materials and have yet to submit an acceptable

implementation plan to meet the requirements of Recommendations 94-1 and 2000-1. DOE’s

latest plan shows this important task remaining incomplete until 2010—far too long in the

Board’s view.

IV. The adequacy of safety systems in aging facilities.

The Board issued Recommendation 2000-22

 to ensure that aging safety systems are

properly maintained. DOE found, in response to this Recommendation, deficiencies in safety

systems that are being addressed, but much more remains to be done in 2004 and beyond. Many

of the safety analysis revisions resulting from implementation of the nuclear safety management

rule (10 CFR Part 830) assigned safety related functions to systems that had not previously

served this purpose. The Board will continue its efforts during 2004 to ensure that these systems

satisfy safety class or safety significant criteria.

V. The adequacy and quality of safety controls.

Previous efforts by the Board led to several DOE initiatives to improve upon, and ensure

the adequacy and quality of, safety controls relied on in defense nuclear facilities. Actions taken
3

 Quality Assurance for Safety Related Software, issued September 23, 2002.

4

 Requirements for the Design, Implementation, and Maintenance of Administrative Controls, issued December 11,

2002.

xii

to carry out the Implementation Plan for the Board’s Recommendation 2002-13 should lead to

correction of flaws in software affecting safety. By the same token, DOE’s Implementation Plan

for the Board’s Recommendation 2002-34 should lead to actions strengthening administrative

controls affecting safety. DOE’s Quality Assurance Improvement Plan is intended to correct

deficiencies identified by the Board in the quality of engineered safety systems, covering such

matters as design, fabrication, procurement, and installation. In addition, actions by the Board

led DOE to strengthen its program to prevent the introduction of suspect and counterfeit items

into safety systems. All of these initiatives will remain a focus of the Board’s attention during

2004.

VI. Ensuring that safety is addressed early in the design and construction of new

facilities.

With more than 20 DOE projects currently in the design and construction phase, the

Board will need to maintain a significant focus on the review of design and construction

activities during 2004. Reviews of the design and construction of major facilities and projects

are resource intensive and time consuming, but they result in significant safety improvements. 

The Board’s reviews of the Waste Treatment Plant (WTP) at Hanford, the Tritium Extraction

Project and Plutonium Disposition and Conversion Facility at SRS, and the Highly Enriched

Uranium Material Facility at the Y-12 National Security Site, have ensured the adequacy of the

design, drawings, and specifications. The reviews have also ensured that the physical design is

consistent with system functions and requirements and that all safety structures, systems, and

components are adequately incorporated into the design. The Board has demonstrated the value

of rigorous technical oversight to ensure that safety is addressed early in the design process and

intends to continue to focus on these activities in 2004.

VII. The technical competence of DOE and contractor personnel.

The Board has devoted constant effort for more than a decade to ensure that DOE

maintains and continually upgrades the knowledge, skills, and abilities of its technical personnel. 

During the past three years, DOE has been updating technical qualification standards for its

federal employees and placing them in the DOE Directives System, where they can be formally

controlled. In 2003, the Board reviewed and provided extensive comments on 16 new or revised

Functional Area Qualification Standards. DOE should complete this effort during 2004.

In Recommendation 2000-2, the Board urged DOE to institutionalize the use of system

engineers and federal subject matter experts for vital safety systems. DOE is now attempting to

fill these important technical positions, but in the Board’s view more senior management

attention and resources are needed during 2004 for this effort. The functional area qualification

standards for these positions are expected to be completed during 2004.
5

 Continuation of Criticality Safety at Defense Nuclear Facilities in the Department of Energy, issued May 19,

1997.

xiii

VIII. Development, maintenance, and implementation of safety-related standards.

During 2003, the Board reviewed 68 new or revised drafts of DOE health and safety

directives and NNSA policy letters. The Board’s review of NNSA’s internal policy directives

system revealed significant weaknesses and inconsistencies. The Board will provide oversight

of NNSA’s efforts in 2004 to design a system consistent with safety priorities. The Board will

also continue to work towards strengthening DOE’s directives and standards affecting safety at

defense nuclear facilities.

In an additional development, on December 8, 2003, DOE provided notification of a

proposed rule on worker protection, 10 CFR Part 851, Worker Safety and Health. This action

was required under the Bob Stump National Defense Authorization Act, Public Law 107-314,

which directed DOE to promulgate regulations on worker safety and health, rather than rely

exclusively on a contractual approach. The Board is conducting a detailed review of the

proposed rule. Of immediate concern is that DOE intends to cancel DOE Order 440.1A, Worker

Protection Management for D0E Federal and Contractor Employees. Currently, this order and

its associated manuals and guidance documents provide specific safety requirements for several

areas of interest to the Board: explosives safety, pressure vessel safety, and suspect and

counterfeit parts. They also serve as implementing directives for Integrated Safety Management

at the activity level. Many requirements and guidance, painstakingly developed during 50 years

of experience across the complex, may be lost unless these requirements and guidance are

formally implemented in a new set of directives to be issued concurrently with the new rule. 

During 2004, the Board will be heavily involved in DOE's efforts to satisfy Public Law 107-314

in a manner that provides optimal protection of worker health and safety.

IX. The continued implementation of complex-wide safety programs such as Integrated

Safety Management and criticality safety.

In 2003 the Board devoted particular attention to three integrated safety management

(ISM) initiatives: improvement of the annual update process, completion of DOE’s

implementation of Recommendation 2000-2, and full use of ISM at the activity level. The

concept of ISM is particularly well suited to ensuring safety at the activity level, and the Board

will continue this focus in 2004. 

The Board is closely monitoring DOE’s criticality safety program. During 2003 the

Board closed Recommendation 97-2,5

 with the expectation that improvements accomplished

because of it will be maintained and assessed on a yearly basis. During 2004 the Board will

ensure that DOE embeds criticality safety practices into its organizational structure and manuals

of practice.

The current plan to relocate the LANL Critical Experiment Facility to the Nevada Test

Site is of great interest to the Board because this facility represents a key component in DOE’s

capability to develop, train, and maintain a core of exceptionally qualified engineers specializing
xiv

in nuclear criticality safety. During 2004 the Board will closely follow implementation of this

relocation plan to ensure there is no detrimental interruption of operations or loss of capability.

X. Formality and discipline of nuclear explosive and nuclear processing operations.

The safety of operations involving nuclear explosives and other nuclear materials is

assured through verbatim compliance with explicit procedures by trained personnel. In 2003, the

Board identified numerous deficiencies in the formality of explosives operations. DOE is

developing corrective action plans to correct these deficiencies. The Board will assess the

effectiveness of DOE’s corrective actions in 2004.

OUTSTANDING SAFETY PROBLEMS IN 2002 REPORT

In the Thirteenth Annual Report for CY2002, the Board identified three outstanding

safety problems. One of these was identical to item II above. Progress in 2003 on the other

problems discussed in last year’s report has been as follows:

Ensuring Safety in the Design and Construction of New Defense Nuclear Facilities.

! New Facilities. The Board reviewed design and construction activities at the Hanford

Waste Treatment Plant, the Highly Enriched Uranium Materials Facility at the Y-12

National Security Site (Y-12), the Pit Disassembly and Conversion Facility and the

Tritium Extraction Facility at the SRS, the Melton Valley Waste Treatment Facility at

Oak Ridge, and the Dynamic Experiments Project at LANL.

! Major Modifications. The Board provided oversight of modifications to Building 12-64

at Pantex, Technical Area 18 (TA-18) at LANL, and the K-Basins Spent Nuclear Fuel

Project at Hanford. 

Ensure Effective and Reliable Controls to Protect Health and Safety.

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

Maintenance of Administrative Controls: DOE provided an Implementation Plan for

this Recommendation and began its execution. 

! Suspect and Counterfeit Parts: Under continuous Board scrutiny, DOE revamped its

program for preventing the use of such parts at defense nuclear facilities.

! Quality Assurance: DOE (1) began to correct deficiencies identified by the Board in the

quality of engineered safety systems, and (2) developed and began implementation of an

Implementation Plan in response to the Board’s Recommendation 2002-1.
xv

HUMAN CAPITAL MANAGEMENT

The ability of the Board to fulfill its mission depends heavily on attracting and retaining

top-caliber, competent technical staff. The Board has been successful in creating a work

environment that emphasizes excellence as the standard for staff performance, and rewards staff

members accordingly. The pay banding and pay-for-performance programs developed and

implemented by the Board have proven to be effective in hiring technical talent, holding

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

job. This is evidenced by the low turnover rate, which was about four percent in 2003 even

when intern hiring is taken into account. 

In 2003, the Board operated at 63 percent of its statutory employment ceiling of 150 Full

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

statutory excepted service hiring authority, along with recruitment and relocation bonuses,

student loan repayments, and retention allowances to hire and retain competent personnel. This

approach has allowed the Board to remain successful in securing scientific and technical staff in

a competitive employment market. 

During the year 2003, the Board continued to require its engineers and scientists to

maintain the highest level of technical knowledge to meet a wide range of health and safety

challenges. Ninety percent of the senior technical and legal staff hold advanced degrees, 33

percent of which are at the Ph.D. level. To meet future staffing needs, the Board continued its

recruitment of senior, experienced technical staff. To attract recent graduates, the Board relies

on its Professional Development Program, a 3-year program that brings entry-level technical

talent into professional positions within the Board. The Board provides them a technical mentor,

individually-tailored developmental assignments, post-graduate education, and a one-year,

hands-on field assignment. This is a highly competitive program to attract the next generation of

scientific and technical talent to federal service.
xvii

TABLE OF CONTENTS

Section 

 Page

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

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

1.2 Oversight Strategy . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1-2

1.3 Strategic Plan . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1-3

2. NUCLEAR WEAPONS OPERATIONS . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2-1

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

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

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

2.1.3 Savannah River Site ........................................ 2-5

2.2 Safe Conduct of Stockpile Stewardship ............................... 2-5

2.2.1 Recommendation 2002-2. . . ................................. 2-5

2.2.2 Los Alamos National Laboratory ............................. 2-6

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

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

3. NUCLEAR MATERIALS PROCESSING AND STABILIZATION .............. 3-1

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

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

3.1.2 Plutonium ................................................ 3-1

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

3.1.4 Special Isotopes ........................................... 3-4

3.1.5. Inactive NNSA Nuclear Materials ............................. 3-4

3.2 Stabilization of Spent Nuclear Fuel . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3-5

3.2.1 Hanford Site .............................................. 3-5

3.2.2 Savannah River Site ........................................ 3-6

3.2.3 Idaho National Engineering and Environment Laboratory .......... 3-6

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

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

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

TABLE OF CONTENTS (Continued)

Section Page

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

3.4.1 Overview ............................................... 3-10

3.4.2 Ohio Field Office ......................................... 3-10

3.4.3 Fernald Closure Project .................................... 3-10

3.4.4 Miamisburg Closure Project ................................ 3-10

3.4.5 Y-12 National Security Complex ............................ 3-11

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

3.4.7 Savannah River Site ....................................... 3-12

3.4.8 Lawrence Livermore National Laboratory ..................... 3-12

4. NUCLEAR FACILITIES DESIGN AND INFRASTRUCTURE ................. 4-1

4.1 Nuclear Facility Design Reviews ................................... 4-1

4.1.1 Plutonium Storage at Savannah River Site ...................... 4-1

4.1.2 Hanford Waste Treatment Plant ............................... 4-1

4.1.3 Highly Enriched Uranium Materials Facility .................... 4-3

4.1.4 Savannah River Site: Pit Disassembly and Conversion Facility ...... 4-3

4.1.5 Los Alamos National Laboratory: TA-18 Safety

Class Control Design. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4-3

4.1.6 Pantex Building 12-64: Roof Design Weaknesses ................ 4-4

4.1.7 High Efficiency Particulate Air Filter Testing and Infrastructure ..... 4-4

4.1.8 Dynamic Experiments at Los Alamos National Laboratory ......... 4-4

4.1.9 Tritium Extraction Facility at Savannah River Site ................ 4-4

5. NUCLEAR SAFETY PROGRAMS AND ANALYSIS ........................ 5-1

5.1 Federal Oversight. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5-1

5.1.1 Overview ................................................ 5-1

5.1.2 Public Meetings ........................................... 5-1

5.1.3 Informational Seminars ..................................... 5-2

5.1.4 DOE and NNSA Initiatives .................................. 5-2

5.1.5 Conclusion ............................................... 5-3

5.2 Integrated Safety Management . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5-3

5.2.1 Overview ................................................ 5-3

5.2.2 ISM Annual Update Process ................................ 5-4

5.2.3 Reliability and Configuration Management of Vital Safety Systems . . 5-4

5.2.4 Activity Level Work Planning ................................ 5-4
xix

TABLE OF CONTENTS (Concluded)

Section Page

5.3 Health and Safety Directives . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5-5

5.3.1 Improvement of Directives .................................. 5-5

5.3.2 Worker Safety Rulemaking .................................. 5-6

5.3.3 Implementation of Directives ................................ 5-6

5.4 Safety Programs . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5-7

5.4.1 Development and Implementation of Safety Controls .............. 5-7

5.4.2 Quality Assurance ......................................... 5-8

5.4.3 Software Quality Assurance ................................. 5-8

5.4.4 Suspect and Counterfeit Parts ................................ 5-9

5.4.5 Hoisting and Rigging ...................................... 5-10

5.4.6 Criticality Safety ......................................... 5-10

5.4.7 Research and Development Safety ........................... 5-10

5.5 Technical Competence . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5-11

5.5.1 Training and Qualification of DOE and Contractor Personnel ...... 5-11

5.5.2 System Engineers and Federal Subject Matter Experts ............ 5-11

5.5.3 Nuclear Weapons Knowledge ............................... 5-11

6. PUBLIC OUTREACH

6.1 Public Meetings . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6-1

6.2 Responding to Public Requests ..................................... 6-1

6.3 Electronic Access ................................................ 6-1

6.4 Inquiries Into Health and Safety Issues ............................... 6-1

6.5 Site Representative Activities ...................................... 6-2

APPENDICES 

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

B. 2003 REPORTING REQUIREMENTS. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . B-1

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

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

E. ACRONYMS AND ABBREVIATIONS . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . E-1
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1. INTRODUCTION

1.1 BACKGROUND

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

established by Congress in 1989. Simply stated, the Board’s mandate under the Atomic Energy

Act is safety oversight of the civilian nuclear weapons facilities managed by the Department of

Energy (DOE). The nuclear weapons program remains a complex and hazardous operation. 

DOE must maintain in readiness a nuclear arsenal, dismantle surplus weapons, dispose of excess

radioactive materials, maintain aging facilities, clean up surplus facilities, and construct new

facilities for many purposes. All of these functions must be carried out in a manner that protects

the public, workers, and the environment. 

Congress established the Board to serve as an independent, expert agency capable of

understanding the complexity of nuclear weapons facilities and operations. For that reason,

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

Board has, in turn, assembled a permanent staff with broad experience and competence in all

major aspects of safety: nuclear, mechanical, electrical, chemical, fire protection, and structural

engineering, as well as physics and metallurgy. Currently, 90 percent of the Board’s technical

staff hold advanced degrees, of which 33 percent are at the Ph.D. level.

The Board has established site offices at five high-priority defense nuclear sites: the

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

National Security Complex (Y-12) in Tennessee, Savannah River Site (SRS) in South Carolina,

and the Hanford Reservation in Washington State. The site offices provide the Board with a 

continuous presence at these locations. 

During the Board’s 14 years of operation, its priorities have evolved with changes in the

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

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

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

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

embodied in this plan. The Strategic Plan was revised during 2003; it now contains four

Strategic Areas of Concentration, an increase from prior years’ three. This report is organized

using the revised strategic plan as its outline.

This Annual Report summarizes the Board’s work during calendar year 2003. Sections

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

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

and Infrastructure, and Nuclear Safety Programs and Analysis. Section 6 addresses the Board’s

interactions with the public. Appendices A through E provide additional material: a table of all

Recommendations cited in this report (Appendix A), a list of reports requested from DOE

(Appendix B), a list of the Board’s letters (Appendix C), a summary of administrative and

human resource activities (Appendix D), and a list of acronyms and abbreviations used in this

report (Appendix E).
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1.2 OVERSIGHT STRATEGY

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

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

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

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

principles:

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

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

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

safety problems and to recommend solutions, DOE remains responsible for taking

actions based on the Board’s insights.

! Risk-based Oversight - The Board’s safety oversight activities are prioritized

predominantly on the basis of (a) risks to the public and the workers, (b) the types

and quantities of nuclear and hazardous material at risk, and ©) the hazard of the

operations involved.

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

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

management of nuclear activities. 

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

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

line management and workers to safe work planning and performance.

! Clear Expectations - Effective safety management demands that safety expectations

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

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

! Effective Transition Planning - The Board’s safety oversight of defense nuclear

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

ensure a smooth transition from deactivation to environmental regulation.

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

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

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

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

operations, it has issued 45 formal Recommendations, comprising 210 individual subrecommendations. In that same period of time, the Board has issued 115 reporting requirement

letters. In 2003 alone, the Board issued 26 such letters to DOE, the majority aimed at

operational safety and integrated safety management.

The Board’s Recommendation authority has been used most fruitfully to gain DOE

response to complex-wide hazards and safety management problems. Examples of such matters
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include stabilization and remediation of hazardous materials, technical qualifications of DOE

and contractor personnel, criticality safety, and configuration management of vital safety

systems. In view of the typical breadth and complexity of the issues addressed by a

Recommendation, several years are often needed for DOE to develop an implementation plan

and carry it to completion. By contrast, the reporting requirement has been an effective tool in

obtaining more expeditious action. By using each method in appropriate cases, the Board has

been able to enhance safety and minimize delays and administrative costs to the government.

1.3 STRATEGIC PLAN 

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

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

Strategic Plan identifies the serious hazards associated with the handling of nuclear weapons,

weapon materials, and cleanup of aging and surplus facilities. These hazards include the

following:

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

some stored in an unstable state.

! Aging facilities that require ever-increasing maintenance and surveillance to assure

safety.

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

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

criticality events.

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

lightning.

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

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

concept is called “defense in depth,” and it has been a precept of nuclear safety in the United

States for many decades. Defense in depth is especially important with respect to nuclear

weapon operations, which involve the handling of high explosives in proximity with radioactive

material. 

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

! Nuclear Weapons Operations: Operations that directly support the nuclear stockpile

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

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

! Nuclear Materials Processing and Stabilization: Processing, stabilization, and

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

ensures adequate protection of the health and safety of the workers and the public.
1-4

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

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

manner that ensures adequate protection of the health and safety of the workers and

the public.

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

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

workers, are developed and implemented by DOE.

The remainder of this report is organized according to these safety goals.
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2. NUCLEAR WEAPONS OPERATIONS

2.1 SAFE CONDUCT OF STOCKPILE MANAGEMENT

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

the nation’s nuclear weapons stockpile. Examples of the Board’s activities to improve health

and safety in stockpile management are discussed in the following subsections.

2.1.1 Pantex Plant

Pantex, located near Amarillo, Texas, serves a central role in stockpile management. 

Operations at the site include the assembly, disassembly, dismantlement, and surveillance of

nuclear weapons, as well as interim storage of plutonium removed from retired weapons. In

2003, the Board sought health and safety improvements in weapons operations, fire protection,

lightning protection, laboratory support, and storage of special nuclear materials. The Board’s

pursuit of operational safety improvements at Pantex involved three related areas: development

of adequate safety bases, re-engineering of nuclear explosive processes consistent with

Recommendation 98-2, and operators’ procedural compliance.

SS-21 Upgrades. For several years, the Board has been exhorting DOE to improve the

safety of weapons-related work at Pantex, as provided in Recommendation 98-2. A key concept

of this Recommendation was that DOE needed to simplify and expedite the re-engineering of

nuclear explosive processes at Pantex, such that attendant safety improvements could be put in

place more rapidly. In this regard some progress was made in 2003. DOE completed the

start-up of the SS-21 process for W62 Disassembly and Inspection Program and for the W88 Bay

operations. DOE has also begun development of SS-21 processes for the W78, B83, W87, and

B61 weapon programs. The prompt completion of re-engineering the nuclear explosive

processes for the remaining weapon programs will result in substantial safety improvements.

Transportation and Fire Protection. The Implementation Plan for Recommendation

98-2 includes a commitment by DOE to improve on-site transportation and fire protection at

Pantex. In response to the Board’s critical examination of these areas, DOE completed safety

basis documents and implemented essential safety controls.

Nuclear Materials Management. The Board reviewed the management of inactive

actinide and legacy nuclear materials at Pantex, including Radioisotopic Thermoelectric

Generators containing Plutonium (Pu)-238 (in interim storage). Site personnel initially

identified three groups of items as constituting inactive actinide materials, but the Board

identified other materials that need a clearly defined disposition path and final endstate to be

achieved through the inactive actinide program. In a July 2001 letter, the Board raised several

other materials management issues regarding the packaging and storage program at Pantex. By

the end of 2003, DOE had made progress in completing corrective actions.

Software Quality Assurance. In a letter dated March 25, 2003, the Board highlighted

significant quality assurance faults in the Move Right System, software used to control the onsite transportation of nuclear materials. In response, Pantex upgraded requirements for software
2-2

quality assurance and took compensatory actions to improve the transportation program until the

software system is strengthened.

Repackaging of Pits. In response to Recommendation 99-1, DOE has continued to

repackage pits into durable containers suitable for interim storage. DOE has now repackaged

more than 8,600 pits. The associated container surveillance program has also been rejuvenated;

the surveillance backlog was worked off by the end of fiscal year (FY)03.

Hoisting and Rigging Safety. The proper planning and conduct of lifting activities is

essential to safe operations at Pantex. In a letter dated July 10, 2003, the Board provided an

assessment of the hoisting and rigging program at Pantex. The Board identified a number of

weaknesses in equipment design, reliability, maintenance, and training. In response, DOE

implemented a number of improvements.

Training. In an April 4, 2003, letter, the Board highlighted problems at Pantex with the

methods used to develop training courses, evaluate personnel knowledge, assess training

program elements, and ensure continuous training. These serious deficiencies affect the ability

to maintain and improve the conduct of operations at Pantex. In response, DOE developed shortterm and long-term action plans to correct the deficiencies. Further DOE actions, in response to

the Board’s letter, included an assessment of the Pantex training program that confirmed the

Board’s findings and led to additional corrective actions.

A specific training issue was identified by the DOE readiness assessment for W62

disassembly and inspection operations. First line supervisors at Pantex were not trained on

program-specific procedures, and were not responsible for ensuring that production technicians

implemented procedures in accordance with program-specific training. This issue was not

limited to W62 operations and, in fact, involved all nuclear explosive operations. Encouraged by

the Board to take immediate action, site management promptly initiated a self-study training

program to ensure that first line supervisors are familiar with the safety basis for the programs

they supervise. 

NESS and Readiness Review Conflicts. The Board has repeatedly warned the National

Nuclear Security Administration (NNSA) that concurrent Nuclear Explosive Safety Studies

(NESS) and readiness reviews at Pantex strain contractor resources and hamper the effectiveness

of both reviews. Following the most recent restart of W62 activities, NNSA finally made

changes to its NESS Process Guide to better coordinate these two reviews.

2.1.2 Y-12 National Security Complex 

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

management activities at Y-12 include the production, maintenance, refurbishment,

dismantlement, evaluation, and storage of certain components of nuclear weapons. Production

activities include the manufacture or re-manufacture of unique nuclear weapon components. The

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

preparations for processing of highly enriched uranium, criticality safety, maintenance, nuclear

material storage, fire protection, and limits on combustible loading.
2-3

Readiness for Hazardous Operations. The Board continued to review the readiness

preparations for resumption of hazardous activities at Y-12. Results of a operational readiness

review by the contractor in late 2002 indicated that line management preparations for wet

chemistry operations in Building 9212 were deficient in the areas of procedures, training, and

conduct of operations. The Board monitored both the contractor’s effort to correct these areas

and the operational readiness review completed by NNSA in February. Results from the NNSA

review indicated that adequate improvements had been made; NNSA authorized restart of wet

chemistry operations in March of 2003. While restart of wet chemistry operations with enriched

uranium has been greatly drawn out due to numerous equipment failures, these operations have

been conducted in a manner that adheres to conduct of operations principles. The Board also

provided safety oversight of operational readiness reviews for start-up of a special material

packaging operation in Building 9720-5. Line management preparations in this case were

generally satisfactory. These two readiness efforts exemplify the pre-operational reviews that

will be needed at Y-12 in the future.

Conduct of Operations. The Board found that numerous operational errors implied a

serious decline in proper conduct and formality of operations and in overall safety culture. 

Examples included failure to use required procedures in moving and storing nuclear material,

failure to report equipment deficiencies or events, non-conservative decisions, and poor control

of maintenance work. In September 2003, the Board was briefed by senior site office and

contractor managers on plans to improve operations. A project execution plan, defining the

specific tasks to be accomplished, was issued in December and, if carried out fully, should

improve conduct of operations.

Building 9212 Safety Systems. The Board reviewed implementation of the Operational

Safety Requirements for enriched uranium operations in Building 9212. In an October letter to

NNSA, the Board questioned whether several sprinkler systems met current standards and

whether Y-12 had justified the upgrading of a sprinkler system from safety-significant to safetyclass. In response, the Y-12 site office committed to identify and evaluate differences between

the code of record and new fire safety codes and to document an evaluation for the upgraded

sprinkler system. The Board’s letter also noted that three organic phase separators used in wet

chemistry processes required operator action to ensure safe operation. DOE intends to complete

modifications to two phase separators for passive self-decanting and confirm the adequacy of the

third. 

The wet chemistry area of the B-1 Wing in this building lacks a fixed fire suppression

system. While wet chemistry operations were authorized to be restarted with controls considered

adequate for short-term operations, the Board suggested in 2002 that NNSA consider installation

of a fixed fire suppression system to provide long-term protection for the structure and workers. 

In response, NNSA stated that a decision would be made by April 2003 on whether to proceed

with planning and budgeting for a project to provide fixed fire suppression for B-1 Wing. This

decision was not made, and the Board pressed for progress on the matter with NNSA

management. In September, NNSA informed the Board that quantities of combustible organic

liquids were being further restricted, that certain mitigative options were under review, and that a

decision on a path forward would be made in early 2004. 
2-4

Criticality Safety. The Board has continued its oversight of criticality safety practices at

Y-12. In a letter to NNSA in late 2002, the Board maintained that Y-12 was not placing

sufficient emphasis on simplifying and standardizing the dozens of different containers and

various postings for storage arrays. The Board urged NNSA to standardize storage conditions,

requirements, postings, and containers to ensure that facility operators could understand and

comply with criticality safety criteria. In response, NNSA reduced the amount of stored nuclear

materials and has begun to standardize the storage containers used for fissile material.

Excess Combustible Materials. The Board observed a substantial excess of

combustible materials and generally poor fire safety housekeeping in several Y-12 facilities. 

Locations included sections of Buildings 9201-5, 9212, 9204-4, and 9204-2. DOE took

corrective actions in each of the facilities. The Y-12 contractor recognized the need for an

aggressive program to minimize combustibles and improve overall housekeeping, and was

initiating such a program at year’s end. 

Storage of Depleted Uranium Chips. An inquiry by the Board revealed that depleted

uranium machine chips had been stored in Building 9204-4 in an unsafe configuration for years. 

Several drums were not vented, as required, and the potential existed for chips being stored in a

dry environment. Near-term corrective actions planned by Y-12 management included venting

of the unvented drums using a remotely-operated brass punch and then inspecting the drums for

evidence of water. The Board noted, however, that planning for the venting project had not

taken into account lessons learned from a similar drum-venting operation at another DOE site

where the venting resulted in a fire. As a result, Y-12 incorporated into its work plan electrical

grounding of the drums and extra preparations for fire response. The drums were safely vented

in December 2003. The site also took action to verify that there are no other similar storage

situations existing at Y-12 and reemphasized the protocols for storage of pyrophoric chips.

Glovebox Explosion. In May, an explosion and fire occurred in a Building 9202

glovebox during development testing of a process for uranium metal production. The

contractor’s analysis of the explosion identified corrective actions, including adequate process

safety analysis, equipment design reviews, and start-up testing protocols. The Board reviewed

the proposed corrective actions and characterized them as imperative for proper safety

management of research and development activities beyond bench-scale testing. 

Uranium Storage Facility. The Board continues to review the design of the Highly

Enriched Uranium Materials Facility (HEUMF) for long-term uranium storage at Y-12. The

Board’s constant oversight of this project has led the contractor to adopt a safety-grade, filtered

ventilation system and design a stronger foundation. 

Oxide Conversion Facility. Y-12 is in the final stages of preparing for start-up of the

Oxide Conversion Facility in Building 9212. The Board recently reviewed the operation and

found weaknesses in the functional classification of safety controls, uncertain weld quality, and

an unanalyzed criticality safety scenario. The Board has communicated these concerns to site

personnel for action and will ensure that appropriate actions are taken prior to start-up.
6

 Management of the Department of Energy Weapon Program and Weapon Complex (1979).

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2.1.3 Savannah River Site

Tritium Facilities Modernization and Consolidation. This project was undertaken to

update processing capabilities and reduce the tritium facilities’ operating cost. In 2003, DOE

conducted an operational readiness review for five major systems installed in Building 233-H. 

The Board identified inconsistencies between the contractor and NNSA plans of action for this

review and found deficiencies in the basis upon which the scope of the review depended. NNSA

corrected these problems to the Board’s satisfaction.

Software Quality Assurance. During a review of SQA, the Board noted a significant

number of errors and omissions in the software specification for safety-significant worker

protection systems. Errors included permitting the use of non-safety-grade computers to change

software setpoints and control safety-significant field hardware, thus violating the integrity of a

safety-significant system. SRS agreed to correct the problems the Board had identified.

2.2 SAFE CONDUCT OF STOCKPILE STEWARDSHIP 

Stockpile stewardship is the term used by NNSA to refer to activities carried out in the

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

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

test data in combination with future non-weapon test data and aggressive application of

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

major sites engaged in stockpile stewardship are discussed in the following subsections.

2.2.1 Recommendation 2002-2

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

abilities of the scientists and engineers at the nuclear weapons laboratories. These individuals

apply unique expertise to ensure the safety of weapons operations. The safety information

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

relevant sites. Clear lines of communication are vital to ensure that safety issues raised at any

facility are properly routed to the laboratories for resolution, timely answers are developed, and

critical information is then transmitted for use throughout the complex.

Responding to Recommendation 2002-2, the Secretary of Energy affirmed that support

for the nuclear weapons stockpile remains the highest priority at the national laboratories

assigned to this work. NNSA directed each defense laboratory to establish single points of

contact for safety issues affecting each weapon for which they are responsible and to certify 

processes for selection, training, mentoring, and succession planning for these positions. In

parallel, the NNSA directed each site office to take steps to ensure that requests for laboratory

support are tracked and met. These steps must include provisions to resolve priority conflicts. 

Related actions to implement the Recommendation included a redrafting of DOE Order 5600.16

to clarify roles and responsibilities defined in the order and issuing policy guidance to confirm

the priority of the work supporting the nuclear weapon stockpile.
2-6

In one recent instance, these changes led to the timely resolution of a resource conflict at

LANL so that stockpile support work received suitable priority.

2.2.2 Los Alamos National Laboratory 

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

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

Major projects under scrutiny by the Board include a program for certifying the safety and

reliability of nuclear weapons in the absence of nuclear testing and the development of a limitedscale manufacturing capability for replacement pits. In 2003, the Board focused its attention on 

the Pu-238 Scrap Recovery Line, work planning, lightning protection, design of safety controls,

stabilization of nuclear materials, and fire protection.

Scrap Recovery Line. LANL has almost completed construction of a new aqueous

processing line for recovery of scrap Pu-238. Based on current plans, the new line will be the

only source of purified Pu-238 for at least the next decade. The Board previously found

significant deficiencies in the safety basis and safety controls for this facility. LANL personnel

revised the process hazards analysis and developed more reliable controls. However, the

Board’s review of the revised analysis disclosed that not all safety issues had been identified and

fully explored, suggesting the need for new safety controls. Additional attention to this matter

will be required in 2004.

Work Planning. The Board reviewed LANL’s process for identifying hazards,

describing controls, and authorizing work, and concluded that complete identification of

significant hazards and practical controls does not always occur. Improvements are needed in

the involvement of subject matter experts, training, and use of engineering standards in

programmatic work. To that end, LANL is revising its work planning requirements.

Weapons Engineering Tritium Facility. Previously the Board had noted that although

the lightning protection system at the Weapons Engineering Tritium Facility had been designated

as safety-class (important for the protection of the public), there were numerous physical

deficiencies in system components. In a recent review, the Board discovered that not all

deficiencies had been corrected, and the system still did not meet normal industrial standards. 

LANL engaged two subject matter experts to determine whether the existing lightning protection

system, if properly maintained, could meet its safety requirements. The experts’ opinion was

that the existing system could not fully perform its safety-class function. LANL is developing a

plan to modify the system.

TA-18 Safety Class Controls. In a letter dated July 19, 2003, the Board objected to

LANL’s failure to follow DOE requirements for new safety-class equipment. The primary

concern was that credible single failures would prevent the required safety actions. The Board

also questioned the technical feasibility of the approach that NNSA had directed, namely, to

monitor the temperature of the nuclear material and automatically shut down nuclear assemblies

under certain circumstances. Further reviews are planned to determine the adequacy of LANL’s

corrective actions.
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Recommendations 94-1 and 2000-1. In these related Recommendations, the Board

encouraged DOE to stabilize and safely store nuclear materials. LANL has been the least

responsive site with regard to this important task, due in part to inadequate funding by DOE. On

August 5, 2003, a serious incident occurred that could have been prevented had DOE and LANL

been more responsive to these two Recommendations. 

Fire Protection. LANL conducted a safety review of its site-wide fire alarm system

following the Cerro Grande wildfire and concluded that the system is antiquated and inadequate. 

DOE requested funds for upgrading the system as part of a program to mitigate impacts from the

Cerro Grande fire, but on January 9, 2003, DOE rescinded some Cerro Grande funds including

those allocated for the alarm system upgrade. In a letter to DOE dated January 24, 2003, the

Board highlighted the negative safety implications of this action and requested a report

documenting how DOE planned to ensure fire safety in light of the funding cut. DOE restored

the funds in response to Congressional inquiries, but recent discussions with DOE reveal that the

project schedule has slipped by 5-6 months and funding is not yet stable. 

In the course of implementing Recommendation 2000-2, LANL assessed the adequacy of

the remaining facility fire alarm system and the balance of the site-wide communication system. 

The Board is seeking from LANL an explanation regarding necessary upgrades not scheduled for

completion until FY12.

2.2.3 Lawrence Livermore National Laboratory 

Lawrence Livermore National Laboratory (LLNL), located 45 miles southeast of San

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

technical expertise to support stockpile stewardship and management, including consultation on

the surveillance and dismantlement of LLNL-developed nuclear weapons. Most defense nuclear

activities are conducted in the Superblock complex, which includes the Building 332 Plutonium

Facility and the Tritium Facility. The Board conducted several on-site reviews during 2003,

focusing on the Superblock safety bases and vital safety systems, the deactivation of the Heavy

Element Facility (Building 251), and the management of nuclear materials. 

Defective Safety Basis. The Board reviewed the current safety bases for the Plutonium

Facility (Building 332), the Hardened Engineering Test Facility (Building 334), and the Material

Management Source Vault (Building 23lV). This review was supplemented by walkdowns of

safety-related systems and components. In a letter dated April 10, 2003, the Board

communicated to NNSA a number of inadequacies. These inadequacies included postulated

accident scenarios for which unmitigated consequences had been evaluated to exceed the off-site

evaluation guidelines, but for which no safety-class controls had been identified. In some cases,

safety systems had been implicitly credited with performing a safety function, but had not been

assigned a formal functional classification. In a response dated June 23, 2003, NNSA committed

to correcting these faults as part of the new documented safety analysis. LLNL is also upgrading

Building 332’s Emergency Power System to meet safety class electrical codes. This system had

been found deficient by the Board in connection with the reviews of vital safety systems under

Recommendation 2000-2.
7

 “ALARA” refers to a radiation protection program based on the principle of reducing exposures to a level “as low

as reasonably achievable.”

2-8

Deactivation of Building 251. In 2003, the Board continued its review of LLNL’s plans

for the deactivation of the Heavy Element Facility, Building 251 (B. 251). The deactivation of 

B.251 involves the removal of nearly 300 items of radioactive material, some posing a

significant risk of radiation exposure to workers and potential for release of contamination in the

building. Decontamination and removal of 48 gloveboxes and other equipment will require

careful planning to ensure that contamination is properly controlled. The project is being carried

out on an accelerated schedule to achieve near-term risk reduction and thus avoid costly safety

basis upgrades. During 2003, the Board conducted reviews of final preparations for the

readiness assessment for large-scale inventory reduction operations.

Despite NNSA’s authorization to commence the inventory reduction campaign,

inadequacies remained in ALARA7

 practices, formality of operations, and work control.

Continuing safety oversight by the Board led to the engagement of expert observers during initial

operations. Late in 2003, LLNL safely completed an initial campaign that removed enough

inventory to meet the year-end goal of reducing the building’s inventory by 80 percent (based on

curie content). 

Recommendation 94-1. LLNL has completed most of the stabilization and packing of

material covered by Recommendation 94-1. The plutonium-containing materials are now stored

in strong, welded containers that meet DOE’s Plutonium Storage Standard, DOE-STD-3013. 

LLNL examined additional material, termed inactive, to ensure that it could be dealt with in a

similar way and in a timely manner. LLNL is characterizing, stabilizing and packaging the

inactive materials using the same methods and equipment used in the Recommendation 94-1

campaign.

2.2.4 Nevada Test Site 

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

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

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

weapons is no longer being conducted at NTS. However, NTS is maintained in a state of

readiness should national security requirements demand the resumption of underground testing. 

The Board seeks to ensure that if testing is resumed, it would be done safely. During 2003, the

Board focused its attention on NTS’s test readiness posture, capability to dispose of a damaged

nuclear weapon, to undertake subcritical experiments, and to conduct transuranic (TRU) waste

operations.

Underground Testing. In 2002 the Board had found weaknesses affecting NNSA’s

ability to conduct safely an underground nuclear weapons test. The number of personnel

qualified to plan and conduct underground nuclear weapons tests was shrinking. There was no

formal safety basis for an underground nuclear weapons test, nor was there a rigorous process to

assess the safety of such a test. During its 2003 review of NTS’s current test readiness posture,

the Board found an improved capability to resume testing. NNSA implemented a plan to prepare

a safety basis, stem the loss of experts, improve the state of readiness of facilities and equipment,
8

 An improvised nuclear weapon produces explosive yield from nuclear fission. Such devices may be fabricated in

a completely improvised manner or may result from a modification to a U.S. or foreign nuclear weapon.

2-9

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

explosive operations. The Board observed improvements in personnel, facilities, equipment and

training.

Damaged Weapons. The Board continued to press for a program and infrastructure to

safely dispose of a damaged or improvised nuclear weapon.8 During 2003, the Board reviewed

safety basis developments, infrastructure improvements, practices, procedures, and training. 

NNSA continued to make physical improvements to G-Tunnel, and conducted training on the

full scope of disposition activities at NTS. The Board provided feedback on the developing

safety basis and pointed out that the conduct and formality of operations needed significant

improvement. To accomplish this, NNSA plans to complete the safety basis, strengthen conduct

of operations, develop specific procedures for disposition operations, and conduct training.

Subcritical Experiments at NTS. After reviewing the Joint Actinide Shock Physics

Experimental Research facility at NTS, the Board concluded that the quantity of nuclear material

in the targets would exceed the threshold values for a Hazard Category 3 nuclear facility. 

However, NTS personnel had not developed safety controls appropriate for this level of hazard. 

As a result of a July 2001 letter from the Board, a visit by the Board to NTS in April 2002, and

numerous other communications, the contractor designed controls adequate for the safety of this

operation. In 2003, the Board reviewed and found adequate the controls and configuration

management for experiments with plutonium. 

Safety Basis Reviews. The Board reviewed the safety basis for the Device Assembly

Facility, U1a Complex and Subcritical Experiments, Area 5 Radioactive Waste Management

Complex, and G-Tunnel. While the Board found that the safety bases had improved, they were

nonetheless faulty in several respects, including use of an incorrect methodology in a hazard

analysis, inadequately developed safety controls, incomplete description of the scope of some

activities, incompletely analyzed operations, and erroneous classification of safety controls. 

Corrections are underway.

Electrical and Lightning Safety. In 2003, the Board reviewed electrical and lightning

protection and detection systems for the U1a Complex, Device Assembly Facility, G-tunnel, and

the Joint Actinide Shock Physics Experimental Research facility. Several facilities at NTS

perform operations in which special nuclear material is collocated with significant quantities of

high explosives, and operations of this kind could commence with little or no warning. 

However, the Board observed that not all of the facilities that could potentially house these

operations are currently equipped with adequate lightning detection capabilities or welldocumented lightning protection controls. Two workers were struck by lightning at the U1a

Complex in 2002 because lightning warning was insufficient. NNSA increased the distance for

lightning warning but did so without adequate technical basis and due consideration of other

warning and protection mechanisms. The Board informed NNSA it would be prudent to

establish compensatory measures to mitigate potential lightning hazards until code-compliant

lightning detection and protection programs have been adequately implemented.
9

 Stabilization, Packaging, and Storage of Plutonium-Bearing Materials (September 2000).

3-1

3. NUCLEAR MATERIALS PROCESSING AND STABILIZATION

3.1 STABILIZATION AND STORAGE OF REMNANT MATERIALS

3.1.1 Complex-Wide Program

Research and Development Funding. Recommendation 94-1 stressed the importance

of establishing a research program to close gaps in the technical bases for safe interim storage

and long-term disposition of fissile materials. DOE’s Implementation Plan for Recommendation

2000-1 noted the contributions made by its research and development program in providing

technical support for site operations to safely stabilize, package, and store plutonium. DOE’s

standard for handling plutonium, DOE-STD-3013,9 which establishes requirements governing

the long-term storage of plutonium metal and oxides, relies on several research and development

programs, including the Materials Identification and Surveillance Program, to ensure the longterm safety of stored packages containing plutonium-bearing materials. 

In early 2003, the Board discovered that the budget DOE submitted to Congress had

eliminated funding for the 94-1 research and development program in Fiscal Year 2004 and

beyond. In a letter to DOE dated March 20, 2003, the Board pointed out that significant

reductions in research and development could make it impossible to verify safe storage

parameters as required by DOE-STD-3013. In response, the Assistant Secretary for

Environmental Management, in a letter dated May 27, 2003, committed to restore funding for

this program.

Deactivation of F-Canyon. The Board has urged DOE on several occasions to ensure

that clear and achievable stabilization and disposition paths are available for fissile materials

remaining in the defense nuclear facilities complex. In 2002, DOE began the deactivation of the

F-Canyon facility at SRS, thereby removing from service one disposition path. To assess the

wisdom of this course of action, Congress mandated in FY03 legislation that the Board and DOE

certify that the capabilities of the F-Canyon facility were no longer needed and that all

processing needs could be met by using the H-Canyon facility at SRS or by alternative means.

In early 2003, staff members of the Board and DOE provided briefings on F-Canyon to

representatives of the Office of Management and Budget and to staff members of the South

Carolina Congressional delegation and the Armed Services Committees of the House and Senate. 

Following these briefings, Congress deleted the requirement for the Board to certify the need for

further utilization of F-Canyon; DOE is still required to provide such a certification, which it has

not yet done. Meanwhile, many metric tons of plutonium and uranium materials under the

control of DOE’s Office of Environmental Management lack clearly defined disposition paths. 

3.1.2 Plutonium

Overview. In response to Recommendations 94-1 and 2000-1, DOE committed to

stabilize and package its legacy plutonium materials. Significant progress has been made toward 
3-2

meeting this commitment at some sites. Rocky Flats completed stabilizing and packaging all of

its plutonium metal and oxide into durable, sealed containers complying with DOE-STD-3013.

At Hanford’s Plutonium Finishing Plant, most activities committed to in the Implementation

Plan for these Recommendations have been completed, including the stabilization and packaging

of plutonium solutions, alloys, polycubes, and residues. Facility operators completed packaging

of plutonium metal items in containers compliant with DOE-STD-3013, but weld porosity

problems led DOE to conclude that 358 of the cans require further evaluation with digital

radiography. Cans found to have unacceptable porosity will be rewelded. This work is planned

to be completed no later than May 2004. Also during 2003, SRS started up plutonium oxide

stabilization furnaces and a packaging system for its plutonium oxides and metals.

Unfortunately, other sites have missed or will likely miss milestone dates for completion

of Implementation Plan commitments. LLNL missed the milestone to complete stabilization and

packaging of excess plutonium and uranium during 2003. Oak Ridge National Laboratory

(ORNL) has again missed the milestone to disposition 701 grams of Pu-238 and 132 grams of

surplus Plutonium (Pu)-239.

LANL. The protracted stabilization program at LANL remains a concern. 

Approximately 3,000 excess items and 1,500 programmatic items remain to be stabilized and

repackaged. Managers at LANL have completed a revised project execution plan for the

stabilization program. However, the schedule is still based on the July 2002 revision of the

Implementation Plan for Recommendation 2000-1, a plan rejected by the Board because it

extended the schedule to 2010. 

Despite the slow pace, LANL continues to make progress in repackaging programmatic

materials and stabilizing certain residues. The most encouraging development at LANL during

2003 was the successful initiation of a program to discard low-assay plutonium residues rather

than expend resources on processing them to recover small quantities of plutonium. In

correspondence to DOE dating back to 1999, the Board had suggested that such a strategy could

significantly accelerate the stabilization program at LANL.

Hanford Oxides. During 2003, the Board evaluated a Hanford proposal to stabilize

plutonium oxides containing chloride salts at a lower temperature than established by

DOE-STD-3013. This request was based on achieving technical equivalency with the standard’s

requirements for allowable moisture. Initially, Hanford proposed performing stabilization at

750°C, measuring weight loss at 600°C, and then inferring the moisture loss that would occur up

to 1000°C. The Board maintained that there were insufficient technical data to support DOE’s

assertion that essentially all sample weight loss above 750°C would be due to volatilization of

compounds other than water. DOE subsequently revised its approach to measure moisture loss

up to 1000°C and to re-stabilize the material in the event that total sample weight loss exceeded

the allowable limit. Stabilization of plutonium oxides containing chloride salts has commenced

and is expected to be completed before May 2004, the date committed to in the Implementation

Plan for Recommendations 94-1 and 2000-1.

The Board reviewed DOE’s plans to recover and dispose of 12 drums at Hanford 

containing high concentrations of Pu-238 oxide. This material is thermally hot due to the high 
3-3

specific activity of Pu-238 and will pose a significant radiological hazard during the recovery

and handling of the drums. In early 2003, the Richland Operations Office requested technical

assistance from DOE Headquarters to help with the difficulties of handling these drums, but the

request was denied for lack of resources. To date, DOE has yet to develop a viable plan for the

safe recovery and handling of these drums. On November 7, 2003, the Board issued a letter to

DOE requesting such a plan.

3.1.3 Uranium

Highly Enriched Uranium. Operators at SRS met the commitment in the

Recommendation 2000-1 Implementation Plan to begin downblending solutions of highlyenriched uranium. The low-enriched uranium solution resulting from this activity is being

shipped offsite for fabrication into fuel for commercial power reactors.

Building 3019 at ORNL. In July 2003, the Board found weaknesses in the documented

safety analysis (DSA) submitted to DOE for Building 3019 at ORNL. This building currently

serves as the national repository for Uranium (U)-233. The ORNL contractor agreed to make

certain changes including (1) revising the process used in the DSA for evaluating and screening

toxicological and radiological hazards to comply with current standards, (2) designating the high

efficiency particulate air filters in the Vessel Offgas System as safety-significant equipment, 

(3) adding a Limiting Condition of Operation for operability of the Vessel Offgas System, and

(4) adding a Technical Safety Requirement to ensure that the cell covers, which provide a safetyclass function for radiological confinement. The Board believes these changes will significantly

enhance the safety of storing U-233 in this aging facility.

U-233 stored in Building 3019 was the primary concern of Recommendation 97-1. The

Phase 1 container inspection program defined in DOE's Implementation Plan for this

Recommendation has been completed, and DOE has selected a contractor to safely process these

materials as part of a Medical Isotope Program. All deliverables from the Recommendation 97-1

Implementation Plan have now been completed.

DOE is taking action in response to a letter issued by the Board in September 2002

regarding the safe storage of sodium fluoride traps in Building 3019. These vessels, which store

Uranium (U)-233 hexafluoride recovered from the Molten Salt Reactor Experiment, are being

subjected to increasing internal pressure from radiolytic gas production. ORNL has now

completed depressurizing all but one of the 26 traps as an interim measure and is monitoring the

relatively low pressure in the remaining trap until it can be depressurized.

Depleted Uranium. The plutonium production mission at SRS required large quantities

of depleted uranium to be fabricated into targets, irradiated in reactors, and subsequently

processed through chemical separations facilities. During approximately 40 years of plutonium

production, a significant inventory of depleted uranium trioxide and metal accumulated at SRS. 

On March 7, 2002, the Board issued a letter urging DOE to correct unacceptable storage

conditions and to develop an integrated plan for disposing of this excess material. DOE replied

on December 20, 2002, with a project plan for dispositioning these materials.
10 DOE M 435.1-1 (1999).

3-4

Overpacking of severely degraded drums now has been completed, and DOE is on track

to dispose of these materials by the end of 2004. All 2,735 metric tons of depleted uranium

metal has been shipped to Envirocare, a commercial low-level waste facility in Utah, for

disposal, along with 2,000 metric tons of depleted uranium trioxide. By December 2003,

contracts were either in place or pending approval for the off-site disposal of the remaining

18,000 metric tons of depleted uranium trioxide, 260 metric tons of low-enriched uranium oxide,

and 186 metric tons of depleted uranium solutions by the end of 2004.

3.1.4 Special Isotopes

Slurry Transfer at SRS. The Board reviewed DOE plans for transferring 30,000

gallons of slurry containing 148,000 curies of americium and curium from F-Canyon to a highlevel waste tank (Tank 51) in H-Area for subsequent vitrification in the Defense Waste

Processing Facility at SRS. This complicated inter-area transfer required extensive coordination

between F-Canyon, F-Area Tank farms, and H-Area Tank farms. The Board suggested

improvements for handling contingencies associated with a potential loss of active ventilation in

H-Area Diversion Box 8 and encouraged integrated test-runs with surrogate slurry materials. 

DOE incorporated the Board’s comments into the control strategy and preparatory activities for

the transfer. On January 28, 2003, the contractor safely and successfully completed the transfer.

Hanford Cesium and Strontium. The Hanford Waste Encapsulation and Storage

Facility holds approximately 100 million curies of cesium and strontium salts in doubly

contained capsules. DOE has proposed to transfer these capsules from the storage pool into dry

storage in shielded containers on a storage pad. The Board’s review of the project’s plans

revealed that DOE’s approval of safety design criteria was not going to be obtained, in

contravention of 10 CFR Part 830 and the Radioactive Waste Manual.10 DOE has directed the

contractor to correct this error.

3.1.5 Inactive NNSA Nuclear Materials

Overview. The Board continues to believe that NNSA must improve its management of

inactive nuclear materials. In a letter dated December 31, 2002, the Board pointed out

deficiencies in nuclear materials management that were not adequately addressed in NNSA’s

letter to the Board dated September 17, 2002. The principal deficiencies involved

characterization of materials for storage or disposition, identification of materials having no

defined future use, and analysis and upgrading of materials packaging and storage facility

conditions. In a response to the Board’s letter on February 7, 2003, NNSA reported the

formation of an Inactive Actinides Working Group (IAWG). 

The IAWG has developed a strategy for achieving improvements in three distinct areas: 

(1) Acceptance and Retention of Nuclear Materials, (2) Materials Characterization and Storage

Adequacy, and (3) Disposition. The IAWG made progress toward achieving these goals by

preparing an update to the Nuclear Materials Inventory Assessment Guide. This guide

recommends classifying all nuclear materials as “needed” or “unneeded,” providing justification
3-5

for continued storage, ascertaining the adequacy of characterization of materials needed for

continued storage, and developing a disposition path for all unneeded inactive actinide materials.

Specific Facilities. The Board reviewed the packaging, storage, and disposition plans for

inactive nuclear materials at LLNL, Sandia National Laboratory, LANL, and Y-12. These sites

continue to house substantial inventories of active (programmatic) and inactive nuclear materials

that represent a potential hazard to the workers, the public, and the environment. NNSA will

need to support the efforts of the IAWG to repackage or otherwise dispose of materials in

configurations unsuitable for long-term storage.

At Y-12, the Board reviewed the nuclear materials management program and evaluated

the steps taken in response to the Board’s letters of May 20, 2002, and December 31, 2002. The

Board’s close oversight of this program spurred NNSA to release funds making it possible for 

Y-12 to begin disposing of material no longer needed to support site missions. Environment,

safety, and health vulnerabilities will be reduced by the near-term disposition of combustibles

contaminated with highly enriched uranium, its residues, and excess depleted uranium. 

3.2 STABILIZATION OF SPENT NUCLEAR FUEL

3.2.1 Hanford Site

The Board continues to place a high priority on its oversight of the Spent Nuclear Fuel

Project (SNFP) at Hanford’s K-Basins. DOE has reduced risk significantly by removing

approximately 70 percent of the spent fuel from the K-Basins. K-Basin workers removed

approximately 55 percent of the fuel from the K-East Basin, where fuel degradation has

generated about 42 cubic meters of highly radioactive sludge. Continuing equipment problems

are hindering the efficient removal of the remaining fuel. The contractor was unable to meet the

milestone in the Implementation Plan for Recommendation 94-1 to begin sludge removal from

the K-East Basin in December 2002 and has yet to do so.

The fuel retrieved from the K-Basins is cleaned, dried, and sealed in Multi-Canister

Overpacks (MCOs). The MCOs initially are mechanically sealed as an interim measure, and

then are permanently welded shut. When the Board suggested that the lack of capability to

perform the required closure weld on the MCOs was a significant vulnerability, DOE chose in

early 2003 to implement such a system. Shortly after welding became available, an MCO with a

leaking mechanical seal was identified. With technical oversight from the Board, DOE opted to

promptly weld the leaking MCO (in contrast with a previous instance, when a leaking MCO had

been inserted in an overpack storage tube, a less desirable solution). All MCOs in storage now

have mechanical or welded seals that have passed the required leak tests.

In its letter of March 7, 2003, the Board pointed out deficiencies in the preparations for

start-up of the system to transfer fuel between basins. Neither DOE nor contractor oversight was

effective in identifying and correcting these problems. Additional reviews by both the Board

and DOE identified significant weaknesses in the authorization basis and procedures, leading the

contractor to delay its operational readiness review (ORR) for the K-East Basin Sludge Water

System several times in early 2003. The contractor’s ORR finally began in April 2003 but was
3-6

terminated because of significant deficiencies in procedures and training, problems in the

system’s technical basis, and overall poor performance by project management.

Subsequent reviews by the Board revealed programmatic breakdowns in the areas of

configuration management, conduct of engineering, conduct of design, project management, and

project oversight. The Board noted that self-assessment by the project was not effective and that

lessons from these failures were not passed on to other SNFP activities. For example, the Board

reviewed fuel transfer operations and design modifications and found problems with

configuration management of safety documents and implementation of the Unreviewed Safety

Question process. DOE representatives reviewed the Fuel Transfer System and identified

additional safety basis and design issues. The extent of the problems led DOE to conclude that

integrated safety management (ISM) is not adequately implemented for this project.

The extensive problems described above have made it impossible for DOE to meet the

commitment in the Implementation Plan for Recommendations 94-1 and 2000-1 to complete

removal of sludge from the K-Basins by August 2004. In a letter dated April 10, 2003, before

the true extent of these problems had been acknowledged by DOE, the Board requested that

DOE provide a clear path forward for meeting the completion date in 2004 or provide a revised

implementation plan with a justification for the delay. DOE’s reply admitted that the schedule

and path forward for sludge removal are no longer clear. DOE is now considering developing a

new approach to processing the sludge for disposal and leaving most of the sludge in the basins

in the interim, with some risk reduction actions taken. This approach would likely add several

years to the sludge removal schedule.

3.2.2 Savannah River Site

During the last few years, DOE has been consolidating storage of spent nuclear fuel at

SRS into the L-Basin facility. DOE completed the emptying of the K-Basin in the fall of 2002

and implemented a safe shutdown and deactivation plan to minimize the need for surveillance

and maintenance. In October 2003, DOE completed the removal of spent nuclear fuel from the

Receiving Basin for Off-Site Fuel and developed a similar safe shutdown plan for this facility. 

Once this plan is implemented, surveillance will be limited to inspection of basin water level and

periodic inspection of the waste cell. All foreign and domestic research reactor fuel will now be

received and stored at L-Basin. 

In December 2003, DOE completed the dissolution of the last Mark 16/22 spent nuclear

fuel bundle. This achieves the milestone in the Implementation Plan for Recommendations 94-1

and 2000-1 for stabilizing spent nuclear fuel at SRS. The campaign began in July 1997 and

resulted in stabilization of 1,170 fuel assemblies. 

3.2.3 Idaho National Engineering and Environmental Laboratory

The Board reviewed operations to dispose of spent nuclear fuel at the Idaho National

Engineering and Environmental Laboratory (INEEL). Idaho site workers completed the transfer

of 2,425 pins of spent nuclear fuel from the Power Burst Facility reactor pool to dry storage in

the Irradiated Fuel Storage Facility, located in the Idaho Nuclear Technology Engineering 
3-7

Center (INTEC). DOE completed this action in September 2003, in advance of the commitment

in the Idaho Settlement Agreement. This achievement consolidates nearly all of the Idaho spent

fuel at INTEC where it may be dried and packaged in standard containers for shipment to the

planned geologic repository at Yucca Mountain. The final items to be transferred are six dry

casks containing commercial fuel from earlier rod consolidation testing at Test Area North. The

contractor plans to ship these casks to INTEC in 2004.

3.3 WASTE MANAGEMENT

3.3.1 High-Level Waste

Tank Integrity. Based on guidance provided by the Board in a 2002 letter, DOE

extended the high-level waste (HLW) tank inspection program at SRS to require ultrasonic

inspection of all double-shell tanks. Previously, DOE had proposed a 9-year schedule for

inspecting all the double-shell tanks at SRS. When the Board pointed out the potential for

corrosion in this long time period, DOE accelerated the inspection schedule. The initial

inspection of all double-shell tanks at SRS is now scheduled to be completed before the end of

fiscal year 2006.

Accelerated Salt Waste Disposition at SRS. DOE has attempted to accelerate the

stabilization of salt waste at SRS using on-site disposition of saltcake after limited processing. 

Saltcake is generated by the precipitation of materials during the concentration of HLW

solutions in the three HLW evaporators, and contains smaller concentrations of fission products

and actinides than the concentrated HLW liquid and sludges. One option being considered is to

make use of a planned salt waste processing facility designed to decontaminate concentrated

HLW liquids. This facility would be capable of decontaminating saltcake; however, the

schedule and capacity of this facility are based on the assumption that most saltcake will be

disposed of by other means. It will not be operational until 2009, and it is not clear whether the

current design throughput will be sufficient to meet the site’s closure goals.

The Board has continued to encourage DOE to avoid excessive reliance on optimistic

predictions of unproven technologies and initiatives, to systematically and realistically assess the

technical and regulatory risks associated with its plans for disposing of salt waste, and to develop

strategies to mitigate identified risks. Toward these ends, the DOE Implementation Plan for

Recommendation 2001-1 committed DOE to submit to the Board by August 2003 a

programmatic risk analysis for the salt processing program, as well as an evaluation of the

progress on the saltcake disposition effort. DOE was unable to meet this deadline. The Board

will continue to insist that DOE expedite completion of these tasks. 

SRS Tank Farms. In 2003, the Board sought to reverse a marked and worrisome

increase in inadvertent waste transfer events at the HLW tank farms. Causes included operator

errors, inadequate procedures, and equipment malfunctions. With the Board’s oversight, the

tank farms contractor developed corrective actions in conduct of operations, equipment

conditions, and work practices. The corrective actions included additional operator training, a

review of siphon evaluations for each waste transfer by an experienced engineer, maintaining a

record of the operability of transfer equipment, and verifying siphon break design features in
3-8

equipment. Changes are also being made in transfer control procedures and other documents to

help prevent inadvertent transfers.

INEEL Tank Closure Preparations. Preparations for closing high-level waste tanks at

INEEL are on schedule. INEEL operators successfully washed and sampled two additional

HLW tanks in preparation for grouting and closure, consistent with the closure plan submitted to

the Idaho Department of Environmental Quality. This increases to four the number of tanks in

seismically vulnerable pillar-and-panel vaults ready for closure. The fifth tank is expected to be

washed and sampled by spring 2004. 

Hanford Tank Farms. The Board continued to oversee activities at the Hanford HLW

tank farms, conducting reviews in areas such as work planning and safety analyses for waste

retrieval activities, conduct of operations, training, and feedback and improvement. Examples

follow.

! Tank Integrity: In response to an earlier request by the Board for action to

remediate corrosion in double-shell HLW tanks, the tank farms contractor sought to

adjust waste chemistry. In April 2003, corrosion inhibitors were added to doubleshell tank 241-AN-107. This action was accomplished in support of a DOE

commitment to the Board to correct the chemistry for four double-shell tanks.

! Waste Feed Delivery: In a letter to DOE in September 2002, the Board found fault

with the uncertainty in the analysis to determine the minimum design pressure of the

waste feed delivery transfer system. DOE responded by initiating a technical

evaluation to confirm that the analysis and assumptions support the design. In 2003,

the tank farms contractor prepared an action plan responding to the recommendations

in this evaluation, and undertook additional waste characterization and engineering

studies.

! Safety Basis for Tank Farm Operations: The Board reviewed the DSA for the tank

farms, prepared to comply with 10 CFR Part 830. Responding to the Board’s

questions on the use of less-than-bounding factors in the analysis, DOE conducted an

assessment and found that the estimate of the bounding source term for design basis

accidents was incomplete. To remedy this, a more conservative factor was used to

calculate the radiological consequence of the flammable gas accident scenario in the

final safety analysis. DOE also modified the Technical Safety Requirements for the

tank farms to explicitly require the use of process control plans for activities that can

induce flammable gas release from the wastes.

! Waste Retrieval: The Board reviewed safety basis documents, plans, and

procedures that had been prepared for the retrieval of high-level waste by sluicing,

acid dissolution, and vacuum retrieval, and supplemented this review by observing

sluicing and acid dissolution in the tank farms. The Board shared observations from

the reviews with DOE and contractor personnel, and subsequently observed

improvements where deficiencies had been identified. In particular, the Board has

noted improved operator training and testing, and training for supervisory personnel.
3-9

3.3.2 Low-Level and Transuranic Waste

Waste Isolation Pilot Plant. The Waste Isolation Pilot Plant (WIPP) is a geologic

repository utilized for the disposal of defense TRU wastes. WIPP received its first waste

shipment on March 25, 1999. During 2003, the site received and deposited in the underground

repository more than 800 shipments totaling in excess of 8,000 cubic meters of contact-handled

TRU waste. The Board monitored operations at WIPP to assure that worker safety would be

protected as the facility moved toward full production. The Board plans to review in depth the

preparations for disposal of higher hazard, remote-handled TRU waste.

Idaho National Engineering and Environmental Laboratory. The Board issued a

letter on March 7, 2003, identifying the absence of activity-based hazard analyses for the

retrieval of transuranic waste containers. In response, the DOE Idaho Operations Office

imposed the requirement that respirators be worn by the work force at the Advanced Mixed

Waste Treatment Project until justification could be provided to relax this control. In November

2003, the contractor submitted an exposure assessment report intended to justify removing the

requirement for respiratory protection. The report describes an extensive personnel and area

monitoring program that was conducted during the retrieval of 600 waste containers. No

significant chemical or radiological contaminants were observed during the monitoring program. 

Melton Valley Transuranic Waste Treatment Project. The Melton Valley

Transuranic Waste Treatment Project at ORNL is designed to process liquid and solid TRU

waste and low-level radioactive waste, including high-activity low-level wastes, for offsite

disposal. The Foster Wheeler Environmental Corporation designed and constructed the project

under a DOE privatization contract. Foster Wheeler will operate the facility and decommission

it when its mission is complete.

Due to the hazards posed by high activity of substantial portions of the TRU and

low-level wastes to be processed by this facility, the Board closely examined the design and

construction of the project’s Valley’s Waste Processing Facility and the preparation of its

documented safety analysis. Due to regulatory delays in WIPP’s readiness to receive remotehandled TRU waste, initial operations will be restricted to the processing of supernate from the

Melton Valley Storage Tanks for disposal at NTS as high-activity low-level waste. A Foster

Wheeler ORR and a DOE Oak Ridge line management assessment of readiness were completed

in late 2003. An ORR conducted by DOE headquarters is scheduled for early 2004. 

Hanford. At Hanford, the Board reviewed plans and safety documents associated with

the retrieval of drums of TRU waste from soil-covered trenches. Among the approximately

38,000 drums to be recovered are many that will likely be unmarked, unvented, and in poor

physical condition. The Board focused its review on the controls to prevent the spread of

contamination and potential uptakes of airborne contamination by workers. The Board found

that the controls proposed by the contractor were not commensurate with the hazard presented by

the worst-case accident scenario. The Board informed DOE of its concerns, and in response,

DOE directed the contractor to strengthen the control set. Operators at the Hanford burial

grounds began retrieval operations in late 2003. 
3-10

3.4 FACILITY DEACTIVATION AND DECOMMISSIONING

3.4.1 Overview

Fires, personnel contaminations, and other accidents continue to occur during

deactivation and decommissioning (D&D) of defense nuclear facilities. The Board is concerned

about increased risk to the workers, the public and the environment caused by inadequacies in

DOE’s oversight of these activities and its increasing reliance on contractors to ensure safety. 

The Board analyzes each accident, and for the more serious events requests a briefing from DOE

officials to better understand the causes of the accident and probe the efficacy of solutions.

3.4.2 Ohio Field Office

DOE’s Ohio Field Office is responsible for the cleanup of the Fernald and Miamisburg

(Mound) Closure Sites. Work at these sites has been progressing on or ahead of schedule, but

experienced DOE and contractor personnel are leaving as the completion date of 2006 draws

nearer. The Board recognizes the need for DOE to consolidate resources as work at these sites is

completed, but such consolidation cannot be allowed to reduce prematurely necessary federal

oversight of contractor work. The Board has informed DOE of this concern and is continuing to

monitor safety at Fernald and Mound.

3.4.3 Fernald Closure Project

Although the contractor is making good progress toward closure of the Fernald site by

2006, the Board observed that the number of reportable occurrences and near misses in 2002 and

the first half of 2003 was on the rise. The Board’s review found that many of the contractor’s

project and field managers believed that they had achieved adequate safety and that meeting the

schedule was the top priority. The Board also noted that new workers at the site were involved

in a disproportionate share of the site’s injuries. From the Board’s perspective, both DOE and

the contractor had been slow to take corrective actions. In August 2003, the Board sent a letter

to DOE documenting these and other worker safety issues.

In response to the Board’s letter, DOE and the contractor took several corrective actions. 

First, the contractor provided additional training to field managers, emphasizing accountability

for safety performance. Second, the qualifications of new workers were more closely examined. 

Third, workers and supervisors who did not exhibit safe work practices were replaced. Fourth,

the contractor halted work on the silos and other D&D projects to evaluate safety issues and

improve safety performance. Fifth, the site contractor terminated the main subcontractor on the

D&D project and assumed responsibility for completing the remainder of the D&D work. The

Board plans to review the D&D project when work resumes.

3.4.4 Miamisburg Closure Project

The Miamisburg Closure Project includes D&D of former radioactive materials research,

development, and processing facilities at the Mound Site. The new contract for closure activities

specifies accelerated cleanup and transfer of the site to the Miamisburg Mound Community 
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Improvement Corporation for industrial use by March 31, 2006. The tempo of site demolition

and cleanup work has increased since the new contract was signed. The new contractor also has

taken actions to correct weaknesses previously identified by the Board, for example, insufficient

detail in work procedures. A core team of facility and project managers and safety and

radiological protection personnel has also been established to review all work procedures before

they are approved for use.

3.4.5 Y-12 National Security Complex

Building 9206 at Y-12, currently classified as a Hazard Category 2 facility for storage of

nuclear material, is being deactivated by NNSA. In recent years, the Board sent several letters to

NNSA urging action to reduce the risk from significant amounts of hazardous and radioactive

materials in this facility. A particular hazard involved uranium-contaminated solutions that

remained in glass extraction columns out of service since 1994. In June 2003, the contractor

drained secondary extraction column liquids into bottles for interim storage. In October 2003,

the bulk of the liquid in the primary extraction columns was drained, greatly reducing the

uranium solution inventory. The safety benefits include reducing the likelihood of exposing the

workers to radioactive material and removing a significant source term in the event of a fire.

3.4.6 Rocky Flats Environmental Technology Site

Decommissioning activities are the last of high-hazard nuclear operations at the Rocky

Flats Environmental Technology Site (RFETS). RFETS is on schedule for accelerated cleanup

and closure by 2006, but there have been a number of significant safety incidents in the past

year. These include (1) exposure of 23 individuals in Building 776 to high levels of airborne

contamination when a flow reversal occurred in the ventilation system, (2) vandalism of highefficiency particulate air filters, and (3) a fire in a highly contaminated glovebox. The Board

believes that ineffective DOE oversight and inadequate work planning contributed to these

events.

The most serious of the incidents was a fire that occurred on May 6, 2003, during

preparations to dismantle an atypical glovebox contaminated with plutonium in Building 371. 

No workers were injured, but operators who unsuccessfully fought the fire were needlessly

endangered. Four firefighters received skin contamination, and a significant cleanup effort was

required. The Board’s initial review determined that inadequate work planning and the failure to

follow procedures were key contributors to the fire. The contractor had approached this task

using a standard work package that did not take into account the unique configuration of the

glovebox. Furthermore, workers did not adhere to controls for combustible materials, which had

been allowed to accumulate in the glovebox. The Board issued a letter on July 31, 2003, asking

DOE to take immediate actions to verify that conditions which had contributed to the fire did not

exist elsewhere at RFETS. DOE provided an action plan to the Board in a letter dated August

15, 2003, and inspected all of the remaining gloveboxes in Buildings 371 and 707. 

The Board conducted an investigation of the fire and issued a comprehensive report on

December 2, 2003. The investigation revealed that DOE’s safety oversight of decommissioning

activities at RFETS had been ineffective, and that there had been no coverage of D&D work in 
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Building 371 by DOE’s Facility Representatives. The Board's letter forwarding the report

identified the need for an independent review of ISM at RFETS, including an assessment of the

effectiveness of DOE's health and safety oversight of decommissioning activities. The letter also

established a reporting requirement for DOE to identify how the problems at RFETS would be

corrected. DOE has agreed with the Board’s findings, and is proceeding with its contractor to

carry out intensive reviews of safety oversight and the planning and execution of work at the

site. These reviews will contribute to the development of a comprehensive corrective action

plan.

In the vandalism incident, 14 high-efficiency particulate air filters (relied on to prevent

release of airborne contamination) in the Building 771 ventilation system were deliberately

damaged by workers and had to be replaced. The Board’s evaluation of this event found that the

report filed by RFETS in the DOE Occurrence Reporting and Processing System was inaccurate

and did not acknowledge that the filter damage was caused by vandalism. The Board further

determined that neither the manager of DOE’s Rocky Flats Field Office nor appropriate

personnel within DOE Headquarters were aware of the vandalism. A corrected occurrence

report was issued after the Board notified DOE Headquarters of the situation. 

3.4.7 Savannah River Site

DOE issued a major contract modification for work at SRS in June 2003, effective

through 2006. The contract modification incorporates an accelerated cleanup and

decommissioning schedule with performance incentives for meeting goals. Several incidents

have occurred during recent decommissioning work: (1) a worker in Building 247-F was struck

by a falling pipe when it was cut for removal; (2) workers removing electrical lines in Building

247-F cut into energized electrical lines; and (3) two workers in Building 221-F were spattered

with radioactive liquid when drilling a hole in a processing line. The Board has reviewed each

of these incidents and has examined DOE’s oversight of D&D activities at SRS. In the future,

the Board plans to follow closely the work of a new DOE unit at SRS devoted to oversight of

D&D activities.

3.4.8 Lawrence Livermore National Laboratory

In January 2003, the Board reviewed preparations for deactivation of Building 251 at

LLNL. LLNL plans to empty Building 251 of heavy elements and decontaminate and dismantle

its glovebox and enclosure systems. Encapsulation and removal of plutonium-beryllium neutron

sources from the underground storage vaults in Building 251 have been completed. This task

was considered a pilot project for removal of other items. Based on the plutonium-beryllium

experience, it appears that significant additional preparations must be made before the facility

will be ready to begin removal of additional items from the vaults.
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4. NUCLEAR FACILITIES DESIGN AND INFRASTRUCTURE

4.1 NUCLEAR FACILITY DESIGN REVIEWS

The Board is required by statute to review the design and construction of defense nuclear

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

efficient operations for 20 to 50 years. This demands an exacting design process, guided by ISM

principles, that will ensure appropriate safety controls are identified early in the design. The

Board’s expectation is that the design and construction phases of defense nuclear facilities will

demonstrate clear and deliberate use of ISM principles and core functions, and development of

ISM-based manuals of practice to be followed throughout design and construction.

4.1.1 Plutonium Storage at Savannah River Site

DOE is planning to consolidate its excess plutonium at SRS pending final disposition. 

Some of the material will be used as feed to manufacture mixed-oxide reactor fuel. Disposition

is still being determined for the remaining material. DOE is considering immobilizing the

plutonium in glass and shipping the glass logs to the planned Yucca Mountain repository. 

Neither of these disposition paths will be completed in the next 10 years.

Whatever options are chosen, it is clear that plutonium will be stored at SRS for many

years. As requested by Congress, the Board evaluated the SRS facilities planned to be used for

this storage. In the mid-1990s, DOE had planned to store the excess plutonium in a new facility

specifically designed for storage. This facility had been designed and excavation begun when

DOE canceled its construction in 2001. This decision was based primarily on budget constraints

and expectations that the plutonium would be disposed of in a short period of time. DOE’s plans

have now shifted to utilizing several 50-year-old facilities at SRS that do not meet modern safety

standards. The two main facilities planned for storage are the old K-Reactor facility in which

several areas have been modified for storage, and Building 235-F. The plutonium storage

facility is now called the K-Area Material Storage (KAMS) facility.

The Board’s study concluded that storage of plutonium in KAMS could be safely

accomplished for the next 4 or 5 years, but that for extended storage beyond this time,

improvements in fire protection should be undertaken. The Board’s study further concluded that

DOE should carry out its plan to remove plutonium currently in 235-F and should not plan on

extended storage of plutonium in this facility without substantial modernization of the safety

systems and confirmation of the building’s structural adequacy. 

The Board issued its report to Congress and DOE on December 1, 2003. In the Board’s

view, construction of a modern plutonium storage facility might prove to be both cost-effective

and safety-conscious.

4.1.2 Hanford Waste Treatment Plant

The Board continues to review development of the design and safety basis for the WTP at

Hanford. The Board’s oversight was directed into two major areas in 2003: adequacy of the
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structural design and construction effort, and technical adequacy and basis for safety-related

controls. 

Structural Design. The structural design review continued to focus on the adequacy of

the High-Level Waste (HLW) building, a very large, complex structure. In light of this

complexity, the Board requested that DOE prepare a summary structural report for this building

(and for other WTP facilities). DOE has made significant progress towards completing this

report. Results so far suggest that those portions of the HLW building already constructed are

structurally sound.

Concrete Placement. The Board’s construction review has concentrated on the

problems encountered by the contractor in placing structural concrete. Concrete placed in

December 2002 in the foundation of the HLW facility developed surface cracks without an

obvious cause. The contractor prematurely declared the pour acceptable without any clear

understanding of the potential detrimental effects to the structure. The Board’s concern with the

rigor of the evaluation prompted the contractor to conduct a more thorough evaluation. The

results confirmed the structural integrity of the foundation and provided the contractor the basis

to improve work procedures to prevent recurrence. 

Another concrete placement problem occurred in July 2003, when concrete placed during

the month showed a general decrease in strength, calling into question the adequacy of thousands

of cubic yards of concrete already placed. Unlike previous problems, this event was vigorously

evaluated by the contractor to determine the cause and find corrective actions. The evaluation

demonstrated that the weak concrete would likely gain the necessary strength as it continued to

cure, and it also showed the need to improve the process for controlling raw material input more

closely.

Safety Basis and Hydrogen Gas Issue. In a 2002 letter to DOE, the Board pointed out a

number of flaws in DOE’s development of the WTP safety basis and requested a report

describing how these deficiencies would be corrected. Responding in 2003, DOE proposed

solutions to substandard calculation quality, systematic weaknesses in the evaluation of hazards,

and the lack of a suitable technical basis for controlling the generation of hydrogen gas. The

Board reviewed and found these proposals acceptable. 

With respect to the hydrogen problem, DOE has recently completed development of a

hydrogen generation rate model that effectively bounds how much of this flammable gas will be

generated within the WTP. To lend experimental support to the model, the Board suggested and 

DOE has performed tests to understand how hydrogen gas is retained and released from WTP

wastes under a variety of anticipated plant conditions. These tests allow DOE to adequately

design the air dilution systems needed to prevent hydrogen gas accumulation.

Electrical Safety. The Board completed a review of the WTP electrical system and

identified problems with cable degradation that would be caused by radiation exposure. DOE

agreed and decided to test electrical cables to establish defensible cable lifetime estimates. 

These estimates will be used to draft cable replacement plans.
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Requirements and Standards. In a letter dated May 29, 2003, the Board challenged

proposed changes to the WTP Safety Requirements Document. These changes permitted the

contractor to alter required codes and standards and to make significant design changes, both

without prior DOE review. DOE responded by retaining control over such changes.

4.1.3 Highly Enriched Uranium Materials Facility

The Board identified deficiencies in the foundation design and confinement ventilation

system in the HEUMF located at Y-12. The previous foundation design relied on a fill material

that would have caused unacceptable forces in the structure during a seismic event. In response,

DOE adopted a design that employs concrete fill; this approach has been analyzed and found to

produce acceptable building responses. This change in foundation design will significantly

reduce the risk of damage due to an earthquake and will promote long-term stability of the

structure. 

The Board also questioned the lack of a filtered confinement ventilation system in the

original design. DOE modified the design to include a safety-grade, filtered confinement system

that will provide a required level of protection. 

4.1.4 Savannah River Site: Pit Disassembly and Conversion Facility

For several years, the Board has been reviewing the design for the Pit Disassembly and

Conversion Facility (PDCF). While the main structure of PDCF’s Plutonium Processing

Building was designed to survive the design basis earthquake, this is not the case for many of the

2-hour fire barriers between fire zones. As a result, a seismically-induced, full-facility fire could

lead to an offsite dose exceeding the evaluation guideline. The Board issued a letter on May 13,

2003, urging DOE to consider upgrading the design of the fire barriers to withstand the design

basis earthquake, thus eliminating the potential for a full-facility fire. The contractor has

prepared a Fire Risk Analysis that concludes a seismically-induced, full-facility fire is not a

credible scenario. The Board is reviewing the analysis to determine whether it agrees with the

contractor’s conclusions.

4.1.5 Los Alamos National Laboratory: TA-18 Safety Class Control Design

In a letter dated July 19, 2003, the Board objected to LANL’s failure to follow DOE

requirements for new safety-class equipment in the Technical Area (TA)-18 facility. While the

Board’s primary concern was that single credible failures would prevent the required safety

actions, the Board also questioned the technical feasibility of the DOE-directed

approach—monitoring the temperature of the nuclear material—to preventing the accident. 

Adding to these concerns was a lack of independent review of the design. As a result of the

Board’s objections, DOE performed a review of the completed design package for one of the

TA-18 safety class controls. Initial indications are that some of the problems have still not been

adequately resolved. 
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4.1.6 Pantex Building 12-64: Roof Design Weaknesses

In a letter dated June 25, 1998, the Board questioned the use of Pantex Building 12-64 for

nuclear explosive operations, primarily because of significant cracking on the underside of the

bay roofs caused by a deficiency in the original design. As a consequence, DOE terminated

nuclear explosive operations in this building but also decided to upgrade the building as needed

to resume nuclear explosive operations. The Board, in a letter dated October 10, 2003, stated

that the proposed upgrades do not fully correct structural deficiencies. DOE is now developing a

plan to correct roof deficiencies for both seismic loads and internal explosions. 

4.1.7 High Efficiency Particulate Air Filter Testing and Infrastructure

The Board identified many weaknesses in DOE's program for the use of High Efficiency

Particulate Air (HEPA) filters in safety applications. In response to the Board’s January 9, 2003,

letter, DOE confirmed its original commitments to maintain the Filter Test Facility, send certain

classes of HEPA filters through this facility, assess the results of filter testing, and perform selfassessments of HEPA test programs.

4.1.8 Dynamic Experiments at Los Alamos National Laboratory

For the past several years, the Board has reviewed design and development work on the

Dynamic Experiments (DynEx) Project. Among the Board’s findings have been the need to

strengthen the vessel design requirements and procurement specifications and to identify safetyclass or safety-significant systems and equipment early in design. In a letter dated May 12,

2003, the Board noted that LANL had made major changes in its approach to this project in line

with the Board’s observations, resulting in significant safety improvements. 

4.1.9 Tritium Extraction Facility at Savannah River Site

The Tritium Extraction Facility (TEF) will be used to extract tritium from target rods

irradiated in commercial light water reactors. The extracted tritium is to be used to replenish

tritium reserves for the nation’s nuclear weapons stockpile. During the past 6 years, the Board

conducted extensive reviews and provided comments to DOE. The Board has continually

stressed the application of ISM to the design process to ensure that hazards were identified and

appropriate controls developed. The Board has concluded that the TEF design provides adequate

controls to address the potential hazards posed. The completed facility should be capable of

operating in a manner that provides adequate protection of the workers, the public and the

environment, provided it is constructed in accordance with the design requirements. 

During 2003, the Board reviewed building construction and safety-related component

fabrication for conformance to design requirements. The Board found that the contractor had

procedures in place to ensure design requirements would be met. Confirmation that the

procedures were being correctly implemented was obtained by reviewing selected building

construction features and components down to the level of inspection reports. Based on these

reviews, the Board concluded that the TEF is being constructed in accordance with the specified

design requirements.
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5. NUCLEAR SAFETY PROGRAMS AND ANALYSIS

5.1 FEDERAL OVERSIGHT

5.1.1 Overview

To meet its statutory health and safety mandate, the Board must continuously assess

DOE’s ability to conduct adequate oversight of contractors working on defense nuclear facilities. 

In this context, oversight includes Federal line-management assessment of contractors,

contractor self-assessment, and independent assessment. For much of the work conducted in the

defense nuclear complex, DOE relies upon contractors to perform inherently risky activities in

government-owned facilities. These activities are nevertheless governed by nuclear safety

requirements promulgated by the government. Thus, DOE fills three simultaneous roles: owner,

customer, and regulator. Preventing conflict among these roles requires a complex oversight

system strained by competing demands that must be reconciled to ensure that the overall mission

is achieved safely.

DOE is engaged in making major changes in its approach to safety oversight of defense

nuclear facilities. DOE is currently implementing, or is planning, three simultaneous initiatives

that affect its safety oversight of defense nuclear facilities. The sum and substance of this

initiative is to place principal reliance on the contractor to ensure that work is done safely, move

from prescriptive requirements to performance criteria, and decrease reliance on federal safety

oversight of contractor operations. In the midst of this, information developed by the Columbia

Accident Investigation Board with respect to the loss of the space shuttle, and by the U. S.

Nuclear Regulatory Commission in connection with the “near miss” at the Davis-Besse nuclear

power plant, suggests that a weakening of federal oversight of contractor operations can have

dire consequences. In furtherance of its statutory duty to protect the public health and safety

from hazards at defense nuclear facilities and its charge to restore confidence in DOE’s

management capabilities, the Board conducted six public meetings between September and

December 2003. The meetings, which will continue in 2004, are intended to provide a record on

which to assess DOE’s proposals for changing its oversight, contract management, and directives

systems.

5.1.2 Public Meetings

During its public meetings, the Board heard testimony from representatives of the U.S.

Nuclear Regulatory Commission, the Naval Reactors Program, the Columbia Accident

Investigation Board, the Deputy Secretary of Energy, the Administrator of NNSA, the

Undersecretary for Energy, Science and Environment, selected DOE and NNSA Site Managers,

and senior contractor managers from SRS, RFETS, Hanford, Pantex, Y-12, LANL, and LLNL. 

The Board explored proposed oversight policies, contract reform initiatives, and contractor

self-assessment programs. Because the Board had observed that some DOE or NNSA sites had

exerted rigorous federal oversight, while others had relaxed the level of oversight by varying

degrees, testimony was elicited on what these organizations had learned with regard to safety

performance.
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5.1.3 Informational Seminars

In addition to the public meetings, the Board invited social science experts to present inhouse seminars on the causal relationships between organizational behavior and operation of

high risk activities. The experts included Dr. Sonya Haber (key member in the FirstEnergy

Nuclear Operating Company’s investigation of the Davis-Besse nuclear power plant incident);

Dr. Scott Sagan (Professor at Stanford University and author of Limits of Safety); Mr. James

Chiles (author of Inviting Disasters); Dr. Charles Perrow (Professor Emeritus at Yale University

and author of Normal Accidents); and Dr. Todd LaPorte (Professor at University of

California–Berkeley and author of numerous papers on highly reliable organizations). 

The Board gleaned from these seminars that a key attribute of successful organizations is

an independent, technically competent engineering staff that centrally controls technical safety

specifications and waivers. This attribute was stressed in the Columbia Accident Investigation

Board’s report and highlighted in the testimony from the Naval Reactors program. Another

characteristic of success is redundancy in systems—whether engineered or human—to improve

overall system reliability. The Columbia Accident Investigation Board identified reductions in

institutional redundancy at the National Aeronautics and Space Administration as one of the

organizational contributors to the Columbia shuttle accident.

5.1.4 DOE and NNSA Initiatives

Overview. DOE and NNSA are revising their oversight model and asserting that the

proposed changes will allow the government to obtain work more efficiently without a loss of

safety, and with a concomitant reduction in government costs and accelerated completion of

projects. These improvements would be welcome. However, the Board is concerned that these

changes may trade safety for efficiency. Admittedly it is difficult to define acceptance criteria in

advance for these new oversight methods. The best measure of any oversight model is longterm performance, suggesting the advisability of gradual change to evaluate the effects and

change course as needed. But because DOE and NNSA are making rapid changes in

organizational structure and staffing, altering course later may become difficult or impossible. 

DOE’s reliance on generating and gathering performance data using information

technology is also cause for concern. The performance metrics in use or planned by DOE may

or may not give adequate warning of incipient safety problems. 

Reduction of Headquarters Staff. The Board has observed that DOE and NNSA are

reducing if not entirely eliminating headquarters technical staff assigned to support oversight by

line management. Such reductions may deprive senior DOE line managers of technically

competent assistance. Over-reliance on a common data source (that is, field-level assessments)

may lead to common-mode failure at upper levels of the organization. This problem is

compounded if field elements lack skilled and technically trained personnel to perform oversight

work.

Directives System. DOE is also modifying its directives system in an attempt to

emphasize “what” is to be accomplished but not necessarily “how” it is to be accomplished. 

This approach is intended to provide contractors with the flexibility to streamline approaches to
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their work, resulting in improved efficiency. While this tactic has potential advantages, relaxing

centrally-controlled, prescriptive safety requirements derived from 60 years of nuclear

operations experience is a perilous step to take.

Contracts. DOE and NNSA are altering the terms of many contracts to reward the

achievement of ultimate outcomes or results rather than intermediate milestones. NNSA

contracts increasingly specify required end-states, products, or conditions, but are becoming less

prescriptive about required methods to achieve those outcomes. This approach could result in

unintended consequences if it invites taking greater risks to obtain promised contractual benefits. 

5.1.5 Conclusion

The ability to spot negative trends and incipient safety problems should not be the only

measure of an adequate safety oversight system. A complete, trustworthy, and technically

competent system of safety oversight should be used to find the root causes of problems, identify

effective corrective actions, verify that the actions are taken, and to establish a rational set of

safety requirements. The Board will continue to evaluate all the information it has collected

from its public meetings and seminars and will be deciding upon a course of action in 2004.

5.2 INTEGRATED SAFETY MANAGEMENT

5.2.1 Overview

ISM is a concept that evolved from Recommendation 95-2. The basic tenets of ISM

provide the framework for safely performing all of the diverse hazardous activities in the defense

nuclear complex. ISM provides for a single safety management program rather than multiple,

unintegrated programs. Nuclear safety is an important but not exclusive target of ISM. 

Nonradioactive hazardous materials and operations require attention in proportion to the risks

they pose to the public, workers, and the environment. ISM builds upon standards of safe

practice for nuclear, chemical, and other hazardous operations to ensure protection of the public,

workers, and the environment. 

 Since the Board’s issuance of Recommendation 95-2, the implementation of ISM has

progressed through three phases: (1) developing necessary guidance documents; (2) establishing

the infrastructure for implementing ISM at individual sites and facilities, and (3) confirming that

ISM systems are effective and are being applied to design and construction, start-up, operation,

and decommissioning of DOE’s hazardous facilities. At the end of 1999, the implementation of

ISM was well into the second phase. With the successful completion of ISM System

Verification Reviews at all sites during 2000, the Board’s focus on implementation of ISM

shifted to the third phase. Throughout 2003, the Board stressed the need to look beyond initial

implementation to ensure continued improvement. In addition to ensuring that ISM was

implemented at all DOE sites, the Board focused on three key initiatives that are critical to the

long-term effectiveness of ISM: the annual update process, completion of Recommendation

2000-2 tasks, and activity-level implementation.
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5.2.2 ISM Annual Update Process

In 2003, the Board continued to oversee the implementation and effectiveness of ISM at

defense nuclear facilities. The Board evaluated the efforts of the Energy Facility Contractors

Group to improve ISM and the updated ISM descriptions for several sites. 

In an October 2001 letter to DOE’s Office of Environmental Management, the Board had

noted the failure to correct numerous deficiencies in the operations of the Bechtel Jacobs

Company and its subcontractors at ORNL. The long-standing failure to apply nuclear safety

requirements in those operations indicated that the ISM systems for the Oak Ridge Office and for

the Bechtel-Jacobs Company were not functioning, most especially in the area of feedback and

improvement. In response to the Board’s letter, DOE corrected the deficiencies and verified the

adequacy of the ISM systems at ORNL. The Board noted a major positive shift in ISM

implementation by the Bechtel-Jacobs Company and DOE’s Oak Ridge Office. 

5.2.3 Reliability and Configuration Management of Vital Safety Systems

Defense nuclear facilities typically incorporate safety systems designed to control the

hazards that are present. Conditions specifying operational limits for these systems placed into

Authorization Agreements between DOE and its contractors. For the many facilities constructed

decades ago, it is essential that emphasis be placed on the maintenance and continued reliability

of vital safety systems.

In Recommendation 2000-2, the Board urged DOE to ensure the operability of vital

safety systems by (1) assessing their reliability and operability; (2) requiring that contractor

personnel responsible for configuration management maintain the design basis and operating

limits; (3) confirming that DOE’s technical staff has the requisite number of qualified subject

matter experts; and (4) inserting necessary legal requirements into DOE directives and contracts.

In response to the Board’s actions, DOE has taken steps to ensure the operability of vital

safety systems. During 2003, DOE actions in this regard included in-depth reviews of specific

systems and programs (such as control of drawings and configuration management) known to be

problem-ridden. These reviews uncovered weaknesses in the operability of several systems,

leading to further evaluation and sometimes to repairs. DOE is now evaluating these

deficiencies and formulating corrective actions. 

At the Board’s urging, DOE has also staffed the federal oversight positions for key safety

systems and is developing suitable qualification and training programs. In addition, DOE has

issued a major revision to the handbook on ventilation design. Overall, the Board noted that a

number of important improvements have been made in ensuring that vital safety systems remain

fully operable.

5.2.4 Activity Level Work Planning

The Board has been emphasizing the importance of ensuring that hazards are identified

and controlled, that work is performed in a careful manner in accordance with the safety

controls, and that DOE use appropriate feedback mechanisms to ensure continuous improvement
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at the individual activity level. The concept of ISM is particularly well suited to ensuring safety

at the activity level. In 2003, the Board focused attention on the implementation of ISM at the

activity level by conducting a number of site-specific safety reviews. Significant deficiencies

were revealed in the methods being used to implement ISM at Pantex, LLNL, and LANL. The

Board will provide oversight to DOE and NNSA as they define and implement corrective

actions.

5.3 HEALTH AND SAFETY DIRECTIVES

5.3.1 Improvement of Directives

During 2003, the Board received 68 new or revised drafts of health and safety directives

and NNSA policy letters from DOE for review. Highlights of the Board’s reviews follow:

! Nuclear Air Cleaning Handbook. In response to Recommendation 2000-2, DOE

committed to publishing a revised Nuclear Air Cleaning Handbook (DOE-HDBK1169-2003) by December 2002. The Board provided extensive commentary to

improve the overall quality of the handbook. Resolution of comments forced DOE to

extend the publication date; the handbook was eventually published in December

2003.

! Worker Protection Management. The Board scrutinized the revision of DOE

Order 440.1A, Worker Protection Management for DOE Federal and Contractor

Employees. This effort was completed in June 2003, culminating in an updated

directive that included important new biological agent protection requirements

developed in response to increased homeland security awareness.

! Electrical Safety Handbook. In June 2001, the Board had urged DOE to take a

leadership role with respect to electrical safety. DOE agreed to update the Electrical

Safety Handbook in August 2002. However, in July 2003 the Board learned that

DOE had deleted much of the technical content in the proposed revision. The Board

informed DOE that this was unacceptable, especially in light of the high rate of

electrical safety incidents observed across the defense nuclear complex. DOE is now

revising the handbook.

! Environment, Safety, and Health Reporting. During 2003, the Board provided

technical advice on DOE’s effort to consolidate and revise various reporting orders

into a single directive. The Board commented on draft DOE Order 231.1A,

Environment, Safety and Health Reporting and its many supporting documents.

These revisions, which are key to maintaining a strong feedback and improvement

program across the defense nuclear complex, are now being implemented. The Board

will monitor closely the effectiveness of the revised program during this

implementation phase.

! NNSA Policy Letters. NNSA instituted in 2003 an internal system of directives

under the authority of its organic statute, Public Law 106-65. The Board’s review of

this system, however, found that it had not been adequately described, new directives
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were being issued in potential conflict with existing directives, and all of the

conditions of the Public Law had not been satisfied. The Board has provided expert

oversight of NNSA’s effort to design a system that would meet the needs of NNSA

without adversely affecting safety. 

! Assignment of Functions, Responsibilities, and Authorities. The Board’s

comments on a proposed revision to DOE Manual 411.1-1, Safety Management

Functions, Responsibilities, and Authorities Manual, helped clarify the role of DOE’s

safety oversight offices. At the end of 2003, DOE issued the revised Manual. Subtier documents prepared in the interim by NNSA and by DOE’s Office of

Environment, Safety, and Health were also reviewed and commented upon by the

Board before issuance. 

! Functional Area Qualification Standards. During 2003, the Board reviewed and

provided extensive comments on 16 new or revised Functional Area Qualification

Standards. With continuing oversight by the Board, DOE’s Federal Technical

Capabilities Panel is upgrading the knowledge, skills, and abilities of DOE technical

personnel.

5.3.2 Worker Safety Rulemaking

On December 8, 2003, DOE provided notification of a proposed rule on worker

protection, 10 CFR Part 851, Worker Safety and Health. This action was required under the Bob

Stump National Defense Authorization Act, Public Law 107-314, which directed DOE to

promulgate regulations on worker safety and health, rather than rely exclusively on a contractual

approach. The Board is conducting a detailed review of the proposed rule. Of immediate

concern is that DOE intends to cancel DOE Order 440.1A, Worker Protection Management for

D0E Federal and Contractor Employees. Currently, this order and its associated manuals and

guidance documents provide specific safety requirements for several areas of interest to the

Board: explosives safety, pressure vessel safety, and suspect and counterfeit parts. They also

serve as implementing directives for Integrated Safety Management at the activity level. Many

requirements and guidance, painstakingly developed during 50 years of experience across the

complex, may be lost unless these requirements and guidance are formally implemented in a new

set of directives to be issued concurrently with the new rule. During 2004, the Board will be

heavily involved in DOE's efforts to satisfy Public Law 107-314 in a manner that provides

optimal protection of worker health and safety.

5.3.3 Implementation of Directives

A directive can only contribute to health and safety if it is rigorously and competently

carried out in the field. In 2003, the Board continued to closely scrutinize the implementation of

health and safety directives at defense nuclear facilities. Examples of the Board’s work in this

area include:

! Systematic Review of Orders. In 2001, DOE initiated an internal review to

determine whether the requirements in DOE orders were consistent with its current

intent to focus on performance objectives. Teams were formed to review the orders
5-7

and provide their findings and recommendations to a panel of senior DOE managers.

The panel reviewed the teams’ reports and forwarded recommendations to Program

Secretarial Officers. The Board reviewed the proposed changes and identified two

safety concerns: the proposed relaxing of requirements for accident investigations,

and a scheme to reduce the applicability of DOE to defense nuclear facility contracts.

! Unreviewed Safety Question Procedures. The Unreviewed Safety Question (USQ)

process required by 10 CFR 830.203 is the mechanism for ensuring that the safety

basis for a defense nuclear facility is not invalidated by undocumented or

unauthorized changes. In 2003, the Board reviewed seven USQ procedures and

identified substantial areas of noncompliance with the governing requirements. 

Responding to these findings, DOE required substantial revisions and demanded that

contractors submit for approval changes to documents that previously could have

been changed without DOE approval.

! Integration of Hazard Analyses. The Board’s review of this topic found less-thanadequate implementation of safety requirements caused by inconsistencies and lack

of integration of directives. In particular, the use of inconsistent methodologies in the

hazards analyses for such applications as emergency management, facility safety

design, and documented safety analyses resulted in conflicting safety data. As a

direct result of the Board’s activities, DOE issued a handbook entitled Integration of

Multiple Hazard Analysis Requirements and Activities (DOE-HDBK-1163-2003).

Using this handbook, several DOE contractors have performed their activities in a

safer, more integrated, and significantly more cost-effective manner.

5.4 SAFETY PROGRAMS

5.4.1 Development and Implementation of Safety Controls

The development of a comprehensive safety basis and the identification and selection of

an appropriate control set are cornerstones of safe operation at defense nuclear facilities. The

Board conducted numerous reviews of safety bases throughout the DOE complex in 2003. The

Board reviewed the critical assumptions made and the control strategies relied upon to prevent

and mitigate accidents.

The Board identified a number of specific instances where unjustified assumptions and

methodologies were used in the development of safety bases. For example, some analyses did

not consistently use bounding input assumptions and implicitly credited non-qualified plant

equipment. These deficiencies led to safety analyses that may not have bounded the actual

hazard conditions for the facilities concerned. In a letter to NNSA dated April 10, 2003, the

Board documented weaknesses in the documented safety analysis for the plutonium facility at

LLNL. As a result of this letter, DOE took corrective actions.

Contractors at nuclear facilities were required by 10 CFR Part 830 to submit to DOE

safety analyses and controls by April 2003. Many contractors had to develop new analyses and,

perhaps more importantly, new safety controls. In many cases, the choice of these new safety

controls was limited because the equipment had been built years or even decades ago. As a
5-8

result, DOE chose to reclassify existing equipment as safety-related and, in a departure from past

practice, opted to rely also on safety-related administrative controls rather than engineered

features.

Recommendation 2002-3 identified the need for DOE to improve its guidance and

expectations on the use of administrative controls at defense nuclear facilities. As a result of the

Recommendation, DOE developed a plan to improve the reliability and effectiveness of

administrative controls that serve safety functions. The Board accepted DOE’s Implementation

Plan in July 2003. In letters dated August 25, 2003, and December 8, 2003, the Board agreed

that DOE had completed some of the commitments in this Plan. 

5.4.2 Quality Assurance

During 2003, the Board continued to seek improvements in DOE’s Quality Assurance

(QA) Programs. In previous years, the Board had found weaknesses in DOE’s implementation

of existing QA requirements for safety-related components and systems, as well as weaknesses

in requirements and guidance on engineering practices for safety-related software. DOE

completed several commitments in its Quality Assurance Improvement Plan to strengthen the

implementation of quality assurance in the design, procurement, construction, operation, and

maintenance of vital safety systems. To date, these actions have not been fully effective in

achieving the required quality objectives.

5.4.3 Software Quality Assurance

Overview. The design and operation of many of DOE’s defense nuclear facilities relies

on analysis and operational support by computer codes. During the past few years, the Board

has identified problems caused by inadequate software design, implementation, testing,

configuration management, and training. These problems could lead DOE to rely on erroneous

information affecting safety. For this reason, in late 2002 the Board issued Recommendation

2002-1, proposing significant changes to DOE’s policies and practices for software quality

assurance (SQA). These changes included clearly assigning responsibilities and authorities for

SQA, issuing revised directives for software development and use, and recommending software

packages for use in safety system analysis and design.

Following the incorporation of extensive comments and final approval from the Board,

DOE issued on March 13, 2003, its plan to improve SQA at defense nuclear facilities. Initial

DOE efforts to complete the commitments were ineffective. However, DOE made

improvements following the completion of the commitment to establish an Office of Quality

Assurance reporting to the Assistant Secretary for Environment, Safety and Health. Since that

time, DOE has completed several other commitments, including: developing SQA criteria for

commonly used software analysis codes; publishing guidance reports for users of six software

analysis tools; selecting the industry SQA standards that will be invoked by DOE directives;

developing a qualification standard for DOE personnel involved with the oversight of contractor

SQA practices; and developing the criteria that will be used to assess existing safety-related

software. The majority of the DOE efforts associated with this Recommendation remain to be

completed.
5-9

Site-Specific Reviews. During 2003, the Board assessed SQA at SRS (Tritium

Extraction Facility), Pantex (movement of high explosives and nuclear material between

facilities), Hanford (Waste Treatment Plant), and LANL (criticality control systems). The

Board’s oversight of Pantex is illustrative of this year’s accomplishments. 

 In a letter dated March 25, 2003, the Board questioned the quality of two computer

software products developed to improve Pantex operations. The Move Right System, activated

in January 2003, controls and tracks the movement and storage of nuclear explosives, high

explosives, and radioactive material. The Board noted deficiencies in the associated software

engineering products, as well as a lack of rigor in DOE’s testing of the system. Another product,

Interactive Electronic Procedures, will be used by technicians to disassemble, assemble, and

maintain nuclear weapons. The product will also be used by the engineers and scientists at the

supporting national laboratories to develop, review, and approve the procedures used by the

technicians. The Board learned that although system level testing of the Interactive Electronic

Procedures was scheduled to begin a few weeks after the Board’s review, key elements of the

software, such as the requirements specifications, were still in draft form, and the test procedures

had not yet been written. 

As a result of the review conducted by the Board, the Pantex contractor improved the

procedures associated with SQA. The contractor formed an SQA Section within the Information

Technology Department and staffed it with experienced personnel. The Move Right System

software was revised and upgraded to correct known problems and meet more stringent quality

requirements. Software and documentation practices for the Interactive Electronic Procedures

were similarly upgraded. Other plant software was tested and enhanced test procedures were

designed for future use.

5.4.4 Suspect and Counterfeit Parts

In June 2002, Department of Defense investigators notified DOE that a vendor of heat

treating services supplied potentially improperly heat-treated aluminum to firms that supplied

parts to DOE. Notwithstanding repeated assurances from DOE’s Quality Assurance Working

Group that reviews would be conducted to detect nonconforming heat-treated aluminum, DOE

failed to adequately assess whether such parts were installed until the Board brought the matter

to the direct attention of the Secretary of Energy. The Board also observed that DOE had

repeated several of the missteps that occurred in response to similar quality issues affecting

semiconductor devices in previous years. As a result of the Board’s efforts, DOE has

fundamentally restructured its quality assurance programs.

The Board continues to provide oversight and technical assistance to DOE in order to

identify and prevent the introduction of suspect and counterfeit parts into safety-related or

mission sensitive applications affecting defense nuclear facilities. The Board’s oversight and

timely intervention in dealing with suspect and counterfeit parts has been pivotal in energizing

the establishment of DOE quality assurance programs.
5-10

5.4.5 Hoisting and Rigging

The proper planning and conduct of lifting tasks is an important element of nuclear

operations safety at defense nuclear facilities. In 2003, the Board reviewed the safety of hoisting

and rigging activities at Pantex, SRS, and NTS. In a letter dated July 10, 2003, the Board

provided to DOE an assessment of the hoisting and rigging program at Pantex, and some general

observations pertaining to all sites. The Board identified a number of weaknesses in equipment

design, reliability, maintenance, and training. As a result of the Board’s review, DOE made

substantial safety improvements in this program. 

5.4.6 Criticality Safety

Throughout 2003, the Board conducted a comprehensive review of the results obtained

from DOE’s implementation of Recommendation 97-2. The Board was able to conclude that

criticality safety had improved across the complex and closed the Recommendation in August

2003. To maintain these gains, however, the Board has stressed the need for aggressive selfassessment programs and expanded use of operational facility reviews and independent

oversight. In closing the Recommendation, the Board requested an annual report from DOE on

funding for this program. 

Criticality control principles must be incorporated into the design of new facilities at an

early stage. For this reason, the Board has had under continuous review the design of criticality

controls at PDCF. This design employs a unique safety control system involving numerous

measurements of weight and radiation signatures throughout the process. To assess the wisdom

of this approach, the Board urged DOE to take advantage of the expertise available in DOE’s

Nuclear Criticality Safety Support Group, composed of senior criticality specialists. Their

review highlighted significant potential issues with the development and operation of similar

critical mass control systems.

To highlight the Board’s interest in criticality safety, a member of the Board provided the

keynote presentation on this topic at the 2003 joint winter meeting of the American Nuclear

Society and the European Nuclear Society.

5.4.7 Research and Development Safety

As a result of a series of incidents in the past two years, the Board has begun to review

the research and development work practices of the major DOE defense nuclear contractors. The

most serious near-miss accidents occurred at LANL in 2002 and at Y-12 in April 2003. The

Y-12 incident involved an explosion and glovebox fire at the Development Division’s Saltless

Direct Oxide Reduction pilot plant. The Board reviewed the Division’s revised work practices

and corrective actions, including new requirements for process hazard analyses, design reviews,

and formal start-up procedures. 
11 Personnel Selection, Qualification, and Training Requirements for DOE Nuclear Facilities (2001).

5-11

5.5 TECHNICAL COMPETENCE

5.5.1 Training and Qualification of DOE and Contractor Personnel

During 2003, the Board continued to monitor the competence of key health and safety

personnel at defense nuclear facilities. Early in the year, the Board reviewed actions being taken

at Pantex to improve procedural adherence, conduct of operations, and training. The Board

found that site instructions and supporting records did not ensure accomplishment of training

objectives as set forth in DOE Order 5480.20A.11 In an April 2003 letter to NNSA, the Board

observed that these training deficiencies may affect the contractor's ability to maintain and

improve conduct of operations. On July 9, 2003, the Board requested that NNSA describe the

scope and periodicity of the training assessments conducted as required by DOE Order 5480.20A

for all NNSA site offices, including Pantex, and determine whether the required assessments are

being performed. NNSA initiated a review at all field sites and in an October 2003 letter to the

Board, reported that three sites in addition to Pantex were not in compliance with the scope and

periodicity of the reviews required by the Order. NNSA committed to conducting the required

reviews by the end of June 2004. 

5.5.2 System Engineers and Federal Subject Matter Experts

In Recommendation 2000-2, the Board urged DOE to develop requirements for training

and qualification of subject matter experts in vital safety systems (“system engineers”) for both

federal and contractor organizations. From July 2002 to March 2003, the Board evaluated

DOE’s efforts to institutionalize the use of system engineers and federal subject matter experts

for vital safety systems. The Board conducted reviews at five sites Y-12, Pantex, LLNL, the

Office of River Protection, and the Richland Operations Office.

Although it appeared that, for the sites visited, the managers of the DOE site offices and

the site contractors supported Recommendation 2000-2 and were working to implement its

principles, there was a wide disparity in effectiveness. Specific problems identified included

lack of full staffing of federal and contractor slots for subject matter experts and systems

engineers, and failure to complete work on functional area qualification standards. DOE is now

attempting to fill these vital technical positions, but in the Board’s view more senior

management attention and resources are needed for this effort. The functional area qualification

standards were nearing completion by the end of 2003. 

5.5.3 Nuclear Weapons Knowledge

DOE needs to retain a cadre of professionals having deep understanding of nuclear

weapons assembly and disassembly. The needed expertise is not available outside of the defense

laboratories and is only developed through experience in nuclear operations. Encouraging the

brightest minds to devote a portion of their time to developing weapons expertise remains a

challenge and was the focus of Recommendation 2002-2. In 2003, the Board approved DOE’s

Implementation Plan for this Recommendation.
6-1

6. PUBLIC OUTREACH

The Board keeps the public informed of its work through public meetings, quick

responses to public requests for documents, effective responses to public inquires into health and

safety issues, outreach activities of the Board’s site representatives, and an Internet website.

6.1 PUBLIC MEETINGS

During 2003, the Board conducted six public meetings in Washington, D.C., regarding

DOE oversight policy. (See Section 5.1.2 above for further information.)

6.2 RESPONDING TO PUBLIC REQUESTS

The Board answered numerous public requests for documents and information during

2003. The Board also responded to 21 requests filed under the Freedom of Information Act. 

The average response time was 3.5 working days, as compared with the statutory requirement of

20 working days. The Board has posted on its website a complete list of requests processed

since 2000.

6.3 ELECTRONIC ACCESS

The Board posts all essential, publicly-releasable documents on its website

(www.dnfsb.gov) in a timely manner. All documents are downloadable in PDF format. The

Board also mails paper copies of certain documents (annual reports, technical reports, public

hearing notices, and others) to a list of more than four hundred addressees. There were five such

mailings in 2003. An initiative was begun in late 2003 to offer those on the Board’s mailing list

the option of receiving documents via e-mail in lieu of paper copies. This would serve to speed

distribution of these documents, provide significant savings in printing and postal costs and

would further the Board’s E-Government initiative. 

The Board continues to evaluate the effectiveness of its information security program to

ensure that it is in compliance with the requirements of the Federal Information Security

Management Act and other related standards and guidance. During 2003, the Board’s

information technology (IT) security staff upgraded computer security by measures such as

strengthening the Board’s internet firewall to prevent intrusion. The Board will commission

another independent evaluation of its information security program during 2004 to ensure that

past improvements have been successfully implemented and to detect any additional weaknesses.

6.4 INQUIRIES INTO HEALTH AND SAFETY ISSUES

The Board often receives information regarding potential health and safety hazards from

private citizens or from employees at defense nuclear facilities. The Board treats these matters

with the utmost seriousness by assigning members of its legal and technical staff to investigate

or inquire further. These inquiries, which may involve interviews, review of documents, and site

visits, are continued until the Board is able to reach a technical judgment on the issues raised. If

the Board finds that a health or safety hazard exists, it takes prompt action to inform DOE and

closely monitors DOE’s corrective actions. When the Board receives information on matters
6-2

outside its jurisdiction, such as alleged criminal activities or unlawful personnel practices, it

refers the information to the appropriate federal agency for action.

During 2003, the Board directed inquiries into health and safety issues at DOE

Headquarters, RFETS, Hanford, Fernald, SRS, and LANL. The DOE-Headquarters review

resulted in a complete restructuring of DOE programs and responsibilities established to prevent

the introduction of suspect and counterfeit items into safety or mission-sensitive applications. 

The Board identified fundamental breakdowns in DOE’s suspect and counterfeit parts programs

and shortcomings in DOE’s response to a Department of Defense notification of a suspect and

counterfeit parts alert. Suspect and counterfeit parts continue to be supplied to DOE, and

constant attention is required to prevent installation. Where such parts have already been

installed, they must be identified and removed without delay. The RFETS inquiry identified

systemic failures in contractor and DOE oversight activities leading up to and subsequent to a

fire in a plutonium-contaminated glove box. As a result, the Board communicated to DOE a

comprehensive list of health and safety issues which are now being addressed by DOE. 

6.5 SITE REPRESENTATIVE ACTIVITIES

The Board enhances its on-site health and safety oversight of defense nuclear facilities by

assigning experienced technical staff members to full-time duty at priority DOE sites: Pantex,

Hanford, SRS, Y-12, and LANL. Site representatives conduct first-hand assessments of nuclear

safety management to identify health and safety concerns promptly. They meet regularly with

the public, union members, Congressional staff members, and public officials from federal, state,

and local agencies. The Board receives regular briefings from its site representatives in person,

and maintains continuous contact with them using all available communications media. 
A-1

APPENDIX A

Recommendations Cited

Number Date Title

94-1 May 26, 1994 Improved Schedule for Remediation in the Defense

Nuclear Facilities Complex

95-2 October 11, 1995 Safety Management

97-1 March 3, 1997 Safe Storage of Uranium-233

97-2 May 19, 1997 Continuation of Criticality Safety at Defense

Nuclear Facilities in the Department of Energy

98-2 September 30, 1998 Safety Management at the Pantex Plant

99-1 August 11, 1999 Safe Storage of Fissionable Material called “Pits”

2000-1 January 14, 2000 Prioritization for Stabilizing Nuclear Materials

2000-2 March 8, 2000 Configuration Management, Vital Safety 

Systems 

2001-1 March 23, 2001 High-Level Waste Management at the 

Savannah River Site

2002-1 September 23, 2002 Quality Assurance for Safety-Related Software

2002-2 October 3, 2002 Weapons Laboratory Support of the Defense

Nuclear Complex

2002-3 December 11, 2002 Requirements for the Design, Implementation, and

Maintenance of Administrative Controls
B-1

APPENDIX B

2003 Reporting Requirements

Date of Letter Subject Response Required ResponDecember 8 NNSA roles and responsibilities plan With FRA Manual With FRDecember 2 Glovebox fire at RFETS Action Plan 60 daysNovember 7 Transuranic waste retrieval at Hanford Letter 90 daysAugust 19 Electrical and lightning protection at LANL Letter 30 daysAugust 7 Electrical safety handbook Letter 30 daysAugust 7 Improving operational safety at Fernald Briefing 90 daysAugust 7 Criticality Safety Program/closing Rec. 97-2 Report 6 monthJuly 31 Combustibles at RFETS Report 15 daysJuly 10 Hoisting and rigging operations at Pantex Briefing 120 dayJuly 9 Rec. of NNSA Senior Technical Advisory Panel Informed 90 daysJuly 9 Training and qual. of NNSA site office personnel Report 30 daysJuly 9 LANL safety-class instr./control systems Report 60 daysJuly 9 Implementation of SS-21 at Pantex Briefing ASAPJune 12 KAMS safety basis review Report 60 daysJune 12 Rec. 2000-2 implementation plan Briefing 6 monthApril 10 Hazard assessment and control at LLNL Report 60 daysApril 10 Sludge removal from the Hanford K-Basins Report 60 daysApril 4 Conduct of operations and training at Pantex Report 60 daysMarch 25 Software quality assurance at Pantex Report 30 daysMarch 27 Temperform quality assurance issues Report 30 daysMarch 20 Recommendation 94-1 R&D Program Report 6 0 daysMarch 7 INEEL Advanced Mixed Waste Treatment Project Briefing 30 daysMarch 7 Flood mitigation at LANL Report 90 daysFebruary 14 Temperform heat-treated aluminum parts Report/Plan 30/60 dFebruary 6 Proper sealing of the MCOs at Hanford Report 15 daysJanuary 24 Fire, Safety and Preparedness Action Plan Report 30 daysJanuary 9 HEPA filter testing protocols and procedures Report 45 days
C-1

APPENDIX C

CORRESPONDENCE

Fernald Closure Project

August 7 letter to the Assistant Secretary for Environmental Management regarding worker

safety.

Hanford Site

January 21 letter to the Assistant Secretary for Environmental Management regarding ground

motion criteria.

February 6 letter to the Assistant Secretary for Environmental Management regarding multicanister overpacks (MCOs).

March 7 letter to the Assistant Secretary for Environmental Management regarding electrical

distribution instrumentation and control systems.

March 7 letter to the Assistant Secretary for Environmental Management regarding Advanced

Mixed Waste Treatment project.

March 7 letter to the Assistant Secretary for Environmental Management regarding operational

readiness reviews for fuel transfer system, Spent Nuclear Fuel project.

March 7 letter to the Assistant Secretary for Environmental Management regarding electrical

distribution systems at WTP.

April 4 letter to the Assistant Secretary for Environmental Management regarding T-Plant

seismic review.

April 10 letter to the Secretary of Energy regarding K-Basins sludge removal.

May 29 letter to the Manager, Office of River Protection, regarding safety management changes.

August 7 letter to the Assistant Secretary for Environmental Management regarding the status of

Recommendation 2000-2.

November 7 letter to the Assistant Secretary for Environmental Management regarding

transuranic waste retrieval.

Los Alamos National Laboratory

January 16 farewell letter from the Board to Mary Ann Rosenthal.

January 24 letter to the Secretary of Energy on the recommendations of the Department of

Energy’s Commission on Fire Safety and Preparedness.
C-2

March 7 letter to the Acting Administrator of NNSA regarding flood mitigation.

March 31 letter to the Acting Administrator of NNSA regarding funding for affects of Cerro

Grande wildfire.

May 12 letter to the Acting Administrator of NNSA regarding development and design of the

DynEx project.

July 9 letter to the Administrator of NNSA regarding LANL critical experiments facility.

August 1 letter to the Deputy Administrator for Defense Programs regarding aqueous processing

of scrap plutonium-238 oxide.

August 7 letter to the Administrator of NNSA regarding work planning and practices.

August 19 letter to the Deputy Administrator for Defense Programs regarding electrical and

lightning protection.

November 5 letter to the Administrator of NNSA regarding extension of response on lightning

protection systems.

Lawrence Livermore National Laboratory

April 10 letter to the Acting Administrator of NNSA regarding hazard assessment and control.

Nevada Test Site

July 1 letter to the Administrator of NNSA regarding electrical and lightning protection.

Y-12 National Security Site

January 9 letter to the Secretary of Energy regarding high-efficiency particulate air filter testing.

October 16 letter to the Administrator of NNSA regarding Building 9212 operational safety

requirements.

December 31 letter to the Deputy Administrator for Defense Programs regarding safety review

of oxide conversion facility.

Pantex Plant

March 18 letter to the Acting Administrator of NNSA regarding implementation of fire safety

controls.

March 25 letter to the Acting Administrator of NNSA regarding software quality assurance.

April 4 letter to the Acting Administrator of NNSA regarding conduct of operations and training.
C-3

July 9 letter to the Secretary of Energy regarding accelerated SS-21 tooling for W88 weapons.

July 9 letter to the Deputy Administrator for Defense Programs regarding NNSA and Pantex

training issues.

July 10 letter to the Deputy Administrator for Defense Programs regarding hoisting and rigging.

October 10 letter to the Deputy Administrator for Defense Programs regarding Building 12-64

structural upgrade.

Rocky Flats Environmental Technology Site

July 31 letter to the Assistant Secretary for Environmental Management regarding combustibles

in gloveboxes.

December 2 letter to the Secretary of Energy regarding glovebox fire.

Savannah River Site

Jun 6 letter to the Under Secretary of Energy, Science and Environment regarding Plutonium

Finishing Plant IAEA swap dose consideration.

June 12 letter to the Secretary of Energy regarding safety basis review of plutonium material

storage and support facilities (KAMS).

July 10 letter to the Assistant Secretary for Environmental Management regarding review of

electrical and lightning protection and detection systems for KAMS.

August 14 letter to the Secretary of Energy regarding testing of high-efficiency particulate air

filters at the filter testing facility.

Other Significant Correspondence With DOE

January 9 letter to the Secretary of Energy responding to DOE’s quality assurance improvement

plan for defense nuclear facilities.

March 20 letter to the Assistant Secretary for Environmental Management regarding Rec. 94-1

research and development funding.

March 27 letter to the Assistant Secretary for Environment, Safety and Health regarding quality

assurance of Temperform heat-treated aluminum parts.

April 10 letter to the Secretary of Energy regarding Rec. 2001-1 quality assurance for safetyrelated software.

April 25 letter to the Secretary of Energy regarding suspect and counterfeit parts.
C-4

May 13 letter to the Acting Administrator of NNSA regarding documented safety analysis and

criticality safety strategy for PDCF.

Jun 12 letter to the Secretary of Energy regarding site visits for Rec. 2000-2.

June 12 letter to the Assistant Secretary for Environmental Management regarding quality

assurance improvement plan (QAIP).

July 9 letter to the Secretary of Energy regarding implementation plan for Rec. 2002-2.

July 9 letter to the Assistant Deputy Administrator for Military Applications and Stockpile

Operations regarding NESS and readiness assessment for the W62 program.

July 14 letter to the Secretary of Energy regarding acceptance of implementation plan for 

Rec. 2002-3.

August 7 letter to the Assistant Secretary for Environment Safety and Health regarding DOE’s

electrical safety handbook.

August 7 letter to the Secretary of Energy regarding closing Rec. 97-2 (criticality safety).

August 25 letter to the Assistant Secretary for Environment, Safety and Health regarding Rec.

2002-3 commitment 4.1 acceptance.

November 13 letter to the Secretary of Energy regarding DNFSB/TECH-33, Control of Red Oil

Explosions in Defense Nuclear Facilities.

December 8 letter to the Administrator of NNSA regarding the nuclear explosive safety study.

December 8 letter to the Secretary of Energy regarding administrative controls for Rec. 2002-3.
D-1

APPENDIX D

ADMINISTRATIVE ACTIVITIES

INFORMATION TECHNOLOGY AND SECURITY

The Board has continued to increase its use of advanced information technology (IT). 

Desktop hardware, software, and network servers provided to the staff are continually upgraded

to ensure that the latest tools are available. The Board’s internet website (www.dnfsb.gov) is

kept current to ensure that public documents are available for viewing and download. The

website also provides a link to live webcasts of the Board’s public meetings, six in 2003. Video

transmissions are archived so that they can be viewed at a later time.

The Board continues to place heightened emphasis on both IT and physical security. One 

key improvement made in 2003 was the establishment of an alternate operations facility,

complete with current system backup and IT resources to support 15-20 staff members for an

extended period of time. Security controls, including cipher locks to control physical access and

a perimeter firewall to control network access, have been established and tested. In addition, the

Board is working to provide secure remote access to its information systems so that missioncritical documents can be accessed from offsite locations.

STAFF

As of December 31, 2003, the Board employed 94 full-time staff in addition to the four

full-time Board Members. The Board continued its aggressive recruitment program to attract the

brightest engineering students from colleges and universities across the country, as well as

experienced engineering professionals. This year, technical recruiters visited 10 campuses and

10 career fairs, and the Board continued its recruitment outreach program through the National

Society of Black Engineers and Mexican-American Engineers and Scientists.

DISPUTE RESOLUTION PROGRAMS

The Board, like other federal agencies, is required by the Administrative Dispute

Resolution Act of 1996 to provide an alternative dispute resolution program for use in resolving

appropriate disputes. The Board maintains such a program, making use of cooperative

agreements with other agencies to resolve disputes economically.

HUMAN RESOURCES

The Board’s ability to fulfill its safety mission rests heavily on attracting and retaining

top-caliber technical staff. The Board has succeeded in creating a work environment that

emphasizes excellence as the standard for staff performance, and has rewarded its staff

accordingly. The pay banding and pay for performance programs developed and implemented

by the Board have proven to be effective in hiring technical talent, holding employees

accountable for their performance, and rewarding outstanding performance on the job. 

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

classification. Using this authority, along with recruitment and relocation bonuses, student loan
D-2

repayments, and retention allowances, the Board has been successful in competing for scientific

and technical staff in a competitive employment market.

Competition from the private sector and fiscal constraints make recruiting and retaining a

high-quality, diverse workforce a challenge. Competition for top engineering professionals is

intense. Even with the special hiring and pay authorities granted to the Board, private industry

can easily promise higher salaries and benefits. The Board has also found that the federal

downsizing campaigns of the 1990s, coupled with the perception that the federal bureaucracy

stifles creativity and fails to encourage and reward outstanding work, have damaged its

recruiting campaigns. Recruitment and retention of recent college engineering graduates,

especially women and minorities, is difficult in the current job market, and will become even

more challenging with the renewed activity in the commercial nuclear industry. 

Despite these problems, the Board has assembled a professional staff of exceptional

technical capability. Staff members’ expertise covers all major aspects of nuclear safety: 

nuclear, mechanical, electrical, chemical, fire protection, and structural engineering, as well as

physics and metallurgy. Most mid- to senior-level technical staff members possess practical

nuclear experience gained from duty in the United States Navy nuclear propulsion program, the

nuclear weapons field, or the civilian nuclear reactor industry. Both the Board and its staff

include individuals experienced in environmental impact assessments and regulatory processes. 

Four of the Board’s attorneys have technical degrees, and one is a licensed professional engineer. 

 Seven technical staff members are located at priority DOE sites. There is one site

representative at the Pantex Plant near Amarillo, Texas; two at Hanford near Richland,

Washington; two at SRS near Aiken, South Carolina; and one each at Y-12 in Oak Ridge,

Tennessee, and LANL in New Mexico.

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

knowledge, encouraging them to improve their skills continually through academic study. 

Ninety percent of the Board’s senior technical and legal staff hold advanced science and

engineering degrees, 33 percent at the Ph.D. level. Younger technical staff members have been

recruited through the Board’s professional development program. Entry-level employees

recruited into this 3-year program receive graduate-school education and intensive on-the-job

training guided by experienced technical mentors. Currently, there are 11 entry-level employees

in this program. Three completed their master’s degrees in the summer of 2003 and are in their

third-year field assignment. By the summer of 2004, five more of these individuals should be

awarded a master’s degree in an engineering discipline. The Board’s professional development

program remains extremely useful in attracting and retaining high-quality, entry-level engineers

and preparing them for challenging assignments in their fields.
E-1

APPENDIX E

Acronyms and Abbreviations

Board Defense Nuclear Facilities Safety Board

CFR Code of Federal Regulations

D&D Deactivation and Decommissioning

DOE Department of Energy

DSA Documented Safety Analysis

FY Fiscal Year

Hanford Hanford Reservation

HEPA High Efficiency Particulate Air

HEUMF Highly Enriched Uranium Materials Facility 

HLW High-level Waste

IAWG Inactive Actinides Working Group 

INEEL Idaho National Engineering and Environmental Laboratory

INTEC Idaho Nuclear Technology Engineering Center

ISM Integrated Safety Management

IT Information Technology

KAMS K-Area Material Storage

LANL Los Alamos National Laboratory

LLNL Lawrence Livermore National Laboratory

MCOs Multi-Canister Overpacks

NESS Nuclear Explosive Safety Studies

NNSA National Nuclear Security Administration

NTS Nevada Test Site

ORNL Oak Ridge National Laboratory

ORR Operational Readiness Review

Pantex Pantex Plant

PDCF Pit Disassembly and Conversion Facility 

Pu-238, 239 Plutonium-238, 239

QA Quality Assurance

RR Readiness Review

RFETS Rocky Flats Environmental Technology Site

SNFP Spent Nuclear Fuel Project

SQA Software Quality Assurance

SRS Savannah River Site

SS-21 Seamless Safety for the 21st Century

TA Technical Area

TEF Tritium Extraction Facility

TRU Transuranic

U-233 Uranium-233

USQ Unreviewed Safety Question

WIPP Waste Isolation Pilot Plant

WTP Waste Treatment Plant

Y-12 Y-12 National Security Complex