SEVENTH ANNUAL REPORT

TO CONGRESS

DEFENSE NUCLEAR FACILITIES

SAFETY BOARD

FEBRUARY 1997
John T. Conway, Chairman

A.J. Eggenberger. Vi~e Chalrnun

John W. Crawford. Jr.

Joseph J. DiN\lnno

Herbert John Cecil KQut$

DEFENSE NUCLEAR FACILITIES

SAFETY BOARD

6251ndirnl<1 Avellue. NW, Suite 700. Washington, D.C. 20004

(~02) 208·6400

FebrualY 25, 1997

To the Congress ofthe United States:

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

annual report for calendar year 1996, The Board is an independent executive braneh establishment

responsible for providing advice and recommendations to the Secretary ofEnergy regarding public

health and safety issues at Department ofEnergy (DOE) defense nuclear facilities, and to the

President if necessary, The Board also reviews and evaluates the content and implementation of

health and safety standards, as well as other requirements, relating to the design, construction,

operation, and decommissioning ofDOE defense nuclear facilities,

As required by statute, the Board's report summarizes activities during calendar year 1996,

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

problems,

During J996, with the cooperation ofDOE, the Board devoted significant attention to

ensuring the safe stabilization ofresidues and wastes, set the framework for integrated safety

management programs across the defense nuclear complex, and stimulated DOE progress toward

upgrading the technical expertise ofits staff

Of particular concern was the loss of nuclear weapon expel1ise due to downsizing the

weapons national laboratories, In response to earlier Board recommendations, more than 100

individual and group interviews ofretired weapons experts were conducted to record their safety and

reliability knowledge that otherwise was in danger of becoming irretrievable, Efforts were also

directed toward upgrading safety analytical reviews preparatOly to specific weapon disassembly, It is

essential that safety and reliability continue to be given top priority in implementing'our nation's

stockpile stewardship and management efforts,

j",t4'/~~ tJ ~ohnT~~aYf Chairman

~~7?1.. xr./h }Ph~O (lJo's;fJ 1. ~unno

Member

Respectfully submitted

~""b"g" Vice-Chairman

Herbert J, C. Kouts

Member
EXECUTIVE SUMMARY

During the past seven years, the Defense Nuclear Facilities Safety Board (Board) has

witnessed profound changes in the mission ofthe Department ofEnergy (DOE). In early

1990, DOE faced numerous issues concerning the safety ofits operations at several facilities

in the defense nuclear complex. A number offacilities had been shut down for extended

periods (e.g., the K- and L-Reactors at the Savannah River Site and certain production

facilities at the Rocky Flats Environmental Technology Site); they would remain shut down.

In addition, with the end ofthe Cold War, the mission ofthe complex shifted from the

production of plutonium and tritium and the fabrication, assembly, and testing of nuclear

weapons to the stewardship ofthe remaining weapons stockpile, the dismantlement of

nuclear weapons removed from service, and the cessation of nuclear weapons testing. DOE

was also faced with the daunting task of bringing numerous facilities to a safe shutdown

condition and cleaning up the radioactive contamination that had accumulated during

approximately fifty years ofweapons production.

The Board has retained its flexibility during this continuing transitional period,

adapting to DOE's evolving mission. During 1996, the Board devoted significant attention

to ensuring the safe stabilization ofresidues and waste, set the framework for integrated

safety management programs across the defense nuclear complex, and stimuiated DOE

progress toward upgrading the technical expertise ofits staff. These accomplishments could

not have been realized without the substantial cooperation of Secretary O'Leary and those

with line management responsibility, notably Deputy Secretary Charles Curtis and Under

Secretary Thomas Grumbly.

Significant progress has been made in improving the safety of operations in the

defense nuclear complex. This has been accomplished by both DOE and the Board working

together, with mutual respect for our separate roles and responsibilities.

A summary of accomplishments in 1996 follows. Many ofthese achievements relate

to matters pursued by the Board during a period ofyears. Most represent milestones in

continuing programs for protecting the health and safety ofworkers, the public, and the

environment.

• Plutonium and transplutonium solutions are chemically unstable and are readily

dispersible. In pursuing its safety mission, the Board has paid close and

continuing attention to facility preparations and stabilization activities associated

with these solutions. The Board's efforts have contributed to:

Dissolution of approximately 138 metric tons of deteriorated Mark-31

plutonium targets in F-Canyon at the Savannah River Site for conversion to

stable metal in FB-Line.

III
- Operation ofF-Canyon and FB-Line at the Savalmah River Site and

stabilization of about 50,000 gallons of plutonium solutions,

- Preparations for restart ofthe Savannah River Site H-Canyon and HB-Line to

support expedited stabilization of plutonium and neptunium solutions,

- Initiation ofthe development ofa vitrification capability in F-Canyon to

stabilize the highly radioactive americium/curium solutions and the H-Canyon

neptunium solutions,

- Initiation of plutonium solution processing in Buildings 771 and 371 at the

Rocky Flats Environmental Technology Site and the start of hydroxide

precipitation processing,

- Processing of about 2,700 liters of highly enriched uranium solution

containing more than half a metric ton of highly enriched uranium, thereby

eliminating all highly enriched uranium solutions stored at the Rocky Flats

Environmental Technology Site,

• The Senate Armed Services Committee report on S, 1085, establishing the Board,

includes the following mandate: "The Board is expected to raise the technical

expertise ofthe Department substantially...." In 1996, Board actions to address

this problem included a public meeting in January and issuance of a technical

report' in March, which led directly to a joint DOElBoard conference held June

13-14, 1996. As a result, DOE has now initiated the first rigorous review ofthe

technical qualifications ofits Senior Technical Safety Managers. Additionally,

DOE efforts to address criticalunmet staffing needs in the latter half of 1996

resulted in the hiring of S6 new staff members under its excepted service

authority.

• The Board issued Recommendation 96-1 in August 1996, urging DOE not to

proceed with large-scale process testing at the In-Tank Precipitation (ITP)

Facility at the Savannah River Site until the mechanisms by which flammable

gases are generated, retained, and released in the ITP process are bett:er'

understood, Recent test results have suggested that the precipitated cesium and

potassium tetraphenylborate solids, as well as the excess tetraphenylborate in

solution, may be vulnerable to rapid decomposition by catalytic attack under

certain conditions. Such a case would pose a major flammability hazard from the

resulting benzene.

, An Assessment Concerning Safety at Defense Nuclear Facilities: The DOE Technical

Personnel Problem, DNFSBffECH.IO,

IV
• As a result ofthe Board's initiative, sludge and incinerator ash residues at

Hanford's Plutonium Finishing Plant have been stabilized.

• In response to Recommendation 94-1, the contractor at the Rocky Flats

Environmental Technology Site has inspected, treated, and repackaged more than

half of 1,858 plutonium items identified lIS posing a potential fire hazard. More

than 42 kilograms of plutonium oxide has been stabilized.

• Addressing the Board's identification of one ofthe most unstable forms of

plutonium, workers at the Rocky Flats Environmental Technology Site have

drained ten tanks of plutonium-bearing solutions left behind from past production

processes in Building 771. In addition, more than 900 liters of plutonium and

uranium solutions in Building 774 was mixed with cement to form a solid, more

stable form ofwaste.

• In 1996, in response to the Board's urging, DOE and the Hanford contractor

submitted a major revision to the implementation plan for Recommendation 93-5.

The revised plan was accepted by the Board. This revision better recognizes the

data needs for each major safety issue and establishes priorities for sampling of

individual waste tanks based on these needs.

• In Septe/TIber 1996, in response to Recommendation 94-3, DOE submitted an

integrated program plan for completion of required upgrades to Building 371 at

the Rocky Flats Environmental Technology Site, development of a safety

management program, and initial actionstoward the Department's preferred

alternative of constructing an interim storage vault in lieu of using Building 371

for that purpose. The Board accepted the plan. In late 1996, the structural

upgrades were designed and installed, thus making the building structurally

adequate for a storage mission.

• In January 1996, the Board requested that DOE take action to eliminate

potentially explosive amounts of hydrogen in certain tanks containing plutonium

solutions at the Rocky Flats Environmental Technology Site. The affected tanks

have now been 'sampled, and the contractor has purged 43 of 76 tanks in Building

771 and 6 of 8 tanks in Building 371.

• At the beginning of 1996, the authorization basisl for the Hanford tank farms

consisted of a loosely maintained collection ofvarious safety assessments,

2 Authorization basis is broadly defined as" ... Ole composile ofinformalion a contraelor musl

provide in response to all environmental, safety, and health requirements applicable to a facility." An

authorization basis includes those aspects offacility design and operational requirements relied upon by DOE to

authorize operalions (Fundamentalsfor Understanding Standards-!lased Safety Management ofDel'0l"lmelll of

Energy Defense Nuclear Facilities. DNFSBrrECH-S, p.13).

v
analyses, requirements, and procedures. At the urging ofthe Board, the Hanford

contractor developed a Basis for Interim Operations (BIO) based on a full hazard

analysis, thus providing not only the first complete picture ofthe risks associated

with tank farm operations, but also a necessary start on development of an

acceptable authorization basis.

• In response to Recommendation 95-1, DOE has taken action to slow the

degradation of cylinders containing depleted uranium hexafluoride (UF6) in

outdoor storage at the three gaseous diffusion plants. Substantial progress has

been made, including removal ofcylinders from direct ground contact, design and

construction of new and improved cylinder storage yards, and initiation of a pilot

program for recoating entire cylinders (more·than 1,500 cylinders have already

been recoated under this pilot program).

• The Board identified a number of deficiencies in the execution ofthe initial

Operational Readiness Review for startup ofthe High-Level Liquid Waste

Evaporator at the Idaho Chemical Processing Plant. As a result, improvements in

formality of operations and in DOE line managementreview ofthe contractor's

readiness were observed in a subsequent Operational Readiness Review. Further

improvements are required, however, to assure safety.

• In response to Recommendation 94-4, the Oak Ridge Y-12 Plant contractor and

DOE took a number ofsteps to correct deficiencies in criticality control that had

been identified. These steps were recognized as necessary to prepare for

resumption of operations. Operational activities in three offive mission areas for

which corrective actions were required were restarted in 1995, and activities in a

fourth were successfully resumed in 1996.

• The Board's interest spurred the development offonnal methods for integrated

safety management review and authorization ofsubcritical experiments at the

Nevada Test Site. These methods are scheduled to be institutionalized by two

new DOE-Nevada Operations Office Orders in early 1997.

• As a result ofRecommendation 93-6, three Weapon Safety Specifications were

issued, incorporating previously unrecorded operational safety information. More

than 100 individual and group archiving interviews ofretired weapons experts

were conducted by the weapons laboratories and weapons production and testing

facility organizations, and records ofthe dismantlement process that were in

danger of becoming irretrievable were preserved.

• In response to Recommendation 93-1, DOE revised nuclear explosive safety

directives, including two DOE orders, an implementation guide, a technical

standard on the Nuclear Explosive Safety Study (NESS) process, a technical

VI
standard on performing hazard analysis, and an interim rule on the Personnel

Assurance Program.

• In February 1996, the Board entered into a Memorandum ofUnderstanding with

DOE, the Environmental Protection Agency, and the State ofColorado to ensure

the cooperation of oversight and regulatory bodies during decommissioning at the

Rocky Flats Environmental Technology Site. A lead oversight or regulatory

agency is designated as' the sole contact with DOE for each decommissioning

activity or material, to the extent provided by law. This should avoid redundant

and duplicative regulation and inconsistent safety instruction at the site. As

recently acknowledged by Congress, similar arrangements could result in efficient

and effective oversight and ref,'Ulation at other defense nuclear sites throughout

the complex.

• The Board has been influential in arranging for reactivation of a long-term study

ofthe original group oftwenty-six individuals who received known radiation

exposures from internal deposition of plutonium. Affected individuals were

examined every five years from 1951 through 1991. The target group includes

nineteen surviving workers who were exposed during the time they worked at Los

Alamos National Laboratory in the early days ofthe nuclear arms race.

In achieving this progress, the Board has demonstrated the value of a small,

dedicated, technically competent group conducting oversight ofsafety at DOE facilities.

Successes result from the ability ofthe Board and its staffto interact with DOE and

contractor officials at all appropriate levels in a timely fashion. As a result, badly needed

changes and safety improvements are acknowledged more readily by the officials involved at

all levels, and corrective actions are expedited. This scenario has been acted out many times

over, in almost all the areas ofsafety interest that have commanded the Board's attention.

The Board looks forward to meeting future challenges in helping DOE improve

safety management plans at defense nuclear facilities. These challenges will be met, and the

safety ofworkers and the public will be enhanced, by the Board's ongoing programs for

monitoring DOE's activities. to ensure the safety and reliability ofthe weapons in the

stockpile; verifying the safe dismantlement of nuclear weapons; overseeing the processing of

production residues and handling of contaminated waste; and confirming the safety of

deactivation, decommissioning, and restoration offormer production facilities.

VII
Section

Table of Contents

Page

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

2 MAJOR TECHNICAL ACTIVITIES OF THE BOARD DURING 1996 .... 2-1

2.1 Activities Related to Stewardship ofthe Weapons Stockpile 2-1

2.1.1 Pursuit of an Integrated Approach to Safety in DOE's Nuclear Explosive

Operations 2-2

2.1.2 Activities Related to Specific SiteslFacilitiesiActivities 2-4

2.2 Cross-Cutting Activities . . . . . . . . . . . . .. 2-11

2.2.1 Development and Implementation of Sound Nuclear Safety Standards .. 2-11

2.2.2 Processing and Storage of Surplus Special Nuclear Materials 2-13

2.2.3 Establishment of Sound Integrated Safety Management Systems. . . . . .. 2-14

2.2.4 Teclmical Expertise ofDOE Staff. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2-15

2.2.5 Status ofDOE Functions, Authorities, and Responsibilities Manual for

Nuclear Safety (FAR Manual) ....._. . . . . . . . . . . . . . . . . . . . . . . . . . .. 2-18

2.2.6 Operational Readiness Review Activities 2-18

2.2.7 Operational Radiological Safety 2-19

2.2.8 Health Effects ofPlutonium Uptake by Workers 2-21

2.3 Activities Related to Decontamination and Decommissioning 2-21

2.3.1 Rocky Flats Environmental Technology Site . . . . . . . . . . . . . . . . . . . . .. 2-24

2.3.2 Hanford Site . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. 2-24

2.4 Activities Related to Design, Construction, and Initial Operations 2-26

2.4.1 SavarUlah River Site 2-26

2.4.2 Rocky Flats Environmental Technology Site 2-28

2.4.3 Los Alamos National Laboratory 2-28

2.4.4 Hanford Site. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. 2-29

2.4.5 Gaseous Diffusion Plants at Oak Ridge, Portsmouth, and Paducah 2-30

2.5 Activities Related to Plutonium Stabilization 2-30

2.5.1 Savannah River Site 2-32

2.5.2 Rocky Flats Environmental Technology Site 2-32

2.5.3 Hanford Site 2-34

2.6 Activities Related to Waste Management 2-35

2.6.1 Implementation ofRecommendation 94-2 . . . . . . . . . . . . . . . . . . . . . 2-36

2.6.2 Hanford High-Level Waste Tank Farms 2-36

2.6.3 Waste Characterization 2-37

2.6.4 Tank Waste Remediation System 2-38

IX
Section

Table of Contents (concluded)

Page

3 ADMINISTRATIVE MATIERS ......................................... 3-1

3.1 Personnel Recruitment 3-1

3.2 Official Site Visits by Board Members and Staff 3-2

3.3 Public Interaction with the Board 3-2

3.4 National Performance Review Objectives 3-3

3.4.1 Starting Without Encumbrances 3-3

3.4.2 Reducing Regulatory Burden 3-4

3.4.3 Excepted Service and Pay for Performance 3-4

3.4.4 "No Frills" Approach to Operations 3-4

3.4.5 Effective Organization Structure 3-4

3.4.6 Management Continuity .................................•.... 3-5

3.4.7 Experienced Leadership 3-5

3.4.8 Infonnation Teclmology 3-5

4 PERFORMANCE GOALS .....•: 4-1

4.1 Broad Safety Issues 4-2

4.2 Evolving Technical Challenges 4-4

4.3 Long-Range Goals .............•............................ 4-5

4.4 Near-Term Objectives 4-6

4.5 Site-Specific Objectives 4-8

APPENDIX A FEDERAL REGISTER NOTICE FOR

RECOMMENDATION 96-1 A-I

APPENDIX B PROGRESS TOWARD IMPLEMENTING

PROVISIONS OF THE GOVERNMENT

PLANNING AND REPORTING ACT OF 1993 (GPRA) -" ..... B-1

x
1. INTRODUCTION

The Manhattan Project, initiated in the early days ofWorld War II, is generally

recognized as the start ofthe nuclear age. Since then, the Department ofEnergy (DOE) and

its predecessor agencies, the Atomic Energy Commission and the Energy Research and

Development Administration, have produced considerable quantities ofspecial nuclear

materials and designed, manufactured, tested, and maintained the weapons in the nation's

nuclear arsenal. During most ofthe last fifty years, the nuclear weapons complex operated

without independent external oversight. In 1988, Congress, mindful ofthe accumulating

public health and safety issues involving many ofthe aging defense nuclear facilities,

enacted into law the creation ofthe Defense Nuclear Facilities Safety Board (Board). The

five-member Board, composed of "respected experts in the field of nuclear safety with a

demonstrated competence and knowledge relevant to the independent investigative and

oversight functions ofthe Board," was empowered to provide advice and recommendations

to the Secretary ofEnergy to ensure adequate protection of public and worker health and

safety at DOE's defense nuclear facilities. The Board became functional in late October

1989, when the charter Board members w.ere sworn in.

The Board is responsible for independent oversight of all activities relating to nuclear

safety within DOE's nuclear weapons complex. Today, DOE is actively engaged in the

ongoing process of disassembling nuclear weapons, maintaining the remaining weapons in

the stockpile in a safe and reliable condition, and conducting research focused on ensuring

the continued stewardship ofthe stockpile. In addition, considerable attention is currently

being devoted to safe disposition offissionable material removed from disassembled

weapons and ofmaterial remaining in the system following the abrupt cessation of many

production activities more than seven years ago. Many ofDOE's current activities are

associated with cleanup of extensive radioactive contamination resulting from decades of

production.

Its enabling statute, 42 USC § 2286, et seq., requires the Board to review and analyze

facility and system design, operations, practices, and events, and make recommendations to

the Secretary ofEnergy that are necessary to ensure adequate protection of public health and

safety. The Board must consider the technical and economic feasibility ofimplementing the

recommended measures, and the Secretary must report to the President and Congress if

implementation of a recommendation is impracticable because of budgetary considerations.

If an imminent or severe threat to public health or safety is determined to exist, the Board is

required to transmit its recommendations to the President, as well as to the Secretaries of

Energy and Defense.

The Board is required by law to review and evaluate the content and implementation

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

pertaining to the design, construction, operation, and decommissioning ofDOE defense

1-1
nuclear facilities. The Board must then recommend to t!Je Secretary ofEnerb'Y any specific

measures, such as changes in the content and implementation ofthose standards, that it

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

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

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

recommend necessary changes. The Board's review and advisory responsibilities continue

throughout the full life cycle offacilities, including the shutdown and decommissioning

phases.

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

information, conduct studies, establish reporting requirements for DOE, and take other

actions in furtherance ofits review responsibilities. These ancillary functions relate to the

accomplishment ofthe Board's primary function, which is to assist DOE in identifying and

correcting health and safety problems at defense nuclear facilities. The Department and its

contractors at defense nuclear facilities are required to cooperate fully with the Board.

The terms ofthe enabling statute give clear guidance about what Congress expected

the Board to do and in what manner. Congress expected the Board's oversight to have many

ofthe same positive results as formal regulation: assurance that DOE is implementing a

program that provides for the safe management ofthe production and use of defense nuclear

materials, which, in tum, gives reasonable assurance ofrio undue risk to workers and the

public, and protects the environment. Congress was well aware that DOE had issued safety

policies and standards ofgood practice. However, Congress was also aware that these

practices needed upgrading, and that DOE and contractor operations in the past had left

extensive residual contamination in buildings and the surrounding environment. DOE's

problem appeared to be primarily a failure to establish clear expectations ofits contractors

and to build safety compliance into the fabric ofwork planning and execution.

During the past seven years, the Board has focused much ofits attention on

examining the standards identified by DOE as codes of good practice, the way DOE defines

what is expected ofits contractors in the performance ofthe Department's mission, and the

means by which such requirements are enforced. These elements are basic to any safety

management program, whether internally or externally driven. The most significant

deficiencies in these basic elements have been communicated to DOE by means of'the

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

not only describe perceived deficiencies, but also provide guidance as to what the Board

believes are advisable solutions. Implementation plans for addressing the issues identified in

these recommendations are then submitted by the Secretary for Board approval. The Board

follows the progress of each required action program until the planned action has been

completed. To date, the Board has issued 34 sets ofrecommendations containing 149

specific recommendations; these are discussed in detail later in this report.

In meeting its responsibilities, the Board recognizes DOE's legitimate need to do its

essential national defense work without unjustifiable delay. Through assignment of its staff

to monitor and review work involving design, construction, or preparations for readiness to

1-2
operate, the Board has been able to keep its safety reviews synchronized with DOE activities.

Technical concerns that arise during these reviews are frequently resolved by the technical

staffs ofDOE, the Board, and contractors without the need for formal action-forcing

measures by the Board. Ifthe Board determines there are unresolved safety issues that

require resolution before work proceeds, it can define those issues and recommend their

resolution by the Department. In the case ofoperations at the Rocky Flats Environmental

Technology Site, Congress required that before resumption of plutonium operations in

specified buildings, the Board determine to its satisfaction that DOE's response to specific

recommendations ofthe Board adequately protects public health and safety.

In addition to its reviews ofthe basic elements and structure ofDOE's safety

management program, the Board has given priority attention to particular facilities and

activities considered to represent the greatest safety risks-mainly those that now comprise

the remaining portions ofthe nuclear weapons complex devoted to (1) the stewardship,

maintenance, and surveillance of nuclear weapons; (2) the stabilization of hazardous

remnants ofweapons production; and (3) the storage ofstrategic and highly radioactive

materials. For those facilities and operations representing significant hazards, the Board is

actively pressing DOE to develop improved safety management programs that would result

in clearly defined systems and components important to safety, technical specifications

. defining limiting conditions for operation, .and the infrastructure needed to support

maintenance and safety in operation. This has already been done for a number offacilities

and operations. The extension ofthis effort to high-risk facilities is the thrust of

Recommendation 95-2, Safety Management, the end goal ofwhich is to have safety

management programs that are not only well defined, but also tailored to the diverse

operations ofthe DOE complex.

With respect to decommissioning of defense nuclear facilities, the Board has thus far

paid particular attention to those facilities in transition to cleanup or environmental

restoration under the Comprehensive Environmental· Response, Compensation, and Liability

Act (CERCLA) and the Resource Conservation and Recovery Act (RCRA). CERCLA and

RCRA statutes are administered by the Environmental Protection Agency (EPA) and the

states. The Board is working cooperatively with EPA and the states to effect a smooth

transition to CERCLA and RCRA oversight by the states involved, and has recently signed

cooperative agreements V{ith the State ofColorado, EPA, and DOE with respect to activities

at the Rocky Flats Environmental Technology Site.

The Board is required by statute to report to Congress each year concerning its

oversight activities, its recommendations to the Secretary ofEnergy, and safcty

improvements achieved at defense nuclear facilities as a result ofits activities. This report

responds to that requirement. It is organized as follows:

• Section 2 dcscribes the major technical activities ofthe Board during 1996.

• Section 3 addresses administrative matters.

1-3
• Section 4 identifies the Board's performance goals.

In addition, two appendices are provided: Appendix A contains the Federal Register

notice for Recommendation 96-1, while Appendix B describes the Board's progress toward

implementation ofthe provisions ofthe Government Planning and Reporting Act of 1993.

.... ,

1-4
2. MAJOR TECHNICAL ACTIVITIES OF THE BOARD DURING 1996

This section reports on major technical activities ofthe Board during 1996 in the

following areas:

• Activities related to stewardship ofthe weapons stockpile (Section 2.1)

• Cross-cutting activities that apply to several facilities or sites, or to the entire

defense nuclear complex (Section 2.2)

• Activities related to decontamination and decommissioning (Section 2.3)

• Activities related to design, construction, and initial operations (Section 2.4)

• Activities related to plutonium stabilization (Section 2.5)

• Activities related to waste management (Section 2.6)

2.1 ACTIVITIES RELATED TO STEWARDSHIP OF THE WEAPONS

STOCKPILE

Nuclear weapons remain a vital part ofU.S. national security. With the end ofthe

Cold War, the manufacture of nuclear weapons ceased, and with the Administration's

commitment to conclude a Comprehensive Test Ban Treaty, all underground testing of

nuclear weapons ended as well. DOE's strategy for dealing with this significantly changed

mission is embodied in its Stockpile Stewardship andManagement Plan. Formalized by the

Secretary ofEnergy on December 19, 1996, tllis plan provides for continuation ofthe

ongoing defense missions at eight DOE sites, and includes appropriate adjustments

consistent with post-Cold War national security policies. This new approach also calls for

construction ofselected facilities with enhanced experimental capabilities; these facilities

will be operated at the various national laboratories. Weapons manufacturing capability at

existing plants will be maintained, but the plants' capacity will be appropriately reduced. In

addition, the capability for manufacturing components of plutonium pits will be reestablished

at a national weapons laboratory.

These changes will have a significant impact on the way DOE assures safety in its

facilities for research. manufacturing, assembly, disassembly, and testing of nuclear

weapons. For example, existing weapon systems will remain in the nation's stockpile

significantly longer than in the past. New methods will be necessary to ensure that

operations involving nuclear weapons remain safe while the weapons are in the custody of

the Department. In addition, in the absence of underground nuclear testing, alternative

means oftesting and confirming the safety ofweapons at all stages in their life cycle are

being developed.

2-1
The Board will continue to assess the safety implications ofthese changes and

monitor DOE's implementation ofthe Stockpile Stewardship andManagement Plan.

2.1.1 Pursuit of an Integrated Approach to Safety in DOE's Nuclear Explosive

Operations

Since late 1991, when it was assigned oversight responsibility for the assembly,

disassembly, and testing ofnuclear weapons, the Board has been assessing the safety

management programs for the design, operation, and maintenance offacilities for nuclear

explosive operations and comparing such programs with other nuclear programs both within

and outside the DOE complex. These reviews have led the Board to conclude that

substantially enhanced safety could be achieved by improved integration of explosive safety

management programs and other nuclear safety programs.

As a result, the Board issued two recommendations (93-1 and 93-6) and a reporting

requirement. The Board detennined that two distinct and inconsistent safety management

programs existed at nuclear explosive facilities--one for nuclear explosive operations and

another for operations involving nuclear materials not combined with explosive materials.

Further, the Board noted that the existing safety management system for nuclear explosive

operations was largely expert-based, as opposed to the more standards-based approach that

was pioneered by the commercial nuclear industry and was in the process of being

implemented at DOE's other nuclear facilities. The Board identified two potential problems

associated with DOE's expert-based approach:

• Weapons experts were retiring and, for the most part, leaving a void in knowledge

and expertise at the weapons design laboratories.

• Nuclear Explosive Safety Studies (NESSs)~safety assessments of explosives in

pr~ximity to nuclear materials-lacked documented rigor.

These issues are discussed further in the subsections below.

During the past three years, the Board has interacted frequently with DOE to improve

the management ofsafety in nuclear explosive operations. Fifteen letters have been sent to

DOE containing specific observations regarding the nuclear explosive safety stud)iprocess

and its integration with other facility safety processes. Beneficial changes have resulted, as

subsequent discussions in this report indicate. (see Section 2.1.2).

Access to Weapons Expertise. In Recommendation 93-6, Maintaining Access to

Nuclear Weapons Expertise in the Defense Nuclear Facilities Complex. the Board urged

DOE to establish formal programs to capture knowledge possessed by nuclear weapons

experts who are retiring or otherwise leaving the progra)ll. The Board considers such

information to be essential to the safe maintenance ofthe enduring nuclear stockpile, the

safety of dismantlement programs at the Pantex and Oak Ridge Y-12 plants, and the retention

2-2
ofthe capability to safely resume nuclear testing should that course of action be directed by

the President.

DOE's initial attempts to implement Recommendation 93-6 were not successful, as

noted in the Board's sixth annual report. The Board staffworked closely with DOE to

develop a revised implementation plan, which was subsequently submitted to the Board in

February 1996. The Board has noted significant progress in DOE's execution ofthis plan

during the remainder of 1996. Several examples can be cited. First, the Oak Ridge Y-12

Plant and the DOE Oak Ridge Operations Office institutionalized and implemented an

effective knowledge preservation program. Second, the Sandia National Laboratories

implemented a knowledge preservation program that showed good promise. Third, the

Lawrence Livermore National Laboratory took steps to start and conduct an effective

program to capture the knowledge ofretirees. Finally, the Los Alamos National Laboratory

developed a program that placed considerable emphasis on documenting the expertise of

senior weapons design personnel, including retirees, 'for both Pantex and Nevada Test Site

operations.

Tllis progress has been accompanied by some difficulty in ensuring that the weapons

laboratories complement their efforts to preserve weapon design information with actions to

capture operational safety information. The Board sees the need for improvement in this area

at all the weapons laboratories and will continue its oversight ofthis matter. -

Recommendation 93-1. In early 1993, the Board issued Recommendation 93-1,

Standards Utilization in Defense Nuclear Facilities, recommending that DOE address the

differences between the safety requirements applicable to nuclear explosive facilities and

those applicable to other defense nuclear facilities. In response, DOE issued an

implementation plan aimed at ensuring that the requirements governing the safety of nuclear

explosive operations would be fully integrated with those for other defense nuclear

operations.

Later in 1993, the Board established a reporting requirement calling on DOE to

address specific issues associated with the nuclear explosive safety study process used by the

Department to ensure the safety ofits nuclear explosive operations. DOE responded with a

Nuclear Explosive Safety Study Corrective Action Plan (NESSCAP), which identified

several fundamental improvements in the nuclear explosive safety study process. In

addition, the plan committed DOE to resolving issues associated with contamination by and

dispersal of plutonium and other radioactive material, addressing the evaluation of

environmental safety and health requirements during nuclear explosive operations, and

improving the planning and conduct of appraisals of nuclear explosive weapon safety.

Moreover, with the Board's approval, DOE combined that plan with the implementation plan

for Recommendation 93-1, to ensure that the requirements governing the safety of nuclear

explosive operations would be fully integrated.

During 1996, DOE completed the revision ofits nuclear explosive safety orders. The

orders package now includes the two applicable orders, an implementation guide, a technical

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standard on the safety study process, a second technical standard on performing hazard

analysis, and an interim rule on the Personnel Assurance' Program. These new safety

requirements meet the objectives ofboth the NESSCAP and Recommendation 93-1. When

fully implemented, they will better ensure that operations at those facilities that assemble,

disassemble, and test nuclear weapons will provide the requisite protection ofthe public,

workers, and the environment.

Several issues will continue to require Board attention during implementation of

these requirements. For example, the quality of documentation and reports will need to be

improved to meet the new guidelines in the standard. The Board and its staffwill continue to

work with DOE in developing guidance for the conduct of nuclear explosive safety study

reviews. The goal ofsuch technical interactions is to ensure that these reviews provide a

thorough technical analysis ofthe potential hazards ofthe operations, detennine the safety

impact of procedural and equipment changes, and resolve potential safety issues prior to

operation..

DOE has recently formed a task force to integrate facility Safety Analysis Reports

with operations Hazard Analysis Reports, and to address deficiencies at the interface

between safety and hazard analyses. The Board will continue to follow the development of

DOE's standard on hazard analysis for nuclear explosive operations. In addition, the Board

will follow closely DOE's activities designed to ensure that the analyses ofspecific weapons

operations complement the safety analyses ofthe facilities, and that the two together are

appropriately comprehensive.

. DOE's Assistant Secretary for Defense Programs has recently concluded that the

safety practices applied to nuclear explosive operations must be extended to subsidiary

operations involving nuclear weapons. The Board supports this decision.

2.1.2 Activities Related to Specific SiteslFacilities/Activities

Safety Management of Research and Development at the Weapons Laboratories.

As discussed briefly in Section 2.1, the three weapons laboratories (Los Alamos National

Laboratory, Lawrence Livermore National Laboratory, and Sandia National Laboratories)

have taken on a greatly increased role under DOE's Stockpile Stewardship andManagement

Plan. The laboratories will be shouldering new responsibilities in the areas of production

and surveillance, in addition to expanded research and development.

It is recognized that work planning, which includes the analysis of hazards and the

subsequent development and formal implementation of preventive and mitigative controls,

needs considerable improvement at some research and development facilities ofthe weapons

laboratories. For example, at Los Alamos National Laboratory, there have been several

recent incidents and accidents whose root causes could be traced directly to inadequate

understanding ofthe hazards or lack ofimplementation of protective measures, Work

planning will continue to receive increased emphasis throughout 1997.

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The Board's efforts in safety management have kept pace with those ofDOE. In

1995, the Board asked the Department to prepare a report addressing the proper manner of

ensuring that nuclear research and development at the laboratories is conducted safely and in

accordance with safety requirements that do not unduly impede the creative process. This

reporting requirement, which served as a precursor to the Board's technical report on Safety

Management andConduct ofOperations, DNFSBrrECH-6, and Recommendation 95-2

(see Section 2.2.3), noted that the nuclear safety standards made obligatory by DOE for its

operating contractors have general applicability to the wide diversity ofDOE activities.

Although DOE's safety policy and the applicable standards pennit a "graded" approach, in

which the formality of operations varies in form and degree depending on the nature and

extent ofthe hazards involved, just what is acceptable has never been well defined, nor is its

definition apparent from case histories. This is especially true for the weapons laboratories,

where there are far more research and development activities under way than production

activities, and in which the mix ofskills for research and development is much different from

that for production.

The weapons laboratories have main,tained that safety management programs should

reflect this difference. The Board also believes that DOE requirements need not be applied

in the same way at both production facilities and research and development laboratories; i.e.,

it is not a "one size fits all" situation. Be\ieving that the laboratories are in the best position

to define a safety management program for facilities where research and development

functions are dominant, the Board has encouraged them to do so. The reaction of

management at the laboratories has been positive, as evidenced by the progress being made

in developing integrated safety management programs in response to Recommendation 95-2

(discussed further below).

In a parallel but separate activity, the Secretary ofEnergy's Advisory Board was

asked to review the Department's management ofits laboratories. Among other conclusions,

the Advisory Board's review committee, chaired by Robert Galvin, stated that the

laboratories were subject to excessive micro-management in the form of a multiplicity of

DOE internal Jnd external audits oflaboratory operations.

In response to the Galvin report, DOE established an Environment, Safety and Health

(ES&H) Oversight Pilot initiative, in which all three weapons laboratories currently

participate. This study is intended to determine whether DOE's on-site appraisal activities

could be reduced substantially through increased dependence on the results ofthe

laboratorie's' self-assessment programs. It became evident in 1996 that all ofthose programs

will require significant upgrading before they can provide adequate assurance of effective

safety. This conclusion was reached by DOE field personnel as they monitored the progress

ofthe initiative, and was confirmed by reviews conducted by the Board staff at the three

weapons laboratories. The required improvements are expected to be incorporated in the

laboratories' integrated safety management plans,

Pantex Plant. The Pantex Plant, located outside Amarillo, Texas, is DOE's

remaining site for the assembly, disassembly, and surveillance of nuclear weapons. In

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addition, it serves as an interim storage site for retired weapons and strategic reserve

plutonium. Pantex also plays a central role in DOE's plans for stockpile stewardship and

management.

The Board has continued its review ofthe content and implementation ofsafety basis

documents at Pantex. During the past year, the Board has monitored activities at Pantex to

develop new Safety Analysis Reports and Teclmical Safety Requirements, and to improve

the Unreviewed Safety Question Determination (USQD) process used for reviewing and

correcting such documents. The Board notes that its previous efforts have resulted in

improvements in the analysis and control ofsafety, and that the newer Safety Analysis

Reports and Basis for Interim Operations documentation also represent an improvement.

The Board continues to find problems, however, »,ith the Pantex safety basis

documents. For example, the Board stafffound that the DOE-approved safety limit for

temperature control of environmental chambers used to age nuclear explosives artificially

was set at the exact temperature at which a runaway reaction could be expected, and

therefore it did not provide an adequate margin ofsafely. After the Board brought this

shortcoming to DOE's attention, the Department initiated a broad-based effort to upgrade

and properly integrate safety management at Pantex. DOE developed a short-term plan that

included action to suspend approval of activities in the environmental chambers, pending the

establishment of a firmer basis for safety contFOls and better assurance of acceptable

implementation ofthose controls. A longer-term effort will be to evaluate all ofthe current

processes used at Pantex to assess safety and develop safety controls. This evaluation is

intended to identify areas of overlap (i.e., where streamlining is possible to accelerate the

implementation ofsafety improvements), gaps (i.e., where a hazard may go unidentified or

unmitigated), and control measures that merit augmentation.

On a related matter, the Board is working with DOE to improve the Pantex USQD

process. During the past year, the Board identified several conceptual errors in the process

used to determine whether proposed changes in activities or questions raised about an

existing activity have significant safety implications. These errors led to an understatement

ofthe safety significance 'ofsome changes. As a result of constructive interactions with the

Board and its staff, DOE and its contractor have changed the way USQs are processed at

Pantex. TillS action led Pantex to declare that changes to operations, such as the use of

portable x-ray equipment in nuclear explosive assembly cells, constitute positive tiSQs. For

activities that are declared a positive USQ, Pantex developed adequate controls to prevent or

mitigate the risks and to execute the activities safely.

Improved Conduct ofOperations and Use ofStandards-Safety of operations

involving nuclear explosives at Pantex is managed through strict adherence to explicit

procedures that have been developed, approved, and followed verbatim by knowledgeable

personnel. It has long been a common objective ofthe Board and DOE that those procedures

not only be technically sufficient to ensure safety, but also be written so that users can

understand them. This is essential at a time when many older and more experienced workers

are retiring. Pantex evaluated all ofits critical-usc procedures to ensure that they are not too

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complicated and are sufficiently easy to read, understand, and follow. Pantex now has

assurance that the procedures can be used effectively by the technicians who perform handson nuclear explosive operations. Pantex has also developed a schedule for converting old

procedures to a new format that is clearer and easier to follow.

Integrated Plan-Three long-term initiatives to improve safety are under way at

Pantex. First, as part ofthe Seamless Safety-21 process, activities involving nuclear

explosives are being redesigned to improve safety. Second, in support ofthe project for

upgrading Safety Analysis Reports, operations at Pantex will be reanalyzed to ensure that

hazards are adequately controlled. Finally, in parallel with these two safety efforts, DOE is

in the process of adopting a new set of orders that rely on consensus standards for nuclear

operations.

In the last year, with encouragement from the Board, DOE developed its first

integrated plan for implementing each ofthe above safety improvement programs. This plan

represents a cooperative effort among DOE, its Pantex contractor, and the national weapons

laboratories. It identifies improvements and efficiencies that will allow DOE to

expeditiously convert its improved safety concepts into true safety benefits in Pantex

operations.

During the past several years, DOE has significantly improved its program for

assessing the safety of operations with nuclear explosives. The improved process, as

described in the new DOE Orders 452.1, Nuclear Explosive and Weapon Safety Program,

and 452.2, Safety ofNuclear Explosive Opera/ions, together with their associated

implementing guides and standards, will increase the technical rigor of nuclear explosive

safety reviews and the quality oftechnical information on which these reviews will be based.

Much ofthe improvement has been guided by DOE's implementation plan for

Recommendation 93-1 and the NESSCAP, which responded to the Board's reporting

requirement ofDecember 8, 1993 (see Section 2.1.1).

The scope ofthe Board's interest in integrated safety of nuclear explosive operations

includes potential impacts on operational safety from facility, process, and human hazards, as

well as hazards inherent in the materials being worked. Nuclear explosive safety studies

have historically been defined by, and restricted to, consideration of only those scenarios that

would result in nuclear detonation, the detonation or deflagration of high explosives, or fire

in the vicinity of a combination of high explosives and nuclear materials. Since the early

development of nuclear weapons, nuclear explosive safety studies have emphasized the need

for a heightened degree of assurance against unintended nuclear detonation. However,

nuclear explosive safety study groups reviewed only·those operations involving the assembly

of pits and high explosives, in which an accident could potentially result in a nuclear yield.

One ofthe upgrades to the process defined in the recently revised DOE Order 452.2 is a

widening ofthe scope ofthe studies to cover all operations where pits and high explosives

are collocated, even ifthey are not being assembled. DOE has been working to improve the

conduct of nuclear explosive safety studies by implementing requirements in the new orders.

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Part ofthe success ofDOE's integrated plan for Pantex is due to a concept in the new

Order 452.2 called revalidation, which was introduced by DOE to provide a limited-scope

safety review as a basis for extending the expiration date for a nuclear explosive safety study.

Revalidations are performed to ensure that the operation studied by the original nuclear

explosive safety study has not been altered as a result ofsubsequently approved changes.

Board review ofthe first several revalidations identified concerns with the process as it was

being implemented. Further guidance was then issued by DOE, and the revalidation

requirements in the DOE Standard on the Nuclear Explosive Safety Study Process were

strengthened. Revalidations bridge the gap between DOE's old and new processes for safety

review during the transition to Seamless Safety-21. The Board will continue to watch for

improvements in the conduct ofrevalidations.

Nevada Test Site. Although all underground weapons testing at the Nevada Test

Site has been suspended, the Board is continuing its oversight ofthe safety ofsubcritical

experiments and the planned operations ofthe Device Assembly Facility.

Safety Oversight ofSubcritical Experiments-As part ofDOE's Stockpile

Stewardship and Management Program, the weapons design laboratories had planned to

conduct two subcritical experiments in 1996 at the Nevada Test Site. These experiments

were to involve devices containing both high explosives and special nuclear materials in

confif,'Urations that, by design, could not achieve criticality. The first ofthese "subcritical"

experiments was scheduled to be conducted by Los Alamos National Laboratory in June

1996; the second was scheduled to be carried out by Lawrence Livermore National

Laboratory approximately one month later.

The Board staff conducted several reviews at the Nevada Test Site and at Los Alamos

National Laboratory to evaluate (I) the hazard analyses prepared by the laboratory for its

experiment; (2) DOE's review and authorization process, and (3) the safety management

system for the subcritical experiment program. The results ofthese reviews indicated that,

given the low level of hazards, the laboratory's hazard analyses and the resulting plan for a

safety management approach were adequate. However, it was not apparent that DOE had a

well-defined plan for, or expectations for development of, the necessary authorization basis,

technical review, or integrated safety management ofsubcritical experiments in g!lneral.

Consequently, in a June 1996 letter, the Board urged the Department and the national

weapons laboratories to develop a comprehensive safety management plan addressing the

full range of potential hazards associated with future subcritical experiments, and noted that

the plan should be graded according to the risk associated with the activity.

DOE subsequently deferred the initial subcritical experiments until 1997, and they

have not yet taken place. However, during 1996, the Board and its staff continued to discuss

the development of an integrated safety management system for these experiments. In

response to the Board's encouragement and guidance, the DOE Nevada Operations Office

and the laboratories have developed a promising approach. Tlus approach is to be

documented in new Nevada Operations Office orders, which are expected to be finalized in

early 1997 and used for future subcritical experiments.

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The Board will continue to review the safety bases for the individual subcritical

experiments, as well as DOE's review and authorization for these experiments. Review of

the hazard analysis for the experiment to be conducted by Lawrence Livermore National

Laboratory is scheduled for early 1997.

Device Assembly Facility-The Device Assembly Facility at the Nevada Test Site is

a new facility for nuclear explosive operations. Although originally intended for the

assembly of one-of-a-kind nuclear test devices, the facility is being modified to

accommodate a broader range of operations, such as disassembly, modification, staging,

maintenance, repair, retrofit, and surveillance of nuclear weapons.

During 1996, the Board evaluated the adequacy ofthe facility's safety systems, its

safety authorization basis (including facility plans and procedures), and the Device Assembly

Facility Nuclear Explosive Safety Master Study. In addition, the Board staffidentified and

called to DOE's attention deficiencies in the electrical distribution and fire protection

systems. The Department addressed these deficiencies in coordination studies for protection

devices, anticipated electrical system upgrades, and a consolidated fire hazard analysis.

DOE expects that the facility will commence operations during 1997. Activities will

include the assembly ofsubcritical experill1ents, the preparations for test readiness exercises,

and p·ossibly the conduct ofresearch on surveillance ofweapons.

Oak Ridge Y-12 Plant. Activities conducted at the Oak Ridge Y-12 Plant include

the manufacture, surveillance, and dismantlement of nuclear weapon components fabricated

from both highly enriched and depleted uranium. Since DOE's Stockpile Stewardship and

Management Plan calls for retaining this capability at the Y-12 Plant, the Board has focused

significant attention on reviewing safety-related matters at the site. Several examples of

recent Board activities regarding nuclear safety at Y-12 are discussed below.

Conduct ofOperations ami Criticality Safety-Recommendation 94-4, Deficiencies

in Criticality Safety at the Oak Ridge Y-12 Plant, discussed weaknesses in criticality safety

programs, as well as the adequacy of experience, training, and performance of personnel both

at DOE and in contractor operations. In accordance with its implementation plan for this

recommendation, DOE and its Y-12 contractor undertook a number ofinitiatives considered

vital to resumption of operations. For example, immediate steps were taken to correct safety

deficiencies, and those steps were validated through a forinal restart process conducted in

accordance with applicable DOE orders. Corrective actions were initiated in 1995 and are

scheduled to be completed in 1998.

During the past three years, the Board and its staff have had numerous interactions

with DOE regarding restart activities. In addition, DOE has performed several independent

functional area assessments (i.e., training, conduct of operations, and criticality safety) in

accordance with conunitments in the implementation plan. Each assessment found that, in

general, DOE has made significant progress toward meeting its commitments in 1996. The

evaluators also noted that continued improvement is still called for in those areas which have

2-9
been restarted, and that significant work is still needed in those mission areas where restart

has not yet occurred, particularly with respect to nuclear criticality safety. The Board will

continue to interact closely with DOE as enriched uranium operations (discussed further

below) are restarted to support national security programs.

Processing ofExcess In-process Hig!l/y,Ellriclled Uranium-In late 1995, the

Board issued one ofits ongoing series oftechnical reports, Status ofHighly Enriched

Uranium Proces~~ing Capability at Building 9212, Oak Ridge Y-12 Plant (DNFSBrrECH-9).

In that report, the Board staff observed that in-process, higWy enriched uranium materials

comprise the largest portion ofmaterials at risk in Building 9212, and that these materials

contribute significantly to the radiation doses received by personnel at Y-12. DOE has

declared a large amount ofthis material to be excess to mission needs. The sheer bulk ofthis

material poses problems for managing the inventory and for controlling the radiation

exposure ofworkers. The Board concluded that it would be prudent for DOE to process the

material at the earliest opportunity, once Y-12 management has upgraded the authorization

basis for Building 9212 and demonstrated its readiness to operate.

In a February 1996 letter forwarding its technical report to DOE, the Board asked

DOE to describe actions that would be taken to characterize and catalogue the excess highly

enriched uranium residues, and to establish priorities for processing these residues when

enriched uranium operations are restarted at the Y-12 Plant. During 1997, and continuing

into 1998, the Board will monitor progress toward the successful processing ofthis material.

Tritium Production Issues. Tritium is a radioactive isotope of hydrogen used in the

nation's nuclear weapons. It has a relatively short half-life (12.3 years) and must be replaced

periodically in order for the weapons to function as designed. Tritium was last produced in

the Savannah River Site K-Reactor, which was shut down in 1988. Currently, DOE does not

have the capability to produce tritium.

During the fiscal year 1993 budget process, Congress required the Administration to

prepare and submit a report on the tritium stockpile and the necessary schedule for resuming

production. In October 1995, the Secretary announced the results of a Programmatic

Environmental Impact Statement for Tritium Supply and Recycle. The preferred alternative

was a dual-track strategy under which the Department would begin work on two promising

tritium production options: use of an existing commercial light water reactor, and

construction of a linear accelerator. Current plans require the new tritium facilities to be

operational between 2005 and 20 I0, depending on the required number ofweapons in the

stockpile.

The Savannah River Site has been selected as the preferred location for an

accelerator, should one be constructed. Under this alternative, tritium is produced by

exposing targets to an accelerator proton beam, following which the target assemblies are

processed to extract the tritium. Under either alternative, new processing facilities to extract

the tritium from reactor- or accelerator-irradiated targets are planned for construction at the

Savannah River Site.

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Starting in fiscal year 1997, the Board intends to review the preliminary designs for

these proposed facilities. The Board expects to continue its reviews ofthese projects as they

progress through the detailed design phase into construction, startup, and operation.

Mound Laboratory. The Mound Laboratory (Mound) is currently involved in the

cleanup of nuclear waste and in the safe shutdown and decommissioning offacilities

formerly used for the production, repackaging, and off-site shipment of nuclear materials.

The Board has monitored the radiological safety aspects ofDOE's project for unloading

more than 500 special tritium reservoir units at Mound. During the past year, only about half

ofthe reservoirs scheduled to be unloaded have actually been unloaded. The main

contributor to the slip in schedule was a three-month work suspension to resolve a tritium

inventory discrepancy that was eventually attributed to accounting and calibration errors.

The Board will continue to review the remaining tritium operations at Mound to ensure that

safety issues arising during the final stages ofshutdown are properly resolved; the Board has

some concern that the level oftechnical expertise available to complete the remaining tritium

operations may be inadequate to deal with technical issues that may arise.

2.2 CROSS-CUITING ACTIVITIES

A number ofissues are common to several facilities or sites, or in many cases to the

entire defense nuclear complex. These cross-cutting issues are examined in the following

subsections. They include DOE's overall actions to develop and implement sound nuclear

safety standards; the emerging program for processing and storing surplus special nuclear

materials; the establishment ofsound integrated safety management systems; the technical

expertise ofDOE staffmembers in both Headquarters and field organizations; the clear and

unequivocal articulation ofthe authorities and responsibilities ofDOE staff members; the

implementation of adequate reviews ofreadiness for initiation or resumption of operations;

the improvement ofthe Department-wide program for operational radiological safety; and

the health effects of plutonium uptake by workers.

2.2.1 Development and Implementation of Sound Nuclear Safety Standards

In its enabling statute, 42 U.S.C. § 2286 et seq., the Board is assigned responsibility

for review and evaluation of " ... the content and implementation ofthe standards relating

to the design, construction, operation, and decommissioning of defense nuclear facilities of

the Department ofEnergy (including all applicable Department ofEnergy orders,

regulations, and requirements) at each Department ofEnergy defense nuclear facility." In

addition to requirements imposed by statute, DOE sets requirements for its contractors

through one or both ofthe following vehicles:

• Rules promulgated in the Code ofFederal Regulations

• Contractual requirements drawn from any appropriate source, including, but not

limited to, DOE safety orders or Standards/Requirements Identification

2-1 I
Documents (S/RIDs)' for specific subject areas, and standards established by the

American National Standards Institute (ANSI), by other recognized standardswriting bodies (such as technical or professional organizations), or by DOE.

During 1995 and 1996, DOE embarked upon a major undertaking-the

OrderlRequirement Reduction and Streamlining effort-'to revise, improve, and upgrade

many ofits requirements. The scope ofthis ongoing effort includes substantial revisions to

requirements covering administrative, procurement, and technical aspects ofthe way DOE

conducts its business. These requirements are set forth in a small number ofrules and in

hundreds ofDOE orders covering the broad spectrum ofthe Department's responsibilities.

The undertaking involves large commitments ofthe Department's technical, administrative,

and legal staffs.

Ofthe many hundreds of orders in effect when the revision process was initiated, 51

were related to nuclear safety matters for which the Board has oversight responsibilities. The

Board has carefully evaluated the revision effort to the extent that it has addressed these 51

orders. The Board staff conducted an extensive review of each ofthe original set of 5I

safety orders and each ofthe new safety orders and rules proposed to replace them. Based on

that review, the Board staff determined that a majority ofthe requirements and guidance in

most ofthe s~fety-related orders should be retained.

In July and September of 1995, the Board held public meetings to review DOE's

development process for "new" safety orders and rules. During these meetings, the Board

staff testified that the requirements in some ofthe proposed rules or draft orders did not

represent an adequate set ofrequirements and guidance for establishing DOE's safety

management program. Based in part on that testimony, the Board concluded that DOE

needed to examine more closely the total set ofrequirements and guidance encompassing

nuclear safety. During the September meeting, DOE representatives committed to

completing a "crosswalk" for each ofthe requirements in the previously existing set of 51

safety-related orders, mapping each old requirement to a specific element in the proposed

new set.

The Board also held two public meetings on this subject during 1996. The first was

on November 7, the second on December 12. ,At the November meeting, the Board staff

reported that DOE had completed its crosswalk. In addition, the staff presented its review

and evaluation ofthe new orders and proposed rules. Ofthe set of new safety orders in place

at the end of 1996, only six were complete and judged by the Board staffto be adequate:

DOE 430.1, Life Cycle Asset Management; DOE 425.1, Startup/Restart; DOE 151.1,

Emergency Management System; DOE 225.1, Accident Investigations; DOE 231. I, Safety

, DOE safety orders or SIRIDs, by tllemselves, do not impose enforeeable requirements on DOE

contraetors, but become enforceable when they are invoked by specific contract provisions, which arc legally

binding (see the Board's teclmical repOlt FllndamenlalsJor Underslanding Standards-Based SaJety

Managemenl ojDepartment ojEnergy DeJe",.. Nllclenr Facililies, DNl'SSffECH-S).

2-12
andHealth ReportingRequirements; and DOE 451.1, National Environmental Policy Act

Compliance Program. The remaining orders require additional changes.

On the basis ofits review of proposed nuclear safety rules, the Board staff concluded

that the technical aspects ofthe rules appeared to be sound, and that the proposed rules

retained the essential elements ofthe predecessor orders. However, policy and legal

questions remained regarding the provisions for granting exemptions from regulatory

requirements and for rule implementation. These questions were communicated to DOE.

At the December public meeting, DOE managers concurred in the analysis ofthe

orders completed by the Board staff and proposed an action plan for making needed changes

to the new safety orders. With respect to proposed rules, DOE staffmembers agreed with the

Board staffregarding exemption language. With respect to other issues raised regarding the

nuclear safety rules, however, DOE representatives stated that certain internal Department

matters required resolution before further discussion could take place. Both DOE

management and the Board expressed a desire to resolve the outstanding issues quickly.

Even iffull agreement on the content ofthe new orders and proposed rules can be reached

expeditiously, some implementation issues will remain.

2.2.2 Processing and Storage of Surpl!1s S(!ecial Nnclear Materials

In Recommendation 94-1, Improved Schedule for Remediation in the Defense

Nuclear Facilities Complex, the Board recommended that all plutonium metal and oxide be

stored in conformance with the then-existing draft of a standard for long-term storage. The

Board also urged DOE to expedite preparations to repackage plutonium metal in contact with

or in proximity to plastic because ofthe risk that the hydrogen generated by radiolytic

decomposition ofthe plastic could give rise to an explosion.

,. DOE initially intended to issue the storage criteria as "guidance" with loose

specifications, allowing individual sites to develop specific local requirements. The Board

ultimately convinced DOE ofthe need for a technica:I standard for the safe long-term storage

of plutonium that would provide specific requirements whose fulfillment could be

measured-a standard that could be applied throughout the defense nuclear complex. That

standard was subsequently issued in December 1994 as DOE-STD-3013-94. As a result of

the Board's participation in the review and revision ofthis standard, important changes were

incorporated, thereby establishing acceptable criteria for safely storing plutonium.

DOE is now using this standard as the basis for the following:

• Storage of plutonium at all DOE sites

• Procurement of a standardized stabilization and packaging process line

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• Development ofstandardized containers to be used throughout the complex

• Consolidated storage ofstrategic reserve plutonium

DOE reports that all plutonium known to be in direct contact with plastic (the higherhazard condition) has now been repackaged and that work is progressing to repackage

plutonium in proximity to plastic. The Mound Laboratory has shipped its plutonium to the

Hanford Site and Los Alamos National Laboratory for repackaging.

2.2.3 Establishment of Sound Integrated Safety Management Systems

In Recommendation 95-2, issued in late 1995, the Board urged DOE to

institutionalize a process ofintegrated safety management for activities at defense nuclear

sites. It is the Board's view that effective implementation ofRecommendation 95-2 has the

potential to upgrade DOE's program for ensuring nuclear safety throughout the defense

nuclear complex. To support the achievement ofthis most important goal, individual Board

members expended considerable time and energy throughout 1996 in communicating with

DOE Headquarters, field, and contractor elements about the intent ofthis recommendation.

In Recommendation 95-2, the Board advocated the issuance of complex-wide

standards to govern the development, approval, and implementation ofintegrated safety

management. The integrated use ofsafety management functions and processes to facilitate

the conduct ofwork in achieving site missions is a major objective ofthis recommendation.

The Secretary ofEnergy accepted Recommendation 95-2 in January 1996 and

submitted an implementation plan in April 1996. In responding to the recommendation,

DOE stated that "the Department and Contractors must systematically integrate safety into

management and work practices at all levels so that missions are accomplished while

protecting the public, the worker, and the environment."

In accepting DOE's implementation plan, the Board stressed the following:

• That the Board was encouraged by DOE's commitment to reconciling)nd

integrating into a consistent whole the existing directives and various DOE

initiatives that affect safety management, and to making safety management

planning an integral part ofwork planning.

• That the safety management program developed in response to Recommendation

95-2 should be pursued in parallel with effective implementation of

Recommendation 93-3, Improving DOE Technical Capability in Defense Nuclear

Facilities Programs, ifthe numbers of qualified personnel needed to execute the

safety management program are to be available at the right places and at the right

times.

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• That firm dates for delivery ofsafety management plans within a year are needed

for priority facilities, including the Hanford K-Basins and tank farms, the

Lawrence Livermore National Laboratory Superblock, the Los Alamos National

Laboratory Technical Area-55 and Chemistry and Metallurgy Research Building,

the Pantex Plant cells and bays, the Savannah River Site canyons, the Rocky Flats

Environmental Technology Site Buildings 371 and 771, and the Oak Ridge Y-12

Plant.

DOE has made progress in meeting the commitments ofits implementation plan. A

Safety Management Implementation Team was established early in the process to oversee the

execution ofthe commitments and internal management actions outlined in the plan, A DOE

policy to institutionalize the Department's safety management system-DOE P 450.4, Safety

Management System Policy-was issued in final form in mid-October 1996, An acceptable

contract clause was developed that will require contractors to follow the objectives, guiding

principles, and functions for safety management. Encouraging as this progress has been,

much work will be needed throughout 1997 and beyond to implement fully the intent ofthis

overarching Board recommendation,

The Board was briefed in June and July 1996 on the approaches being taken by the

various contractors who are implementing integrated safety management systems at the

priority facilities. These briefings indicate'd that while some projects were progressing more

rapidly than others, an encouraging start was evident overall. To assist DOE in developing

guidance for Recommendation 95-2 implementation efforts, the Board commented, in an

early October 1996 letter, on what it had observed in the contractors' briefings that appeared

to reflect particularly effective and useful practices,

Since not all ofthe ten priority facility briefings to the Board contained firm

schedules for implementatipn.ofintegrated safety management systems, DOE provided a

separate set of milestones in early October. Board review ofthese milestones revealed

several issues, which include the following:

• The terms used to communicate the integrated safety management concepts are

not clearly defined and consistently employed.

• Front-line operations personnel and operations-oriented personnel do not appear

to be involved in concept development and implementation ofintegrated safety

management systems at a site, Without their involvement, it is unlikely that the

concepts developed will result in a workable approach.

Resolution ofthese issues will require both DOE and Board effort in 1997.

2.2.4 Technical Expertise of DOE Staff

The report ofthe Senate Armed Services Committee on S. 1085 that accompanied the

legislation establishing the Board includes thc following statement: "The Board is expected

2-15
to raise the technical expertise ofthe Department substantially...." The technical

qualifications ofDOE personnel who are assigned safety-related responsibilities merit

continued attention. The Department faces the diminution ofthe extensive background and

experience in weapons that once resided in contractor organizations. Also, to administer

effectively the upgraded approach to safety management advocated by DOE will require

highly experienced staff.

The Board has issued a number oHormal recommendations addressing this subject,

including 90-1,92-7,93-2,93-3, and 93-6. In addition, numerous letters, as well as reports

generated by the Board's technical staff, have been specifically directed to the technical

qualifications ofDOE's safety managers. Despite DOE"s actions in this arena, the number of

highly qualified technical personnel added to the Department during the 1994-95 period

remained minimal.

In January 1996, the Board held a public meeting in Washington, D.C., to address this

issue. At that meeting, members ofthe Board staff who had studied this matter reported the

following observations:

• Although DOE had added a number of new hires to its technical staff, most of

these were not the senior, highly experienced individuals required for technical

leadership roles.

• DOE had elected to conduct its hiring almost exclusively under the more

constrained rules ofthe civil service system, rather than enrich the talent pool

through outside recruitment under the excepted service provisions authorized by

Congress.

As a result ofthe January public meeting, ajoint DOElBoard ~onference was held, at

which a plan for attacking the critical unmet staffing needs ofthe Department was addressed.

Two members ofthe Board and the Under Secretary ofEnergy, along with senior

representatives ofDOE Headquarters and Field Office Management and members ofthe

Board staff, participated in this conference to focus on developing specific courses of action

to address the DOE technical expertise issue. As a result ofthe conference, a plan to attack

the critical staffing needs ofthe Department and to improve its cadre of Senior Technical

Safety Managers was initiated by the Under Secretary.

A key action item resulting from the conference was to have Operations Office

managers and Headquarters line management review their organizations and identify the

required senior technical safety management positions (existing, as well as those that should

be created). Approximately 250 such positions were identified.

A second key action item was for DOE to increase substantially its use of existing

excepted service authority. By the end of 1996, DOE had filled a total of 59 excepted

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service positions, with another 22 in various stages ofrecruitment and staffing.' Since

DOE's authorization to fill 200 technical excepted service positions expires in October 1997,

it is imperative that DOE give prompt attention to these efforts.

Despite encouraging signals from the conference, however, DOE is still experiencing

difficulties in meeting its goals. Therefore, a second joint conference is tentatively scheduled

for the spring of 1997. Given the expected long-range nature of any solution to this issue and

the need to maintain the momentum represented by these initial actions, the Board will

undoubtedly be required to sustain its active participation on a continuing basis.

Through efforts related to the joint conference, DOE has addressed issues associated

with standards for various management-level technical positions, and a revision to the

radiological protection standard is in process. Nevertheless, the Board believes that

qualification standards in several other functional areas are marginal, and most ofthe

standards require specific improvements. Further, and of perhaps greater importance,

approved training activities and acceptable equivalencies to meet competencies identified in

technical qualification standards have not yet been fUlly identified, developed, or

promulgated.

It is not clear that this program will accomplish its objective, especially in a DOE

environment in which increasing demands "are placed on a dwindling staff. However, theBoard remains intensely interested and intends to monitor the effectiveness ofthe program

closely.

Finally, a success story can be reported in this area ofinterest. As a result ofthe

Board's continuing emphasis on DOE's lack of adequate numbers of highly qualified

technical personnel, the Richland Operations Office (DOE-RL) identified a need for added

technical strength in the areas ofradiological control and nuclear safety. The Board strongly

encouraged DOE-RL to use the Department's excepted service hiring authority to acquire the

necessary "seed" talent.

During the summer of 1996, DOE-RL received more than 300 applications for the

eight identified positions and interviewed more than 100 people. The Board's continuing

attention to tillS issue ensured technical competence and demanding interview techniques on

the part ofthe DOE-RL Technical Review Board performing screening ofresumes and

interviews. As a result ofthis recruitment effort, eigllt new hires with substantial technical

credentials were added to the DOE-RL staff.

• After considerable eff0l1 by both the Board and DOE, the National Defense AuUlOrization Act for

fiscal year 1995 had granted Ule Department 200 additional exccpled service employment slots for scientific.

engineering, and technical personnel whose duties would relatc to safely at defense nuclear facilities.

2-17
2.2.5 Status ofDOE Functions, Authorities, and Responsibilities Manualfor Nuclear

Safety (FAR Manual)

DOE continues to experience changes in programs and organiution. An important

element ofthese ongoing changes is the delegation of broad operational responsibilities to

field organizations. Yet in spite ofthe reorganiution ofmanagerial processes, poor

definition ofthe authorities and responsibilities ofDOE staff members continues to be a

fundamental weakness affecting the Department's ability to ensure safety. During the past

three years, the Board has placed substantial emphasis on the need for DOE to establish a

clear definition ofroles and responsibilities for nuclear safety within the Department.

Departmental changes have outpaced corresponding changes to the FAR Manual, which is

therefore out of date.

In July 1995, in response to Recommendation 94-5, DOE committed to delivering an

approved, revised FAR Manual by February 1,1996. In the implementation plan for

Recommendation 95-2, this schedule was subsequently revised to mid-September 1996, and

a requirement was added that"... the Department roles and responsibilities in the FAR

Manual ... be consistent with changes in the safety management organization instituted

pursuant to this Implementation Plan." The importance ofthis issue was also emphasized at

the joint DOE/Board conference discussed in Section 2.2.4 above. A specific DOE Action

Item arising from that conference addressed the role ofthe federal employee in the DOE

defense nuclear complex, especially the need to reflect ownership ofissues related to safety

management ofDepartmental facilities. DOE noted thai "this responsibility can be shared,

but DOE's portion is not diminished." .

An updated draft document, the DOE Safety Management Functions, Responsibilities

andAuthoriliesManual (FRAM), was delivered to the Board in July 1996. The Board

provided comments to DOE in mid-August; a revised FRAM was then provided to the Board

in October. Based on a review ofthe revised manual by its staff, the Board concluded that

significant deficiencies limit the usefulness ofthe draft FRAM. In its present form, it cannot

act as a stand-alone statement ofthe Department's assignment offunctions, responsibilities,

and authorities. Detailed comments were forwarded to DOE. As a result, DOE concluded

that the manual cannot be issued until additional details, to be provided by an integrated

series ofsubtier documents (Level 2 FRAMs), are developed. DOE has indicated.that this

effort cannot be completed before May 1997.

The Board has continued to emphasize the importance it attaches to the issuance of an

updated FRAM, and to DOE's ensuring that its line management clearly understands its

responsibilities.

2.2.6 Operational Readiness Review Activities

Since its inception, the Board and its staff have carefully reviewed preparations for

starting or restarting activities at defense nuclear facilities and the conduct of associated

readiness reviews. Confirmation ofreadiness to proceed is a major element of an acceptable

2-18
safety management program as outlined in Recommendation 95-2, Safely Management. The

Board has made a number of other recommendations that have addressed standards for

performance of Operational Readiness Reviews, including Recommendations 90-4, 91-3, 91-

4, 92-3, 92-5, and 92-6.

Throughout 1996, the Board and its staff continued to monitor readiness for startup or

restart of activities and conduct ofreadiness reviews throughout the complex, including the

following:

• Startup ofthe evaporator for the New Waste CalcineI' Facility at the Idaho

Chemical Processing Plant

• Draining ofhighly enriched uranium solutions from tanks in Building 886 and in

Building 771, and startup ofthe Caustic Waste Treatment System in Building 371

at the Rocky Flats Environmental Technology Site

• Nuclear weapons surveillance and disassembly activities at the Pantex Plant

• Dissolving ofMark-31 plutonium targets in F-Canyon at the Savannah River Site

to convert plutonium in irradiated targets to plutonium metal for safe interim or

long-term storage -

• Disassembly of nuclear weapon components and quality evaluation ofweapon

components at the Oak Ridge Y-12 Plant

• Startup ofthe Device Assembly Facility at the Nevada Test Site

• Startup ofthe Tritium Emissions Reduction Facility at the Mound Laboratory and

preparations for restart of all tritium activities at Mound as a result oftritium

inventory control problems in late 1996

• Startup of a classified program at Los AJamos National Laboratory

In general, the Board continues to observe improvements in preparations by line

management for startup or restart of operations and the conduct ofreadiness reviews.

2.2.7 Operational Radiological Safety

The Board's initiatives during the past five years have led to distinct improvements in

radiological control programs throughout the DOE complex. In November J996, the Board

determined that the major purposes ofRecommendation 91-6 on improving the DOE

program for radiological protection ofworkers and the public had been met. This

recommendation is now closed. However, continued vigilance and strong technical

leadership at all levels ofDOE management will be required ifDOE is to continue to meet its

declared goal of excellence in radiological protection performance.

2-19
Since its establislunent, the Board has advocated improvement in DOE's complexwide radiological protection program. In addition to monitoring Department-level policy and

requirements regarding radiological protection, the Board and its staff have made numerous

visits to assess the overall adequacy ofsite radiological protection programs and the degree

oftheir conformance with existing DOE guidance. In addition, the Board staff has been

especially active recently in reviewing the development ofDOE's proposed revisions to its

radiological protection rule, 10 CFR 835.

During the first year and a halffollowing its establishment, the Board conducted

assessments and reviews ofradiological protection programs at several DOE defense nuclear

facilities. As a result ofthese efforts, the Board identified significant weaknesses in DOE's

radiological protection program and in December 1991 issued Recommendation 91-6,

Radiation Protection for Workers and the General Public at DOE Defense Nuclear

Facilities. In this recommendation, the Board identified a need for increased DOE attention

in five major areas: (1) DOE management and leadership in radiological protection

programs, (2) radiological protection standards and practices at defense nuclear facilities,

(3) training and competence of health physics technicians and supervisors, (4) analysis of

reported occurrences and correction ofradiological protection program deficiencies, and

(5) understanding of and attention to radiological protection issues by DOE and its contractor

organizations.

The Board has consistently urged DOE to improve its radiological protection

program and, in Recommendation 91-6, it explicitly encouraged the Department to strive

toward excellence in this area. DOE responded to Recommendation 91-6 by strengthening

its policies, standards, training, oversight, and organizational infrastructure for the

Department-wide radiological protection program. In June 1992, partly in response to Board

urging, DOE incorporated mandatory radiological controls, requirements, and practices in its

newly issued Radiological Control Manual. Late in 1993, DOE codified its radiological

protection requirements in 10 CFR 835, which included as-Iow-as-reasonably-achievable

(ALARA) provisions.

As part ofthe 1995 consolidation ofits health and safety orders, DOE redesignated

the Radiological Control Manual as simply a guidance document, covering any gaps left by

this action with pertinent requirements contained in DOE Notice 441.1, Radiolog(cal

Protectionfor DOE Activities. The Board found that tHese standards provide an adequate

framework for an acceptable occupational radiological protection program. The guidance

thus promulgated is consistent with standards applicable to the commercial nuclear industry.

During 1996, the Board conducted assessments ofwork planning practices, with

particular attention to radiological protection programs at the Hanford Site, the Rocky Flats

Environmental Technology Site, the Los Alamos National Laboratory, the Idaho National

Engineering Laboratory, and the Oak Ridge Y-12 Plant. The greatest emphasis was on the

Hanford Site, where deficiencies in the radiological protection program are long-standing,

and where a continuing lack of both management attention and technical expertise was

2-20
evident. Considerable improvement in the level oftechnical expertise at Hanford resulted

(see Section 2.2.4 above).

The Board and its staff also reviewed proposed changes to the rule on Occupational

Radiation Protection, 10 CFR Part 835. Among the issues raised by the Board staff and

resolved by DOE were dose limits, use ofthe terms "survey" and "monitoring," and

.requirements for calibration of equipment such as air samplers. DOE published an

amendment to 10 CFR 835 for public comment in late December 1996. The Board will

continue to work with DOE staff during the public comment period, staying abreast of

comments, their resolution, and changes made in the final rule.

2.2.8 Health Effects of Plutonium Uptake by Workers

The Board has been influential in arranging for the reactivation of and a modest

increase in funding for a long-term study ofindividuals who have received known radiation

exposures from internal deposition of plutonium. Affected individuals were examined every

five years from 1951 through 1991. The target group includes nineteen surviving workers

(seven others have died) who were exposed during the time they worked at Los Alamos

National Laboratory in the early days ofthe nuclear arms race.

The forty-year study of known and measurable plutonium deposition in these

individuals constitutes hard evidence that the radioactive element is not as hazardous as

generally believed. Reacting to criticism that DOE lacked public credibility, DOE's Office

ofEnvironment, Safety and Health (ES&H) transferred the study from Los Alamos National

Laboratory to the Department ofHealth and Human Services' National Institute for

Occupational Safety and Health (NIOSH), Two years later, NIOSH decided to drop the

program, alleging that it was too small to be statistically significant, and ES&H subsequently

decided not to fund it.

In response to urging from the Board and action by Under Secretary Thomas

Grumb:y when he was informed ofthe situation, DOE has once again resumed the study,

under the direction ofDr. George Voelz, an internationally recognized expert, who had

directed the study from 1970 through 1988. A funding level of $90,000 is earmarked for this

work during fiscal year 1997, but none is currently available for fiscal year 1998. The Board

believes that adequate funding should be made available to continue the health studies ofthe

remaining former employees with known plutonium contamination.

2.3 ACTIVITIES RELATED TO DECONTAMINATION AND

DECOMMISSIONING

As DOE's mission has changed from production to cleanup, the Board has increased

its attention to the decommissioning of production facilities, This shift has included greater

emphasis on the safety standards to be used during decommissioning and closer scrutiny of

programs aimed at ensuring the health and safety of workers, as well as the offsite public,

2-21
during the stabilization and deactivation phases of decommissioning (see Section 2.5 for a

discussion ofstabilization ofresidual radioactive materials). DOE initiatives to develop pilot

programs on enhanced work planning are designed to involve workers along with safety

professionals in work planning. These pilot programs are leading to improved safety

awareness and to incorporation of appropriate safety measures in work plans.

The Atomic Energy Act requires the Board to review and evaluate the content and

implementation ofstandards (including applicable DOE orders, regulations, and

requirements) relating to the design, construction, operation, and decommissioning of each

DOE defense nuclear facility. Decommissioning commences in earnest when DOE

determines that facilities are no longer needed to support the weapons program; the facilities

are then scheduled for deactivation and eventual dismantlement or reuse. The Board has

defined terms related to decommissioning and clarified its jurisdiction and responsibilities

during the decommissioning process in its policy document PS-3 and its technical report on

Regulation and Oversight ofDecommissioning Activities at Department ofEnergy Defense

Nuclear Facilities (DNFSBfTECH-12).

As described in these documents, decommissioning has different meanings for

different agencies. In the context ofBoard oversight of a DOE defense nuclear facility under

the Atomic Energy Act, decommissioning starts at the end of operations and ends when

radioactive materials have been adequately removed from the facility. DOE, for its own

purposes, has brOken down the period following operations into phases such as stabilization,

deactivation, and decommissioning. Although this has caused no conflicts, clarification of

terms is needed for jurisdictional purposes. The above documents also clarifY that,

regardless ofthe term applied to the phases in the life ofa facility, the Board's interest

follows the hazards to worker and public health and safety posed by the radioactive materials

involved.

DNFSB/TECH-12 goes on to describe the interactions that occur among the Board

and other regulators as a facility progresses through decommissioning (from operations to

environmental restoration). Board interest in a facility diminishes as radioactive hazards are

removed, whereas Environmental Protection Agency (EpA) and state interests increase as the

facility progresses through cleanup to environmental restoration and release for limited or

unrestricted use. DNFSBfTECH-12 suggests principles of cooperation to streamline the

transition and minimize the impact of multiple regulators on DOE activities.

On the basis ofunderstandings with EPA and associated state authorities, DOE is

proceeding to decontaminate excess facilities to the extent required to maintain and monitor

them safely until they can be dismantled or converted to other uses, and envirorunental

restoration can be accomplished under provisions ofthe Resource Conservation and

Recovery Act (RCRA), the Comprehensive Environmental Response, Compensation, and

Liability Act (CERCLA), or applicable state statutes as appropriate. Provisions ofthose

statutes bring such actions under the oversight ofEPA and/or the affected states, as well as

the Board.

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In keeping with its interest in following hazards to the health and safety ofworkers

and the public, the Board has focused its attention with regard to deactivation and

decommissioning primarily on the Rocky Flats Environmental Technology Site (RFETS), the

Hanford Site, and the Savannah River Site-three locations DOE has selected for early

cleanup:

• At RFETS, work is under way to develop miw methods for deactivation and

decommissioning offacilities, and to streamline processes for getting this work

done much more rapidly than the ten-year span previously projected.

• At the Hanford Site, DOE has identified deactivation projects involving the

Uranium Trioxide (UO,) and PUREX facilities as models for the development of

common deactivation practices. Deactivation ofthe B-Plant will use the models

developed by these facilities. DOE has identified the C-Reactor at the Hanford

site as the centerpiece of a large-scale demonstration project for development of

new decommissioning technologies, including placement ofthe reactor in a

cocoon.'

• At the Savannah River Site, the Board has only recently initiated contacts to

examine planning activities and their application to near-term facilities for

decontamination and decomn1issioning. -

To avoid duplication ofthe regulation and oversight of decommissioning, the Board,

along with DOE, EPA, and the State ofColorado, developed a Memorandum of

Understanding (MOU) that coordinates their respective oversight and regulatory authorities

during the cleanup ofRFETS. Coordinated efforts under such an MOU should minimize the

impact of multiple regulators on DOE activities, while accommodating each agency's

statutory mandate. Specifically, one agency with jurisdiction over a given DOE activity

takes a primary role, and the other regulatory or oversight agencies with jurisdiction or

special expertise take secondary roles, advising the primary agency or working through that

agency to discharge their jurisdictional responsibilities. The MOU ndther expands nor

diminishes statutory powers, and DOE need only work directly with one agency and follow a

set of consolidated and agreed-upon requirements. DOE, EPA, the State ofColorado, and

the Board executed the RFETS MOU in February 1996. It was then issued as an appendix to

the final Rocky Flats Cleanup Agreement.

The Board has pursued cooperative arrangements with other states that have DOE

sites involved in substantial decommissioning activities. For example, the Board is now

working with the State ofTennessee and DOE to establish an informal protocol to ensure

that CERCLA activities at the Oak Ridge National Laboratory Molten Salt Reactor

, TIllS technique involves extending all reactor shield walls to the same height and adding a new

concrete roof above Ule reactor, moditying U,e reactor building to seal all penetrations and most oUler building

access points, removing all ancillary buildings and structures, and allowing only inti'equent and limited access to

the facility for periodic inspection.

2-23
Experiment are coordinated with the Board's health and safety activities. Close cooperation

among the parties should help prevent duplication and negative impacts on the DOE cleanup

schedule. This protocol may be expanded, as mutually agreed, to accommodate future

decommissioning activities at Oak Ridge.

2.3.1 Rocky Flats Environmental Technology Site

The Board has identified Building 771 at RFETS as one ofthe highest-priority

facilities in the DOE nuclear weapons complex to be inventoried for decommissioning.

Plutonium processing and research and development in the building have been shut down

since 1989. Under DOE's planning, deactivation is scheduled to begin during fiscal year

1998, with decommissioning due to start two years later. Many ofthe processes carried out

in Building 771 involved weapons-grade plutonium dissolved in strong acid solutions. On a

number of occasions in the past, these solutions have leaked from equipment and

contaminated various areas ofthe building. A significant amount of plutonium is held up in

the production equipment, including gloveboxes, ventilation ducting, filters, and inaccessible

areas. More than 10 kilograms (kg) of plutonium is held up in ductwork alone, with

unknown quantities in equipment, tanks, and piping.

Building 779, previously used for research and development of pnlcesses for

handling special nuclear materials, is to be a pilot project for deactivation of other highhazard buildings. Deactivation, which is expected to last abo'ut three years, is presently

under way with removal ofspecial nuclear materials and remaining chemicals. Deactivation

and decommissioning will overlap, with dismantlement of process equipment due to begin in

March 1997.

2.3.2 Hanford Site

Deactivation of the Uranium Trioxide (UO,) Facility. The UO, Facility was

formerly used to convert uranyl nitrate hexahydrate solution from the PUREX Plant into UO,

powder. The facility's last operating campaign was completed in June 1993, after which

deactivation began immediately.

Deactivation ofthe UO, Facility is intended to establish a passively safe and

environmentally secure configuration and to preserve that configuration for up to ten years.

DOE considers the project to be completed. Currently, the plant is unoccupied and contains

no portable equipment or furniture. Nearly all radioactive or hazardous materials have been

removed. Only minimal effort is required for surveillance and maintenance activities. All

process equipment, instrumentation, and systems for heating, ventilation, and air

conditioning have been shut down. The building doors lind gates in the perimeter fence are

locked to limit access. The facility is entered only to conduct quarterly surveillance visits or

to correct deficiencies identified during previous surveillance entries.

The Board completed a review ofthe authorization basis for the UO, Facility

applicable during this period ofthe facility's life cycle and found that for the near term, the

2-24
existing framework ofimplementation and safety management provides adequate protection

for workers, the public, and the environment. However, the environmental restoration

contractor has not demonstrated that long-tenn surveillance and maintenance activities will

provide the same level ofprotection. Furthennore, the ability to plan adequately for and

manage an emergency situation has not been demonstrated.

The PUREX Facility and tlte D-Plant. The PUREX Facility processed irradiated

fuel from the Hanford production reactors for the recovery of plutonium and uranium

between 1956 and 1972. It was restarted in 1983 and continued to operate until 1990. The

B-Plant had several functions during its 50-year life, the most rccent ofwhich was the

removal of cesium and strontium from high·level radioactive waste.

DOE intends for PUREX to follow a deactivation process similar to that used at the

VO) Facility. The deactivation ofPUREX neared completion during 1996, and DOE expects

completion by early 1997. Deactivation ofthe B-Plant is scheduled to begin during 1997,

following the model developed for the VO) and PUREX facilities (see Section 2.4.4).

Tlte C-Reactor. The C-Reactor is a surplus production reactor originally scheduled

to be the first of eight to be dismantled at the Hanford Site. In lieu of dismantling, DOE now

intends to place the C-Reactor in a cocoon for a period of up to 75 years before

dismantlement is completed.

C-Reactor cocooning consists of demolishing and removing or burying all the

structures and the fuel pool, with the exception ofthe walls immediately surrounding the

graphite reactor block. The reactor block and walls are then to be sealed and capped for the

long tenn.

DOE expects that this method will provide a safe storage mode during this extended

period and reduce the risks and costs of prolonged maintenance. In addition, DOE believes

that the use of a cocoon could demonstrate technology improvements with the potential to

reduce cost, improve safety, and lessen environmental liabilities within the DOE complex.

Technologies developed at the C-Reactor could be transferred quickly to other Hanford

facilities, where similar reactors and dozens of other large facilities require action, as well as

to facilities elsewhere in the defense complex.

lOS-N Basin Cleanout. The N-Reactor is a surplus dual-purpose production reactor

that operated from 1963 through 1987. The 105-N Basin contained irradiated fuel

assemblies discharged from the N-Reactor during its operating lifetime. In 1989, the reactor

was completely defueled, and all remaining spent fuel was removed from the basin. Debris

removal began in 1995 and currently continues. Debris remaining in the basin includes

highly radioactive hardware (greater than 1 rad per hour on contact) that was irradiated in the

reactor, basin sediment, and basin water.

The Board staff observed basin c1eanout activities during 1996 and reviewed

applicable safety documentation. These reviews, as well as assessments completed by DOE

2-25
and other independent reviews, identified weaknesses in the contractor's safety

documentation. Hazard and safety analyses made assumptions that could not be fully

supported, and the adequacy of protective measures in place was questionable.

Subsequently, the contractor reverified and formalized its safety controls under the scrutiny

ofDOE. The Board continues to monitor these activities as the contractor upgrades safety

documentation and continues I05-N Basin c1eanout.

2.4 ACTIVITIES RELATED TO DESIGN, CONSTRUCTION, AND INITIAL

OPERATIONS

While the overall budget and manpower ofthe DOE defense nuclear complex are

shrinking, there are still several large construction projects under way or in advanced

planning stages. In some cases, new facilities are needea to ensure the safety and reliability

of existing nuclear weapons and to provide component testing capabilities in the absence of

future underground nuclear testing. Other new facilities are needed to stabilize and store

large quantities of high-level nuclear waste, plutonium, and other hazardous legacies ofthe

production of nuclear weapons.

The Board's statutory mission includes responsibility for reviewing the design of new

defense nuclear facilities, monitoring the construction of new facilities, and making health

and safety recommendations to the SecretalY ofEnergy related to new construction. This

obligation applies not only to altogether new, free-standing facilities, such as the Actinide

Packaging and Storage Facility at the Savannah River Site (described below), but also to

substantial modifications of existing facilities. In many cases, ambitious remodeling of old

facilities, such as the Chemistry and Metallurgy Research Building at Los Alamos National

Laboratory and Building 371 at Rocky Flats, will be more difficult technically than

construction of completely new buildings.

2.4.1 Savannah River Site

In-Tank Precipitation (ITP) Facility.· The ITP Facility is a pretreatment facility

used to concentrate and remove radioactive fission products from high-level waste liquids.

The separated fission products will be processed at the Defense Waste Processing,l'acility.

The decontaminated liquids are to be processed at the Saltstone Facility.

In the ITP process, tetraphenylborate is added to the contents of a waste storage tank,

causing cesium and certain other fission products to precipitate out ofthe liquid waste.

During the process, chemical and radiolytic decomposition ofthe tetraphenylborate occurs,

liberating substantial quantities of highly flammable benzene. Test results suggest that the

precipitated cesium and potassium tetraphenylborate solids, as well as the

excess tetraphenylborate in solution, may also be vulnerable to rapid decomposition by

catalytic attack. Ifthe precipitated solids should decompose, the resulting benzene release

could be very large indeed. Such an event would pose a major flammability hazard.

2-26
This potential hazard was a key factor in the'Board's decision to issue

Recommendation 96-1, In-Tank Precipitation System, Savannah River Site, in August 1996.

The Board strongly urged DOE not to proceed with large-scale process testing in the ITP

Facility until the mechanisms by which flammable gases are generated, retained, and

released in the ITP process are better understood, and appropriate safety measures to prevent

a deflagration are in place.

The Board's review ofthe safety basis for ITP disclosed further that the maximum

percentage of oxygen permitted in the vapor space in the tank was inadequately justified.

The tank involved (Tank 48) has an inerting system intended to keep the percentage of

oxygen in the vapor space below the minimum concentration required to support combustion.

However, the percentage of oxygen required for combustion varies for different admixtures

of gases, and the safety evaluation for ITP did not show whether the chosen oxygen limit was

appropriate for the gas compositions that could exist in Tank 48. When informed ofthis

problem, Savannah River Site personnel performed additional calculations to justifY the

limit, updated the safety evaluation, and added a new control on tank operations to prevent

hydrogen from accumulating to a concentration that would invalidate the new analysis.

The output from the ITP Facility will eventually serve as another feed stream to the

Defense Waste Processing Facility, where high-lever waste is vitrified. The latter facility is

currently operating and has enough feed material to operate for several years before the

output from ITP will be needed.

The Board regards process safety at ITP as one ofthe highest-priority issues in the

complex. The combination of benzene and high-level waste being created at ITP is a unique

hazard that will need to be carefully analyzed and controlled, and the potential problem has

not yet been fully resolved. The Board is closely monitoring DOE's efforts to characterize

lTP's chemical process to ensure that sufficient understanding is developed to suppoli safe

operations. The Board is also carefully evaluating safety systems being developed for ITP to

ensure that process controls are adequate, and that preventive and mitigative controls will

protect facility workers and the public from undue risk.

Actinide Packaging and Storage Facility. A new Actinide Packaging and Storage

Facility is to be constructed at the Savannah River Site. This new facility will be required to

meet the storage standard for plutonium metal and oxide discussed in Section 2.2.2. It will

incorporate plutonium stabilization and packaging equipment, along with sufficient vault

space to permit extended interim storage ofthe site's plutonium. In a recent Record of

Decision, DOE stated its intention to store up to 10 metric tons ofsurplus plutonium in the

expanded Actinide Packaging and Storage Facility. This facility will also store plutonium

from the Rocky Flats Environmental Technology Site, as well as material already at the

Savannah River Site.

Conceptual design documentation for the facility was completed during 1996;

detailed design will begin in the second quarter of 1997. Construction is scheduled to start at

the end of 1998 and to be completed by 200 I. During 1996, the Board staffreviewed the

2-27
safety aspects ofthe conceptual design documentation; safety aspects ofthe detailed design

will be reviewed during 1997.

2.4.2 Rocky Flats Environmental Technology Site

In 1993, DOE fonnulated plans for the consolidated storage ofspecial nuclear

material in Building 371 at the Rocky Flats Environmental Te<:hnology Site. The Board

reviewed the design ofthe building, including its capacity to withstand external forces from

natural phenomena (e.g., earthquakes and high winds). Based on its reviews, the Board

concluded that activities to prepare Building 371 for an extended storage mission were

neither logical nor sufficiently broad in scope to ensure protection ofthe health and safety of

the public and workers since, in due course, Building 371 will contain a large part ofDOE's

supply of plutonium.

In Recommendation 94-3, Rocky Flats Plutonium Storage, the Board urged DOE to

use systems engineering methods in the development of an integrated plan for addressing the

civil engineering, structural, and seismic safety issues and evaluations related to the planned

use ofBuilding 371. In October 1995, DOE completed an analysis which determined that

the building could be made structurally adequate provided several structural upgrades were

perfonned. In September 1996, the Board accepted an integrated program plan that requires

the completion ofrequired upgrades to those structures, systems, and components which

provide safety functions; the development of a safety management program; and the

initiation of actions toward DOE's preferred alternative of constructing an interim storage

vault in lieu of using Building 371. In late 1996, the structural upgrades were designed and

installed, thus making the building structurally adequate for the interim storage mission.

2.4.3 Los Alamos National Laboratory

Capability Maintenance and Improvcmcnt Project and Upgradcs to Technical

Area-55 and the Chemistry and Metallurgy Rcsearch Building. The objectives ofthe

Capability Maintenance Improvement Project are to (I) improve the capability to carry out

current missions by maintaining and improving facilities and (2) develop the capacity for

limited-scale manufacturing of plutonium pits for nuclear weapons. The project involves

Technical Area-55 (TA-55), the Chemistry and Metallurgy Research Building, ancLsome

non-nuclear facilities and infrastucture. The cost ofthe program is expected to be about

$360 million. The conceptual design report is expected to be completed in early 1997. The

Board has conducted an initial review ofthe Capability Maintenance and Improvement

Project and the planned upgrades to the Chemistry and Metallurgy Research Building to

identify any safety-related issues. The need to specify more clearly the roles and

responsibilities at the Los Alamos National Laboratory was highlighted to laboratory

management. Also, since some assumed scenarios regarding safeguards and security have

the potential to affect safety within nuclear facilities, the importance of clarifying

requirements for safeguards and security early in the design process was noted.

2-28
E

..

Upgrades to the Nuclear Materials Storage Facility at Technical Area-55. The

Nuclear Materials Storage Facility is to be upgraded and used for storage ofspecial nuclear

material needed at the Los Alamos National Laboratory. To date, no special nuclear material

has been stored at the facility, and major modifications are needed to make the facility

usable. In its review ofthe conceptual design for the upgrades to the facility, the Board

identified several issues, including potentially out-of-specification placement ofreinforcing

steel in the concrete walls. As a result ofthis review, cognizant personnel at the laboratory

have developed a plan to resolve the flawed conditions. Replacement ofsome structural

members may be required.

Integrated Safety Management and Authorization Basis. The Board has reviewed

the Los Alamos National Laboratory's progress in developing an integrated safety

management system for TA-55 and has had a number ofinformal discussions in this regard

with laboratory management. Technical management approaches to reviewing proposed

activities, including analyses of process hazards, continue to be reviewed. TA-55

management has been encouraged to place increased emphasis on risk reduction. In addition,

specific issues related to safety management have been evaluated. For example, the Board

staff noted that the laboratory does not have an adequate electrical safety program. The

Board expects such a program to be incorporated into the integrated safety management

system under development. The Board ~taff also identified a need for operating limits related

to degradation ofthe system supplying water for fire suppression.

2.4.4 Hanford Site

In late 1995, DOE began deactivating the B-Plant at the Hanford Site. This facility

was used in several defense production and waste management missions during its 50-year

life, the last being the removal of cesium and strontium from high-level radioactive waste

stored in the Hanford tanks.

The Board's review ofthe B-Plant found that over the lifetime ofthe plant, a large

amount ofradioactive material had been deposited on the operating high-efficiency

particulate air (HEPA) filter in the exhaust ventilation system. The filter unit in use at the

time ofthe Board's evaluation showed signs of degradation due to its age and the resulting

exposure to radiation. A new unit was made available for service after appropriate checkout

and testing. Three previously retired filter units were also heavily contaminated with

radioactive material. Although these three units were isolated by water seals, such seals do

not provide a reliable means for isolating airborne radioactivity.

Although DOE and its contractors had previously discussed retiring the degraded

filter, it remained in service. When the Board pointed out the safety issues involved, which

were documented in a report prepared by the Board staff, DOE removed the filter from

service and placed the new unit in operation. DOE also decided to construct a new exhaust

filter system to bypass the existing system, and to replace the water seals with physical

barriers. These actions significantly reduced the potential for a radiological release to the

environment in the event of a failure ofthe operating exhaust filter unit.

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2.4.5 Gaseous Diffusion Plants at Oak Ridge, Portsmouth, and Paducah

Approximately 50,000 cylinders containing more than 500,000 metric tons of

depleted uranium hexafluoride (UP6) gas from the production of enriched uranium for both

defense and civilian purposes are stored outdoors at gaseous diffusion plants in Oak Ridge,

Tennessee; Portsmouth, Ohio; and Paducah, Kentucky. In early .1995, the Board found that

the corrosion-resistant coatings ofthese cylinders had not been maintained and that many

cylinders were being handled and stored under conditions that could lead to increased

breaching ofthe cylinders. To protect against further cylinder breaches and the resulting

potential for dispersion oflarge amounts ofUF. to the environment, the Board issued

Recommendation 95-1, Improved Safety ofCylinders Containing Depleted Uranium, in May

1995, recommending that DOE address the problem promptly. The Secretary ofEnergy

accepted the Board's recommendation and submitted an acceptable implementation plan in

October 1995.

During 1996, the Board reviewed DOE's progress in implementing Recommendation

95-1, and found that significant actions have been taken to slow the degradation of cylinders.

Substantial progress has been made in several areas, including removing cylinders from

direct ground contact, painting the areas of cylinders most vulnerable to corrosion,

completing design and construction ofseveral new and improved cylinder storage yards, ap.d

establishing a pilot program at the Paducah Gaseous Diffusion Plant to demonstrate a method

for recoating entire cylinders (approximately 1,500 cylinders have been recoated under this

pilot program).

The actions ofDOE in 1996 indicate an understanding ofthe intent of

Recommendation 95-1. While significant action has been taken, more remains to be done,

including the establishment of cylinder coating programs to recoat cylinders in storage at all

three sites. The Board will continue to monitor DOE's progress toward implementation of

Recommendation 95-1.

2.5 ACTIVITIES RELATED TO PLUTONIUM STABILIZATION

In the Board's early years, stabilization of plutonium and other nuclear raW' materials

was not a prominent issue. During the era of active weapons production, plutoniu'm and

other weapons materials were in demand as feed materials. Any plutonium-rich scrap from

weapons fabrication processes was quickly recycled. When older weapons were retired and

disassembled, the plutonium they contained was quickly'reused for the production of new

weapons, Only small amounts of plutonium or plutonium-rich scrap were ever allowed to

remain in storage for more than a few months. This situation changed dramatically starting

in 1989.

DOE shut down weapons production activities at many defense nuclear facilities

during the period from 1989 to 1992. In most ofthose facilities, substantial quantities of

plutonium, uranium, and irradiated fuel were in storage awaiting processing, In many cases,

2-30
the storage configurations were intended to be temporary 'and were not considered safe for

long periods oftime. Plutonium in reactive forms or in temporary, unsealed containers

needed to be converted to stable metallic or oxide forms and placed in durable, sealed

containers. Irradiated fuel needed to be removed from temporary storage in water basins,

and converted to stable forms for long-term storage.,

In order to deal with the wide scope ofthe material instability problem, the Board

issued Recommendation 94-1, Improved Schedulefor Remediation in the Defense Nue/ear

Complex, which called for an aggressive timetable for removing plutonium and irradiated

fuel from temporary storage and placing the materials in stable forms for safe long-term

storage.

The implementation plan for Recommendation 94-1 also calls for stabilization of

solutions containing other actinides. These actinide solutions are chemically unstable and

readily dispersible. Stabilization has required restarting certain processes in older facilities,

as well as installing new processing capability in some other facilities. Tlie Board's close

and continuing attention to facility preparations and stabilization activities and DOE's

response to Recommendation 94-1 have led to the following key accomplishments:

• Operation ofF-Canyon and F.E!-Linc at the Savannah River Site and stabilization

of about 50,000 gallons of plutonium solutions

• Dissolution of approximately 138 metric tons of deteriorated Mark-3) plutonium

targets in F-Canyon for conversion to stable metal in FB-Line

• Expedited preparations for restart ofthe Savannah River Site H-Canyon and

HB-Line to support stabilization of plutonium and neptunium solutions

• Progress in a development program for vitrification ofthe highly radioactive

americium/curium solutions in F-Canyon and the neptunium solutions in

H-Canyon

• Continuation of hydroxide precipitation processing of plutonium solution in

Buildings 771 and 371, startup ofthe Caustic Waste Treatment System, and

preparation for the start of oxalate precipitation processing at the Rocky Flats

Environmental Test Site

• Processing of all higWy enriched uranium solution at the Rocky Flats

Environmental Technology Site

• Development and testing of a prototype vertical calciner at Hanford's Plutonium

Finishing Plant to process plutonium-bearing solutions

2-3\
The following subsections detail activities and issues related to plutonium

stabilization at the Savannah River Site, the Rocky Flats Environmental Technology Site,

and the Hanford Site.

2.5.1 Savannah River Site

In Recommendation 94-1, the Board urged DOE to expedite processing of

deteriorating Mark 16 and Mark 22 aluminum-alloy spent fuel stored in basins at the

Savannah River Site. In its implementation plan for this recommendation, DOE committed

to begin stabilizing the fuel by November 1996. Although DOE had planned to conduct

additional studies ofthe feasibility of dry storage, the Board pointed out problems involved

in pursuing these dry storage plans and identified other rapidly corroding nondefense fuel

that had previously been predicted by DOE to remain stable for another ten years. In an

earlier technical report, the Board had established the technical basis for concluding that

stabilization ofthe fuel by chemical separation is a better alternative. The Board's attention

to this matter contributed to a DOE decision to stabilize this particular spent fuel by

processing it in the Savannah River Site canyon facilities.

The conversion ofthe fuel into more manageable components (i.e., feed for the

Defense Waste Processing Facility and low-enriched uranium) did not begin on the desired

schedule. A delay in processing ofthe material resulted from a DOE and contractor review

ofthe adequacy ofthe seismic analyses ofthe P- and H-Canyons. The Board and its staff

participated in an aggressive review ofthe analytical effort and supported a DOE decision to

resume processing in the P-Canyon. A decision on the adequacy ofthe H-Canyon was

pending at year's end (it has since been determined that the H-Canyon is sufficiently robust

for tlus use). A revised schedule for conversion ofthis fuel is being actively reviewed with

DOE.

2.5.2 Rocky Flats Environmental Technology Site

Minimizing of Explosive Potential. In November 1994, a review by the Board

concluded that certain tanks containing plutonium solutions at the Rocky Flats

Environmental Technology Site might not be adequately vented and that explosive amounts

of hydrogen could be accumulating. This conclusion was substantiated by indepe'ndent

analysis performed by the Board staff in March 1995. At the urging ofthe Board, DOE took

gas samples from several ofthe tanks. These samples confirmed that hydrogen was present

at concentrations up to 15 times the minimum explosive limit. In January 1996, the Board

requested that DOE take more aggressive action to resolve this issue. DOE and the Rocky

Flats contractor then took corrective action to sample and adequately vent the tanks of

concern. Witlun nine months ofthe Board's letter, all 84 tanks had been sampled, and the

19 tanks that had contained excessive concentrations of hydrogen gas had been purged.

DOE is continuing to evaluate further actions needed for piping and other tanks containing

contaminated organic solutions that may also contain hydrogen gas.

2-32
Resumption ofPlutonium Operations. Stabilization of plutonium solutions has

required restarting hydroxide precipitation in Building 771, as well as installing the Caustic

Waste Treatment System in Building 371.

In accordance with the Board's statutory responsibility, plutonium operations in

specific Rocky Flats buildings may not resume until the Board determines to its satisfaction

that DOE's response to identified Board recommendations adequately protects public health

and safety. To fulfill this requirement in this instance, the Board conducted thorough

reviews ofthe design, process hazards, building authorization bases, formality of operations,

and other related topics that support plutonium operations. Before the Board reported

favorably, DOE addressed several safety issues raised by the Board concerning such matters

as worker safety controls, fire protection, and demonstration ofsafety basis implementation.

Hydroxide precipitation ofuranium and plutonium solutions began in November

1996 and should continue through the spring of 1997. The Caustic Waste Treatment System

began operations in December 1996 and will be processing solutions from tanks and pipes

through 1999. The Board has initiated its review ofthe oxalate precipitation process that

will be used to stabilize the remaining high-concentration plutonium solutions in Building

771 starting in late 1997.

Board review and deliberation on resumption of other plutonium operations (e.g.,

stabilization processes for plutonium oxide and solid residues, discussed below) will also be

conducted during 1997.

Stabilization of Plutonium Oxide. In Recommendation 94-1, the Board

recommended that DOE expedite preparations for repackaging plutonium metal in contact

with plastic, and for packaging all plutonium metal and oxide in accordance with the

plutonium storage standard under development at that time (see Section 2.2.2). In addition,

for some time the Board has urged DOE to raise the temperature used in thermal stabilization

of plutonium oxide at Rocky Flats.

Plutonium metal known to have been stored originally in direct contact with plastic

has been repackaged. Subsequently, a few additional packages containing plutonium in

contact with plastic have been identified; as they are discovered, corrective action is being

taken. DOE has designated Rocky Flats as the site for a pilot plutonium stabilization and

repackaging line, which will provide for storage of plutonium metal and oxide in a manner

that complies with the plutonium storage standard. This process line will be delivered soon

and is expected to be operational by next summer. Finally, the Rocky Flats contractor has

been able to raise the thermal stabilization temperature to IOOOQC using existing equipment,

consistent with the plutonium storage standard, and the backlog of plutonium oxide has been

stabilized.

Stabilization of Solid Residues. In 1996, the Board completed an in-depth technical

evaluation ofthe safety risks ofstoring solid materials contaminated with plutonium, and

developed a priority ranking for those materials, referred to collectively as "solid residues,"

2-33
which are now in vented drums at Rocky Flats. Solid residues posing the highest risk

include such items as ion-exchange resins, leaded glovebox gloves, wet combustibles, and

filters. Based on its evaluation, the Board concluded that significant hazards remain.

Early treatment ofion-exchange resins and leadea glovebox gloves was essentially

completed in 1996. The final methods to be used for processing and stabilizing wet

combustible residues are only now under development by DOE. As part ofits response to

Recommendation 94-1, DOE recently conducted detailed studies of alternative methods for

processing ofwet combustibles and other high-risk residues. As a result ofthese studies,

DOE now plans to change its proposed methods for treating solid residues, and that is likely

to delay schedule commitments in the implementation plan for Recommendation 94-1. The

Board continues to follow the development oftrade-offstudies and their effects on the design

of processing systems for solid residue processing systems. The Board has strongly

encouraged DOE to minimize the impact of any such design changes on the schedules for

processing this material, which becomes more hazardous as time passes.

2.5.3 Hanford Site

Plutonium Stabilization. Recommendation 94-1 led to several activities at the

Hanford Site to stabilize, repackage, and store or dispose of plutonium-bearing materials.

Most ofthe plutonium-bearing materials at Hanford are located at the Plutonium Finishing

Plant; many ofthese materials exist as unstable oxides and in other chemical forms unsuited

for long-term storage. The Department's implementation plan for Recommendation 94-1

calls for stabilization of urgent-risk materials by May 1997 and remaining at-risk materials

by May 2002.

In addition to the above, significant stabilization activities at the Plutonium Finishing

Plant during 1996 included the following:

• Completion of characterization ofthe plutonium inventory, which includes six

physical and chemical categories of plutonium-bearing materials. This was done

by x-ray radiography, which identified at-risk containers that were then

repackaged to meet current interim storage criteria.

• Cementation ofseveral kilograms of plutonium-bearing residues that were

collected during facility cleanout and placed in more than 500 polyethylene jars

for disposal.

• Continued operation offurnaces to stabilize plutonium metal and oxides to meet

the thermal stabilization criterion specified by the DOE Standard Criteriafor Safe

Storage ofPlutonium Metals and Oxides, DOE-STD-30 13-94.

The Board and its staff will continue to monitor the stabilization activities at the

Plutonium Finishing Plant throughout 1997 to ensure that adequate progress is made in

reducing the health and safety risks posed by the plutonium-bearing materials at the plant.

2-34
Spent Nuclear Fuel Project for the K-Basins. At the beginning of 1994, DOE

pursued a vaguely defined course of action to resolve the recognized safety issues ofseverely

deteriorated spent fuel stored in leaking basins located next to the Columbia River. DOE had

committed to removing fuel ITom these K-Basins by the end ofthe year 2002, although DOEHeadquarters expressed reservations about the feasibility ofmeeting that completion date. In

early 1994, the Board pointed out the lack ofa technical basis for DOE's planned course of

action and urged DOE to identitY engineering alternatives, the criteria for selecting an

alternative, and the anticipated radiological consequences of proposed actions. In May 1994,

the Bc;>ard issued Recommendation 94-1, specifically recommending that the program be

accelerated to place the deteriorating spent fuel in a stable configuration for interim storage

until an option for ultimate disposition is chosen. As a result ofintense interactions between

DOE and the Board and its technical staff, DOE's implementation plan committed to

initiating fuel removal by the end of 1997 and completing it by December 1999.

The Board was instrumental in steering both the contractor and DOE toward a system

in which all activities associated with the stabilization ofthe fuel in the K-Basins would be

conducted on an integrated project basis. Project engineering studies identified stabilized dry

storage as the best interim storage method for the type offuel stored in the K-Basins.

.Characterization tests for spent fuel and sludge are in progress in hot cell laboratories to

determine the appropriate fuel conditioning processes and the necessary facilities for

stabilization ofthe fuel. Construction started in 1996 on a Canister Storage Building to

provide interim storage for the stabilized fuel.

The Board and its technical staff have continually and aggressively reviewed these

project activities, and have encouraged the timely implementation of consistent design

criteria for the Canister Storage Building. The Board's involvement with these issues

contributed significantly to DOE's development ofa technically sound path forward and an

expedited schedule for resolving the safety and environmental vulnerabilities associated with

the leaking fuel. The Board will continue to encourage timely completion ofthe project

activities as facility design and construction are completed and preparations for operations

intensitY in 1997.

2.6 ACTMTIES RELATED TO WASTE MANAGEMENT

After decades of production of nuclear materials and weapons, DOE is now faced

with the daunting task of cleaning its sites ofradioactive and other hazardous wastes left

behind. The Board considers oversight ofDOE's activities in this regard one ofits highest

priorities. Since the Board's inception, it has made several recommendations to the

Department addressing deficiencies in characterizing, processing, and ultimately disposing of

wastes. These recommendations have a common theme in that they request DOE to

understand the problem fully, and then to take a systematic approach to solving it. DOE's

actions have met with varying degrees ofsuccess. While understanding has improved and

much progress in remediation has been made, significant work must still be done. This work

2-35
will remain a strong focus ofBoard activities in 1997 and well into the future. Several

activities related to these efforts are detailed in the following subsections.

2.6.1 Implementation of Recommendation 94-2

Recommendation 94-2, Coriformance with Safety Standards at DOE Low-Level

Nuclear Waste andDisposal Sites, was issued in September 1994. It called for a complexwide review ofDOE's low-level radioactive waste program to establish the dimensions of

the low-level waste problem and identify suitable corrective actions. DOE's implementation

plan for this recommendation organized overall efforts into six areas: (1) systems

engineering, (2) a complex-wide vulnerability assessment, (3) a study ofDOE's regulatory

structure and process, (4) performance assessments, (5) projections, and (6) research and

development.

Originally, the implementation plan called for all work to be completed by August

1997, with most activities completecj by late 1996. DOE made little initial progress toward

achievement ofthis schedule. In response to prompting'by the Board and recognizing that its

original schedule was overly optimistic, DOE redirected its efforts in late 1995, with the aim

ofreassessing existing commitments and formulating a new strategy that would be more

consistent with available funds and technical resources. This effort culminated in April 1996

with the issuance of a revised implementation'plan, which was subsequently accepted by theBoard.

To date, all deliverables scheduled for completion under the revised plan have been

completed and provided to the Board on schedule. All deliverables reviewed have been

found to be acceptable; however, significant technical issues remain to be resolved. These

include the following:

• Development of a sound technical strategy for reflecting composite radionuclide

source terms, Le., the inventory ofradioactive materials buried at waste sites

• Revision ofDOE Order 5820.2A, Radioactive Waste Management, covering

requirements determined to be necessary as a result ofstudies performed in

accordance with the implementation plan

Overall, after initially misjudging the technical c6mplexity ofimplementing this

recommendation, DOE appears to have successfully changed course and is making progress

in implementing Recommendation 94-2. The Board is following the Department's ongoing

efforts closely to ensure that implementation ofthe recommendation remains consistent with

the Board's intent.

2.6.2 Hanfo.'d High-Level Waste Tank Farms

The Board continues to place high priority on safety problems arising from the

storage of high-level radioactive waste in underground storage tanks at the Hanford Site.

2-36
Safety issues are associated with continued storage, as well as with ultimate remediation of

the waste. The Board has issued several recommendations calling for improved knowledge

ofthe composition ofthe waste, and for better planning and systems engineering in its

retrieval, treatment, and immobilization. .

Recommendation 95-2, Safety Management, called for the development of an

integrated safety management system for DOE facilities. In response, DOE proposed to

implement such a system at a number of priority facilities, including the Hanford tank farms.

In 1996, in fulfillment ofthis commitment, DOE upgraded its safety documentation for the

tank farms by completing and approving a Basis for Interim Operations, which was the first

consolidated safety analysis for the tank farms based on a complete hazard analysis. The

DOE contractor also completed the Final Safety Analysis Report by the end of 1996 and

submitted it to DOE for approval.

Because ofthe uncertainty associated with the tank contents and phenomena

associated with chemical reactions in the tanks, bounding calculations have determined that

several accident types are credible and could result in severe consequences to both the public

and workers. In particular, the risk from potential organic nitrate reactions or flammable gas

deflagrations in the tanks was calculated to be excessive. DOE has yet to provide sound

justification for allowing operations under these conditions. During fiscal years 1997 and

1998, the Board will continue to review DOE's work to resolve this important issue.

2.6.3 Waste Characterization

Recommendation 90-3, Hanford Future Tank Monitoring, first identified issues

related to characterization ofthe Hanford wastes, particularly those containing potentially

explosive ferrocyanide compounds. That recommendation was superseded by

Recommendation 90-7, Safety at Single-Shell Hanford Waste Tanks, which called on DOE to

assign appropriate urgency to studying, characterizing, and monitoring the wastes to ensure

that the potential for an explosive ferrocyanide reaction would be minimized.

Recommendation 93-5, Hanford Waste Tanks Characterization Studies, urged general

acceleration ofthe waste characterization program, with emphasis placed on those tanks

posing the greatest hazards.

In 1996, after some success in accelerating its program ofwaste sampling and

characterization, DOE revised its implementation plan for Recommendation 93-5. The new

plan incorporates the remaining commitments ofRecommendation 90-7. This plan, accepted

by the Board in September, focuses on sampling and characterizing certain high-priority

tanks, intended to provide the greatest amount of useful information for resolving safety

issues. Additional data on characterization are to be gained from historical records, analysis,

and experimentation.

DOE subsequently obtained samples from several ferrocyanide tanks, and performed

theoretical analysis and experiments to determine the ability ofthat waste to sustain a

propagating reaction. From these tests, DOE determined conclusively that the ferrocyanide

2-37
had degraded to relatively inert compounds and that the risk of explosion was negligible.

Therefore, with the Board's concurrence, DOE closed the ferrocyanide safety issue at the end

of 1996. The Board recognized this achievement as a significant milestone and considers

DOE's performance in resolving the ferrocyanide issue a model to be followed in

investigating and ultimately resolving the remaining tank safety issues.

2.6.4 Tank Waste Remediation System

The Tank Waste Remediation System (TWRS) is DOE's conceptualized system for

retrieving, treating, immobilizing, and otherwise preparing for the ultimate disposal ofthe

high-level radioactive wastes stored in tanks at the Hanford Site. As currently conceived, the

system will require the construction and operation of a number ofmajor new facilities, none

ofwhich is yet firm in design. The need for a number of new tanks was identified iil early

studies ofTWRS to facilitate the transfer, stabilization, and treatment of materials from

existing tanks, and to add capacity for anticipated new wastes resulting from deactivation and

cleanup offorrnerly used production facilities.

One ofthese new facilities was the subject ofRecommendation 92-4, Multi-Function

Waste Tank Facility at the Hanford Site. In this recommendation, the Board stressed the

need for a systems engineering approach for the entire TWRS progr~m to ensure that the

Multi-Function Waste Tank Facility design would be closely integrated into the design ofthe

TWRS as a whole and not be developed as an isolated component. DOE's implementation

plan for Recommendation 92-4 did commit to a systems engineering approach for the

TWRS. The plan, however, was never brought to fruition. The Multi-Function Waste Tank

Facility project was canceled. Instead, the entire TWRS program is being restructured.

Under the new strategy for developing the TWRS, DOE is attempting to attract

private industry to finance, build, and operate facilities to treat and process the tank wastes

into a form suitable for long-term disposal. Presumably; under such an arrangement, DOE

would commit to payment per unit ofimmobilized product delivered. In addition, the

Department envisions Nuclear Regulatory Commission licensing of any such facilities

financed, built, and operated by the private sector.

In the first phase ofthis privatization effort, DOE has let two contracts for pilot-scale

facilities that will treat and immobilize the waste from some tanks. The Department has also

funded a series ofstudies and reports to demonstrate the feasibility ofthe project. These

studies are intended to establish the viability ofthe technical approach by developing process

flow sheets and conducting process and product verification tests. During this phase, the

contractors are required to deliver program plans describing to DOE how the environment

and the health and safety ofthe public and workers will be protected during system

operations.

The Board will continue its safety oversight ofthis evolving DOE strategy and ofthe

safety ofthe facilities that result from this arrangement.

2-38
3. ADMlNISTRATIVE MATIERS

3.1 PERSONNEL RECRUITMENT

All ofDecember 31, 1996, the Board had a staff of 101 full-time employees,

including two Site Representatives at the Pantex Plant, near Amarillo, Texas; two Site

Representatives at the Hanford Site, in Richland, Washington; two Site Representatives at

the Rocky Flats Environmental Teclmology Site, near Denver, Colorado; and two Site

Representatives at the Savannah River Site, near Aiken, South Carolina.

The highly technical mission ofthe Board requires staff of very high scientific and

technical caliber with demonstrated competencies in all major aspects of nuclear safety. The

Board's technical staffincludes individuals with extensive backgrounds in nuclear,

mechanical, electrical, chemical, structural, and metallurgical engineering and in physics. As

an indication ofthe Board's technical talent, 20 percent ofthe technical staff hold degrees at

the Ph.D. level, and an additional 66 percent have masters degrees. Most ofthe others, all of

whom are college graduates, are technical interns who are likely to complete their masterslevel programs within the next year. Moreover, almost all technical staffmembers, except

interns, possess practical nuclear experien~e gained from duty in the U.S. Navy's nuclear

propulsion program, the nuclear weapons field, or the civilian reactor industry. Five senior

members ofthe Board staff have law degrees (JD), in addition to degrees in a technical

specialty. Both the Board and its staff include individuals experienced in environmental

impact assessments and regulatory processes.

Staff expertise is supplemented on occasion by outside experts with special technical

knowledge and extensive experience in the areas of plutonium processing, weapons assembly

and disassembly, and other nuclear operations. Since the limited staffsize precludes the

ability to cover all scientific matters by means ofin-house specialists, the Board contracts for

specialized technical expertise as needed. Drawing on the work ofits teclmical staff and

outside experts and utilizing its own considerable specialized knowkdge and capabilities, the

Board has been able to make technical judgments and to serve collectively as author ofits

recommendations and related actions.

Through its technical intern program, the Board has continued to recruit and develop

a select group ofthe nation's top engineering graduates. Currently, eight interns are in

various phases of a three-year training program encompassing formal graduate school

education and on-the-job training. The outstanding academic and on-the-job perfomlance of

the five staff members that have already completed the intern program are proof ofthe

effectiveness ofthese recruitment and selection methods. Board staffing projections include

the recruitment oftwo technical interns in 1997.

3-1
3.2 OFFICIAL SITE VISITS BY BOARD MEMBERS AND STAFF

From the establishment ofthe Board in October '1989 through the end of 1996, the

Board, its staff, and its contractor experts have collectively made 1,033 site visits to DOE's

defense nuclear facilities. In 1996 alone, 163 site visits were made. These visits focused

primarily on selected facilities that both the Board and DOE consider to pose the most

pressing concerns in light ofDOE's mission. Where appropriate, trip reports on staff visits

have been conveyed formally to DOE managers.

During its visits to DOE sites, the Board has reviewed health and safety issues

firsthand and gathered information relevant to its recommendations to the Secretary of

Energy and their implementation.

3.3 PUBLIC INTERACTION WITH THE BOARD

The Board is sensitive to the need for public involvement in and awareness of defense

nuclear safety issues. In its public health and safety reviews, the Board's contacts with the

public are primarily through open hearings and access to the Board's public reading room.

Since 1990, the Board has held 52 public hearings at sites across the nation and in

Washinj:,'ton, D.C. The public reading room'is'open to the public every working day. The

staff has received numerous complimentary letters from 'private citizens, public interest

groups, corporations, and other government agencies.

To assist the public in requesting information, the Board published a Customer

Service Standard in July 1995. This publication catalogs the various public information

services offered by the Board. It was mailed to all groups and individuals on the Board's

mailing list and placed in a new customer service category on our Internet site.

The Board has found public meetings to be very effective tools for encouraging

responsiveness on the part ofDepartment representatives, and for exchanging information

with state and local officials, labor leaders, DOE facility workers, public interest groups, and

area residents. .

..

During 1996, the Board conducted a public hearing near the Savannah River Site to

review the status ofDOE's plans to start up and operate the Defense Waste Processing

Facility. In addition, three public meetings were held at the Board's Washington, D.C.,

offices, at which the Board, its technical staff, and outside experts discussed, among other

topics, the status ofwork in DOE's Standards Based Safety Management Program, as well as

DOE technical personnel issues. In addition to these public meetings, members ofthe Board

staff have provided information briefings to local officiats and public interest groups in the

vicinity ofthe Pantex Plant and the Savannah River, Hanford, and Rocky Flats

Environmental Technology Sites.

3-2
Notices ofsuch public Board meetings are published in the Federal Register and are

mailed to more than 400 organizations and individuals that have requested to be on the

Board's mailing list. In addition, each notice is published three times in several local

newspapers serving the communities near the DOE facility involved, as well as being placed

on the Board's Internet site.

During fiscal year 1996, the Board continued to offer more information to the public

through its Internet site. This electronic library gives the public an opportunity to view a

collection of documents that represent products direCtly related to the Board's mission. The

Board recently added the full text ofeach ofits six previous annual reports to Congress and

expanded its database oftechnical staffreports on trips to DOE defense nuclear facilities. In

addition, the Board's Internet site now has an automated search feature that allows readers to

locate specific words or phrases in all available documents. Electronic access to information

on the Board's health and safety review activities continues to be heavily utilized by the

public, DOE, and its contractors.

In January 1997, the Board's Internet site received a "Four Star Best ofthe Web"

Award from NetGuide, Inc., as one ofthe best sites on the World Wide Web for content,

design, and overall rating. The award is given to only those organizations whose Web sites

meet stringent criteria for overall excell~nce.

3,4 NATIONAL PERFORMANCE REVIEW OBJECTIVES

During the past four years, the President has directed that all executive branch

agencies conduct an in-depth examination oftheir individual legislative mandates and

operations as an integral part of a fundamental rethinking ofwhat the federal government

should do and how it should be done. This program', under the direction ofthe Vice

President, is called the National Performance Review.

The Board believes that as a relatively new agency, not encumbered by years of

bureaucratic rules, regulations, and practices, it has already accomplished many ofthe

streamlining objectives ofthe National Performance Review. At its inception, the Board

recognized the importance of carefully structuring an organization that would avoid layering,

promote empowerment, and encourage timely action. It has built a strong organization based

on the successful implementation ofthe following initiatives.

3.4.1 Starting Without Encumbrances

When it started its operations in November 1989, the Board did not inherit any staff,

organizational structure, or internal regulations governing the conduct of business.

Therefore, it was free to create a lean organization tailored to its specialized scientific and

technical mission, without the encumbrances often associated with traditional government

operations, such as vertical layering, excessive administrative support, and duplication of

3-3
function. The lean structure ofits technical organization enables the Board to use technical

staff members in an optimum way to address each new topic as it arises.

3.4.2 Reducing Regulatory Burdcn

Thc Board's policy on regulations is fully consistent with the Presidcnt's

memorandum on streamlining the bureaucracy. To date, the Board has promulgatcd only

those intcrnal regulations necessary to maintain orderly operations-relatcd to the Frcedom

ofInformation Act, the Privacy Act, the Government in the Sunshine Act, and

Organizational and Consultant Conflicts ofInterest. Moreover, in promulgating these

rcgulations, the Board has written the rules in ways that achieve the statutory purposes

without burdening the Board or the public with inflexibility, or with overly prescriptive

requirements that attcmpt to substitute excessive paperwork for sound judgment.

3.4.3 Excepted Service and Pay for Performance .

The Board successfully argucd for, and subsequently received through legislation and

administrative delegations, the mcans to overcome many ofthe administrative roadblocks

that have traditionally frustrated change in government organizations. Most prominent on

this list ofspecific statutory authorities sought by the Board and ultimately granted by the

Congress is the excepted-selvice personnel authority.

The pay banding and pay for performance concepts recommended in the National

Performance Review have been operational at the Board for morc than four years and have

received favorable review by the General Accounting Office and the Office ofPersonnel

Management. These concepts have proven to be highly effective in hiring technical talent,

holding employees accountable for their performance, and rewarding outstanding'

performance on the job.

3.4.4 "No F.'iIIs" Approach to Operations

From the first day of operation, the Board members have set a standard for having a

"no frills" approach to conducting business. Administrative expenses are carefully reviewed

for absolute necessity before expenditures are allowed. For example, the Board d<l.es not

employ chauffeurs and has no government automobiles for local travel ofBoard members or

staff. It carefully enforces the federal travel regulations, These internal policies have been in

place since the Board's inception with no adverse impact on operations, Internal directives

have been written to give practical and easily understood guidance in the most simplified

manner.

3.4.5 Effective O"ganization Structure

The Board maintains focus on its mission regarding the adequate protection of public

and worker health and safety at DOE defense nuclear facilities, Using a matrix form of

organization, the Board has gained management flexibility and avoided the creation oflayers

3-4
of middle management that could dilute its limited staffresources and thereby impede its

ability to perform health and safety reviews. .

Adopting the philosophy of economies ofscale for obtaining needed administrative

support services, the Board has negotiated Interagency Agreements with the U.S. Nuclear

Regulatory Commission, the Public Health Service, and the General Services Administration

to obtain support for accounting, procurement, personnel, and payroll services. Resources

that would normally be diverted to these administrative functions remain dedicated to the

health and safety mission.

3.4.6 Management Continuity

Under the Board's enabling legislation, the five members are appointed to staggercd

five-year terms on a full-time basis. Thus, the Board has enjoyed management continuity

and has not been subjectcd to the disruption offrequent changes in leadership experienced by

many government agencies. TillS has permitted the Board to provide precise and consistent

direction for the conduct ofits technical mission and major policy issues, as well as a degree

of constancy and stability for DOE's upgrading efforts in safety managcment.

3.4.7 Experienced Leadel'ship

Building an organization from~ts statutory foundation offers a special management

challenge requiring individuals with outstanding planning skills, organization skills, and

detailed knowledge of a wide range offedera! government policies and practices. To meet

this challenge, the Board successfully recruited a small senior management staffwith

demonstrated management experience and proven accomplishments. Using their collective

knowledge of government operations, the Board and its senior management staff planncd and

implemented an organizational structure that maximizes the effectiveness ofthe scientific

and technical resources available and avoids unnecessary layers of managemcnt.

3.4.8 Information Technology

To improve communications with DOE field sites and to reduce travel time and

expenses, the Board installed video teleconferencing equipment at its headquarters location.

The Board has used this technology for the rapid exchange ofinformation during briefing

sessions with multiple DOE field sites on issues that impact the entire weapons complex.

This technology enables the Board's technical staffto receive briefings from DOE and its

contractors with minimal burden to the DOE site staff. During the first five months of

operation, the Board's video teleconferencing facility was used 37 times with 192

participants (some individuals participated in more tnan one conference). Communications

costs for an average session were $.36 per minute. Ifthe Board had purchased airline tickets

for all ofthe staff members participating in these sessions, the cost would have been about

$100,000.

3-5
The Board maintains a high-speed connection to the Internet for all staff members,

which allows technical and administrative staffto communicate via electronic mail with

other federal and state agencies and members ofthe public. Staff members use their desktop

computers to obtain the latest information on events at defense nuclear sites, to review draft

DOE rules and orders, to participate in the exchange ofinformation with professional

societies, to perform research on technical subjects, to access notices and legal decisions, and

to send draft reports to colleagues for review. In addition, technical staff on travel and site

representatives have remote access to the Board's local area network through dial-in

cOlIununications, and can pick up and deposit files, review electronic mail, and communicate

with colleagues at headquarters.

3-6
4. PERFORMANCE GOALS

In its fifth annual report, as required by its enabling statute, the Board reviewed its

first five years' experience, concluding that (1) external oversight ofthe defense nuclear

complex is desirable on a continuing basis; (2) the Board has functioned effectively in

discharging its statutory responsibilities; (3) although some modest increase in the Board's

authority might be worthy of consideration, such changes are likely to be of only marginal

value in terms ofimproving the Board's effectiveness; and (4) formal regulation ofthe

nuclear safety aspects ofDOE's defense nuclear facilities would not be a desirable course of

action for a variety ofreasons, not the least ofwhich is its expense as compared with value

received.

As an independent agency, the Board has demonstrated that it charts its own course,

within the parameters ofits enabling statute, and that it will not be steered by the

organization it oversees into a transition to some other form, structure, or mission. The

Board believes it has been given a clear mandate from Congress to oversee DOE's defense

nuclear complex, and that it has complied with that mandate in a thoroughly competent

manner. Furthermore, the Board is compelled by law to carry out the provisions ofthe

statute that established it.

Changes in emphasis and focus will inevitably occur in the complex, resulting mainly

from the legacy ofthe former weapons production activities. As numerous facilities are

deactivated and decommissioned in the coming decades, the Board expects to oversee their

safe disposition. In addition, it plans to continue to follow closely the safe stabilization and

disposal of plutonium-bearing residues and other materials. Among the Board's highest

priorities will be to help ensure safety in maintenance ofthe weapons stockpile and safe

dismantling of nuclear weapons.

As many DOE activities and programs are brought to a halt, others must be

maintained or will start afresh. To maintain the enduring nuclear weapons stockpile, new

facilities must be designed, constructed, and brought into operation in the next several years,

most specifically for the production oftritium. The Board will follow the work leading to

selection ofthe preferred tritium production technology, and then oversee its design,

construction, testing, and operation. As is the case for all new facilities, the Board intends to

utilize the extensive technical expertise and background it has acquired during the past seven

years to ensure the safety ofthese operations.

A great deal has been written and said in the past several years on the subject of

external regulation ofDOE nuclear facilities. The Board discussed this question briefly in its

sixth annual report and more extensively in its fifth annual report. For the present, the

following observations may be offered.

First, it should be recalled that many aspects ofDOE nuclear facilities are already

subject to external regulation in some form. The Environmental Protection Agency and its

4-1
state counterparts have broad regulatory powers over DOE facilities by virtue ofthe

environmental statutes: the Resource Conservation and Recovery Act (RCRA); the

Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA); the

Clean Air Act; and the Clean Water Act. By Presidential order, DOE must adhere to worker

protection standards set forth in the Occupational Safety and Health Act, and has executed a

Memorandum ofUnderstanding with the Occupational Safety and Health Administration to

study a full transfer ofregulatory powers for worker safety. The Nuclear Regulatory

Commission has regulatory authority over a number ofDOE facilities, including the HighLevel Waste Repository at Yucca Mountain.

Second, the Board has seen no analysis demonstrating that formal regulation ofDOE

defense nuclear facilities (to an extent not already imposed) would result in greater public or

worker safety. Arguments have been put forth that the greater cost offormal regulation can

be justified by increased public confidence and regulatory stability. In the Board's view,

public confidence stems mainly from long-term safety performance, and regulatory stability

does not necessarily follow from a formalized regulatory scheme.

Finally, the Board adheres to the view that each step toward more formal regulation

ofDOE defense nuclear facilities by any federal agency, including the Board, should be

justified in terms of both cost and the impact on national security. Proposals put forth to date

acknowledge these factors, but then appear to brush them aside without thorough analysis.

The Board realizes that tlus issue involves public policy matters that are broader than the

current mission assigned the Board by Congress. However, the Board does have both

expertise and experience pertinent to the subject, and stands ready to make itself available to

those in the Administration and Congress who may elect to deliberate on this subject.

In this context, then, this section sets forth the Board's performance goals with regard

to broad safety issues, evolving technical challenges, long-range goals, near-term objectives,

and site-specific objectives.

4.1 BROAD SAFETY ISSUES

During the coming months, extending through and beyond 1997, the Boar(

anticipates that the nlission ofDOE's weapons complex will continue to undergo transition.

The weapons stockpile programs will,demand continuing attention, even as the legacies of

aging facilities, widespread contamination, and huge inventories of highly toxic and

radioactive waste products and residues from half a century of nuclear weapons production

must be addressed.

In the face ofthese challenges, and as DOE continues to realign itself to

accommodate mandated downsizing, the role of competent, independent external oversight

will become even more demanding. The Board believes firmly that its oversight function is

an indispensable element ofthe overall national effort to cope with the myriad ofsafety

issues at defense nuclear facilities.

4-2
To make the most effective use of available resources, the Board has prioritized its

oversight activities at specific sites primarily on the basis of(1) potential risk to public and

worker health and safety, (2) the effectiveness ofDOE's management ofthose risks, and

(3) timeliness in relation to DOE programmatic or' operational goals and objectives. Ifthe

Board were to learn of an imminent or severe threat to public health and safety at a DOE

facility, it would respond and adjust priorities as necessary. In assessing priorities, the Board

also considers problems brought to its attention by various outside sources, including

members and staff ofthe Congress, the General Accounting Office, workers and their union

representatives, and the public. It should be noted that most ofthe highest-priority nuclear

safety issues involve more than one defense nuclear facility or are complex-wide in scope.

Within this broad context, the Board plans to emphasize the same safety issues it has

identified repeatedly in the past, such as the need to:

• Oversee the continuing dismantlement and storage ofweapons and weapons

components-to help ensure protection ofthe health and safety ofthe public and

the workers involved, and ofthe environment.

• Evaluate proposed upgrades to facilities and processes vital to the stockpile

stewardship and management programs-to ensure their design adequacy and

their safe operation.

• Closely monitor DOE's upgrading of its technical capabilities and expertise and

those ofits contractors-to verifY the effectiveness ofDOE's program for

improving staff qualifications while it seeks to meet demands placed on a

dwindling staff

• Ensure that DOE expedites the processing, packaging, and safe long-term storage

of plutonium-bearing materials-to reduce the risk of unwarranted exposure to

these hazards.

• Review in detail authorization bases prepared by DOE for priority facilities and

activities-to verifY conformance with established principles, including recent

guidance prepared by the Board and its staff

• Monitor the integration ofsafety management of both defense nuclear research

and development activities and weapon assembly, disassembly, and testing

operations-to ensure that both can be accomplished effectively and safely.

• Continue to pay close attention to DOE's program for resolving safety issues

associated with existing inventories of corroding spent fuel in storage pools at

several facilities and with byproduct material from historical defense enrichment

operations-to assist DOE in gaining control ofthese potential and actual sources

ofsignificant contamination and radiological exposure.

4-3
4.2

• Press for safe treatment and disposal of nuclear waste that remains as residues in

buried tanks at former plutonium production sites-to eliminate these sources of

long-term radiological hazard.

• Encourage DOE to continue to improve its radiation protection program-to

reduce the risk of unnecessary worker exposure, as well as potential public

exposure.

• Monitor closely DOE's plarming for work in hazardous and radiological

envirorunents, criteria for release of materials and facilities after cleanup, and

development and evaluation ofindicators ofradiological protection performance

applicable to unique cleanup situations-to ensure adherence to the principles of

the as-Iow-as-reasonably-achievable concept:

• Evaluate DOE's ongoing expedited revision ofits program for development and

promulgation ofrequirements, including orders, rules, standards, guides, and

contract provisions, as well as review DOE's programs for verification of

adherence to those requirements-to ensure that DOE appropriately integrates

these processes.

• Insist that DOE adopt sound systems engineering practices in all its safety-related

projects and programs-to foster the optimum overall management ofthe DOE

safety program.

EVOLVING TECHNICAL CHALLENGES

Teclmical issues at DOE continue to evolve. The combination ofwell-recognized

and long-standing threats to public health and safety and potentially hazardous new activities

presents unique and potentially serious challenges, These include, for example, the need to:

• Operate facilities for short periods to remove and stabilize radioactive or

hazardous materials held up in processing lines and vessels.

• Establish improved storage conditions to minimize corrosion ofspent nuclear fuel

stored in basins that were not designed for long-term use.

• Gain control ofthe existing inventories of chemical and radioactive wastes, which

continue to grow and are bound to become even larger when decontamination and

decommissioning get under way in earnest.

• Surmount technical problems associated with existing high-level radioactive

waste storage tanks.

4-4
• Ensure the safe startup and operation of high-level radioactive waste processing

facilities.

• Ensure that the dismantlement oflarge numbers ofwarheads each year is

conducted safely.

• Design, construct, and operate facilities for storing nuclear materials from

dismantled nuclear weapons.

• Consolidate weapons stockpile stewardship and management functions at a

reduced number ofsites, including upgraded facilities that were previously used

predominantly for research and development.

• Determine possible roles of existing research and development facilities for

limited production missions, and institute as necessary the significant

modifications to traditional laboratory operating practices required to carry out

those roles safely.

• Process and replenish tritium in nuclear weapons retained in service.

The Board is concerned that safety issues associated with these technical challenges,

and others nof yet identified, may be at least as large in number and just as severe as those

encountered during production operations.

4.3 LONG-RANGE GOALS

Within the next five fiscal years, the Board, through its oversight/recommendation

process, will strive to effect within DOE the following improvements to nuclear safety

elements:

• Complete the reconciliation, integration, and upgrading of directives that form the

reference standards base for safety management.

• Firmly institutionalize DOE's program for standards-based safety management of

all its defense nuclear facilities.

• Complete the development and implementation ofintegrated safety management

programs for a prioritized group often operational facilities.

• Complete the development and implementation ofintegrated safety management

programs for at least three shut-down facilities requiring substantial

decontamination as a requisite for safe and cost-effective surveillance and

maintenance while awaiting non-time-critical environmental restoration under

4-5
provisions ofCERCLA or RCM (administered by the Environmental Protection

Agency and the states).

• Across the complex, significantly upgrade hazardous work planning processes

down to the task level, making safety planning an integral part ofthe process.

• Recruit and retain a senior technical core ofDOE personnel with demonstrated

capabilities to manage contractors that are delegated clearly defined safety

responsibilities.

• Effect a substantial strengthening ofDOE's safety management program so that

an orderly transition can be made in which less reliance is placed on the Board

and more on DOE to force needed safety actions.

• Place priority on efforts to ensure safe, reliable operation in those facilities

necessary for DOE to meet the production and dismantlement goals ofthe

national defense program.

4.4 NEAR-TERM OBJECTIVES

During fiscal year 1998, as in fiscal year 1997, the Board intends to continue to place

high priority on oversight objectives for which successful implementation by DOE and its

contractors should result in significant health and safety improvements. Examples are the

following:

• Ensuring that DOE expedites the processing, packaging, and safe long-term

storage of plutonium-bearing materials to reduce the risk of unwarranted

exposures to these hazards.

• Overseeing the development and implementation ofintegrated safety management

programs for ten priority facilities.

• Encouraging safety planning as an integral part of enhanced work planning.

• Overseeing the continuation of dismantlement ofweapons and storage of

weapons components to help ensure protection ofthe health and safety ofthe

public and workers.

• Evaluating DOE's enhanced weapon surveillance processes to anticipate and

resolve potential safety issues resulting from stockpile aging.

• Evaluating proposed upgrades to existing facilities and processes, as well as the

design and construction of new alternative weapon testing facilities vital to the

4-6
stockpile stewardship and management programs, to ensure design adequacy and

safe operation.

• Monitoring closely the upgrading ofthe technical capabilities and expertise of

DOE and its contractors to verifY the effectiveness ofDOE's program for

improving staff qualifications as it seeks to meet demands placed on a dwindling

staff.

• Reviewing authorization bases for priority facilities and activities to verify

conformance with established health and safety principles. including recent

guidance prepared by the Board.

• Reviewing designs for new tritium production facilities to ensure their adequacy

from the point of view ofworker and public safety and protection ofthe

environment.

• Insisting that the safety functions and responsibilities of all DOE organizations

involved be defined and understood.

• Monitoring the integration ofsafety management of both defense nuclear research

and development activities and weapon assembly, disassembly, and testing

operations to ensure that they can be accomplished effectively and safely.

• Continuing to pay close attention to DOE's ongoing program for resolving safety

issues associated with existing inventories of corroding spent fuel in storage pools

at several facilities and with byproduct material from defense enrichment

operations, to assist DOE in gaining control ofthese potential and actual sources

ofsignificant contamination and radiological exposure.

• Encouraging DOE to continue to improve its radiological protection program to

reduce the risk of unnecessary worker exposure, as well as potential public

.exposure.

• Maintaining close scrutiny ofDOE's programs for safe handling and disposition

ofwaste material to help DOE improve its waste management programs.

• Evaluating DOE's ongoing expedited revision ofits program for development and

promulgation ofrequirements, including orders, rules, standards, guides, and

contract provisions, as well as reviewing DOE's programs for verification of

adherence to those requirements, to ensure that DOE appropriately integrates

these processes.

• Evaluating DOE systems engineering practices in all its safety-related projects

and programs. to foster DOE's optimum management ofits safety program.

4-7
4.5 SITE-SPECIFIC ODJECTIVES

The Board has identified specific defense nuclear facilities and activities having high

priority for its oversight attention. Factors influencing the selection ofthese facilities for

priority attention include the severity ofthe hazard, operational intensity, and the expected

lifetime ofthe operation involved. Table 1 presents specific Board oversight actions planned

for each ofthese facilities during fiscal years 1997 and 1998.

4-8
Table 1. Priority Facilities and Activities

FY 1997:

• Oversee the safety ofthe continuing dismantlement ofweapons and weapons components

• Monitor the safety ofDOE's program for surveillance ofnuelear weapons

• Assess the adequacy ofsofety mensures applied to the manufacture of explosive ehorges for nueleor weapons

• Observe DOE's conduct ofspecific nuclear explosive snfely studies

• Assess the adequacy ofDOE's implementalion ofRecommendalion 92·6, involving improvements in the

readiness review process for weapon operations

• Oversee the implementation ofintegrated safety managemenl systems under Recommendation 95-2

• Review the Essential Standards Program

FY 1998:

• Oversee the safety ofthe continuing dismantlement and storage ofweapons and weapons components

• Monitor the safety oCDOE's pl'Ogram for surveillance of nuclear weapons

• Evaluate the inlerfaces belween high-explosives safety and nuclear explosive operations

• Observe DOE's conduct ofspeeifie nuclear explosiv. safety studies

• Oversee the implementation ofintegrated safety management systems under Recommendation 95-2

• Review tile Essential Standards Program

Moderate (at pre,ent):

Plutonium, Uraniun., l'rjtillm

FY 1997:

• Review the safety aspects of design and construelion

• Follow tile development ofthe authorization basis and integrated safety management system

• Monilor preparations for startup

FY 1998:

• Assess the adequacy ofthe final authorization basis and integrated safety management system

• Review the safety aspecls of design and construction

• Observe preparations for startup and the Operational Readiness Review process

Data as of: 01(22/97

4-9
Table 1. Priority Facilities and Activities (Continued)

FY 1997;

• Closely monitor the implementation of contractor and DOE corrective actions identified by assessments in the

areas ofcriticality safety, conduct ofoperations, and training and qualification as specified in the

implementation plan for Recommendation 94- 4

• Monitor the implementation ofintegrated safety management systems under Recommendation 95-2 for

enriched uranium operations; component assembly, disassembly, and evaluation; and nuclear material storage

• Review the Essential Standards Program

• Monitor safety performance under stockpile maintenance

FY 1998:

• Ensure elIeetive completion of corrective actions associated Witil Recommendation 94·4

• Review the implementation ofintegrated safety management systems

• Review the Essential "Standards Program .

• Monitor sarety pcrfomlance under stockpile maintenance

,. ' '.'--:'. ''":;''.

" " ".M"odcrate:

Highly ED:ri~li&nJ~iiji.i~;;·'1fu7rdou., Toxic, and

l!..dioactiver.ia~cria" "

FY 1997:

• Assess ti,e Integrated Safety Management Plan

• Monitor the safety ofrestart activities for the enriched uranium operations in Building 9212 to suppOll

national s~eurity tasking (W87 Life Extension Program)

• Review DOE's plan to process ti,e excess in.process material in Buildings 9212 and 9206

FY 1998;

• Monitor the Operational Readiness Review for enriched uranium operations in Building 9212 and initial

operations

• Monitor progress in processing ti,e in.process material in Buildings 9212 and 9206

4-10
Table 1. Priority Facilities and Activities (Continued)

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FY 1997:

• Monitor the potential safety impacts ofincreased operational tempo in nuclear weapon secondary

dismantlement operations, and review readiness for dismantlement operations On newly retired weapons

systems

• Review the safety aspects of preparations for the weapon life extension program

• Monitor the implementation ofOOE's Enhanced Swveillance Program for potential safety implications

FY 1998:

• Review the authorization bases for Buildings 9402-212E and iniegrated safety management systems

• Continue to review the safety aSpG-clS ofreadiness for dismantlemelll operations on newly retired systems

• Review the safety aspects ofreadiness for additional weapon life extension program activities

• Monitor the OperationafReadiness Review for quality evaluation activities in Building n04,2E and initial

- operations

~4t~~~fu.~:I:;:~1$~t~&±%~tkT~sgi .. :C4:\;;" ,~.••. :\.. I·' . I,. Moderate: :Y:i:Fia'n1!rORNL:·l\?Jlei'ial'\ew"y•. Highly Enriched Uranium; Uranium-233; s;::i;;--,,u,<...-""O;,:::... ,."., - -".....

',~~or!g~i}('),<, . : i.,....;·.:.,,,•.. OperaUo.!'~1 Hazardous, Toxic, and Radioactive Materials

FY 1997:

• Review the safety ofBuilding 3019 as tile uranium-233 national repository

• Oversee the development of a uran.ium storage standard for in-process material, canned subassemblies, and

uraruum-233

FY 1998:

• Continue Board oversight ofthe above activities, as appropriate

!li~II{(4iiil~~f.~;~ffihit~f;j*i,:t:":.:;--" . ,

.••.i··,' ".':.:., . ~,,;:" .:: ..~

Moderate:

~eili!lI'~,!RltleYSt2ta,l\~·or, . ><>.01- lUghly Enriched Uranluin,Depleled Uranium,

i~e!~t;;{f1f!.anlutWT1ii!!.iigs:;· .... Tranlltlon' Hydrogeh Fluoride

FY 1997:

• Review progress on the removal of highly enriched uranium held up in piping and systems in gaseous

diffusion plant equipment

• Review ti,e establishment ofti,e depleted uranium cylinder coating renewal program under Recommendation

95-1

FY 1998:

• Review the construction and loading ofthe depleted uranium cylinder storage yard

4-11
Table 1. Priority Facilities and Activities (Continued)

FY 1997:

• Review integrated safety management systems and their initial implementation at the site level

• Review the adequacy ofseismic design criteria

• Review the Essential Standards Program

FY 1998:

• Review the implementation ofintegrated safety management >)'stems

• Review the Essential Standards Program

FY 1997:

• Review integrated safety management systems. including the adequacy of hazard assessments for research.

development, and demonstration projects

• Review the Advanced Recovery and Integrated Extraction System project for rceovering plutonium from pits

• Review Ole safety aspects ofOle Conceptual Design Report for the Capability Maintenance and Improvement

Project to prepare TA-55 for future pit production

• Continue to review the Nuclear Materials Storage Facility; review the updated preliminary hazards

assessment; begin to review Ole preliminary design

FY 1998:

• Continue to review integrated safety management systems

• Continue to review the Capability Maintenance Improvement Project and related activitiesfor future pit

production

• Conlinue to review the Nuelear Materials Storage Facility (review O,e Preliminary Safety Analysis Report and

the Preliminary Design)

4-12
Table 1. Priority Facilities and Activities (Continued)

FY 1997:

• Review integrated safety management ')lstems. including.the adequacy of hazard assessments for research.

developmcnt. and demonstration projects

• Review the safety aspects ofthe Detailed Dcsign Report for Chemistry and Metallurgy Research Building

upgrades

FY 1998:

• Rcview integrated safcty management systems. including the adequacy of hazard assessments for research.

development. and demonstration projects

• Review the safety aspects ofthe Final Design Report for Chemistry and Metallurgy Research Building

upgrades

• Review preparations for activities related to pit production to ensure safety

",Moderate:

:~ifd.ar Crlildility .

FY 1997:

• Continue to review the adequacy ofimplementation ofsafety measures for criticality controls under

Recommendation 93-2

FY 1998:

• Continue to review the adequacy ofimplementation ofsafety measures for criticality controls under

Recommendation 93·2

~, .~'.~.. ,~" . . .

.>, 'Moderate: "" Trjlfu.~"" ",.

FY 1997:

• Review proposed facility modifications

FY 1998: .

• Review integrated safety management systems. including dIe adequacy of hazard assessments for research.

development. and demonstration projects

4-13

.......
Table 1. Priority Facilities and Activities (Continued)

FY 1997:

• Review the facility design IUld provisions for the safety management program

FY 1998:

• Review readiness for operation

FY 1997:

• Review tlle safety of activitics related to the new defense nuclear mission

FY 1998:

• Review integrated safety management systems, including tl,e adequacy of hazard assessments for research,

development, and demonstration projects

'Moderate:

Trlilu'h', Hlgh:!'norgy

Aeederato.r.neaw . c ..,.,..~'" ».-~ , .. -.-'

FY 1997:

• Review tlle safety aspects oftlle Los Alamos National Laboratory design

FY 1998:

• Conti.nue the design review

4-14
Table 1. Priority Facilities and Activities (Continued)

FY 1997 and FY 1998:

• Monitor ongoing site-wide implementation of provisions for stabilization and disposition ofspecial nuclear

materials under Recommendation 94-1

• Monitor ongoing site-wide implementation of provisions for handling low-level waste under

Recommendation 94-2

• Monitor ongoing site-wide implementation of provisions for standards-based safety management under

Recommendation 95-2

• Negotiate a memorandum ofun~erstanding involving the Board, the state, and the Environmental Protection

Agency

• Continue to review both DOE and contractor implementation of integrated safety management systems,

starting with review of hazard analyses, followed by reviews of Safety Analysis Reports and Technical Safety

RequiremenL, (particularly for the americium-cerium vitrification activity and I-I-Canyon oper.tions)

• Monitor safety aspects ofthe processing of plutonium metal in storage and ofitTadiated fuel and target

assemblies in storage basins

• Review the content and implementation ofsite-wide StanoardslRequirements Identification Documents

...;-.;;.,

. HljJt:

Fis'ion'Product'

FY 1997:

• Review DOE's development oftlle implementation plan for a program to gain understanding ofthe

mechanisms involved in benzene production under Recommendation 96·1

• Closely monitor corrective actions defined by the Recommendation 96-1 implementation plan

• Continue to focus on efforts to understand benzene generation and release mechanisms in the In-Tank

Precipitation process

• Assess the safety ofongoing startup activities and initial operation involving precipitate processing in the

Defense Waste Processing Facility, assuming satisfactory resolution ofbenzcne issues

• Monitor and assess ongoing high-level waste tank farm operations

• Evaluate safety issues associated with startup oftlle Consolidated Incinerator Facility

• Assess and observe activities for closure of high-level waste tanks .

FY 1998:

• Continue to monitor Defense Waste Processing Facility operations, p3l1ieularly during efforts to increase

facility capacity (from 200 to 300 canisters/year)

4-15
Table 1. Priority Facilities and Activities (Continued)

FY 1997:

• Review the transfer ofplutoniwn-239 solutions from H-Canyon to F-Canyon,and the processing ofthese

solutions to oxide in the FE-Line

• Monitor processing ofplutonium-242 solution to oxide in Ole HE-Line

• Review the design, safety analysis, and construction ofthe americium-curium vitrification project

• Monitor thc processing ofirradiated Mark-3l targets to mctal in F-Canyon and FE-Line

• Evaluate O,e operational readiness ofH-Canyon for startup to process highly enriched uranium spent fuel

• Review O,e design, safety analysis, and construction ofmodifications rcquired to process highly enriched

w-aniwn spent fuel in F-Area

• Monitor FE-Line modifications and startup for new characterization, digital radiography, repackaging, and

bagless capabilities for plutonium materials

• Monitor FE-Line operations for processing of plutoniwn scrap metal

FY 1998:

• Review the Integrated Safety Managcment Plan

• Evaluate the operational readiness and monitor operations of americium-curium vitrification

FY 1997:

• Revicw the safety of activities associated with strategic stockpile loadouts

• Assess the adequacy ofsafety measw-cs involved in tritium storage activities

• Monitor DOE's decision-making process regarding potential methods for new tritium production to ensure

Olat suitable safety considerations are taken into account

• Review safety aspects ofthe conceptual and preliminary designs for the selected ne\\, tritium production

technology

• Review Ole conceptual design and Preliminaly Safety Analysis Rep0l1 for Ole new tritium extraction facility

FY 1998:

• Continue to monitor Ole safety ofstrategic stockpile loadouts and tritium storage

• Review O,e safety ofO,e design and construction of an expanded capacity for unloaded reservoirs

• Oversee the safety ofDOE's expwlsion oftritium stockpile surveillance nctivities as these new activities are

developed, approved, and implemcntcd

4-16
Table 1. Priority Facilities and Activities (Continued)

FY 1997:

• Monitor the safety ofthe removal ofdefense-related spent fuel from the basins for processing

• Evaluate the safety/hazards ofMark 16/22 spent fucl transfers to H-Canyon

• Monitor the safety ofllie removal ofconsolidated sludge from L-Basin

• Monitor the vacuum consolidation ofsludge in K-Basin

• Review the DOE-approved Safely Analysis Report for the Receiving Basin for OfT-site Fuel

FY 1998:

• Monitor the safety oflI,e removal ofdefense-related spent fuel from lI,e basins for processing

• Review the safety ofllle continued transfer ofMark 16/22 spent fuel to H-Canyon

• Review the Integrated Safety Management Plan for Iransition to deactivation (except the Receiving Basin for

OfT-site Fuel)

• Monitor lI,e safety ofthe removal of consoli<!ated sludge from K-8asin

Moderllte:

Mi~cd Fission Products,

ActivationJ'rod,itc!, .

FY 1997:

• Review DOE's determination of hazards and thcir potential impact on Jong-tenn surveillance and

maintenance

• Evaluate plans for transition from cold standby to cold shutdown for potential impact on deactivation

• Evaluate the Integrated Safety Management Plan for facility Iransition to deactivation

FY 1998:

• Evaluate IIle Integrated Safcty Manasement Plan for facility Iransition 10 sUlveillance and maintenance status

• Monitor IIle implementation oCthe surveillance and maintenance program

4-17
Table 1. Priority Facilities and Activities (Continued)

FY 1997:

• Review the design and safety analysis for the new Actinide Packaging and Storage Facility

FY 1998:

• Review the safety aspccts of cons\nlelion ofthe new Actinide Packaging and Storage Facility._

.~ ..

......

4-18
Table 1. Priority Facilities and Activities (Continued)

FY 1997:

• Review intennediate and fmal elements ofthe upgraded authorization basis

• Assess tile implementation ofthe integrated safely management system

• Oversee tile ongoing waste characterization program

• Monitor tile ongoing implementation of'ystems engineering

FY 1998:

• Continue to pursue DOE's implementation ofthe integrated safety management system

• Continue to monitor systems engineering practices

• Continue to assess the waste characterization. program and resulting disclosures regarding potential safety

issues

.~.,.:::-::::-: ,>,;;";'

,J'lutonium li·jnl.hing Plant ..,

FY 1997:

Operational

Higb:

Plutonium

• Review ongoing aspects oftile implementation of provisions for stabilization and disposilion ofspecial

nuclear materials unde.. Recommendation 94-1

• Closely monitor plans for treatment of plutoniwn residues

• Oversee preparations for stabilization of plutoniwn solutions

FY 1998:

• Closely scrutinize processing of plutoniwn residues and solutions

4-19
Table 1. Priority Facilities and Activities (Continned)

FY 1997:

• Oversee preparations for the transfer ofdeteriorating spent fuel, stabilization offue1 rods, and cleanup ofthe

basins

• Review the adequacy ofsafety analyses and designs for the new Fuel Retrieval System in the K-B...ins, the

Canister Storage Building, and the Cold Vacuum Dl)'ing Facility

• Monitor thc construction ofthe Fuel Retrieval System, the Canister Storage Building, and thc Cold Vacuum

Dl)'ing Facility

• Review Ule results ofspent fucl and sludge characterization testing for support offuel conditioning

FY 1998:

• Continue oversight offuel transfer, stabilization, and cleanup activities

• Review authorization bases and authorization agreements for the Canister Slorage Building and the Cold

Vacuum Dl)'ing facility

• Monitor the completion of construction and stm1up ofUle Fuel Retrieval System, the Canister Storage

Building, and the Cold Vacuum Dl)'ing Facility .

• Monitor the Operational Readiness Reviews for Ule Fuel ReUieval System, Ule Canister Storage Building,

and the Cold Vacuum Dl)'ing Facility

FY 1997:

• Review authorization bases and safety managemenl plmming

• Assess the adequacy of ventilation systems

• Review the design and integrity of glovcboxes and building roof

• Review the adequacy ofUle design mId operation ofbl'idge cranes

• Review preparations for facility deactivation

• Evaluate readiness for transition to surveillance and maintenance status

FY 1998:

• Monitor the implementation offacility deactivation

• Monitor surveillance and maintenance activities

4-20
Table 1. Priority Facilities and Activities (Continued)

FY 1997:

• Continue to review indicators ofthe long-term integrity of cesium and strontium capsules

• Assess the integrity ofU,e storage pool

• Review the capability to detect and handle a leaking container

• Initiate a review ofthe facility authorization basis

FY 1998:

• Complete Ute review ofthe facility authorization basis

• Continue monitoring ofongoing day-to-day operations

4-21
Table 1. Priority Facilities and Activities (Continued)

FY 1997:

• Assess safety management plans for deinventory activities

• Assess the implementation ofthe upgraded authorization bases

• Assess the adequacy ofthe upgraded authorization bases and U,e Integrated Safety Management Plan

• Review and assess the safety aspects ofthe plan for oxalate precipitation processing

• Evaluate Ule readiness of equipment, personnel, and procedUl'es for stabilization and paekaging

FY 1998:

• Review and assess the safety aspects ofU.e plan for oxalate pl'eeipilation processing, as appl'Opriate

• Evaluate U,e readiness of equipment, personnel, 'lJld procedures for proeessing, as appl'Opriate

• Observe DOE and eontmetor readiness assessments for processing, as appropriate

• Evaluate the Integrated Safety Management Plan for deaetivation

FY 1997:

• Assess Ule adequacy ofthe upgraded authorization bases and the Integrated Safety Management Plan

• Assess the implementation ofthe upgraded auUlorization bases

• Review plans for and assess U,e adequacy and implementation ofsafety upgrades pel' U,e Reconunendation

94-3 Integrated Program Plan

• Assess the adequacy ofUle process selected for processing combustible residues

• Review and evaluate the adequacy ofthe design ofthe interim storage vault

FY 1998:

• Evaluate the readiness of equipment, personnel, nnd procedures for processing of combusliblc residues

• Review and evaluate the adequacy ofthe interim storage vault, as appropriate

• Assess the implementation ofthe upgraded authorization basis

4·22
Table 1. Priority Facilities and Activities (Continued)

FY 1997:

• Assess safety management plans for deinventol)' ofBuilding 776, and deactivation and decommissioning of

Building 779

• Indcpendently asseSs thc adequacy ofthe process sclected for processing ofresidues

• Evaluate tile readincss of equipmcnt, personnel, and procedures for processing ofresidues in Building 707

• Observe DOE and contractor readiness assessmcnts for processing ofresidues

FY 1998:

• Review and assess the deactivation and decommissioning ofBuildings 779 and 776

• Independently assess the adequacy ofthe process selected for pmcessing ofresidues

• Evaluate the readiness of cquipment, personnel, and procedures for processing ofresidues in Building 707

• Observe DOE and contractor readiness assessments for processing ofresidues

FY 1997:

Sbutdown

Mod.erate:

. Highly.Enriehed UraniullI S(>lution, llpecial Nuclear

MM:te.-ial, and Waste

• Review the safety management plans for deactivation and decommissioning ofBuilding 886

FY 1998:

• Continue to review the safety aspects ofthe deactivation and decommissioning ofBuilding 886

4-23.
Table 1. Priority Facilities and Activities (Continued)

FY 1997:

• Review U,e safety aspects offacility upgrades

• Monitor the experiment testing schedule

FY 1998:

• Review facility upgrades

• Monitor the' experiment testing schedule

FY 1997:

• Oversee fuel movements

• Monitor preparations for final disposition of U,e facility

FY 1998:

• Monitor final disposition ofthe facility

FY 1997:

Moderatw

FI..loni~rodud~:YiiWmdjli,il>lUtonium . .'. ~~ , .

. V""''':-!>~,''' . M.l!!leratc:

"'Ji..ionl'rod.,!ct!;;Yt~l1N~!hPIl!IOriiun.

• Review planned seismic upgrades

• Oversee the safety aspects of operation ofthe canning (drying) facility

FY 1998:

• Continue to monitor facility operation

4-24
Table 1. Priority Facilities and Activiti.es (Continued)

• Assess the adequacy oflhe structural analysis ofthe basins

• Review the safety aspects ofthe new fuel rack design

• Oversee the safety ofthe reracking offuel

FY 1998:

• Continue oversight oCtlle safety offuel movements

FY 1997:

• Oversee preparations for startup

• Review the authorization basis

• Monitor the Operational Readiness Review and the safety ofinitial operations

FY 1998:

• Continue to nionitor tlle safety ofoperations

4-25
Table 1. Priority Facilities and Activities (Continued)

FY 1997:

• Review the authorization basis and the Integrated Safety Management Plan

• Review the seismic design ofthe building

• Continue to monitor criticality safety

• Review the safety aspects ofUle heating, ventilation, and air conditioning system

• Monitor the implementation ofRecommend.tion 94-1

FY 1998:

• Continue to monitor the safety of building oper.tions

-·'.Moderate:.

Plutorilum,·Ur~·~~.um

FY 1997:

• Review the ,uUlorization basis and the Integrated Safety Management PI.n

• Monitor the safety of building operations

FY 1998:

• Continue to monitor the safety of building operations

4-26
Table 1. Priority Facilities and Activities (Continued)

FY 1997:

• Review the authorization basis and the Integrated Safety Management Plan

• Monitor the safety ofthe initial subcritieal experiments

FY 1998:

• Monitor the safety of continuing suberitieal experiments

Approaching

Startup

High:

PlutoniumlUraniuUl, High·Ex!'io,ivc,

FY 1997:

• Assess the adequacy of closure of construction issues

• Review the authorization basis and U,e Integrated Safety Management Plan

• Review preparations for the Operational Readiness Review process

• Monitor U,e safety ofthe transition ofoperations from Area 27 to the Device Assembly Facility

4-27
FY 1997:

• Review integrated safety management systems for defense research and development activities developed

under Recommendation 95-2

• Review corrective actions to the radiological protection program in response to recent incidents

FY 1998:

• Review the safety ofreactor operations in Technical Area V

4-28
APPENDlX A. FEDERAL REGISTER NOTICE FOR -

RECOMMENDATION 96-1

A-I
43534 Federal Register I. Vol. 61, No. '165 1 Friday, August 23, 1~96 1 Notices . .

FOR FURTHER INFORMATION CONTACT:

Kenneth M. PuStltcri or Andrew L.

Thibadeau at the address oh'ovo or

telephone (202) 208-6400.

Dated: August 19. 1996.

John T. Conw3.y,

cJlo;nnon.

DEFENSE NUCLEAR FACILITIES

SAFETY BOARD

(Recommendatlon 96-1]

In·Tank Prec(pltatlon System at the

Savannah River Site

AGENCY: Dcfc'nse Nuclear Facilities

Safety Board.

ACTlON: Notice; recommendation.

SUMMARY: The Defense Nuclear

Facilities Safety Board has made a

recommendation to the Secretary of

Energy pU1Suant to 42 U.S.C. 228l;a

concerning the Ifi.¥fank Precipitation

System at the Savaimah River Site. The

Board requests public comments on this

recommendation.

OATES: r..ommcnts. data, viows, or

arguments concerning this

reconunendation arc due On September

23,1996.

ADDRESSES: Send comments, data.

views, Or argwnents concerning this

recommendation to: Defense Nuclear

. Facilities Safely Board. 625 Indiana

Avenue. NW. Suite 700, Washington.

DC 20004--2901.

. exclusively) rather than actual waste!

The first large-scale op,erations with

'actual waste since 1983 were conducted

recently in Tank 48, and they showed'

that the generation and release of

herucne did nOl follow predictions. The

generation of benzene in the waste

under treatment in T8Ilk 48 was

August 14, 1996. unexpectedly rapid. A surpriS~ly large

• The Ocfense Nuclear Fecilities Safety amount oftho henzene remain

b- I captured in the waste, and that henzene

Board (Board) has devoted su stantia was releaSed through action ofmixing

ottention to the planned use of tho In· pumps in tho tank.

Tank Precipitation (ITP)'System ot the The current view ofthe contractor

Savannah River Site, because oHts stoffis that horucne Is produced

importanco to removal of high·level . pri.nl'ipaUy'through catalytic .

radioactivewasta from storage tanks at decomposition ofTPBionsinsolution.

thot Silo, and because certain unique They believo the calJl1ysts are

hazards are ossociated with the ITP potentially both solnblo and insoluble

proocss.· . species, ono of which Is soluble copper The hazards a.ie a consequence of the known to be present in the waste. They

volatile and flammable organic . also helieve that ti,. cesium TPB

compound henzene that is released. precipitate 8Ild the polllssium TPB

during the process in amounts thal must precipitate arc relatively immune to

. not exceed safe limits. The benzene is catalytic decomposition. The contractor

generated through decomposition of. proposes to conduct two Process

teUaphenylborato (TPB) compounds. Verification Tests (PVf), PVf-1 and

These compounds are odded in the PVT-2, to further estoblisb the validity

process with the objective to precipilal~ or these views and to demonstrate the

and remove radioactive ccsiwn from tlccuracy oftho model it has developed

solution in the waste water destined for to predict the rate at which the captured

the saltstone process. The conoontnted benzene is released from solution. PVfslurry containing the precipitated 1 would he porfonned on the

cesium constitutes a much sDlalJer homogenized nuclear waste not in Tank

volume than the original waste, and its '48, which has already heen treated with

feed to the viirification process leads 10 TPB that subsequently has partly

production of 0 correspondingly smoller decomposed with lhe result that sOme

amount of glass ultimately to be cesium has returne<l to solution.

disposed ofin 0 repository. . . Additional TPB would be added to this

The proposed lrooUUent process calls material to reprccipltate that cesium.

for addition of 0 quantity ofTPB in The amount ofTPB to he added would

excess of that tilooretically required to he strictly limited to a sman 8Illounl as

precipitate the cesium tlS oesium TPB. needed to reduce the concentration of

That excess is rcqu.irc:d partly because cesium remaining in solution to a low

: the significant amount of polllssium radiation level ooccptoble for processing

present is also procipitnted as potassium as low level waste in the saltstonc

TPB, and partly hecause OIl excess of process, 8Ild a large part of that solution

TPD in solution ensures more effective would be sent to saltstone. The

scrubbing ofthe radioactivo cesium subsequent proposed experimont. PVTthrough precipitation_ £iowever••!!!e· .2, wiu involve adding to the slurry

benefit of affective scrobblng is remaining in Tank 48 0 large 8Illount of

accompanied by the generntion of the additional untreated wesle and a

henzene, which presents hozards of. substantial quantity of TPB os needed to

different sort. and which also requires precipitate the cesium in this new

safety controls. waste.

Westi.nghouse Savonnal\ River Tbe Board has been infOffilod that the

Company is the Department of Energy primary safety precaution for the

contractor in ChllI"S0 of ITP. The proposed cesium removal activities is to

Westinghouse staff at the Savannah maintain nn i.nert atmosphere in the

IUver Site·believod until recently that headspace of Tan.!< 48. Tbis Is to be oooe

the principal cause of decomposilion of through establishing a sufficient now of

TPB and generation ofbenzcno is nitrogen to tho tank. Two nitrogen feed

exposure of ti,e TPB to the high level of systems are available, a nonna! system

radiation in the waste. That beliof was and a supplemental emergency system.

based on results of full·scale tests The nitrogen systems arc prescnt to

conducted in 1983 that may have been keep the concentration of oxygen below

misinterpreted, and on a decade of the level that would support

subsequent bench~sco.1.le tests using nOn- combustion of the lJcnzenc.

radioactive stimulants (almost WestillehQl..lse staff mombers have
Federal Regisler I Vo1..61. No. 165 I friday, Augusl 23, 1996 ! Notices 43535

poinled. oul that these redundant amount which had bcCn added during

inerting systems provided a .sufficienl the experiment. suggesting thai the

.safety factor for control of 0XY8l'n cesium and potassium Tl'B precipitales

concentration in the h.adspace. They bad elsa partially decomposed.

bave further staled that tho ...Ie of pl'C$umably through catalytic attack. If

buildup of oxygen concentration from the <;<;sium end polassium Tl'B

air ingress Inlo the tank headspaco. if precipitates were subject 10 .rapid and

both inerting syslems ara .xlensive attack by a calalyst. an

simultaneously inop.rable. would be enonmous amount of benzene could be

slow enough to allow reeslablishmenl of g.n....ted. and Ihe ...Ie of release could

nitrogen flow before Ihe bulk vapor in be rnpid enough 10 overwhelm the

T81lk 48 reaches the minimum oxygen removal capability of the purging

concentration that could support system for Tenk 48.

combustion of benzene. 11)e Board concurs with Ihe view that

.Operations since Deoember 1995 . ITP Is ofWgh valuo for subsequenl

indicate thet for the current batch of Vitrification of Ih. nuclel1l' wast. in tho

wasle. mixing pump op.ration increases tanks.t the Savannah River Sile. and

the benzene release rate from the waste that further lestlng is necessar)' to gain

and that turning offthe pumps a better understanding of the science of

essentially stops the release. The Board the process 10 assure safely·during and

has boon inform.ed of the consequenl after precipitation of the Ol1sium. The

bolief that llie actual rale of benzene . Bol1l'd believes thai if il were conducted

release into Ihe lank's headspaoo and its according to the IimilaUons slated

suhsequent removal.can be controlled above. PVT-1 can be run safely 8l1d can

Ihrough managing the action ofthe help in leading to an improved

mixing pumps. This stratagem is to be understarldinl; of tho science and the

followed in the tests 8S a moans of mechanisms involved in the ITP

maintaining the concentration of .

benzene in'the headspace at 8 low p~~s~resenl plan for conduct" ofrVfenough level to provent it from 2 involves new and untested nuclear

becoming flammable even iflhe oxygen waste end a much.lqrOer addition of

concentration were to increase to an '0 u.ndesired lovel. TPD. Furthermore, Iho liquid in Tank

W'e~linghousc ropresentatives also 49. which contains TPB from the

plan to impose a temperature limit for previously mentioned 1983

PVT-1 which is expected 10 prevent demonstration test.. is 10 be used as tlle

decomposition of'tPD Or to reduce ils source of a significanl part of the TPB

rate. Finally, they slate that for PVT-1 to be odded to Tank 48 during PVT-2.

tho addition ofTI'll' will be limited to The Board understands that Tank 49

200 gallons of fresh 0.5 Molar sodium was also Ihe source ofTPD used in the

TPB solution, and that nny subsequent one experiment which led.to an

additions during this experiment would apparent decomposition of precipitated

be subject to review and approval by the 'cesium and potussiwn TPB. Ono vcry

Department of Energy. Westinghouse probable interpretation of thaI anomaly

balieves that this"in tum. would limit is that the material in Tank 49 contain~

the maxirnwn amoWlt of additional ·an Unknown catalyst which can attack

benzene thaI could be produced In .... the precipitoted inaterial and might also

effect. the amount ofTI'll' added·will be increase the rat. of.release of benzene

treated as an Operating Limit. by an amount Ibat IS unpredictable al

The Dopartment and its contractor prescnt. Furthenuore. waste from tanks

have brought substantial expertise 10 nol yellested could contain unknown

bear on understanding the science oflhe constituenls thnl could also adversely

ITP process and the phenomena .affect the rate of production and release

attending it. However, Ihe Board is ofbem.ne.

concerned tl18t some impottant The ~oard beliE:ves that ~e

questions remain lUlanswered, First tho uncertamty in understandmg of lhe

physical basis for holdup of larg.· science of ITI' would make it imprudent

amounts ofbon,...ene in the waste and its .to proceed from PVT-1 to PVT-Z

removal through mixing pump \'\Iithoul substantial improvement in the

operation is not yet well understood. level of lUlderSla..n.ding. Some such

Thorofare. confidence in Ule ability to improvemonllOsy follow interpretation

contrel ilS release is not as high lIS oflhe ""suits of PVT-l. Better

desired. wldorstanding of the anomalous

The Board is also concerned with tho experimaHt sur~estinc dccomposllion of

results of a reCent laboratory-scale TPB precipitates is also required.

experiment USing Tank 48 solution 1lnd Tl1erefore, the Board makes the

TPH additive. the rmmlts from this follOWing reCOllllTIendations:

?xpcrirn?nt indicate that the amount of 1, Conduct of the planlJcd test PVT-2

trw WlllC,.h decomposed exceeded thst should nOl proceed without improved

understondlng of tho mechanisms of

fonnatlon oftho lx:nzono that it wUl genorate,

and the amount and rate of release that may

be encounte:-cd for that benzene. , 2. The edditionallnvestigative eHort

should include rurther work to (a) unCOver'

the roQsOD ro.the apparent decomposition of

precipitated TPD ltithe anomalous

experlmoot. (h) identify the important

catalysts Ihat wl1l bo (lncounterod in the

course of liP. end develop quantitative unde~tanding of the action of these Catalysts.

(e) establish. conviocingly. the chernlco.iand . physial mechanisms that detennlne how

aud 10 what extent beIl%Cntlls retained hi the

waste slurry. why it is released during'

mixing pump operation. Ilod any additional mcchani~ms that might lead to rapid releosc

of bee""n•••nd (d) afftrm the ad"'luacy of

existing sofety measures or de,vise such

edditions as may be needed.

John i. Conway.

Cha;nnon.

Appendix-Transmittal Lette. to Scetetary of

EMrg)'

DEfENSE NlJUEAR f AOLlTlES SArnTY

BOARD

6ZS Indiana Avenue. NW. Suite 700.

W.'hlngton. D.C. 20004 (202l 2.0-6400

August 14, 1996

The Honorabl'.Ha""i R. O·Leary.

Secrelary 01Energy, 1000 Independence

Avenue. SW. Washington. DC 20565-

1000

Dear Sccre:ary O'Leary: On August 14..

1996. the Defense Nuclear Facilities Safety

Bo:lrd (Board), in eocordance with 42 U.S.C.

2286a(a)(5). unanimously approved

Recomntendation 96-1 which Is (Inclosed fo.

your'COnsideration..Recommendation 96-1

deals with the In-Taul::. Precipitation System

at the Savanrtah River Sito,

42 U,S,C, 2286d(a) rcquires.thc Board, after

receipt by you, to promptly moke tbis

recommendation available to the public in

the Department of Encrgy'~ regional public

.oading room$. Tho Board believes the

recommendation CQnlalns no infonnotlon "which is classified o' otherwise restricted. To th~ extent this l'CCom.meodotion does not

include infonnalion restricted by the

Dcpanment or Energy under the Atomic

Energy Act of 1954. 42 U.S.C. 2161-68. as amended, please arrange to bftve this

recommendation pTQmpt1y placcd on file in

your regional public reading rooms,

The Board will continue to revlew these

prepar.itions for routwe octlvHy III tltO In·

Tank Precipitation System and will 5eek. to

CltSUJe that Board actions do not delay this

important program any more than may be

needed fo!' assurance ofsafety. Should the

Secretary accept the .ecommendation~. the

Goa.d is prepared to allocate priority

resources in the form of D:;:..ard membors and

staff to join in expedited development of {I,

mutually acceptable Implementation Plan.

The Board will publish this

rcc(lI'llJncndatioll in the feder,d Register,

Sincerely,

John -I'. Conway.

ChairmQn.

Elldo~u.e
.43536 Federal Register / Vol-. 61. No. 16S·/·Friday. August 23. 1996 f Notices

·c: Mr. Mark B. Wbltakcr. Jr.

IFR Doc. 96-21164 fUed 8-22-90: 6:45 ami

D1WNQ CODe 3d7D-O'~
APPENDIX B. PROGRESS TOWARD IMPLEMENTING PROVISIONS OF THE

GOVERNMENT PLANNING AND REPORTING ACT OF 1993 (GPRA)

In 1993, Congress enacted, and the President signed, the Government Planning and

Reporting Act (GPRA), which required federal agencies to develop five-year strategic plans

including articulation ofthe agency's mission statement, goals, and proposed mcthods for

achieving those goals. The first ofthcse five-year plans must be submitted by the end of

September 1997. Furthermore, commencing in fiscal year 1999, agencies are required by the

GPRA to submit annual program performance plans to the Office ofManagement and Budget,

establishing target levels of performance for program activities. The GPRA requires that

performance target levels be defined in objective, measurable terms so that actual achievement

can be compared against the targets. Agencies are also required to report annually to the

President and Congress, presenting (I) program achievements compared with targets specified

in the performance plans; and (2) when a target has not been met, an explanation of why, and a

de~cription ofthe actions needed to achieve the unmet goals.

The Board has applied the general principles set forth in the GPRA throughout its

existence. The Board is fortunate in having an enabling statute that is quite specific regarding

Congressional expectations. In each ofits previous annual reports, the Board has reviewed its

understanding ofCongress' guidance (goalsy, and h-as described activities during the preceding

year related to achievement ofthose goals. Thus, in at least a qualitative sense, the Board has

been meeting the reporting requirements ofthe GPRA all along. Nevertheless, the Board has

determined that some adjustments are appropriate to meet specific GPRA provisions. In

particular, steps were taken during 1996 to initiate preparation of a formal five-year strategic

plan that will meet the requirements ofthe GPRA, and to develop suitable, measurable

performance goals.

The Board's initial efforts in this regard have highlighted difficulties arising from the

impact ofthe pelformance of another agency (DOE) on achievement oflegitimate goals for the

Board itself For example, it would be logical for an appropriate agency mission statement for

the Board to include a desired ultimate outcome ofBoard actions along the lines of"... an

absence of adverse health effects on any member ofthe public at large or on any worker at any

defense nuclear facility operated by DOE ...." The Board might achieve superlative

quantitative measures ofits performance against ou/put goals, such as surpassing numeric goals

for man-hours of effort by the Board staff in reviewing DOE activities, or receive outstanding

qualitative assessments by independent outsiders ofthe cogency and clarity of applicable Board

outputs (e.g., Board recommendations). Nevertheless, if performance by DOE or contractor

elements were deficient, leading to undesirable consequences offacility operation, the Board

would not have made acceptable progress toward achieving its mission statement. Conversely,

if, in the face of hypothetical dereliction on the part ofthe Board and its staff, circumstances

combined to result in no adverse health effects associated with DOE or contractor activities at

defense nuclear facilities during a given reporting period, the appearance· of acceptable Board

performance toward achievement ofits "no adverse effects" mission statement would be equally

misleading.

B-1