EIGHTEENTH ANNUAL REPORT

TO CONGRESS

DEFENSE NUCLEAR FACILITIES

SAFETY BOARD

FEBRUARY 2008

A.J . Eggenberger, Chairman

John E. Mansfield, Vice Chairman

Joseph F. Bader

Larry W. Brown

Peter S . Winokur

To the Congress of the United States :

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

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

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

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

nuclear facilities.

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

2007, assesses improvements in the safety of defense nuclear facilities, and identifies remaining

health and safety problems .

Respectfully submitted,

Vice-Chairman

DEFENSE NUCLEAR FACILITIES

SAFETY BOARD

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

(202) 694-7000

February 29, 2008

A .J . Eggenberger

Chairman

osep F . Bader

Member

Peter S . Winokur

Member

PREFACE

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

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

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

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

inform the public . The Board is required to review and evaluate the content and implementation

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

practices, and events relating to system design, construction, operation, and decommissioning of

DOE's defense nuclear facilities . The Board makes recommendations to the Secretary of Energy

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

The Board is also empowered to conduct investigations, issue subpoenas, hold public hearings,

and establish reporting requirements .

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

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

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

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

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

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

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

During 2007, Congress directed the Board to prepare several additional reports . House

Conference Report 109-702 on the John Warner National Defense Authorization Act for Fiscal

Year 2007 (H .R. 5122) directed the Board and DOE to report jointly to the congressional

defense committees on their efforts to improve the timeliness of issue resolution, including

recommendations, if any, for legislation that would strengthen and improve technical oversight

of DOE's nuclear design and operational activities . On July 19, 2007, the Board and DOE issued

a joint report identifying actions to promote (1) identification of safety requirements and

strategies at the conceptual and preliminary design phases of a project to avoid cost increases

and schedule delays, and (2) more effective processes or protocols for the communication to

DOE of issues identified by the Board and for the tracking and management of these issues . The

Board and DOE are working together to accomplish these objectives .

In addition, Congress directed the Board to provide quarterly reports on the status of

significant unresolved technical differences between the Board and DOE on issues concerning

the design and construction of defense nuclear facilities . The Board has provided these quarterly

reports as directed.

The Board is currently evaluating 25 defense nuclear facility design activities with a total

project cost of about $20 billion, including $12 .2 billion for the Hanford Waste Treatment Plant .

The Board believes it is critical that outstanding safety issues associated with defense nuclear

projects need to be resolved early in the design phase .

3

Table of Contents

Executive Summary

Responses to Congressional Direction	 7

Summary of the Board's Accomplishments in 2007	 9

Outstanding Safety Problems of Defense Nuclear Facilities	17

Report to Congress

Section 1 : Introduction	 21

1 .1 Mission	 21

1 .2 Oversight Strategy	 22

1 .3 Strategic Plan	 22

Section 2 : Nuclear Weapons Operations	 25

2 .1 Safe Conduct of Stockpile Management 	 25

2 .1 .1 Pantex Plant	 25

2 .1 .2 Y-12 National Security Complex	 28

2.1 .3 Savannah River Site - Tritium Operations	 29

2.1 .4 Nuclear Material Packaging 	 30

2 .2 Safe Conduct of Stockpile Stewardship 	 30

2.2 .1 Los Alamos National Laboratory	 30

2 .2 .2 Lawrence Livermore National Laboratory 	 32

2 .2 .3 Nevada Test Site	 33

2 .2 .4 Sandia National Laboratories 	 33

Section 3 : Nuclear Materials Processing and Stabilization	 35

3 .1 Stabilization and Storage of Remnant Materials 	 35

3.1 .1 Complex-Wide Program	 35

3.1 .2 Plutonium	 35

3.1 .3 Uranium	 36

3 .2 Stabilization of Spent Nuclear Fuel 	 37

3.2 .1 Hanford Site	 37

3.2 .2 National Spent Nuclear Fuel Program 	 37

3 .3 Waste Management	 37

3.3 .1 High-Level Waste	 37

3.3 .2 Low-Level and Transuranic Waste 	 39

3 .4 Facility Deactivation and Decommissioning 	 41

3 .4 .1 Overview	 41

3 .4 .2 Hanford - Plutonium Finishing Plant	 41

3 .4 .3 Idaho Cleanup Project	 41

Section 4 : Nuclear Facilities Design and Infrastructure	 43

4.1 Introduction	 43

4.2 Safety in Design	 43

4.3 Hanford Site	 44

5
4 .4 Savannah River Site	 45

4 .5 Y-12 National Security Complex 	 47

4 .6 Los Alamos National Laboratory 	 47

4 .7 Idaho Cleanup Project	 48

4 .8 Nevada Test Site	 49

4 .9 Seismic Hazard Analysis	 49

Section 5 : Nuclear Safety Programs and Analysis	 51

5 .1 Federal Oversight	 51

5 .1 .1 Overview	 51

5 .1 .2 Recommendation 2004-1	 51

5 .1 .3 Recommendation 2000-2	 52

5 .1 .4 Activity-Level Work Planning 	 52

5 .2 Health and Safety Directives	 52

5 .2 .1 Improvement of Directives	 52

5 .2 .2 Scope of the Directives System 	 53

5 .2 .3 Integrating Safety Into Design 	 53

5 .2 .4 Hazard Categorization	 54

5 .3 Safety Programs	 54

5 .3 .1 Administrative Controls	 54

5 .3 .2 Active Confinement Systems	 54

5 .3 .3 Software Quality Assurance	 55

5 .3 .4 Risk Assessment Methodologies	 55

5 .3 .5 Criticality Safety	 56

5 .3 .6 Readiness Reviews	 56

5 .3 .7 Justifications for Continuing Operations	 57

5 .3 .8 Recommendation 2007-1	 57

5 .4 Technical Competence	 57

5 .4 .1 Federal	 57

5 .4 .2 Criticality Safety Engineers 	 58

5 .4 .3 Federal Facility Representatives 	 58

Section 6: Public Outreach and Agency Administration 	 59

6.1 Public Hearings	 59

6.2 Responding to Public Requests	 59

6 .3 Electronic Access	 59

6 .4 Inquiries Into Health and Safety Issues	 60

6 .5 Site Representative Activities	 60

6 .6 Human Resources	 60

6 .7 Information Technology and Security 	 61

6 .8 Dispute Resolution Programs	 61

6 .9 Financial Management	 61

Appendices

A. Recommendation 2007-1	 63

B . Recommendations Cited	 67

C . Reporting Requirements	 69

D. Correspondence	 71

6
Responses to Congressional Direction

Joint Board/DOE Report

In the Conference Report for the John Warner National Defense Authorization Act, Fiscal

Year 2007, the conferees noted "their concern regarding the untimely resolution by the

Department of Energy of technical issues raised by the Board ." This concern arose primarily as a

result of significant cost increases and schedule delays due to the untimely resolution of

technical safety issues during the design of the Waste Treatment Plant at the Hanford Site . The

conferees requested that the Board and DOE report jointly on efforts to improve the timeliness of

issue resolution, including recommendations, if any, for legislation that would strengthen and

improve technical oversight of DOE's nuclear design and operational activities .

The report was prepared and delivered to Congress on July 19, 2007 . Legislative changes

were not recommended . The report described actions intended to ensure timely identification and

resolution of technical issues raised by the Board :

•DOE Order 413 .3A, Program and Project Management .for the Acquisition of Capital

Assets, was revised to incorporate elements that should help ensure the early integration

of safety into the design process .

•DOE Manual 413 .3-1, Project Management for the Acquisition of Capital Assets, is

being revised and converted to a series of guides to clarify the requirements of the

associated DOE Order .

• Anew standard, DOE-STD-1189, Integration of Safety into the Design Process, is

being developed to specify safety-related design information required to meet the

requirements of DOE Order 413 .3A.

•DOE and the Board are jointly evaluating the effectiveness of DOE Order 413 .3A and

DOE-STD- 1189 as applied to the Integrated Waste Treatment Unit at the Idaho

National Laboratory and the Uranium Processing Facility at the Y-12 National Security

Complex.

•DOE and the Board have reaffirmed the importance of the Board's ready access to

information as described in the Board's legislation .

• The Board has begun issuing "project letters" early in the design process to apprise

DOE of the status of safety issues raised by the Board .

• DOE and the Board are conducting joint periodic discussions to review the status of

significant unresolved safety issues .
Quarterly Reports

In addition to the joint report, the Board has been providing Congress with quarterly

reports on the status of significant unresolved safety issues at defense nuclear facilities . The

Board issued four quarterly reports covering 2007, discussing activities through the end of

November 2007. Highlighted in the fourth quarterly report (issued February 12, 2008) are two

DOE projects facing particular difficulty : the K-Basin Closure Sludge Treatment Project at the

Hanford Site (Section 4 .3 below) and the Chemistry and Metallurgy Research Replacement

Project at Los Alamos National Laboratory (Section 4 .6 below) . The Board will continue to

provide Congress with information on these projects in forthcoming reports .

8
Summary of the Board's Accomplishments in 2007

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

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

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

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

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

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

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

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

public, workers, and the environment .

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

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

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

concentration : Nuclear Weapons Operations, Nuclear Materials Processing and Stabilization,

Nuclear Facilities Design and Infrastructure, and Nuclear Safety Programs and Analysis .

Nuclear Weapons Operations

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

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

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

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

processing and storage of uranium, plutonium, and tritium ; and research, development,

manufacturing, and testing .

As a result of the Board's efforts during 2007, DOE has taken actions to upgrade the safety

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

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

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

and correcting deficiencies in the safety bases for new and ongoing activities . Specific examples

of safety improvements in weapons operations made by DOE in consequence of the Board's

work are given below . (The "Sections" cited provide additional discussion of the subject matter .)

Pantex Plant (Sec . 2 .1 .1) :

•NNSA gathered subject matter experts from Pantex and the nuclear weapons

laboratories to evaluate and disposition potential lightning protection issues . (Board

letter dated March 30, 2007)

•NNSA improved the quality of procedures for nuclear explosive operations . (Board

letter dated April 24, 2007)

• NNSA completed two of five overdue Nuclear Explosive Safety Master Studies and

developed a schedule for completing the other three . (staff-to-staff meetings)
• NNSA issued a letter clarifying its expectation that facility safety documentation for an

activity being started or restarted be implemented and approved prior to beginning

readiness assessments or reviews . (Board letter dated July 16, 2007)

•NNSA instituted changes in its process to ensure that potential inadequacies in

documented safety analyses are identified and declared in a timely manner . (Board

letter dated July 30, 2007)

• NNSA developed a process to ensure proper closure of post-start findings and a plan

and schedule to close 45 open post-start findings from prior nuclear explosive safety

evaluations . (staff-to-staff meetings)

•NNSA is developing new manuals governing nuclear explosive safety . (staff-to-staff

meetings)

• NNSA required the nuclear weapon design agencies to develop expert elicitation

processes' and committed to assess their adequacy in actual use . (Recommendation 98-

2; Board letter dated May 10, 2007)

Y-12 National Security Complex (Sec . 2 .1 .2) :

•NNSA formed an assessment team and formulated a plan for performing regular

assessments of the safety of continued operations in the aging 9212 Complex . (Board

letter dated March 13, 2007)

•NNSA assigned a project manager and deployed additional resources to evaluate

process systems and equipment to support nuclear criticality safety needs . (staff-to-staff

meetings)

•

NNSA evaluated and is revising engineering protocols to require independent design

reviews for all new nuclear process equipment and safety systems . (staff-to-staff

meetings)

•NNSA improved conduct of operations through additional training on disciplined

operations and conservative decision-making . (staff-to-staff meetings)

• NNSA developed protocols restricting opening legacy material containers in an air

environment (a fire hazard) without first conducting a formal hazard analysis . (staff-tostaff meetings)

•NNSA took actions to reinforce formality of operations in wet chemistry operations,

and to reduce the inventory of uranium-bearing solutions . (staff-to-staff meetings)

' "Expert elicitation" is a formal, highly structured, and well-documented process whereby expert judgments,

usually of multiple experts, are obtained .

1 0
Savannah River Site (Sec . 2 .1 .3) :

•

NNSA instituted changes to invigorate the work of the site's Corrective Action Review

Board for tritium facilities . (staff-to-staff meetings)

Los Alamos National Laboratory (Sec . 2.2 .1) :

•NNSA bolstered efforts to disposition transuranic waste in Area G, particularly

containers with the highest radioactive inventories . (Board letter dated January 18,

2007)

• NNSA took actions to strengthen federal oversight, implement safety programs, and

reduce inventories of plutonium-238 residues . (Board letter dated February 1, 2007 ;

public hearing, December 5, 2007)

•NNSA began an analysis of the risk of continued operations in the 55-year-old

Chemistry and Metallurgy Research facility beyond the previously accepted end-of-life

date of 2010 . (Board letter dated October 23, 2007)

• In response to criticality safety inadequacies, the contractor suspended fissile material

operations throughout the Plutonium Facility and established a process to reassess all

criticality limits . (Board letter dated September 10, 2007 ; staff-to-staff meetings)

•

NNSA committed to reinvigorate integrated nuclear planning to ensure that

infrastructure and services will be adequate for increased pit production . (staff-to-staff

meetings)

Lawrence Livermore National Laboratory (Sec . 2 .2 .2) :

•

NNSA developed controls, implemented a process, and safely dispositioned a legacy

item with unique hazards . (staff-to-staff meetings)

• NNSA is developing a configuration management system for vital safety systems .

(Recommendation 2000-2 ; staff-to-staff meetings)

• NNSA directed increased management attention to operations involving special nuclear

material and developed a formal process to evaluate safety-related events . (staff-to-staff

meetings)

Nevada Test Site (Sec . 2 .2 .3) :

• NNSA is carrying out corrective actions to assure the reliability of vital safety systems

at the Device Assembly Facility . (Board letter dated November 28, 2005 ; staff-to-staff

meetings)

•

NNSA is evaluating the strength of the existing concrete structure for the Device

Assembly Facility and is developing an in situ procedure to characterize the strength of

it
concrete in cracked portions of the facility . (Board letter dated March 18, 2005 ; staffto-staff meetings)

Sandia National Laboratories (Sec. 2.2 .4) :

•

NNSA completed implementation of a safety basis improvement project . (staff-to-staff

meetings)

• NNSA completed near-term actions to correct deficiencies in integrated safety

management. (staff-to-staff meetings)

Nuclear Materials Processing and Stabilization

The Board continued to review the substantial efforts of DOE to stabilize remnant

materials from past nuclear facility operations, packaging and storage of those materials, and

final disposition in approved waste repositories . The Board also monitored DOE's efforts to

decontaminate and decommission retired nuclear facilities . DOE is attempting to stabilize liquid

high-level radioactive wastes, spent nuclear fuel, inactive special nuclear materials (which

include uranium and plutonium), low-level wastes, and transuranic wastes . The Board's reviews

in this area focused on specific issues at individual facilities as well as safety topics with broad

implications across DOE's defense nuclear complex . Specific examples of safety improvements

made by DOE in response to the Board's actions are given below .

Complex-Wide Safety Issues:

•DOE issued a new standard, DOE-STD-5506-2007, Preparation of Safety Basis

Documents for Transuranic (TRU) Waste Facilities, providing guidance for enhanced

and consistent safety controls during transuranic waste retrieval, characterization,

shipping, and disposal operations . (Board letter dated January 29, 2007 ; Sec . 3 .3 .2)

• DOE began consolidation ofplutonium-239 materials by making shipments of these

materials from Hanford and Lawrence Livermore to Savannah River . (staff-to-staff

meetings ; Sec . 3 .1 .1)

•

DOE approved implementation plans for the consolidation and disposition of surplus

plutonium-239 and disposition of uranium-233 . (staff-to-staff meetings ; Sec . 3 .1 .1)

Hanford Site (Sec. 3 .2 .1, 3 .3 .1, 3 .3 .2) :

• DOE completed the transfer of all sludge out of K-East basin, allowing that facility to

undergo deactivation and demolition . Sludge in K-West Basin has been containerized .

(Recommendation 2000-1)

•

DOE conducted several investigations of the radioactive waste spilled from Tank S-102

and began implementation of corrective actions to prevent and mitigate spills . (Site

Representative Weekly Reports)

1 2
Savannah River Site (Sec . 3 .1 .3, 3 .3 .1) :

• DOE completed construction, startup testing, and integration of the Actinide Removal

Process and the Modular Caustic Side Solvent Extraction Unit, which taken together

constitute a pilot facility for salt waste processing . (Recommendation 2001-1)

•

DOE reversed the downward trend in conduct of operations and emergency

preparedness at H-Canyon and strengthened training on a site-wide basis . (Site

Representative Weekly Reports)

•

DOE completed a major revision to the Life-Cycle Liquid Waste Disposition System

Plan. (Recommendation 2001-1)

Oak Ridge National Laboratory (Sec . 3 .1 .3) :

• DOE approved the preliminary design of the U-233 Downblending and Disposition

Project and committed to address the Board's comments on the project's design and

safety basis . (Board letter dated September 14, 2007)

Los Alamos National Laboratory (Sec . 3 .1 .2) :

•

DOE stabilized 50 percent of weapons grade plutonium, 90 percent of non-weapons

grade plutonium, and 50 percent of material in the Recovery Evaluation Process .

(Recommendation 2000-1)

Nuclear Facilities Design and Infrastructure

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

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

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

years, the number of design and construction projects under the Board's jurisdiction has

substantially increased . DOE has undertaken design and construction projects with a projected

total cost of about $20 billion . The Board continues to devote extensive resources to ensure that

safety is integrated early in the design process and that designs for defense nuclear facilities

incorporate multiple layers of safety controls commensurate with the hazards . Specific examples

of safety improvements in design and infrastructure accomplished as a result of the Board's

work are given below .

Hanford Site (Sec. 4 .3) :

•Waste Treatment Plant : DOE completed its seismic borehole project and successfully

validated seismic design ground motion criteria . (Board letter dated October 17, 2005)

•Waste Treatment Plant : DOE developed a sound technical basis to assess hydrogen

hazards ; this technical basis includes new design criteria and administrative controls .

(Board letter dated October 17, 2005)

1 3
• Demonstration Bulk Vitrification Project : DOE improved the confinement strategy for

this facility . (Board letter dated September 7, 2005)

•K-Basin Closure Project : DOE returned the Sludge Treatment Project to the conceptual

design stage . (Board's Quarterly Report to Congress dated February 17, 2007)

Savannah River Site (Sec . 4 .4) :

•Salt Waste Processing Facility: structural design expertise and DOE oversight have

now been brought to bear on the project . Geotechnical requirements have been

finalized, and changes to the structural design and the analysis methodology have been

made. Corrective actions were also taken to address deficiencies in the quality

assurance program . (Board letter dated January 10, 2007)

•

Salt Waste Processing Facility : DOE developed a sound technical basis for determining

hydrogen generation rates and used this basis to construct controls for certain

generation mechanisms . DOE also proposed to test the effects of thermolysis on

hydrogen generation rates . (teleconference, December 12, 2007)

•Container Surveillance and Storage Capability project : nuclear incident monitors will

be incorporated into the design of the project . (Board letter dated January 29, 2007)

Y-12 National Security Complex (Sec . 4.5) :

•Uranium Processing Facility: DOE enhanced safety in design early in the project,

allowing the Board to identify safety concerns with the conceptual design as the design

matured. The Board issued a project letter highlighting its safety concerns ; DOE

committed to resolve each of these concerns . (Board letter dated August 9, 2007)

•

Highly Enriched Uranium Materials Facility : NNSA identified near-term actions to

increase the reliability of the water supply system for fire suppression, and is evaluating

long-term improvements for the system . (Board's Quarterly Report to Congress dated

October 17, 2007)

Idaho Cleanup Project (Sec . 4 .7) :

•Integrated Waste Treatment Unit : DOE increased waste sampling to ensure

radionuclide inventories are conservative and completed investigation of an overtemperature event in the pilot plant's charcoal bed . (Board letter dated Jan . 24, 2007)

•

Integrated Waste Treatment Unit : DOE developed technically sound geotechnical, soilstructure interaction, and structural analyses to ensure that the facility will meet

imposed seismic demands. (staff-to-staff discussions)

1 4
Nuclear Safety Programs and Analysis

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

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

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

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

affecting a variety of defense nuclear facilities . As a result of the Board's efforts during 2007,

DOE has taken actions to strengthen the technical competence of its federal employees, to

establish and implement safety standards, and to improve the effectiveness of confinement

ventilation systems . DOE has also taken measures to enhance the effectiveness of oversight and

integrated safety management. Specific examples of improvements in nuclear safety programs

and analysis made in consequence of the Board's work are given below .

•DOE fully implemented the Central Technical Authorities function, with associated

technical support staff managed by the Chief of Defense Nuclear Safety for NNSA and

the Chief of Nuclear Safety for the remainder of DOE . (Recommendation 2004-1 ;

Sec. 5 .1 .2)

•

DOE created an Integrated Safety Management Champions Council responsible for

reinvigorating this program in the complex . (Recommendation 2004-1 ; Sec . 5 .1 .2)

•

DOE evaluated more than two dozen nuclear facilities' ventilation systems and

identified areas where physical modifications are necessary . (Recommendation 2004-2 ;

Sec . 5 .3 .2)

•DOE has incorporated former facility representatives into its integrated project teams,

with noticeable success for the Highly Enriched Uranium Materials Facility at Y- 12

National Security Complex and the Waste Treatment and Immobilization Plant at

Hanford . (Recommendation 2004-1 ; Sec . 5 .4 .3)

•

DOE strengthened its directives for oversight of complex, high-hazard nuclear

operations and made progress towards implementing new requirements in the complex .

(Recommendation 2004-1 ; Sec . 5 .1 .2)

• DOE developed Integrated Safety Management System Descriptions for each of the

program offices, defining the management system these offices will use to perform

work safely . (Recommendation 2004-1 ; Sec . 5 .1 .2)

•

DOE significantly increased the number of federal personnel who have completed or

are in the process of completing their qualifications under an enhanced Technical

Qualification Program . (Recommendation 2004-1 ; Sec . 5 .4 .1)

•

DOE developed and issued supplemental guidance for DOE-STD-1027-92, Hazard

Categorization and Accident Analysis Techniques .for Compliance with DOE Order

5480.23, Nuclear Safety Analysis Reports, Change Notice 1, to address implementation

issues identified by the Board . (Board letter dated June 26, 2006 ; Sec . 5 .2 .4)

1 5

Outstanding Safety Problems of Defense Nuclear Facilities

Integration of Safety into the Design of New Defense Nuclear Facilities

One of the Board's strategic performance goals is to ensure that new defense nuclear

facilities arc designed and constructed in a manner providing adequate protection of the health

and safety of the workers and the public. For the past several years, the Board has made a

concerted effort to ensure that its review of new design projects focuses on early recognition and

resolution of safety issues .

Beginning in late 2005, the Board initiated a series of public hearings concerning

integration of safety into the design process . The third public hearing, held on March 22, 2007,

addressed early identification of safety issues, communication of issues to DOE, issue

management, and timely resolution and closure . The Board also collected information regarding

the implementation of DOE Order 413 .3 A, Program and Project Management . 1br the

Acquisition of Capital Assets, the development of DOE-STD-1 189, Integration of Safety into the

Design Process, and lessons learned from incorporating safety into the design oftwo major DOE

projects : the Waste Treatment Plant at Hanford and the Chemistry and Metallurgy Research

Replacement Project at Los Alamos .

Consistent with commitments made in a report to Congress prepared jointly by the Board

and DOE (Improving the Identification and Resolution of Safety Issues During the Design and

Construction of DOE Defense Nuclear Facilities, July 19, 2007), quarterly meetings are held

between members of the Board's staff and their DOE counterparts . The Board also maintains a

dialog with senior DOE and NNSA management on a monthly basis to ensure that issues receive

the required senior DOE management attention . The Board has initiated the practice of sending

to DOE a "project letter" identifying from the Board's point of view the safety issues that should

be resolved at various stages of the design . These actions all have the same purpose : to ensure

that DOE's senior decision makers have a clear understanding of the Board's concerns when

projects are reviewed at authorization or critical decisions .

To ensure continued compliance in 2008 and beyond, DOE must implement the revised

directives that were developed as part of the safety-in-design initiative .

Safety-Related Research and Development

In accordance with the implementation plan for Recommendation 2004-1, the Secretary of

Energy directed the Assistant Secretary for Environment, Safety and Health to create an Office

of Nuclear Safety Research and to implement an aggressive nuclear safety research program . By

October 2005, the Office of Nuclear Safety Research had been created with a full time director

and staff. Twenty-three proposals were initially solicited and evaluated by an expert panel .

However, DOE was unable to reprogram funds ; as a result, the Office of Nuclear Safety

Research became temporarily inactive and these initial efforts to establish a nuclear-safety

research program were lost . DOE subsequently revised the implementation plan and shifted

responsibility for management of nuclear safety research to NNSA, effective October 1, 2006 .

Since that time, very little has been accomplished . NNSA has not provided documented evidence

17
of significant efforts to identify its nuclear-safety research needs or to create an office with

specific staff consistent with requirements in its revised implementation plan .

The Board remains steadfast in its belief that research in nuclear safety is essential and

should be carried out by DOE . Such research can be directed at many worthy safety objectives,

among them reducing uncertainties in safety analyses, validating analytical models and methods,

improving operating practices, and advancing the fundamental understanding of nuclear safety

science and technology . DOE has already identified a variety of specific nuclear safety research

projects, thirteen of which are listed below . The Board believes these projects need to be funded

and executed .

1 .Deflagration/Detonation of Hydrogen/Volatile Organic Compounds in Nuclear Waste

Drums, Pipes, and Vessels Containing Nuclear Materials

2 . Fire Hazard and Potential Nuclear Material Damage Ratios, Airborne Release Fractions,

Respirable/Non-Respirable Fractions and Facilities Leak Path Factors in Fire Initiated

Accident Scenarios

3 .Characterizing Overpressurization Failures of 3013 Containers Holding Powder Plutonium

4 . Standardized and Vetted Approach to Analysis of Common Accidents for Nuclear Safety

Analyses

5 . Measurement of Leak Path Factors and Comparison with Nuclear Safety Analysis Toolbox

Code-Predicted Results

6 . Leak Path Factors for Seismically Damaged Reinforced Concrete Structures of Nuclear

Facilities

7 . Long-term Storage of Nuclear Material in Type B Containers

8 . Fire Integrity of Glove Box Vision Panels

9. Tritium Oxidation Fraction During Representative Accident Scenarios

10 . Water Mist Fire Suppression Applications in Nuclear Facilities

11. Effectiveness of Automatic (Fire) Sprinklers in High Bay Areas in Nuclear Facilities

12 . Liquid Nuclear Waste Releases from Tanks and Pipes

13 . Incident Response Times for Fire Emergency Responders to Nuclear Facilities

Reinvigorating Integrated Safety Management

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

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

and from DOE's implementation plan is termed integrated safety management. Integrated safety

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

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

implement a comprehensive set of measures, e .g . engineered and administrative controls, to

protect the public, workers, and the environment from nuclear, chemical, and physical hazards .

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

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

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

achievement . Over the next three years, however, implementation faltered . In Recommendation

2004-1, the Board identified the need to reinvigorate integrated safety management through

technical and operational excellence based on nuclear safety standards subjected to rigorous

1 8
oversight . DOE's implementation plan of June 2005 and its subsequent revision in October 2006

contained three major thrusts, one of which directly addresses integrated safety management .

In 2006, the Board closed Recommendation 95-2 after determining that the

Recommendation 2004-1 implementation plan and the recently-issued Integrated Safety

Management System Manual contain the actions necessary to reinvigorate the program . While

progress was made in 2007, issues remain with various elements of implementation of integrated

safety management, including activity level work planning and control, federal oversight of

contractor work, and the establishment of a viable, safety-related research and development

function . Overseeing DOE's implementation and reinvigoration of integrated safety management

will continue to be a major focus of the Board's work in 2008 .

Safe Retrieval, Handling, and Stabilization of Nuclear Materials

At both Hanford and Savannah River, DOE is responsible for the safe storage and handling

of tens of millions of gallons of high-level waste in tanks that have exceeded their original

design lives . While DOE has taken action to prolong the lives of the tanks, high liquid levels in

the tanks continue to make transfers and treatment operations difficult . Waste spills, such as the

spill at Hanford's Tank S-102 in July 2007, have threatened the safety of workers and the

environment. The investigation of the S-102 spill identified several programmatic deficiencies .

DOE is implementing corrective actions at Hanford and Savannah River to prevent or mitigate

potential future waste leaks or mistransfers .

The Board continues to provide close oversight of DOE's efforts to safely retrieve, treat,

and dispose of high-level wastes, spent fuel sludges, inactive actinides, and transuranic wastes .

Many of these activities present significant programmatic and safety challenges to DOE . For

example, the project to retrieve radioactive sludges from the K-Basins at the Hanford Site has

experienced many delays and cost overruns during the past decade . DOE has isolated the sludge

in containers in K-West Basin to prevent release to the environment but faces new challenges in

safely treating the sludge in a timely fashion .

Until recently, investments in the H-Canyon and HB-Line facilities and supporting

infrastructure were minimized because these facilities were expected to be shut down and

deactivated following the stabilization of hazardous materials detailed in Recommendation 94-1 .

The Board believes an extended mission for these facilities through 2019 is acceptable from the

safety standpoint, provided certain upgrades are made . The Board has encouraged DOE to

expand the focus of facility system health reports from near-term operations to the full

anticipated life cycle . DOE must ensure that adequate funding is provided to cover the cost of

necessary H-Canyon and HB-Line upgrades .

1 9

Report to Congress

1 . Introduction

This Annual Report summarizes the Board's work during calendar year 2007 . Section 1

summarizes the Board's mission, oversight strategy, and strategic plan . Sections 2, 3, 4, and 5

describe progress in the four major areas of the Board's operations : Nuclear Weapons

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

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

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

Board's Recommendation 2007-1, Appendix B lists all recommendations cited in this report,

Appendix C lists all reporting requirements imposed on DOE in 2007, and Appendix D contains

a full list of the Board's 2007 correspondence .

1 .1Mission

The Defense Nuclear Facilities Safety Board is an independent federal agency

established by Congress in 1989 . The Board's mandate under the Atomic Energy Act is safety

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

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

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

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

protects the public, workers, and environment.

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

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

Board is composed of respected experts in the field of nuclear safety . The Board has, in turn,

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

safety .

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

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

Complex in Tennessee, Savannah River Site in South Carolina, Hanford Site in the State of

Washington, and Lawrence Livermore National Laboratory in California (temporarily vacant) .

The site offices provide the Board with a continuous presence and oversight at these locations .

At other locations, the Board maintains safety oversight by means of regular onsite reviews by

members of its technical staff.

During the Board's 18 years of operation, its priorities have evolved with changes in the

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

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

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

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

embodied in this plan .

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1 .2

Oversight Strategy

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

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

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

hazardous operations and complex safety issues, guided by its Strategic Plan and the following

principles :

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

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

the Board is empowered to identify current and potential safety problems and to recommend

solutions, DOE remains responsible for taking actions based on the Board's insights .

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

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

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

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

obtains and maintains the high level of technical expertise essential to the management of

nuclear activities .

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

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

management and workers to safe work planning and performance .

Clear Expectations - Effective safety management demands that safety expectations be

clearly defined and tailored to hazards existing in the workplace . Work instructions that are

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

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

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

smooth transition from facility construction and startup to deactivation and decommissioning to

environmental regulation .

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

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

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

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

operations, it has issued 50 formal recommendations, comprising 225 individual subrecommendations . In that same period of time, the Board has issued 196 reporting requirement

letters and held 96 public hearings .

1 .3Strategic Plan

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

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

2 2
Strategic Plan identifies the serious hazards of handling nuclear weapons and weapons materials,

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

•

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

stored in an unstable state .

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

safety .

• Accidental releases caused by inadequate safety controls, human errors, equipment

malfunctions, chemical reactions, building fires, detonations, and criticality events .

• Natural phenomena such as wildfires, earthquakes, extreme winds, floods, and lightning .

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

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

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

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

explosives in proximity to radioactive material .

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

•Nuclear Weapons Operations : Operations that directly support the nuclear stockpile and

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

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

•

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

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

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

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

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

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

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

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

are developed and implemented by DOE .

2 3

2. Nuclear Weapons Operations

2 .1Safe Conduct of Stockpile Management

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

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

management are discussed in the following subsections .

2 .1 .1 Pantex Plant

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

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

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

retired weapons . In 2007, the Board sought health and safety improvements in areas such as

weapons operations and procedures, the Pantex safety basis, readiness for nuclear explosive

operations, lightning protection, and requirements for the evaluation of weapon response to

external stimuli .

Conduct of Operations . The Board issued a letter in May 2005 identifying deficiencies

in the conduct of nuclear explosive operations at Pantex . In a March 2006 letter, the Board reemphasized the importance of a consistently high degree of formality in the conduct of nuclear

explosive operations . After a followup review in 2007, the Board noted in a letter dated April 23,

2007, that slow but continued improvement had been made to correct deficiencies identified in

the May 2005 letter . However, the Board observed that staffing levels for safety oversight of

nuclear explosive operations have dropped dramatically . The Board also observed a lack of

consistency in the formality of operations among work crews . Since the review, NNSA has

increased the number of safety oversight personnel and will continue to search for personnel

until staffing reaches an acceptable level .

Procedures. In a letter dated April 23, 2007, the Board provided examples of .

inadequacies in technical procedures for nuclear explosive operations at Pantex and noted that

improvements are needed in the process for procedure development, review, validation, and

configuration management . In its letter, the Board requested that NNSA identify specific

measures to improve the quality of technical procedures at Pantex . In response to the Board's

letter, NNSA is taking measures to improve flowdown of safety-related requirements into

procedures, the procedure validation process, and the level of detail in technical procedures .

Safety Basis . In a letter dated July 30, 2007, the Board identified several faults in Pantex

safety basis actions and documentation, including inadequate treatment of beyond-design-basis

accidents, inadequate level of detail in some technical safety requirements, and systematic lack

of timeliness in declaring potential inadequacies and taking corrective actions when new

information is identified . The Board also noted in its letter that NNSA had lost configuration

control of the safety basis . NNSA is addressing the first two issues in the annual updates to the

safety basis . In response to the third issue, NNSA is changing its process for handling emerging

information to ensure that a potential inadequacy in the documented safety analysis will be

declared in a timely manner when appropriate . NNSA admits the loss of configuration control of

the Pantex safety basis and has developed a project plan to remedy the problem .

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W76-1 Startup Activities. In a letter dated July 16, 2007, the Board expressed its

concern regarding NNSA's willingness to deviate from its requirements and typical good

practices in response to growing production demands . Specifically, the readiness activities for

W76-1 operations could not be performed with the expected level of rigor in the time frame

specified by NNSA . The Board pointed out in its letter that both the Nuclear Explosive Safety

Study and the contractor readiness assessment for W76-1 assembly operations were conducted

without an approved safety basis in place . In the case of the Nuclear Explosive Safety Study, the

safety basis is a primary source of information for study participants . For a contractor readiness

assessment, the maturity of the safety basis is an indicator of the level of readiness of the

operation in question . Without an approved safety basis in place, the contractor readiness

assessment for W76-1 assembly operations was used to achieve readiness rather than verify it .

NNSA thereafter issued guidance stating that facility safety documentation for an activity being

started or restarted should be implemented and approved prior to beginning the contractor

readiness review for that activity (Memorandum, Ostendorff to Schoenbauer, "Startup and

Restart of Nuclear Facilities," September 27, 2007) .

W80 Nuclear Explosive Safety Study . The Board evaluated the Nuclear Explosive

Safety Study for W80 disassembly and inspection operations to determine whether effective

corrective actions were taken in response to the Board's July 16, 2007, letter on the W76-1

startup preparations . For the W80, NNSA delayed the commencement of the Nuclear Explosive

Safety Study until all safety documentation was complete and approved, thereby addressing the

central concern in the Board's letter . The Board observed that the W80 disassembly and

inspection operations were well engineered, and the Nuclear Explosive Safety Study report did

not contain any adverse findings. The Board noted, however, that several safety-related concerns

identified by the Nuclear Explosive Safety Study were captured as "deliberation topics" rather

than as findings, resulting in no assurance that corrective actions will be fully implemented .

Lightning Protection . The Board has worked with NNSA for the last several years to

minimize the potential lightning threat to nuclear explosive operations . During this time, NNSA

applied resources to understand and mitigate the potential threat from direct lightning effects .

The Board issued a letter on March 30, 2007, identifying work needed to mitigate the indirect

effects of a lightning strike . NNSA responded by forming the Nuclear Weapons Complex

Lightning Committee to analyze these hazards . The committee's efforts currently are directed

towards establishing appropriate input parameters for a gross analysis of the indirect lightning

threat . Future efforts are expected to refine this analysis by adding more detailed facility

configurations. The committee also plans to analyze the hazard of lightning-induced concrete

spalling and induced voltages on wires used to electrically bond metallic penetrations to facility

rebar .

Quality of Safety-Related Information . Commitment 4.2 .2 in the implementation plan

for Recommendation 98-2 mandates that NNSA issue further guidance on how weapon response

is to be analyzed and documented . NNSA intended to meet this commitment with the issuance of

DOE-NA-STD-3016-2006, Hazard Analysis Reports for Nuclear Explosive Operations . This

standard offers expert elicitation, expert judgment, and peer review processes as means of

improving the quality and consistency of safety-related information provided to Pantex by the

design agencies . The Board issued letters on December 15, 2006, and May 10, 2007, requesting

NNSA's expectations for the implementation of these processes because follow-up reviews by

2 6
the Board found no clear plan . The Board also requested NNSA's plan and criteria for review

and approval of the processes once they have been implemented . In response to the Board's

letters, NNSA held a workshop on July 16, 2007, to clarify its expectation that the design

agencies develop processes for expert elicitation, expert judgment, and peer review by the end of

fiscal year 2007. NNSA has developed criteria for review and approval of these processes and is

currently performing a review of design agencies' procedures .

Nuclear Explosive Safety . In response to a commitment made to the Board in 2005,

NNSA conducted a comprehensive top-down review of its nuclear explosive safety directives to

determine if existing requirements are being implemented effectively, and to propose

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

During 2007, NNSA completed, or nearly completed, implementation of most of the open

recommendations from the top-down review, including the following accomplishments :

•Consolidated Master Study guidance and other requirements from sources such as DOESTD-3015, Nuclear Explosive Safety Evaluation Process, Supplemental Directives,

Technical Business Practices, and Engineering Procedures into draft Manuals 452 .2-1,

Nuclear Explosive Safety Manual, and 452 .2-2, Nuclear Explosive Safety Evaluation

Processes .

•

Accepted the need for expiration dates in Nuclear Explosive Safety Studies .

• Completed a Nuclear Explosive Safety Master Study schedule and finished two of the

five overdue Master Studies in 2007 .

• Developed a process for validation of nuclear explosive safety evaluations and

incorporated it into draft Manual 452.2-2 .

• Developed a process to ensure proper closure of post-start findings, incorporated it into

draft Manual 452 .2-2, and developed a plan and schedule to close the 45 currently open

post-start findings .

•

Revised the nuclear explosive safety change control process for contractor-approved

changes and incorporated it into draft Manual 452 .2-2 .

•Clarified the process for final approval of Nuclear Explosive Safety Study reports and

captured the specific process steps, such as management briefings and concurrence into

draft Manual 452 .2-2 .

Draft Manual 452 .2-2 is currently in the directives comment resolution process . The

Board provided numerous comments on this new directive late in 2007 . Many of the comments

are substantial and resulted from an independent review of the nuclear explosive safety process

begun by the Board in 2007 .

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2.1 .2 Y-12 National Security Complex

The Y-12 National Security Complex is a manufacturing facility located in Oak Ridge,

Tennessee . Stockpile management activities at Y-12 include production, maintenance,

refurbishment, dismantlement, evaluation, and storage of certain components of nuclear

weapons. The Board's most recent efforts to improve safety at Y-12 include the following

operations and projects .

Enriched Uranium Operations . The 9212 Complex at Y-12 is a collection of

superannuated structures built between 1947 and 1958 for processing highly enriched uranium .

NNSA has identified numerous structural deficiencies that prevent the 9212 Complex from

meeting current requirements for Hazard Category 2 nuclear facilities . In addition, other aging

facility components continue to deteriorate and increase operational safety risk . In response to

the Board's letters issued April 20 and November 28, 2005, NNSA attempted to identify facility

improvements necessary to ensure safe operations . These improvements were mainly aimed at

improving operational reliability to achieve reduction in material at risk .

By May 2007, NNSA made some progress by completing structural upgrades to 9818, a

small portion of the 9212 Complex . However, NNSA has not made significant progress in

reducing material inventories or making other needed upgrades .

In a letter dated March 13, 2007, the Board noted that it is likely that the 9212 Complex

will continue to operate for 15 or more years because its replacement is currently in the early

stages of design. However, the current list of necessary facility improvements does not provide

upgrades needed to operate the complex for an extended period . The Board advocated a regimen

of increased vigilance and close observation to regularly assess the physical condition of the

9212 Complex as a means of ensuring reliable and safe operation while the proposed

replacement facility, the Uranium Processing Facility, is being designed and constructed . To this

end, the Board requested an annual report and briefing on the safety of operations at the 9212

Complex . NNSA has formed an assessment team and briefed the Board in October 2007 on its

plans for carrying out these annual assessments .

Conduct of Operations . In late 2006, the Board urged NNSA to consider special action

to achieve consistent, disciplined operations in Y-12's nuclear facilities . In several operational

events, the Board noted a lack of proper adherence to procedures or non-conservative decision

making by operations personnel upon encountering unanticipated conditions . In 2007, NNSA

implemented an improvement initiative that included reinforcement training given by senior

management on disciplined operations and conservative decision making . While overall

improvement was evident in 2007, certain events at Y-12 indicated the need for additional

action . NNSA determined that training on conduct of operations is needed on a periodic basis . At

year's end, NNSA was developing protocols for periodic training .

Operational Configuration Tracking . The Board found that, although facility

operations management at Y- 12 maintains status information for general nuclear facility and

safety systems, other system information (e .g ., tank levels, valve alignments, pending

surveillances) was not tracked and readily available for use by production crew management . In

response, NNSA initiated protocols to track information in certain major systems for chemical

2 8
processing of enriched uranium . Deliberate tracking and use of this information by production

crews has proven beneficial to the planning and execution of day-to-day operations .

Processing of Legacy Materials . In September 2006, a small fire occurred during an

operation at Y-12 to open and inspect in air a container of uranium metal items that had not been

opened in more than 30 years . In 2007, the Board found that corrective actions resulting from the

fire did not provide adequate control of operations to open such legacy containers in a non-inert

atmosphere. In response, NNSA committed to performing a hazard analysis before opening such

legacy containers in an air environment .

Administrative Controls . In a letter dated July 30, 2007, the Board questioned the lack

of safety classification of monitoring and alarm equipment supporting an administrative control

to maintain glovebox oxygen concentration to less than two percent . In response, NNSA issued a

safety evaluation report that called for upgrading the equipment to safety-significant and

completing a design adequacy review . The design adequacy review, completed in November of

2007, contains a recommendation to install a backup power system to improve system reliability .

NNSA has established a compensatory measure (daily functional response test) to ensure system

reliability while plans for a system upgrade arc evaluated .

Conduct of Engineering . In 2005, NNSA discovered that the design of a new vessel for

blending enriched uranium would not prevent a criticality in a water intrusion scenario . A design

change was necessary . In 2006, the Board found that NNSA's corrective actions were

inadequate . NNSA evaluated its engineering protocols in 2007, and at year's end was revising

the protocols to require independent design reviews for all new nuclear process equipment and

safety systems .

Uranium Holdup . In 2006, NNSA discovered problems with detecting and controlling

uranium accumulations in process systems and equipment . To correct these problems, NNSA

undertook a program involving application of appropriate design changes, routine monitoring,

and periodic cleanout . The initial activity under the new program was to review fissile material

activities that rely on holdup surveys ; by late 2007, NNSA had made little progress towards

completing these initial reviews . Following an inquiry from the Board, NNSA designated a

project manager and deployed additional resources to complete these reviews by early 2008 .

New Glovebox Project . The Board reviewed the design and safety basis for the new

glovebox project prior to Critical Decision 3B approval . When complete, this glovebox will

increase worker safety. The Board has found no safety problems in the design or with the initial

operations planned in the glovebox . The Board will continue oversight of construction, startup,

and operation .

2.1 .3 Savannah River Site - Tritium Operations

In 2007 the Board focused primarily on conduct of operations and equipment issues at

the Savannah River's tritium facilities . The Board offered and DOE accepted suggestions for

making the tritium Corrective Action Review Board process more proactive and rigorous . Slow

improvements in conduct of operations were observed during the year.

2 9
2 .1 .4 Nuclear Material Packaging

Recommendation 2005-1 . The Board issued Recommendation 2005-1 to increase

protection for workers involved in the storage and handling of nuclear materials . In 2007, the

Board worked to ensure that DOE developed a manual as part of the recommendation's

implementation. In March of 2007, DOE issued for complex-wide comment a draft of DOE

Manual 441 .1-1, Nuclear Material Packaging Manual ; DOE also issued direction to field offices

to develop schedules and funding plans for implementing the requirements in the draft manual .

The Board provided comments on the manual ; as of December 2007, DOE has not issued the

final document .

2.2

Safe Conduct of Stockpile Stewardship

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

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

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

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

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

engaged in stockpile stewardship are discussed in the following subsections .

2.2 .1 Los Alamos National Laboratory

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

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

activities . Work performed at Los Alamos includes stockpile stewardship activities and

increasingly also involves stockpile management activities, such as pit manufacturing . In 2007,

the Board focused its oversight on institutional safety program improvements, the Chemistry and

Metallurgy Research facility, disposition of transuranic waste, nuclear criticality safety, pit

manufacturing, safety systems, and confinement ventilation .

Safety Improvements . The Board visited Los Alamos in November 2006, and in a

February 1, 2007, letter highlighted key areas requiring action to substantially improve the

laboratory's safety posture. The Board held a public hearing in Los Alamos, New Mexico, on

December 5, 2007, to assess the progress made in these areas . Testimony from NNSA and from

the Board's staff revealed that progress had been made in some areas :

Strengthening federal safety oversight . NNSA was able to fill several critical oversight

positions at the Los Alamos Site Office and is working to reestablish traditional safety oversight

processes in this office . NNSA recognizes that significant challenges remain to strengthen

federal oversight of nuclear safety .

Developing effective institutional safety programs . Manuals and plans to strengthen key

safety programs have been issued; however, progress toward implementation is slow .

Improving safety bases and ensuring the efficacy of safety systems . While a few nuclear

facilities' safety bases were updated this year, many others are still operating with dated safety

bases ranging up to 12 years old . For safety systems, the laboratory continues to struggle to put

3 0
in place the configuration management and other engineering, maintenance, and operations

elements necessary to assure these systems will perform their credited safety functions .

Eliminating known hazards . NNSA has made some progress in dispositioning

high-activity transuranic waste drums as well as plutonium-238 and other actinide residues .

However, more work is needed to complete chemical stabilization of the actinide residues and

support timely disposition of the remaining transuranic waste inventory .

Increasing federal management of new projects . NNSA has enhanced federal oversight

of the Chemistry and Metallurgy Research Building Replacement project . This project and

several others are essential to the expanded mission that NNSA envisions for Los Alamos . More

needs to be done to strengthen the federal oversight for the projects necessary to this expanded

mission .

Continued Operation of the Chemistry and Metallurgy Research Facility. In a letter

dated October 23, 2007, the Board questioned NNSA's decision to operate the 55-year-old

Chemistry and Metallurgy Research facility an additional six years past the previously-planned

shutdown date of 2010 . Continued operation of this facility in its current condition poses risks to

workers and the public that have not been comprehensively evaluated since 1998 . Given the age,

material condition, nuclear material inventory, and seismic capacity of the facility, the Board has

encouraged NNSA to assess these risks promptly, and NNSA has agreed to do so .

Pit Manufacturing . NNSA intends to manufacture a greater number of pits at Los

Alamos's Plutonium Facility than has been past practice . The Board's review of this project

concluded that NNSA has narrowly focused its evaluations on pit manufacturing equipment, to

the exclusion of associated infrastructure required to safely support expanded pit production,

e .g ., waste management. In response, NNSA is taking a harder look at the safety implications of

expanded pit production .

Transuranic Waste Operations . In a letter dated January 18, 2007, the Board urged

NNSA to promptly develop a viable pathway for shipping high-activity transuranic waste drums

in Area G off-site for disposal at the Waste Isolation Pilot Plant . A small fraction of high-activity

waste drums (about two percent of the total waste volume) contains about one-third of the

above-ground radioactive inventory . Postulated accident scenarios involving these drums predict

high consequences because of their loading, the proximity of the storage area to the site

boundary, and the lack of robust engineered controls . In response, NNSA has bolstered waste

disposition work at Los Alamos by facility infrastructure upgrades, new safety basis documents,

and training and qualification of operators . By September, NNSA had begun its high-activity

drum processing campaign, although safety and compliance issues have slowed progress through

the end of the year .

Nuclear Criticality Safety . The Board has provided safety oversight of the laboratory's

attempt to develop a standards-based nuclear criticality safety program . During 2007, the Board

assessed operations in the Plutonium Facility's vault for special nuclear materials . This

assessment led to a letter to NNSA dated September 10, 2007, expressing concern over the

laboratory's Materials Accountability and Safeguards System software and the criticality safety

documentation for the vault.

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Confinement Ventilation, Plutonium Facility . The decade-old safety basis for the

Plutonium Facility credits a passive confinement strategy instead of active confinement

ventilation as a safety-class control to protect the public from postulated accidents . As part of

DOE's implementation plan for Recommendation 2004-2, an evaluation of the facility's

confinement strategy was completed in parallel with a separate effort to develop a new safety

basis for the facility . Unfortunately, the proposed safety basis upgrade continues to rely on a

passive confinement strategy . NNSA is currently developing a list of upgrades that would bring

portions of the ventilation system up to safety-class status .

2.2 .2 Lawrence Livermore National Laboratory

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

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

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

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

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

Facility . During 2007, the Board conducted reviews of material packaging, work permits,

conduct of operations, disposition of legacy material, development of a critique process, and

configuration management of vital safety systems at the Superblock facilities .

Radiography Facility . The Board evaluated operations in this facility and found

weaknesses in material packaging, development of work permits, posting of radiological

controls, and training . NNSA has, as a result, increased management attention to these

operations .

Legacy Item Disposition Project . The Board evaluated efforts to address the unique

hazards of a classified legacy component (referred to as Object 77) at Lawrence Livermore and

the unusual challenges to the facility and personnel associated with its safe disposition . The

Board identified deficient safety controls, a problem corrected by NNSA . Preparations to

disposition the item included dry runs during readiness assessments . In May 2007, the key

phases of the project were safely completed .

Critique Process . The Board evaluated informal methods used at Lawrence Livermore

to gather information on safety-related events and identify follow up actions . The Board strongly

urged the development of a more rigorous and formal process for critiquing such events . In

March 2007, the laboratory introduced a new process called Nuclear Material Technology

Program Event Critique ; it proved to have weaknesses . NNSA is working to make

improvements .

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

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

facilities . In 2006, NNSA established procedures and processes to maintain an interim

configuration management system and developed a resource-loaded schedule integrated with the

documented safety analysis implementation schedule . During a review in 2007, the Board

identified a lack of quality in the interim system drawings . NNSA has drafted a corrective action

plan.

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2 .2 .3 Nevada Test Site

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

Vegas. Stockpile activities at the Test Site include test readiness preparations, planning for the

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

nuclear weapons is no longer being conducted ; however, the site is maintained in a state of

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

The Board seeks to ensure that testing, if resumed, will be done safely . During 2007, the Board

focused its attention on the Device Assembly Facility and subcritical experiments .

Device Assembly Facility. NNSA plans to use the Device Assembly Facility to house

nuclear explosive operations and criticality experiments . In 2004, the Board requested that

NNSA assess the facility's safety systems and management programs . NNSA attempted to

respond by using the site office's assessment program, but this was ineffective in delivering a

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

that more aggressive action be taken with respect to the assessment of the safety systems and

management programs needed to ensure that DAF would be ready for planned increases in the

scope of work . In response, NNSA developed assessment plans for each vital safety system and

safety management program and conducted assessments in 2006 and 2007 . Nearly 200

significant findings were identified, and corrective actions are ongoing .

Subcritical Experiments. The Board's review of preparations for subcritical

experiments disclosed inadequate nuclear safety management practices . In 2006, NNSA made

improvements for the UNICORN experiment in areas such as safety basis reviews,

implementation of controls, and readiness reviews. As a result, UNICORN had a more complete

documented safety analysis and thorough verification of readiness . The Board stressed to NNSA

that it is essential to apply the improved practices and formality to future subcritical

experiments . Activities in 2007 indicated that improvements are being applied to other projects .

2.2 .4 Sandia National Laboratories

Sandia National Laboratories are located in Albuquerque, New Mexico, and Livermore,

California. Major defense nuclear facilities at Sandia, most of which are located in Technical

Area V at the New Mexico site, include the Annular Core Research Reactor, Auxiliary Hot Cell

Facility, Gamma Irradiation Facility, and Sandia Pulsed Reactor Facility (no longer in

operation). The Board focused its attention during 2007 on safety bases and the implementation

of integrated safety management . In regard to the former, the Board previously identified

fundamental weaknesses in the implementation of nuclear safety requirements and controls at a

defense nuclear facility located at Sandia, leading to extensive immediate and long-term

corrective actions . In 2007, the laboratory completed implementation of a safety basis

improvement project to resolve the underlying safety-related deficiencies and implemented a

safety basis operations schedule . The Board noted continued improvement during its reviews .

With respect to integrated safety management, the Board identified multiple failures of the

hazard analysis and work control process . In response, NNSA developed a corrective action

plan. Near-term corrective actions for defense nuclear facilities arc now complete . Corporatelevel systems must be implemented to fully achieve integrated safety management across the

laboratory .

3 3

3. Nuclear Materials Processing and Stabilization

3 .1

Stabilization and Storage of Remnant Materials

3 .1 .1 Complex-Wide Program

Nuclear Material Stabilization . The Board continued its oversight of DOE efforts to

improve the safety posture of remnant nuclear materials stored throughout the DOE complex . In

particular, the Board monitored the safety of unstabilized materials still in storage at Hanford

and Los Alamos . During 2007, DOE completed certain commitments in the implementation plan

for Recommendation 2000-1 : at Hanford, sludge removal from the K-East Basin and bulk sludge

containerization at K-West Basin, and at Los Alamos, milestones for the stabilization of

weapons grade and non-weapons grade plutonium .

Nuclear Materials Consolidation, Storage, and Disposition . DOE's Nuclear Materials

Disposition and Consolidation Coordination Committee has identified eight implementation

plans needed to guide the disposition of surplus nuclear materials . Thus far, DOE has approved

plans for consolidation and disposition of surplus plutonium-239, for disposition of surplus

uranium-233, and for removal of category 1/11 special nuclear materials from Sandia National

Laboratories . The committee forwarded to DOE for approval a plan for consolidation and

removal of nuclear materials from Y-12 .

DOE has started to implement the first two plans . In 2007, DOE began to ship

plutonium-239 materials from Hanford and Lawrence Livermore to Savannah River . DOE

continued design work on the uranium-233 disposition project at Oak Ridge, and has nearly

finished the removal of category I and II quantities of special nuclear materials from Sandia . In a

related development, DOE is revising its order and manual, both entitled Management of

Nuclear Materials . The Board reviewed initial drafts of these documents and provided informal

comments; the Board will offer further comments at a later time .

3 .1 .2 Plutonium

Plutonium Stabilization, Los Alamos . Operators at Los Alamos arc stabilizing or

repackaging excess nuclear materials stored in thousands of containers on site . The laboratory

continues to make progress in risk reduction by repackaging materials into more robust

containers and intends to chemically stabilize these materials at a later date when aqueous

chemistry capability is fully restored . Many of these items are stored in containers not suitable

for long-term storage and therefore warrant stabilization or repackaging on a priority basis . DOE

stabilized 50 percent of weapons grade plutonium, 90 percent of non-weapons grade plutonium,

and 50 percent of material in the Recovery Evaluation Process . The Board continues to closely

monitor the storage conditions and stabilization efforts at Los Alamos .

Plutonium Consolidation and Disposition, Savannah River . To disposition surplus

plutonium, DOE initially proposed a "three-prong" strategy, employing Savannah River's HCanyon, the Mixed-Oxide Fuel Fabrication Facility, and a plutonium vitrification process .

However, based upon plans to extend the life of H-Canyon and a broadening of acceptable feed

stock for the Mixed-Oxide Fuel Fabrication Facility, DOE has more recently indicated that a

3 5
plutonium vitrification facility maybe unnecessary . DOE plans to reach a final decision

concerning the fate of the plutonium vitrification facility by mid-2008 . Since all plutonium

disposition facilities are proposed to operate at Savannah River, DOE recommended that all

surplus plutonium be consolidated there as well. In August 2007, DOE began construction of the

Mixed-Oxide Fuel Fabrication Facility . Given this progress, and the continued operation of HCanyon, both viable disposition paths for plutonium, DOE began consolidation of surplus

plutonium in 2007 by starting shipments of plutonium from Hanford to Savannah River .

K-Area Material Storage. In Section 3183 of the National Defense Authorization Act

for Fiscal Year 2003, Congress directed the Board to conduct a study of the adequacy of

plutonium storage at Savannah River and thereafter to file annual reports on DOE's progress in

implementing the study's recommendations . On June 26, 2007, the Board issued its fourth

annual report. DOE has now completed action on all proposals made in the 2003 study . The

K-Area Material Storage facility will provide adequate extended storage of plutonium at

Savannah River.

3.1 .3 Uranium

Savannah River. In August 2006, the Deputy Secretary of Energy approved the mission

need for the Enriched Uranium Disposition Project and designated Savannah River's H-Canyon

as the preferred facility for executing the project . In order to process surplus uranium and the

approximately 19,000 spent nuclear fuel and target assemblies that are within the scope of the

Enriched Uranium Disposition Project, H-Canyon will have to remain operational until at least

2019.

Until recently, DOE minimized its investments in the H-Canyon and HB-Line facilities

and supporting infrastructure because these facilities were expected to be shut down and

deactivated. In light of current plans to extend the mission through 2019, the Board reviewed the

viability of extending the lives of these facilities . The Board does not believe there are any

fundamental flaws that would preclude an extended mission if some upgrades are implemented .

The Board did encourage DOE to begin planning and preparations for extended operation,

including conducting systematic life extension evaluations, and taking advantage of lessons

learned from the commercial nuclear sector . The Board has also encouraged DOE to expand the

scope of system health reports from near-term operations to the full anticipated life cycle .

The Board also focused its oversight on conduct of operations and emergency

preparedness at H-Canyon . Although conduct of operations began a noticeable downward trend

midway through 2007, significant attention by management was able to stop and ultimately

reverse this trend . The annual emergency preparedness exercise revealed weaknesses in H-Area

emergency response, particularly with command and control, mitigation, and radiological

monitoring and control . The Board expressed concern with the effectiveness of corrective

actions from past emergency preparedness exercises and pointed out that similar weaknesses

were also identified during the 2005 and 2006 annual exercises . These concerns go beyond HArea and encompass the entire site's emergency management program . The Board identified

several problems with the realism of drill scenarios and the adequacy of the demonstrated

response . The Board has observed additional training and drills performed to improve site-level

emergency preparedness performance .

3 6
Oak Ridge National Laboratory . The Board continued its design review of the

Uranium-233 Downblending and Disposition Project in Building 3019 at Oak Ridge National

Laboratory. In 2007, DOE approved the project's preliminary design, which the Board found to

be faulty in respect to the safety analysis, fire hazards analysis, ventilation analysis, and the need

to determine a mitigation strategy for the fall hazard of an adjacent exhaust stack . DOE has

committed to upgrade its safety documentation and to remove the exhaust stack .

3.2Stabilization of Spent Nuclear Fuel

3.2 .1 Hanford Site

Tens of cubic meters of radioactive sludge, including corrosion products of spent nuclear

fuel, still remain in the K-West Basin at Hanford . This sludge is the only material at Hanford that

remains to be stabilized under Recommendation 2000-1 . The project warrants some urgency

because the K-Basins are degrading and the K-East Basin is known to have leaked to the

underlying soil . This year, DOE completed transfer of K-East Basin sludge to engineered

containers in the K-West Basin . This allows deactivation and demolition of K-East Basin to

proceed in order to identify the extent of radiological contamination under the basin from past

leaks . DOE also completed bulk sludge containerization in K-West Basin . These activities

represent the closure of all Recommendation 2000-1 milestones for this project with the

exception of the final removal and processing of the sludge from K-West Basin .

3.2 .2 National Spent Nuclear Fuel Program

The Board monitored DOE's efforts to ship aluminum-clad fuel from the Idaho Cleanup

Project to Savannah River for reprocessing in H-Canyon beginning in 2010 . The Board reviewed

the safety of spent fuel storage at Savannah River and found the facilities and systems adequate

to protect worker and public safety. DOE also proposes to ship its stainless steel-clad and

zircaloy-clad fuel from Savannah River to the Idaho Cleanup Project for packaging and storage

pending shipment to the geological repository for disposal . These proposed actions will require a

Supplemental Analysis and an Amended Record of Decision removing melt-and-dilute as the

preferred method of handling aluminum-clad fuel .

3.3Waste Management

3.3 .1 High-Level Waste

Hanford Tank Farms

Tank Integrity . The high-level waste storage tanks at Hanford contain millions of

gallons of radioactive waste that DOE plans to vitrify for eventual disposal . DOE plans to use

these tanks until at least 2046 . Radioactive waste is currently being transferred from 149 older,

single-shell tanks to 28 newer, double-shell tanks to reduce the potential environmental risk .

DOE conducts ongoing tank integrity programs for both types of tanks, although the program for

double-shell tanks is considerably more extensive . DOE is considering an enhanced program for

the single-shell tanks . Corrosion controls are in place to extend the lives of the double-shell

tanks, and in general, these controls arc working reasonably well . However, some anomalous

37
corrosion occurrences led the Board to suggest further studies . In response, DOE performed

tests, and based on the results, changed the pH limit in one tank and may do so for other tanks .

DOE also began a study on vapor space corrosion to identify chemical species that inhibit or

promote corrosion in the space above the liquid waste . DOE continued ultrasonic testing of the

double-shell tank walls to measure general corrosion, potential pitting, and cracks .

To support greater filling levels, DOE conducted a structural analysis of a double-shell

tank; the Board questioned the methods used in this analysis . In response, DOE engaged outside

experts to review structural calculations and discovered potential new safety concerns . DOE

plans to resolve the structural integrity issues prior to increasing the fill height of the next tank .

Tank S-102 Spill Investigation . On July 27, 2007, radioactive waste spilled on the soil

and equipment above single-shell tank S-102 during a waste transfer to double-shell tank

SY-102 at Hanford. Immediately upon learning of the spill, both of the Board's Hanford site

representatives responded to the Incident Command Post at the tank farm to monitor the

situation . Based on subsequent investigations, the most likely pathway of the spill was via the

dilution water system . DOE began an independent Type A investigation of the spill event on

August 20, 2007 . The tank farm contractor commissioned several investigation teams to review

different aspects of the spill, and the DOE field office performed several self assessments . Other

government agencies and Hanford contractors also reviewed specific aspects of the spill event .

The Board was able to provide technical advice and expertise in several areas including health

physics and emergency planning . Comments and questions regarding DOE's efforts have been

communicated to DOE via the Board's site representatives . The Board is reviewing the

implementation of corrective action plans to prevent and mitigate future spills .

Savannah River Site

High-Level Waste Management . Recommendation 2001-1 sought to make changes in

Savannah River's strategy for managing high level waste . In 2007, DOE completed a major

revision of the Life-Cycle Liquid Waste Disposition System Plan, which satisfied an

implementation plan milestone to issue a program evaluation for the integration of processing

facilities . The Board believes that the latest system plan is reasonable, given the many

constraints of the system . The Board has also emphasized the need for a viable Risk

Management Plan and was encouraged by the establishment of a joint DOE and contractor Risk

Management Board to instill rigor in the implementation of risk management strategies.

Another milestone required demonstration that the deliquification, dissolution, and

adjustment process was viable . Although legal challenges delayed the completion of this

demonstration, the Saltstone Production Facility resumed operations in 2007 . Modifications are

ongoing to support the processing of higher curie' salt waste in early 2008 . The implementation

plan also included commitments to begin operations of the actinide removal process and

Modular Caustic Solvent Side Extraction Unit in late 2007 . Salt processing operations are

expected to commence in the spring of 2008, following successful completion of readiness

2

"Curie" is a standard unit for measuring the activity of a given radioactive sample . It is equivalent to the activity of

1 gram of radium, or 3 .7 x IO 10 disintegrations/second .

3 8
reviews . The Board has followed the startup testing of systems and equipment for these

processes and the conduct of readiness activities .

In order to reduce the volume of waste requiring vitrification and to accelerate the

closure of the high-level waste tanks, DOE proposed removing aluminum from future batches of

high-level waste to be vitrified at the Defense Waste Processing Facility . The removal of

aluminum from the first batch of waste will take place in Tank 51 . The low-curie, aluminum-rich

supernate will be sent to Tank 11 for storage and may later be sent to the Salt Waste Processing

Facility for treatment and eventual disposal as low level waste . Tank I 1 is an old-style, singleshell tank with known leak sites . The Board reviewed the safety aspects of using Tank 11 to

store the aluminum-rich supernate and had no objections to DOE's proposed plans . In a letter to

DOE dated August 29, 2007, the Board stated its belief that this operation can be conducted

safely provided that actions are taken to prevent, detect, and respond to leaks .

Idaho Cleanup Project

High-Level Waste Tank Closure . The Board continued to review DOE's efforts to

clean and close high-level waste tanks at Idaho . Historically, DOE stored high-level wastes in

eleven large (300,000 gallon) and four small (30,000 gallon) underground tanks . By the end of

2007, DOE had grouted seven of the large tanks and all four small tanks . Three of the remaining

four large tanks contain 900,000 gallons of sodium-bearing waste which will be treated by a

steam reforming process in the Integrated Waste Treatment Unit now under construction . The

fourth large tank is a spare unused tank . DOE estimates that treatment of remaining waste may

be completed by 2012, and the Board is closely monitoring this effort .

3.3 .2 Low Level and Transuranic Waste

National Transuranic Waste Program . DOE stores large quantities of transuranic

wastes on concrete pads and in soil-covered trenches at many sites and is retrieving these wastes

for shipment to the Waste Isolation Pilot Plant for disposal . On January 29, 2007, the Board sent

a letter to DOE noting that significant differences exist in the safety requirements governing

retrieval work at the various transuranic waste sites . In response, DOE issued a new standard

DOE-STD-5506-2007, Preparation of Safety Basis Documents for Transuranic (TRU) Waste

Facilities . Efforts are underway by the various sites to implement the standard . The Board will

continue to provide oversight until the standard is fully implemented .

Savannah River Transuranic Waste . The Board's oversight of transuranic waste

operations at the Solid Waste Management Facility and F-Canyon focused on ensuring that

proper safety controls were in place for both planned operations and anomalous events . In one

event, a forklift truck accidentally damaged a transuranic waste drum . The Board reviewed the

causes of the accident . The Board also studied DOE's plan to vent bulging drums that may

contain flammable gases . The Board found that the plan did not provide adequate shrapnel

protection for nearby workers if venting caused a deflagration? DOE has moved bulging drums

` A "deflagration" is rapid burning of a material ; in a deflagration, flame propagation proceeds through thermal

conductivity at subsonic speed .

3 9
into concrete culverts until additional analysis can be performed and a better venting plan

formulated.

The Board reviewed plans for transporting transuranic waste drums containing large

quantities of dispersible plutonium between the Solid Waste Management Facility and

F-Canyon. DOE's initial proposal would have authorized the transportation activity under an

inappropriate safety basis . When the safety basis was re-evaluated, the Board challenged the

authorization process itself because it bypassed DOE review and approval, even though a

transportation activity involved quantities of nuclear material greater than the inventory of many

facilities . As a result, DOE revised its processes to require approval of all new or revised onsite

transportation safety assessments and non-routine transfers . The Board also provided feedback to

ensure that workers involved with these transfers were adequately trained with realistic

emergency preparedness drills.

Advanced Mixed Waste Treatment Project. DOE's largest effort to retrieve

transuranic waste at the Idaho Cleanup Project takes place at the Advanced Mixed Waste

Treatment Project, and the Board continues to provide close oversight of the activities there . As

of December 2007, DOE successfully shipped more than 20,000 cubic meters of transuranic

waste from the Advanced Mixed Waste Treatment Project to the Waste Isolation Pilot Plant .

However, many thousands of cubic meters of waste remain to be packaged and shipped. The

Board continues to monitor the safety of this activity and DOE's actions to implement the new

standard (DOE-STD-5506-2007, noted above) .

Accelerated Retrieval Project . DOE operates a second facility to retrieve transuranic

wastes buried at the Idaho Cleanup Project . This smaller operation, run by a different site

contractor, is called the Accelerated Retrieval Project . The Board monitored DOE's operations at

the Accelerated Retrieval Project several times during 2007 . In the summer of 2007, DOE

discovered the accumulation of liquid in the bottom of drums of packaged sludge waste,

preventing acceptance of the drums for disposal at the Waste Isolation Pilot Plant . DOE changed

the design of the drums to prevent future accumulation of water and developed a method to

safely repackage the estimated 1700 affected drums .

Shielded Transfer Tanks. At the Oak Ridge National Laboratory, DOE has been storing

high activity wastes in five shielded transfer tanks since the late 1960s and early 1970s . Four of

the tanks contain highly-contaminated resins that had been used to capture isotopes (primarily

cesium-137) from fuel reprocessing wastes at Hanford . The fifth tank contains waste from

Savannah River reactor operations . Venting, sampling, and characterization of tank contents will

be required prior to future disposal of the tanks because of the potential for hydrogen buildup

during storage . The Board reviewed the safety basis for these tanks and concurred with the

conclusion that the tanks can remain safely in storage for an extended period of time .

Waste Isolation Pilot Plant. The Waste Isolation Pilot Plant in New Mexico is a

geologic repository utilized for the disposal of defense transuranic wastes . During 2007, the

plant received and disposed of nearly 900 shipments of contact-handled transuranic waste, with a

total volume in excess of 7,800 cubic meters . Remote-handled (high activity) transuranic waste

operations began with receipt of an initial shipment from the Idaho National Laboratory on

January 24, 2007 . This was the first of 99 shipments of such waste, totaling approximately 35

4 0
cubic meters . Previously, the Board had reviewed preparations for the start of remote-handled

transuranic waste operations including observing a DOE operational readiness review . A

February 2007 review confirmed that remote-handled transuranic operations were being

conducted safely . Throughout 2007, the Board verified that both contact-handled and remotehandled transuranic waste operations were conducted safely .

3 .4Facility Deactivation and Decommissioning

3 .4 .1 Overview

DOE continues to pursue accelerated decommissioning at some defense nuclear facilities,

while work at other facilities is delayed due to higher priority work or funding reductions . The

Board performs oversight of decommissioning work at DOE's sites .

3 .4.2 Hanford - Plutonium Finishing Plant

Due to budgetary constraints, decommissioning of the Plutonium Finishing Plant has

been delayed from 2009 to 2016 . The Board reviewed the results of life extension evaluations to

determine if upgrades or replacements of vital safety systems arc required during this extended

period . The Board also reviewed and found improvements in the nuclear criticality safety

program at this facility; the number of nuclear criticality safety nonconformances has decreased,

DOE developed a set of generic controls for cleanout of gloveboxes, and steps have been taken

to retain personnel and equipment to perform non-destructive assay of material holdup in the

faci li ty.

3.4 .3 Idaho Cleanup Project

The Board conducted reviews of the decontamination and decommissioning of several

facilities contaminated with radioactive and hazardous materials in the Reactor Technology

Complex, Test Area North, Radioactive Waste Management Complex, and the Idaho Nuclear

Technology and Engineering Center . The Board made several visits to the site and continued to

oversee the decontamination and decommissioning activities . During 2007, DOE demolished all

major facilities to be removed in the Test Area North . In the Reactor Technology Area, DOE

grouted the Engineering Test Reactor vessel and removed it to the Idaho solid waste disposal

facility.

4 1

4. Nuclear Facilities Design and Infrastructure

4.1Introduction

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

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

providing adequate protection of the health and safety of the workers and the public . The Board

is required by statute to review the design and construction of defense nuclear facilities, which

must be designed and constructed in a manner that supports safe and efficient operations . During

the past two years, the Board has made a concerted effort to ensure that its review of new design

projects focuses on early recognition and resolution of safety issues and that new DOE facilities

will be constructed to acceptable industry codes and standards .

4.2

Safety in Design

Beginning in late 2005, the Board initiated a series of public hearings concerning

integration of safety into the design process . The most recent of these public hearings, held on

March 22, 2007, addressed early identification of issues, communication of Board issues to

DOE, issue management, and early resolution and closure of design-related safety issues . In this

public hearing the Board also collected information regarding the implementation of DOE Order

413 .3A, Program and Project Management . fbr the Acquisition of Capital Assets, and the

development of DOE-STD- 1 189, Integration of Safety into the Design Process, and lessons

learned from incorporating safety into the design of two major DOE projects-Hanford's Waste

Treatment Plant and Los Alamos's Chemistry and Metallurgy Research Replacement project .

These public hearings have aided the Board in measuring the success of DOE's actions regarding

their safety-in-design initiative and allowed examination of how DOE develops safety-related

design requirements for its new projects . The Board plans to observe DOE's implementation of

its safety-in-design initiative and revised directives.

The Board has initiated the practice of sending "project letters" to DOE, containing a

summary of the Board's safety concerns at each stage of a project's design and construction . The

first of these letters covered the Integrated Waste Treatment Unit at Idaho ; the next two

addressed the Container Surveillance and Storage Capability Project at Savannah River and the

Uranium Processing Facility at Y- 12 . The Board's aim is to ensure its safety concerns are known

to DOE when projects are reviewed for further authorization .

Consistent with commitments made in the report prepared jointly by the Board and DOE,

quarterly meetings began in 2007 . At these sessions, staff from the Board and DOE discussed

resolution of pending issues and explored new issues . These meetings have generally been

successful in communicating Board concerns and have helped ensure that the resolution of

design issues progresses in a timely fashion . The Board is briefed by senior DOE and NNSA

management on a monthly basis to ensure that issues receive adequate attention . The reports

provided to Congress on a quarterly basis also provide DOE with a clear understanding of the

Board's outstanding concerns .

Overall, the policies instituted by the Board and the safety-in-design initiative have

helped DOE focus more on new facility design projects and successfully address long-standing

4 3
Board issues. The following discussion summarizes actions taken over the past year on specific

design and construction projects currently being reviewed by the Board . The Joint Report to

Congress on this topic, issued July 19, 2007, provides additional detail on these efforts .

4.3Hanford Site

Waste Treatment Plant . The Waste Treatment Plant is a multi-facility complex

designed to treat Hanford's high-level radioactive liquid wastes . It consists of three primary

nuclear facilities known as Pretreatment, Low Activity Waste, and High Level Waste, supported

by an analytical laboratory. The Pretreatment facility receives high-level waste from Hanford's

tank farms and separates it into high and low activity streams . The low-activity portion is

transferred to the Low Activity Waste facility, where it is mixed with glass-forming materials

and converted to a stable borosilicate glass, or "vitrified ." Glass canisters from the Low Activity

Waste facility are subsequently placed in an onsite, near-surface disposal facility. The highactivity waste stream is transferred from the Pretreatment facility to the High Level Waste

facility, where it is also vitrified . After vitrification, high-level waste glass logs are temporarily

stored at the Hanford site in the Canister Storage Building pending shipment to DOE's highlevel waste repository.

Construction progress varies among the facilities . Currently, construction of the LowActivity Waste facility is furthest along . Late in 2007, work on the Pretreatment and High Level

Waste facilities was re-initiated following resolution of ground motion issues and a review of

construction readiness . The Board is continuing its review of design and construction of

important-to-safety structures, systems, and components . During 2007, the Board's activities

focused on the resolution of previously-identified issues .

Structural Design . In response to a finding by the Board that seismic requirements were

not sufficiently conservative, DOE found that these requirements had been underestimated by

about 40 percent . DOE initiated an evaluation in 2006 of the effect of this increase on the design

of the structure and equipment . This review necessitated drilling new bore-holes to allow

measurement of geotechnical properties beneath the facilities . DOE completed the seismic

borehole project in early 2007 and was able to validate the seismic design ground motion . The

Board considers this issue resolved .

The Board has also noted inadequate modeling, no clear seismic load transfer capability

in the structure, and an inadequate finite element analysis . In 2006, DOE developed new

structural design criteria that addressed the issues raised by the Board and late in 2007 completed

a draft summary structural report for the High Level Waste and Pretreatment Facilities . The

Board's staff is currently reviewing these documents and providing comments to DOE . The

Board anticipates that following favorable resolution of staff comments, DOE will have provided

sufficient technical justification to consider the issue closed .

Fire Protection . The Board objected to DOE's decision not to apply fire resistant

coatings to structural steel . DOE changed course and is now committed to a fireproofing strategy

complying with the building code and other DOE requirements . DOE has prepared structural

design criteria for implementing this strategy across the project and will complete calculations to

determine which steel members must be coated . In November 2007, DOE informed the Board

4 4
that calculations supporting the resolution of this issue were being developed and will be

submitted from December 2007 to early 2009 . The Board is currently reviewing the first of these

documents.

Hydrogen Gas Hazards . DOE significantly underestimated the impact of hydrogen

hazards on pipes and small process vessels and components . In 2007, DOE completed final

actions needed to resolve this issue . These actions followed DOE's development of a

comprehensive control strategy to prevent the most serious hydrogen-related accidents and limit

the likelihood of hydrogen explosions . DOE's remaining action was to complete the

development and implementation of design criteria for piping systems . DOE also completed new

design criteria for construction of piping supports to address the impacts from hydrogen

explosions. In mid-2007, DOE briefed the Board on these developments . The Board has

reviewed the actions taken by DOE and believes that the design criteria and administrative

controls, when properly applied, will be sufficient to resolve the Board's concerns . The Board

considers this issue closed .

Demonstration Bulk Vitrification Project. The Demonstration Bulk Vitrification

Project is a research and development project intended to demonstrate the suitability of bulk

vitrification for disposing of low-activity waste from the Hanford Tank Farms . Previously, the

Board pointed out weaknesses in the design for confinement of materials . DOE developed a

confinement strategy that led to improvements in the design . The Board is now satisfied that the

project's design for confinement of radioactive materials is adequate .

K-Basin Closure Project Sludge Treatment . The Sludge Treatment Project is a subproject in the overall K-Basin Closure Project . A major modification to operating facilities, it

will provide capability to treat waste sludge from corroded spent fuel and package it for disposal .

The Board identified continuing problems with the integration of safety in design as the project

approached completion of design work . In response, DOE required that the project fully

implement requirements and guidance for project management, technology maturity evaluation,

and integration of safety in design . While implementing these requirements and guidance, DOE

discovered that the design was not sufficiently developed to support procurement and the

technology was not at a development level suitable to fully support a conceptual design . DOE

returned the project to a conceptual design stage .

4.4

Savannah River Site

Plutonium Storage . The 3013 Container Surveillance and Storage Capability project is a

major modification to a Hazard Category 2 facility within the K-Area Complex . This project will

provide examination, stabilization, and packaging capabilities for plutonium-bearing materials

stored in 3013 containers . It will also provide rack storage for approximately 1900 containers .

The Board continued to review the preliminary design of the Container Surveillance and Storage

Capability project, focusing on hazards analysis, criticality safety, fire protection, and an

evaluation of existing and new structures to meet seismic performance requirements . The Board

issued a project letter in January 2007 communicating several concerns to DOE, including

deficiencies in the hazards analysis and an inadequate basis for excluding nuclear incident

monitors from the facility . As a result, DOE revised the hazards analysis to address the Board's

concerns and directed that nuclear incident monitors be incorporated into the facility's design .

4 5
Salt Waste Processing Facility . The Salt Waste Processing Facility is a new facility

intended to treat salt waste in high-level waste tanks by removing highly radioactive cesium,

strontium and actinides from the bulk salt solution feed . Approximately 37 million gallons of the

waste is currently being stored in 49 underground waste storage tanks . During 2007, the Board

continued its review of this facility's design and processes and identified concerns with

structural design and hydrogen generation .

Structural design. This facility was of particular concern to the Board because of

technical shortcomings in the design process a lack of geotechnical requirements, structural

issues, and issues related to structural modeling . These shortcomings also raised questions

regarding the quality assurance program implemented by the contractor . The Board pointed out

these deficiencies to DOE in a letter dated January 10, 2007 . The Board was concerned about an

adverse schedule and cost impact on the project if these deficiencies were not resolved early in

the design process. Since that letter, DOE, its contractor, and the Board have been working

together to minimize potential impacts on the high-level waste program at the site . Appropriate

structural design expertise and DOE oversight have been brought to bear on the project .

Geotechnical requirements have been finalized, and changes to the structural design and analysis

methodology have been made . Corrective actions were also taken to fix the quality assurance

program. In a letter to the Board dated May 11, 2007, DOE acknowledged that as a result of

these constructive efforts, a mutually agreeable and technically sound path forward for the

design had been developed .

Hydrogen generation . Deflagration or detonation of hydrogen produced during

processing is the main process safety concern for this facility . The Board was not convinced that

DOE had accurately calculated the hydrogen generation rate . Without an accurate generation

rate, the margin of safety provided by process safety controls is indeterminate . The Board

suggested that DOE review and compare the more current, first-principle based, hydrogen

generation rate formulation used at the Waste Treatment Plant. This review was completed to

support some of the assumptions . However, the Board was still concerned that hydrogen

generation that can occur when organic solvent material is heated in the presence of

radiation thermolysis had not been adequately considered . The Board concluded that the

technical basis for estimating hydrogen generation due to thermolysis would best be determined

by experimentation . The Board informed DOE that suitable irradiation tests had already been

performed at the Idaho National Laboratory on solvents very similar to those used at the Salt

Waste Processing Facility . A simple modification of these tests can provide the data needed to

estimate thermolysis . In December 2007, DOE proposed to test the effects of thermolysis at

Idaho National Laboratory.

Pit Disassembly and Conversion Facility . In 2007, work on the Pit Disassembly and

Conversion Facility slowed significantly . The Board reviewed the status of combustible loadings

for seismically induced fires . The Board previously agreed with the project team's approach for

evaluation of seismically induced facility fires as a design basis accident contingent on

finalization of the assumed combustible loading . NNSA conducted fire tests of a glovebox with

prototypical materials, including water-encapsulated polyester, gloves, and a window assembly

consisting of safety glass, leaded glass, and shielding using polymethylmethacryl ate . These tests

revealed higher-than-expected fire loadings . NNSA is analyzing the results and exploring

options to account for the increased fire loadings .

4 6
4.5

Y-12 National Security Complex

Highly Enriched Uranium Materials Facility . The Highly Enriched Uranium Materials

Facility will replace several aging storage facilities . The new facility will reduce the site

footprint of uranium storage, thus simplifying safeguards and security measures . The design of

this facility is essentially complete . NNSA began construction in early 2005, with completion

now projected for late 2009 . The preliminary documented safety analysis identifies the fire

suppression system as safety-significant to control incipient fires . A water supply for the

sprinklers is needed for the fire suppression system to perform its safety function . The Board

noted that the system planned to supply the needed water was not classified as safety-significant,

consistent with the project's design requirements and guidance associated with DOE Order

420. 1 B, Facility Safety . The Board identified this inconsistency in its quarterly report to

Congress dated October 17, 2007 : Status of Significant Unresolved Issues Concerning the

Design and Construction of New DOE Defense Nuclear Facilities .

In response, NNSA identified near-term actions aimed at increasing the operational

reliability of the water supply system including a new safety-significant water supply pressure

monitor that provides an alarm upon loss of supply pressure and an evaluation of scenarios that

would adversely impact required flow . The Board is pursuing whether safety-related

configuration controls ought to be implemented to provide positive assurance of a reliable flow

path from the supply tanks to the fire suppression system . For the long term, NNSA is evaluating

the use of fire water tanks for the planned Uranium Processing Facility .

Uranium Processing Facility . The Uranium Processing Facility is a new project

intended to replace a number of aging facilities that process enriched uranium . The Board

reviewed the conceptual design and safety documentation developed to support NNSA's review

and approval of Critical Decision 1 authorizing preliminary design . NNSA agreed to

retroactively implement the revised requirements of DOE Order 4

Program and Project

Management. for the Acquisition of Capital Assets, and the guidance in draft DOE-STD-1 189,

Integration of Safety into the Design Process, into the conceptual design and safety basis

development for the project . Additional design detail for cost dominant safety systems was

developed, and improved analyses of the safety functions and controls for the facility were

performed . When NNSA approved Critical Decision I for the project, all Board concerns with

the conceptual design, safety analyses and supporting documentation were either corrected or

captured in the project risk management plan with contingency costs allocated . A clearly

identified path forward for resolution of these concerns was also developed .

4 .6Los Alamos National Laboratory

Chemistry and Metallurgy Research Facility . The Board continued its review of the

design for the Chemistry and Metallurgy Research Replacement project . Early in this project, the

Board noted its concern regarding the acquisition strategy being employed . (Letter to NNSA

dated February 24, 2005 .) On March 28, 2007, NNSA directed that the acquisition strategy for

the project be changed to a more traditional design-bid-build4 approach. Preliminary design

4 "Design-bid-build" refers to a traditional contracting method in which the design and the construction phases of a

construction project are performed by two independent contractors under two distinct contracts,

4 7
continued throughout 2007 with the expectation that the project will enter into final design in

2008. NNSA has committed to completing an independent technical project review of the

completed preliminary design . Critical Decision 2, establishing the project baseline, will occur

no earlier than fiscal year 2009 .

The Board's review of preliminary design documentation uncovered weaknesses in the

safety strategy and the method for selecting safety-related systems and conservative design

criteria . The early identification of structures, systems, and components that prevent and mitigate

potential accidents is vital to the successful design of the project . At the end of preliminary

design, the Board will undertake a detailed review of the overall safety strategy, the adequacy of

design criteria, and the design of safety-related systems . NNSA's Chief of Defense Nuclear

Safety has committed to review the safety strategy prior to proceeding into final design . The

Board has stressed that for this project to be successful, aggressive oversight will be required by

federal and contractor personnel experienced in the management and oversight of large, complex

projects .

4.7Idaho Cleanup Project

Integrated Waste Treatment Unit . The Integrated Waste Treatment Unit will convert

approximately 900,000 gallons of acidic sodium-bearing tank waste at the Idaho National

Laboratory to a dry carbonate product for disposal at the Waste Isolation Pilot Plant . The Board

reviewed the final design for this facility, focusing its attention on process safety, seismic and

structural, fire protection, mechanical equipment, confinement ventilation, and instrumentation

and control . The Board also reviewed a draft of the preliminary documented safety analysis, as

well as software quality assurance for both engineering design and safety analysis codes, and

software supporting the control of the waste treatment process .

The Board identified a number of deficiencies in geotechnical data, analysis of soilstructure interactions, and seismic design of the main process and packaging cells . DOE worked

diligently to address each issue, as documented in a series of communications to the Board, the

last of which was received on December 21, 2007 . Based on DOE's analysis, the Board's

concerns have been resolved, and the structure's design is considered adequate .

The Board objected to the removal of a key design code from the design requirements for

the safety-significant' distributed control system . In response, DOE decided to re-incorporate the

standard into the design requirements and is currently evaluating the system against the standard .

The Board issued a project letter at the beginning of 2007 documenting several items that

needed to be addressed during final design to ensure safety . In response, DOE conducted

additional waste sampling to ensure radionuclide inventories supporting the safety analysis are

conservative . DOE also completed the investigation of an over-temperature event in the pilot

plant's charcoal bed .

s

A "safety-significant" system is relied on to protect the workers from the effects of accidents .

4 8
4.8

Nevada Test Site

Device Assembly Facility . The Board continued its review of the seismic hazard and

structural analysis for the Device Assembly Facility. Geotechnical investigations measuring soil

dynamic properties were completed in March 2007 ; the final report was completed in October

2007 . This report incorporates the results from the geotechnical investigations, assessing the

impact of local soil conditions on earthquake ground motions . These reports indicate that

estimates of earthquake ground motion have increased . The Board is reviewing these reports .

The updated design basis earthquake ground motions are being used to perform an updated

seismic analysis of the structure .

The Board has continued its focus on understanding the impact of numerous cracks that

exist within the Device Assembly Facility structure . This issue has been under discussion for

several years, and the Board has stressed to NNSA that progress to address this issue has been

inadequate . The Board's basic concern is that poor construction practices may have adversely

affected the concrete's in situ strength and contributed to the unprecedented level of cracking .

Degraded concrete strength will need to be properly considered as part of understanding the

capability of the structure to resist updated estimates of design earthquake ground motions . On

December 7, 2007, NNSA committed to undertake nondestructive testing of concrete strength to

ensure that low-strength concrete did not contribute to the cracking .

4.9Seismic Hazard Analysis

The Board continued its review of DOE studies and reports on seismic ground motion

across the complex . The Board and its outside experts have been proactive as DOE develops

seismic ground motions to be used in the design of new facilities as well as updating the

probabilistic hazards assessments for some sites .

Probabilistic hazard assessment . The Board continued its review of probabilistic seismic

hazard updates at Savannah River, Los Alamos, and Nevada Test Site . The Board has stressed

the importance of having an adequate review, including independent peer review, of both the site

specific acquisition of data and the subsequent analysis to ensure that design basis earthquake

ground motions are based on accurate scientific knowledge . Los Alamos completed its update of

the probabilistic seismic hazard analysis and development of seismic design ground motions .

The Board reviewed this update and considered it adequate . Predicted seismic design ground

motions have increased and efforts are underway to assess impacts on existing nuclear facilities .

Seismic design of new facilities . Geologic field work was completed at the Hanford

Waste Treatment Plant; the data were used to develop final seismic ground motion criteria . DOE

satisfactorily briefed the Board on July 24, 2007, and the Secretary of Energy certified the final

seismic ground motion criteria on August 10, 2007 . At the Idaho National Laboratory Integrated

Waste Treatment Unit project, DOE completed studies to assess the impact of local site soil

conditions and subsequently revised the seismic design ground motion to reflect these

conditions . Seismic ground motion criteria for the Chemistry and Metallurgy Research

Replacement project at Los Alamos were increased in expectation of an increase in the

probabilistic seismic hazard . The design of the project will be based on these higher seismic

design motions .

4 9

5. Nuclear Safety Programs and Analysis

5.1Federal Oversight

5.1 .1 Overview

To meet its statutory health and safety mandate, the Board must continuously assess

DOE's ability to carry out adequate oversight of contractor work . Oversight, in this context,

includes federal line management assessment of contractors, contractor self-assessment, and

independent assessment of both federal and contractor work . For much of the work conducted in

the defense nuclear complex, DOE relies upon contractors to perform inherently risky activities

in government-owned facilities . These activities are nevertheless governed by nuclear safety

requirements promulgated by the government . Thus, DOE fills three simultaneous roles : owner,

customer, and regulator . Preventing conflict among these roles requires a complex oversight

system strained by competing demands that must be reconciled to ensure that the overall mission

is achieved safely .

5.1 .2 Recommendation 2004-1

The Board continued driving DOE to improve its oversight of complex, high-hazard

nuclear operations . One important aspect of that oversight is integrated safety management, a

concept that evolved from Recommendation 95-2 and continued to be developed in response to

Recommendation 2004-1 . The basic tenets of this approach provide the framework for safely

performing all of the diverse hazardous activities in the defense nuclear complex . Integrated

safety management provides for a single safety management program rather than multiple,

unintegrated programs (e .g ., quality assurance and environmental management) . Nuclear safety

is an important but not exclusive target, because nonradioactive hazardous materials and

operations can also present significant risk . Integrated safety management builds upon standards

of safe practice for nuclear, chemical, and other hazardous operations to ensure protection of the

public, workers, and the environment .

In response to Recommendation 2004-1, DOE completed the following actions in 2007 :

• fully implemented the Central Technical Authorities function, with associated technical

support staff managed by the Chief of Defense Nuclear Safety for NNSA and the Chief

of Nuclear Safety for the remainder of DOE ;

•

created an integrated safety management Champions Council, reporting to the Deputy

Secretary and responsible for reinvigorating integrated safety management ;

• performed program office self-assessments of safety function assignments at the program

office level and defined criteria for the delegation of authority to the field offices ; and

• issued an integrated safety management system description for each of the program

offices defining the management system they will use to perform work safely .

5 1
Several areas continue to receive significant Board attention . In 2006, DOE revised the

Recommendation 2004-1 implementation plan and moved responsibility for the Office of

Nuclear Safety Research from the Office of Environment, Safety and Health to NNSA .

Establishing a nuclear safety research function has been elusive and will continue to be an area

of focus for the Board in 2008 . In addition, NNSA continues to work on a modified line

oversight contractor assurance system, which is intended to focus more NNSA oversight on the

facilities where a low-probability, high-hazard accident is credible, while increasing reliance on

the contractor to oversee the remainder of the facilities . The Board will expend significant effort

in the oversight of this transformation to ensure that safety of defense nuclear facilities is not

jeopardized and that the level and effectiveness of federal oversight is not allowed to deteriorate .

Commitment 5 of the implementation plan for Recommendation 2004-1 called for

development and issuance of a safety oversight guide for effectively implementing the federal

oversight order . In 2007, DOE revised and re-issued both its policy and order on federal

oversight, further strengthening the requirements for federal oversight of its operations .

However, this revision delayed the development of the oversight guide . DOE expects to issue the

guide no later than February 1, 2008 .

5 .1 .3 Recommendation 2000-2

Based on complex-wide progress toward implementation of this recommendation on

configuration management of vital safety systems, the Board decided to close it on August 8,

2007, and address remaining implementation problems on a site-by-site basis . During 2007, the

Board pressed NNSA to complete implementation at Los Alamos and Lawrence Livermore . The

Board's July 2007 review of vital safety systems at Los Alamos uncovered deficiencies that

were communicated to NNSA by letter dated October, 16, 2007 . On December 21, 2007, NNSA

requested an additional 60 days to respond to the Board's adverse findings .

5.1 .4 Activity-Level Work Planning

The Board continuously emphasizes the importance of ensuring that hazards are

identified and controlled, work is performed in a careful manner in accordance with the safety

controls, and that DOE uses appropriate feedback mechanisms to ensure continuous

improvement at the activity level . In its implementation plan for Recommendation 2004-1, DOE

acknowledged the need to strengthen this area and committed to enhanced focus on work

planning and work control at the field office level . During 2007 the Board reviewed work

planning processes at three DOE sites : Los Alamos, Hanford, and Savannah River . The results of

these reviews indicate that corrective actions that were to be taken may not have been fully

institutionalized . This area will require significant effort during 2008 in order to improve

performance .

5 .2Health and Safety Directives

5.2 .1 Improvement of Directives

In 2007, as part of its ongoing review of new and revised DOE directives, the Board and

its staff evaluated and provided constructive critiques of 28 directives associated with, but not

5 2
limited to nuclear design criteria, maintenance management, worker protection, emergency

management, and project management . At year's end, the Board was in the process of working

to resolve issues on 24 pending directives to improve the content, clarity, and consistency in

safety requirements and guidance . Work was completed on eleven directives listed below .

DOE Order 226 .1 A, Implementation of Department of Energy Oversight Policy

DOE Order 410 .1, Central Technical Authority Responsibilities Regarding Nuclear Safety

Requirements

DOE Order 470 .4A, Safeguards and Security Program

DOE Manual 460.2-1 A, Radioactive Material Transportation Practices Manual

DOE Handbook 1129-2007, Tritium Handling and Safe Storage

DOE Handbook 1130-2007, Radiological Worker Training

DOE Standard 1183-2007, Nuclear Safety Specialist Functional Area Qualification

Standard

DOE Standard 11 85-2007, Nuclear Explosives Safety Study Functional Area Qualification

Standard

DOE-STD-1 170-2007, Electrical Systems and Safety Oversight Functional Area Qualification

Standard

DOE-STD- I 138-2007, Industrial Hygiene Functional Area Qualification Standard

DOE-STD- 1137-2007, Fire Protection Engineering Functional Area Qualification Standard

5.2 .2 Scope of the Directives System

The Board maintains a significant level of involvement in reviewing updates to existing

DOE directives and proposed new directives . On September 10, 2007, the Secretary of Energy

issued a memorandum entitled "Principles Governing Departmental Directives ." The

memorandum directs DOE personnel to "review existing and proposed directives to ensure that

they are written and managed in accordance with the principles outlined in this memorandum ."

The stated intent of this review is to ensure that directives' objectives are "accomplished without

being unclear, overly prescriptive, duplicative, or contradictory ." In late December 2007, DOE

released to the Board a plan for the review of 26 safety-related directives in accordance with the

Secretary's memorandum . Based on past experience, the Board is concerned that DOE may

lower safety expectations as a consequence of this review . The Board will maintain a high level

of oversight to ensure that the current margin of safety embodied in DOE directives is

maintained or increased .

5 .2 .3 Integrating Safety into Design

In an August 27, 2004, letter to DOE, the Board requested improved technical criteria for

systems, structures, and components relied upon to confine radioactive materials threatened by

natural phenomena . In 2005, DOE provided a revision to DOE Guide 420.1-2, Guide for the

Mitigation of Natural Phenomena Hazards, for DOE Nuclear Facilities and Nonnuclear

Facilities . The Board provided comments on this revision, suggesting that DOE consider

adopting the national consensus standard American National Standards Institute/American

Nuclear Society Standard 2 .26-2004, Categorization of Nuclear Facility Structures, Systems, and

Components for Seismic Design, rather than revising the guide . DOE has elected to adopt this

national consensus standard by providing guidance for its implementation in a new standard,

53
DOE-STD- 1189, Integration of Safety into the Design Process . In March 2007, DOE issued

DOE-STD-1189 for review in its Revcom process . As of late 2007, DOE was still resolving

outstanding comments . Foremost among these were issues raised by DOE's Chief of Nuclear

Safety and NNSA's Chief of Defense Nuclear Safety regarding problems with federal and

contractor roles and responsibilities and deficiencies in other orders resulting from the content

developed in DOE-STD- 1189 . DOE has undertaken an effort to address these issues and plans to

delay issuance of the standard until the internal issues are resolved .

5.2 .4 Hazard Categorization

In a letter dated June 26, 2006, the Board requested that DOE review and address issues

associated with the implementation of DOE-STD- 1027-92, Hazard Categorization and Accident

Analysis Techniques, for Compliance with DOE Order 5480 .23, Nuclear Safety Analysis Reports,

Change Notice 1 . The letter described specific problems observed throughout the complex,

including inappropriate exclusion of sealed sources from facility inventories . Improper

application of the standard can result in non-conservative facility hazard categorization and a

reduced set of safety requirements and controls . DOE formed a working group to perform a

thorough evaluation of the standard and identify weaknesses that required additional guidance .

On May 7, 2007, DOE issued a supplemental guidance document to further clarify issues

identified by the Board and the working group . This supplemental guidance is already being

used by the sites to reevaluate their facilities' hazard categorization and to identify the potential

need for revising their present hazard category . DOE will revise DOE-STD- 1027-92 to

incorporate the supplemental guidance .

5.3Safety Programs

5.3 .1 Administrative Controls

On January 4, 2007, DOE informed the Board that all commitments in the

implementation plan for Recommendation 2002-3 had been completed and proposed that the

recommendation be closed . The Board conducted a number of independent verification reviews

to assess the effectiveness of DOE's implementation . These reviews identified a number of

implementation weaknesses and deficiencies, and as a result, the Board determined that

additional efforts were warranted on the part of DOE prior to closure of the recommendation . In

response, DOE committed to conduct additional field verification reviews to fully identify and

correct the implementation deficiencies .

5 .3 .2 Active Confinement Systems

The Board issued Recommendation 2004-2 to ensure reliable and effective confinement

of potential accidents at defense nuclear facilities . In accordance with the implementation plan,

DOE issued the Ventilation System Evaluation Guidance document in February 2006 . All

Hazard Category 2 and 3 defense nuclear facilities that had not been excluded or screened per

the implementation plan were to have their ventilation systems evaluated against the criteria

provided in the guidance document to identify any gaps . DOE has completed this evaluation for

some 25 facilities and has identified areas where physical modifications are necessary to

improve the effectiveness of active confinement ventilation systems . These modifications

5 4
include : providing an online stack monitoring system to provide an accurate account of the

facility release to the environment during an accident ; installing a deluge system upstream of the

High Efficiency Particulate Air filters to protect them from the potential severe conditions during

a fire ; and upgrading a portion of the existing ventilation system to safety-class 6 to ensure that

the public is adequately protected in case of a fire inside the facility . These modifications will

significantly improve the safety posture of defense nuclear facilities in the event of an accident .

In addition, the Board has reviewed major DOE design and construction projects to

ensure that their designs do not solely rely on passive confinement for protection of the public

and that they meet the criteria identified in the guidance document for their active confinement

ventilation systems. The remaining hazard category 2 and 3 defense nuclear facilities (most

operated by NNSA) are scheduled to complete their evaluation in 2008, followed by a DOE

commitment to implement the identified modifications to meet the criteria identified in the

Ventilation System Evaluation Guidance document.

5 .3 .3 Software Quality Assurance

The safe design and operation of many defense nuclear facilities is assured, in part, by

analysis and operational support provided by computer software . In January 2002, the Board

issued Recommendation 2002-1 to make changes to DOE's policies and practices regarding

software design, implementation, testing, configuration management, and training of personnel

in order to address longstanding safety deficiencies in these areas . The implementation plan for

this recommendation is complete except for one action on software tools that were to be

upgraded and maintained in a new Safety Software Central Registry . During 2007, DOE made

limited progress addressing software quality assurance gaps identified in the original six toolbox

codes in the registry . In late 2007, DOE developed a plan of action to address the gaps.

In 2008, DOE will provide the Board with a plan and schedule for completion and

closure of this recommendation. The plan will include refining requirements, assessing the

implementation of requirements, revamping DOE's corporate communication infrastructure,

reviewing digital instrumentation and control practices and implementation strategies,

establishing a support group, and setting up a forum to collect lessons learned . Late in 2007, as

the first initiative from this effort, a Digital Instrumentation and Control Working Group was

formed to develop requirements and guidance for digital instrumentation and control

applications .

5.3 .4 Risk Assessment Methodologies

Previously, the Board conducted a comprehensive assessment of DOE's policies,

programs, processes, and procedures on the use of quantitative risk assessment and related

methodologies. This review found that DOE widely employed quantitative risk assessment, but

without adequate controls over quality and applicability . This in turn causes the quality and

relevance of risk management plans, risk mitigative actions, and residual risk identification to be

A "safety-class" system is relied on to protect the public from the effects of accidents . Such systems have the

highest safety pedigree in terms of design, procurement, installation, testing and maintenance,

5 5
highly variable. DOE responded by offering to develop a policy governing the use of risk

assessment methodologies at defense nuclear facilities .

In a letter to DOE dated November 23, 2005, the Board found deficiencies in the policy

as written and objected to the slow pace of its development . As a result of the Board's

observations and concerns, DOE chartered a working group comprised of representatives from

the major program offices, field elements, national laboratories, and major contractors to guide

the efforts in this area . This group developed a draft policy, along with draft implementation

guidance, which was scheduled to be released for general comment in early 2007 . At this point

all progress came to a halt . The Board will work to re-invigorate this area in 2008 .

5.3 .5 Criticality Safety

The Board continued to monitor DOE's progress in improving nuclear criticality safety

programs. DOE's nuclear criticality safety program continues to provide a source of stable

funding for many essential activities related to criticality safety . A total of thirteen training

courses, sponsored by the program, have been conducted since mid-2006, and eight are planned

for FY 2008 . In addition, plans for startup of the Critical Experiments Facility at Nevada Test

Site progressed with validation of the mission need statement . Three criticality experiments are

scheduled following facility startup, currently projected to occur in 2010 . In 2007, DOE

completed the limited-scope, baseline reviews proposed in October 2005 . Future criticality

safety reviews arc planned as a component of reviews conducted by the Chief of Nuclear Safety

or Chief of Defense Nuclear Safety . The Board conducted a detailed review at Los Alamos in

2007, which is discussed in section 2 .2 .1 of this report .

5 .3 .6 Readiness Reviews

In 2005 the Board expressed concerns regarding the proper implementation of DOE

Order 425.1 C, Startup and Restart of Nuclear Facilities . As a result, in 2006 DOE conducted a

comprehensive review of startup and restart procedures, as well as their implementation at

defense nuclear facilities . In 2007, DOE formed a readiness review working group to ensure

more rigorous and conservative implementation of this order . The Board closely followed the

meetings and progress of this group .

DOE's readiness review working group determined it necessary to revise and

reinvigorate readiness review training for specific audiences . DOE developed detailed training

for readiness review team members and tailored training sessions for readiness review team

leaders and contractors . The Board continues to provide input and evaluate these training

sessions . The readiness review working group also worked to further refine the definitions used

in DOE Order 425 .1 C to reduce any ambiguity in the Order . Finally, the working group

developed a streamlined process that contractors will use to notify DOE about upcoming

readiness reviews . Improving the notification step of the readiness review process will help

ensure a more rigorous implementation of DOE Order 425 .1 C .

5 6
5.3 .7 Justifications for Continuing Operations

The Board reviewed DOE's use of justifications for continuing operations' at defense

nuclear facilities and found a number of weaknesses . The Board documented these weaknesses

in a letter to DOE dated April 19, 2007 . In response, DOE established a working group which

collected data during 2007 . A preliminary assessment of the data indicates that DOE may need

to issue additional guidance .

5 .3 .8 Recommendation 2007-1

As a result of several recent events across the DOE complex, the Board issued

Recommendation 2007-1, Safety-Related In Situ Nondestructive Assay of Radioactive Material,

on April 25, 2007 . The recommendation advises that DOE should (1) identify and review all

current in situ measurements used to comply with nuclear safety limits to validate that the results

arc sufficiently conservative, and (2) issue new requirements and guidance . DOE accepted the

recommendation on June 28, 2007, and issued its implementation plan on October 24, 2007 . The

Board is currently evaluating the adequacy of the implementation plan .

5.4Technical Competence

5.4 .1 Federal

In accordance with the implementation plan for Recommendation 2004-1, DOE updated

a corrective action plan to respond to federal technical competency issues . The action plan

focused on several major areas, including : (1) conducting a functional workforce analysis as a

basis for meeting the needs of DOE's missions for the next five years, (2) establishing a

voluntary corporate accreditation process for the Technical Qualification Program based on the

Institute of Nuclear Power Operation model, (3) reestablishing the corporate Technical

Leadership Development Program to hire and develop new engineers, and (4) strengthening the

qualification program for Senior Technical Safety Managers . DOE is currently revising its

Federal Technical Capability Manual to incorporate changes in federal technical capability

expectations developed as part of the implementation plan . The revised Manual is expected to be

issued later in 2008 . DOE will also conduct a follow-on line management review of the

effectiveness of the corrective action plan in 2008 .

DOE achieved several successes in this area in 2007 . DOE significantly increased the

number of federal personnel (1183 to 1346) who have completed or are in the process of

completing their qualifications under an enhanced Technical Qualification Program . NNSA and

DOE have instituted similar two-year career intern programs for training and providing

rotational assignments for recent college graduates, the majority of whom are engineering

majors. NNSA's Future Leaders Program successfully graduated its first class of 29 personnel

and has two other classes of 30 and 24 college graduates in its training cycle . DOE's Office of

Environmental Management just started its first Professional Development Corps program with

A "justification for continued operation" is an analysis supporting a decision to allow operation of a facility or

process to continue in the face of known safety deficiences or noncompliances with safety requirements .

5 7
21 college graduates participating in June 2007 . One year of graduate study will be offered as

part of the program .

5.4 .2 Criticality Safety Engineers

The Board followed progress made by DOE in the areas of nuclear criticality training and

staffing at several DOE site offices . Criticality safety personnel were added at sites that were

previously unstaffed or understaffed, including the Savannah River Operations Office and the

Nevada Site Office . Some of the engineers added by DOE have little or no direct criticality

safety experience and must complete the training necessary to obtain qualification under the

appropriate DOE qualification standard. DOE does not have a defined methodology for

determining the number of personnel needed at each site to provide effective oversight for

criticality safety, similar to the methodology used for determining the required staffing level for

Facility Representatives . Thus, a site may fill the allocated oversight positions, but, in reality,

may not have sufficient resources to perform effective criticality safety oversight . The Board

continues to require annual reporting by DOE on the status of nuclear criticality-related topics .

5.4.3 Federal Facility Representatives

Overall, the DOE Facility Representative program is relatively healthy, continuously

monitored, and fairly well staffed with competent technical personnel . However, the Board

observed that the effectiveness of the Facility Representative programs at several NNSA sites

(Los Alamos, Lawrence Livermore, Nevada Test Site, and Sandia) and one DOE site (Savannah

River) are in need of improvement . At the NNSA sites, the effectiveness was diminished by the

lack of progress in qualifying Facility Representatives, which limited their ability to execute

oversight responsibilities . NNSA senior management is now focusing more attention on the

staffing and qualification of Facility Representatives, and some progress is being observed .

For three consecutive years, the Board has called for DOE to include seasoned Facility

Representatives on Federal Integrated Project Teams in order to gain the benefit of their

operational experience. DOE has complied, with noticeable benefits for the Highly Enriched

Uranium Materials Facility at Y-12 and the Waste Treatment and Immobilization Plant at

Hanford . DOE is now reviewing its procedures for incorporating staffing criteria and special

training needs for this vital capability .

5 8
6. Public Outreach and Agency Administration

6 .1Public Hearings

The Board convened two public hearings in 2007, pursuant to its authority under

42 U .S .C . § 2286b . The first, on March 22, 2007, was convened at the Board's headquarters in

Washington, D .C . This hearing was the third in a series concerning safety in the design,

construction, and modification of defense nuclear facilities . During the first hearing on this

subject, held on December 7, 2005, the Board focused on the adequacy of DOE's existing

directives affecting the design of new facilities . In the second hearing, held on July 19, 2006, the

Board further explored integration of safety into design and the progress being made in

implementing DOE's safety-in-design initiatives . The foci of this third hearing were early issue

identification, communication of Board issues to DOE, issue management, and early resolution

and closure of design-related safety issues . The hearing also addressed the implementation status

of DOE Order 413 .3A and DOE Standard 1189 ; the revision of DOE Manual 413 .3A- l ; and

lessons learned at two major federal projects, the Waste Treatment Plant at Hanford and the

Chemistry and Metallurgy Research Replacement project at Los Alamos .

The Board convened its next public hearing on December 5, 2007, in Los Alamos, New

Mexico. In this hearing, the Board assessed the safety posture of the Los Alamos National

Laboratory, with particular interest focused on NNSA's response to the Board's letter of

February 1, 2007 . In that letter, the Board suggested strengthening federal safety oversight,

improving safety bases, ensuring the reliability of safety systems, developing institutional safety

programs, eliminating known hazards, and increasing federal management of new projects . At

the hearing, the Board further examined how effectively NNSA and its contractor were carrying

out the Atomic Energy Act mandate to protect the health and safety of the public and workers .

The Board received testimony from senior management officials of NNSA, the Los Alamos Site

Office, and the laboratory's operating contractor . Members of the public also testified .

6.2Responding to Public Requests

The Board answered numerous informal public requests for documents and information

and responded to eight formal requests filed under the Freedom of Information Act. The average

response time for Freedom of Information Act requests was 5 .6 working days, as compared with

the statutory requirement of 20 working days . The Board's website ( www.dnfsb .gov) contains a

complete list of Freedom of Information Act requests processed since 2003 .

6 .3Electronic Access

The Board posts essential, publicly-releasable documents on its website in a timely

manner in a format suitable for downloading . The Board also mails paper copies of certain

documents (annual reports, technical reports, public hearing notices, and others) to a list of

nearly four hundred addressees .

5 9
6 .4

Inquiries into Health and Safety Issues

The Board often receives information regarding potential health and safety hazards from

private citizens or from employees at defense nuclear facilities . The Board treats these matters

with the utmost seriousness by assigning members of its legal and technical staffs to investigate

or inquire further . These inquiries, which may involve interviews, reviews of documents, and

site visits, are continued until the Board is able to reach a technical judgment on the issues

raised . The Board informs DOE of any health and safety hazards and then closely monitors

DOE's corrective actions . When the Board receives information on matters outside its

jurisdiction, such as alleged criminal activities or unlawful personnel practices, it refers the

information to the appropriate federal agency for action . During 2007, the Board directed

inquiries into health and safety issues at Hanford, Savannah River, and Los Alamos . These

inquiries led to safety improvements in the conduct of work at the respective sites .

6.5 Site Representative Activities

The Board enhances its onsite health and safety oversight of defense nuclear facilities by

assigning experienced technical staff members to full-time duty in the field . As of December 3 1,

2007, there were two site representatives at the Pantex Plant near Amarillo, Texas ; two at the

Hanford Site near Richland, Washington ; two at the Savannah River Site near Aiken, South

Carolina ; two at the Y-12 National Security Complex in Oak Ridge, Tennessee ; and two at Los

Alamos National Laboratory in New Mexico . The Board's site representative position at

Lawrence Livermore National Laboratory in Livermore, California is temporarily vacant . Site

representatives conduct first-hand assessments of nuclear safety management to identify health

and safety concerns promptly . They meet regularly with the public, union members,

Congressional staff members, and public officials from federal, state, and local agencies . The

Board receives weekly reports and regular briefings from its site representatives in person and

maintains continuous contact with them using all available communication media .

6.6Human Resources

During FY 2007, the Board succeeded in increasing its staff from 86 to 92 government

personnel. Ten engineers were hired . However, the Board lost four personnel to retirement or

attrition . All five Board Member positions are filled . The Board is making hiring a priority in

order to reach full strength of 100 personnel in 2008 .

The Board has assembled a professional staff of exceptional technical capability . Staff

members' expertise cover all major aspects of nuclear safety : nuclear, mechanical, electrical,

chemical, fire protection, and structural engineering, as well as physics and metallurgy . Most

mid- to senior-level technical staff members possess practical nuclear experience gained from

duty in the United States Navy nuclear propulsion program, the nuclear weapons field, or the

civilian nuclear reactor industry . The Board expects its engineers and scientists to maintain the

highest level of technical knowledge, encouraging them to improve their skills continually

through academic study. Ninety-three percent of the Board's technical staff hold advanced

science and engineering degrees, with 18 percent at the doctoral level .

6 0
Junior technical staff members continue to be recruited through the Board's professional

development program . Entry-level employees recruited into this 3-year program receive graduate

education and intensive on-the-job training guided by experienced technical mentors . Currently,

there are three entry-level employees in this program, with one more expected to enter the

program in June 2008 . The Board will continue its vigorous recruitment program to attract the

brightest engineering students from colleges and universities across the country .

6.7Information Technology and Security

In 2007 the Board continued to strengthen internal controls and ensure that it is in

compliance with the requirements of the Federal Information Security Management Act as well

as other security guidance . The Board continues to implement processes called for by Homeland

Security Presidential Directive 12 and expects to issue in 2008 new personal identity verification

cards for physical and logical access .

The Board has made preparations for a complete refresh of its desktop infrastructure in

2008 to take advantage of new technologies . The equipment will also incorporate the new

Federal Desktop Core Configuration settings as required by the Office of Management and

Budget to standardize operating system security settings across the Executive Branch .

Implementing these security settings on desktop and laptop computers will help the Board to

improve system performance, decrease operating costs, and ensure public confidence in the

confidentiality, integrity, and availability of government information .

6.8

Dispute Resolution Programs

The Board, like other federal agencies, is required by the Administrative Dispute

Resolution Act of 1996 to provide an alternative dispute resolution program for use in resolving

appropriate disputes . The Board maintains such a program, making use of cooperative

agreements with other agencies to resolve workplace and contracts disputes economically .

6 .9Financial Management

The Board received a second consecutive "unqualified audit" opinion on its financial

statements from an independent auditor . The auditor found that the Board complied with all

applicable federal laws and regulations and had no financial internal control material

weaknesses .

6 1

effort to reduce paperwork and

respondent burden, conducts a preclearance consultation program to

provide the general public and federal

agencies with an opportunity to

comment on proposed and/or

continuing collections of information in

accordance with the Paperwork

Reduction Act of 1995 (PRA95) (44

U.S .C . 3506(c)(2)(A)) . This program

helps to ensure that requested data can

be provided in the desired format,

reporting burden (time and financial

resources) is minimized, collection

instruments are clearly understood, and

the impact of collection requirement on

respondents can be properly assessed .

Currently, the Corporation is

soliciting comments concerning its

proposed renewal of its Learn and Serve

America Program and Performance

Measurement Reports . These reports are

used by current grantees, subgrantees

and sub-subgrantees to report on Learn

and Serve-funded service-learning

programs . Data collected through the

reports are utilized by the Corporation

for Congressional reporting and program

management . Completion of the

Program and Performance Measurement

Reports is a requirement of the Learn

and Serve grant provisions .

Copies of the information collection

requests can he obtained by contacting

the office listed in the addresses section

of this notice .

DATES: Written comments must be

submitted to the individual and office

listed in the ADDRESSES section by July

2, 2007 .

ADDRESSES: You may submit comments,

identified by the title of the information

collection activity, by any of the

following methods :

(1) By mail sent to : Corporation for

National and Community Service,

Research and Policy Development;

Attention Kimberly Spring, Policy

Analyst, 10th Floor ; 1201 New York

Avenue, NW ., Washington, DC 20525 .

(2) By hand delivery or by courier to

the Corporation's mailroom at Room

8100 at the mail address given in

paragraph (1) above, between 9 a .m* and

4 p .m . Monday through Friday, except

Federal holidays .

(3) By fax to : (202) 606-3464,

Attention Kimberly Spring, Policy

Analyst .

(4) Electronically through the

Corporation's e-mail address system :

kspring cns.go v.

FOR FURTHER INFORMATION CONTACT : Kimberly Spring, (202) 606-6629, or by

e-mail at k springacns .go v .

SUPPLEMENTARY INFORMATION : The

Corporation is particularly interested in

comments that :

Appendix A

Federal Register/Vol . 72, No . 84 /Wednesday, May 2, 2007 /Notices

•Evaluate whether the proposed

collection of information is necessary

for the proper performance of the

functions of the Corporation, including

whether the information will have

practical utility ;

•Evaluate the accuracy of the

agency's estimate of the burden of the

proposed collection of information,

including the validity of the

methodology and assumptions used :

•Enhance the quality, utility, and

clarity of the information to be

collected ; and

•Minimize the burden of the

collection of information on those who

are expected to respond, including the

use of appropriate automated,

electronic, mechanical, or other

technological collection techniques or

other forms of information technology

(e .g ., permitting electronic submissions

of responses) .

Background

The Learn and Serve America

Program was established by the National

and Community Service Act of 1990, as

amended, (42 U .S .C . 12501, et seq .)

(Pub. L . 103-82) to support efforts in

schools, higher education institutions,

and community-based organizations to

involve young people in meaningful

service to their communities while

improving academic, civic, social, and

career-related skills . The Learn and

Serve program is administered by the

Corporation for National and

Community Service and is funded

through grants to states, national

organizations, and institutions of higher

education, and through them to

individual schools and school districts,

community-based organizations, and

colleges or universities . Approximately

100 grantees and 2,000 subgrantees and

sub-subgrantees receive Learn and Serve

funds each year .

The Learn and Serve America

Program and Performance Measurement

Reports provide an annual program

reporting process for Learn and Serve :

Collecting program characteristics,

output measurements, and institutionallevel service-learning policies and

practices . The system is Web-based and

allows for the electronic submission of

reporting information and grantee and

public-use access of data collected

through the system .

Current Action

The Corporation seeks to renew the

current reporting instruments, which

are designed to collect information on

(a) the characteristics of grantee and

subgrantee organizations ; (b) the scope

and structure of service-learning

activities in the funded organizations ;

63

24279

(c) number of participants in servicelearning and the hours of service

provided; and (d) institutional supports

for service-learning . The Corporation

maintains three versions of the reporting

instrument to correspond to the three

major funding streams under Learn and

Serve America : K-12 School-Based,

Higher Education, and CommunityBased . The Corporation also seeks to

continue using the reporting

instruments until the renewal of the

instruments is approved by OMB . The

current application is clue to expire on

September 30, 2007 .

Type of Review : Renewal .

Agency: Corporation for National and

Community Service .

Title : Learn and Serve America

Program and Performance Measurement

Reports .

OMB Number: 3045-0095 .

Agency Number: None.

Affected Public : Learn and Serve

America Grantees and Subgrantees .

Total Respondents : 2,100 .

Frequency : Annually .

Average Time Per Response : '/4 hour

for grantees and one hour for

subgrantees .

Estimated Total Burden Hours: 2,025

hours .

Total Burden Cost (capital/startup) :

None.

Total Burden Cost (operating/

maintenance) : None .

Comments submitted in response to

this notice will be summarized and/or

included in the request for Office of

Management and Budget approval of the

information collection request : they will

also become a matter of public record .

Dated : April 24 . 2007 . Robert Grimm, Jr .,

Direclor, Office of Research and Policy

Development. IHR Doc . E7-8350 Filed 5-1-07 ; 8 :45 am]

BILLING CODE 6050-SS-P

DEFENSE NUCLEAR FACILITIES

SAFETY BOARD

[Recommendation 2007-1]

Safety-Related In Situ Nondestructive

Assay of Radioactive Materials

AGENCY: Defense Nuclear Facilities

Safety Board .

ACTION : Notice, recommendation .

SUMMARY: The Defense Nuclear

Facilities Safety Board has made a

recommendation to the Secretary of

Energy pursuant to 42 U .S .C . 2286a(a)(5)

which addresses the measuring of

radioactive material holdup at defense

nuclear facilities in the Department of

Energy complex .
24280

DATES : Comments, data, views, or

arguments concerning the

recommendation are due on or before

June 1, 2007 .

ADDRESSES : Send comments, data,

views, or arguments concerning this

recommendation to : Defense Nuclear

Facilities Safety Board, 625 Indiana

Avenue., NW, Suite 700, Washington,

DC 20004-2001 .

FOR FURTHER INFORMATION CONTACT:

Brian Grosner or Andrew L . Thibacleau

at the address above or telephone (202)

694-7000 .

Dated : April 27, 2006 .

A.J . Eggenberger,

Chairman .

Recommendation 2007-1 to the Secretary of

Energy

Safety-Related In Situ Nondestructive Assay

of Radioactive Materials

Pursuant to 42 U .S .C . 2286(a)(5) ; Atomic

Energy Act of 1954, As Amended

Dated : April 25, 2007 .

Overview

There are many situations in which the

quantity and composition of radioactive

material must be determined . In some

instances, access to the material is impossible

or undesirable, and consequently, weighing,

laboratory analysis, and calorimetrv are not

viable options . In these cases, in situ

nondestructive assay (NDA), based on the

measurement of signature emissions from a

specific isotope of interest, is used to provide

an estimate of the type and quantity of

radioactive material present . However, large

uncertainties and inaccuracies have occurred

in estimating the type and quantity of

radioactive material using in situ NDA. These

uncertainties and inaccuracies include

incorrect assumptions about shielding and

the spatial distribution of radioactive

material, as well as poor measurement

techniques . Measurement errors, in turn, lead

to potential criticality accident conditions,

unexpected radiation exposure to workers,

and underestimation of radioactive material

available for release in accident scenarios .

In most nuclear safety areas, the

Department of Energy (DOE) has captured

required elements for robust site programs

through its Directives system . These elements

include requirements necessary for proper

functioning of the program, training and

qualification standards for personnel,

assessment criteria to ensure proper

implementation of requirements, and

feedback mechanisms for lessons learned and

continuous improvement. However, DOE has

not established programmatic requirements

for NDA, even though this method is heavily

relied upon for nuclear safety throughout the

complex and is key to many DOE activities .

The capability to perform accurate

measurements and use the results to

determine compliance with nuclear safety

limits is absolutely essential .

Research and development efforts for NDA

have historically focused on the areas of

material control and accountability and

Federal Register / Vol . 72, No . 84 / Wednesday, May 2, 2007 / Notices

nuclear material safeguards ; advances in

these areas have peripherally benefitted in

situ NDA measurement capabilities . Current

research and development efforts appear to

hold little promise for addressing needed

improvements fur in situ NDA measurement .

For example, development of

instrumentation and measurement

techniques is needed to reduce overall

measurement uncertainties .

Examples

Three notable instances of recent errors

associated with in situ NDA measurement of

radioactive material holdup are discussed

below . These errors resulted from the use of

inaccurate correction factors regarding

material geometry assumptions or failure to

perform measurements at locations where the

material was accumulating . In each of these

cases, the amount of radioactive material was

initially underestimated, resulting in a

smaller-than-expected safety margin and

violations of criticality safety limits .

Material holdup in 6-inch diameter vacuum

system pipe at the Hartford Site's

Plutonium Finishing Plant was assumed to

be in the form of a 0 .25 inch layer at the

bottom of the pipe . Using a correction

factor for this geometry, the initial estimate

of material was about 1 kg . When workers

then proceeded to remove the piping, it

was found to he filled with a solid plug of

material, and the actual amount of material

present was nearly twice as high as the

initial estimate .

Measurement of an exhaust filter at the Y12 National Security Complex assumed

that fissionable material was loaded only

on the face of the filler . An estimate of a

few hundred grams of material was

obtained using correction factors for this

geometry . Subsequent investigation

showed that material was loaded

throughout the filter, and not just on the

face . The actual amount of fissionable

material present was several times the

initial estimate .

A second exhaust filter at the Y-12 National

Security Complex was treasured

periodically using NDA, but the

measurement point was not where the

fissionable material was accumulating .

Once this error was discovered, follow-up

measurements showed significant material

accumulation .

In each of these instances, site-specific

corrective actions were taken based on the

specific problem encountered . Lessons

learned from these events do not appear to

have been shared within the DOE complex .

Complex-wide corrective actions have not

been identified to minimize the occurrence of

similar events at other sites . The Board is

concerned that undiscovered problems

currently exist at other facilities within the

DOE complex . It is incumbent upon DOE and

its contractors to review current in situ NDA

measurements to determine whether the

assumptions used to derive results are

sufficiently conservative to ensure

compliance with nuclear safety limits .

Issues

Three main issues dominate the current

technical and regulatory landscape regarding

6 4

in situ NDA measurements : (1) Lack of

standardized requirements for performing

measurements, (2) lack of design

requirements for new facilities that would

facilitate accurate holdup measurement, and

(3) lack of research and development

activities for new instrumentation and/or

measurement techniques . Each of these

issues is discussed below .

Lack of Standardization-DOE has not

established requirements or guidance for

performing in situ measurements in its

Directives system . While the Board

recognizes that measurement techniques can

be highly location specific, a requirement to

follow methods outlined in national

consensus standards when performing in situ

NDA measurements would reduce the errors

and uncertainty of results . Commercial

guidance for NDA is available in a series of

standards published by the American Society

for Testing and Materials (ASTM) . This series

addresses good practices for performing NDA

measurements, methods for performing

specific types of NDA measurements (for

example, AS'TM C-1133-03, NDA of Lot ;,-

Density Scrap and IFaste by Segmented

Passive Gamma Ray Scanning), and training

and qualification of NDA personnel . While

this guidance has been used informally at

some sites, DOE has not required its use for

NDA measurements .

Lack of Design Requirements for New

Facilities-Many of the problems that require

in situ NDA to determine radioactive material

holdup arose because facilities were designed

and built before the need for NDA technology

was evident . As a result, no consistent

attempt was made to design facility systems

to minimize holdup or facilitate its

ineasuremenl . This historical trend should

not be repeated in new facilities . The

necessity of monitoring radioactive material

holdup must be considered in the design of

new facilities . For example, locations for

monitoring can be selected during the design

phase on the basis oft tie most likely

locations for holdup to occur . Calibrations

can then he performed at these locations

before the facility begins operations to

provide a baseline for future NDA

measurements . Facilities can also be

designed to minimize holdup in areas where

it may be of concern .

Lock of Research and Development

Activities-Los Alamos National Laboratory

(LANL) conducted NDA research for more

than 20 years . LANL developed most of the

NDA techniques in current use, and conducts

associated training programs . However, it is

not clear that any significant research and

development for in sill! NDA measurements

is currently being conducted within DOE to

address serious concerns with material

holdup . Research and development activities

are focused in other areas, such as nuclear

material safeguards and homeland security,

but these efforts have different objectives and

may not yield results that are beneficial for

measurements using in situ NDA .

Recommendation

The Board, therefore, recommends that

DOE:

1 . Evaluate the extent of condition

regarding inaccurate in situ NDA programs
within DOE . This effort should involve at

least two actions :

A. Identifying all cases within the defense

nuclear complex in which in situ NDA

results are used to ensure compliance with

nuclear safety limits .

B . Reviewing the cases identified in step

1 .A to validate that the protocols,

methodologies, calculations, and

assumptions used to obtain NDA results are

sufficiently conservative . This review should

take into consideration lessons learned from

recent events .

2 . Establish requirements and guidance in

a DOE directive or directives . The

requirements and guidance should focus on

in situ NDA programs that are used to

demonstrate compliance with nuclear safety

limits . Particular issues to he addressed

should include :

A. Training and qualification standards for

personnel involved in performing NDA

measurements, interpreting and reviewing

results, and managing site programs .

B . Application of standard protocols and

methodologies, such as those given in the

national consensus series issued by ASTM,

for performing NDA measurements .

C . Standardization of correction factors for

common situations (geonetrv and selfattenuation factors) and consistent

application of uncertainty values .

D. Reinforcement of the use of formal

lessons-learned mechanisms in the

application of NDA programs so that

information can he shared easily among

affected DOE sites .

E . Incorporation of features in the design

of new facilities to minimize radioactive

material holdup and facilitate accurate NDA

holdup measurements .

F . Periodic assessments of the need for new

NDA technology and the status of ongoing

NDA-related research and development

programs .

C. Periodic assessments to ensure that

NDA programs are using the best available

technology .

H. Incorporation of appropriate duality

assurance elements into in situ NDA

measurements when used for compliance

with nuclear safety limits as required by 10

Code of Federal Regulations Part 830 .

DATES : An emergency review has been

requested in accordance with the Act

(44 U .S .C . Chapter 3507(j)), since public

harm is reasonably likely to result if

normal clearance procedures are

followed . Approval by the Office of

Management and Budget (OMB) has

been requested by December 7, 2007 .

ADDRESSES: Written continents

regarding the emergency review should

be addressed to the Office of

Information and Regulatory Affairs,

Attention : Rachael Potter, Desk Officer,

Department of Education, Office of

Management and Budget ; 725 17th

Street, NW ., Room 10222, New

Executive Office Building, Washington,

DC 20503 or faxed to (202) 395-6974 .

SUPPLEMENTARY INFORMATION : Section

3506 of the Paperwork Reduction Act of

1995 (44 U .S .C . Chapter 35) requires

that the Director of OMB provide

interested Federal agencies and the

public an early opportunity to comment

on information collection requests . The

Office of Management and Budget

(OMB) may amend or waive the

requirement for public consultation to

the extent that public participation in

the approval process would defeat the

purpose of the information collection,

violate State or Federal law, or

substantially interfere with any agency's

ability to perform its statutory

obligations . The IC Clearance Official,

Regulatory Information Management

Services, Office of Management,

publishes this notice containing

proposed information collection

requests at the beginning of the

Departmental review of the information

collection . Each proposed information

collection, grouped by office, contains

the following : (1) Type of review

requested, e .g., new, revision, extension .

existing or reinstatement ; (2) Title : (3)

Summary of the collection ; (4)

Description of the need for, and

proposed use of, the information ; (5)

Respondents and frequency of

collection ; and (6) Reporting and/or

Recordkeeping burden . ED invites

public comment . The Department of

Education is especially interested in

public comment addressing the

following issues : (1) Is this collection

necessary to the proper functions of the

Department ; (2) will this information be

processed and used in a timely manner ;

(3) is the estimate of burden accurate ;

(4) how might the Department enhance

the quality, utility, and clarity of the

information to he collected ; and (5) how

might the Department minimize the

burden of this collection on

respondents, including through the use

of information technology .

A.J . Eggenberger,

Chairman.

[FR Doe . E7-8374 Filed 5-1-07 : 13 :45 ami

BILLING CODE 3670-01-P

DEPARTMENT OF EDUCATION

Notice of Proposed Information

Collection Requests

AGENCY: Department of Education .

ACTION : Notice of proposed information

collection requests .

SUMMARY : The IC Clearance Official,

Regulatory Information Management

Services, Office of Management . invites

comments on the proposed information

collection requests as required by the

Paperwork Reduction Act of 1995 .

Federal Register/Vol . 72, No . 84 /Wednesday, May 2, 2007 /Notices

6 5

24281

Dated : April 26, 2007 . Angela C. Arrington,

IC Clearance Official . Regulatory Information

Management Services . Office of Management .

Office of Postsecondary Education

Type of Review : New .

Title : U .S .-Russian Program :

Improving Research and Educational

Activities in Higher Education .

Abstract : This is a new Special Focus

Competition, administered by the Fund

for the Improvement for Postsecondary

Education (FIPSE) . FIPSE's U .S .-Russia

Program will award grants to U .S .

institutions participating in bilateral

institutional cooperation to support

innovative projects that will improve

research and education activities in

higher education in the U .S . and Russia .

The rationale for the U .S .-Russia

Program is based upon the need for

increased interconnectedness between

the U .S . and Russia in order to operate

effectively in a global economy .

Institutions will be funded by their

respective government agencies in areas

that advance the study of English and

Russian and demonstrate innovative

and/or best practices in a variety of

academic disciplines, such as

mathematics, science, and economics .

Additional Information : This

important unique program is facing a

tight deadline in order for both nations

to have adequate time to apply, and

hence we are asking for this emergency

clearance to provide possible applicants

a decent amount of time to complete the

necessary application .

Frequency: Annually.

Affected Public : Not-for-profit

institutions .

Reporting and Record keeping Hour

Burden:

Responses : 12 .

Burden Hours : 360.

Requests for copies of the proposed

information collection request may be

accessed from http ://edicsweb .ed .gov,

by selecting the "Browse Pending

Collections'' link and by clicking on

link number 3323 . When you access the

information collection, click on

"Download Attachments" to view.

Written requests for information should

be addressed to U .S . Department of

Education, 400 Maryland Avenue, SW .,

Potomac Center, 9th Floor, Washington,

DC 20202-4700 . Requests may also be

electronically mailed to the Internet

address ICDocketMgr a .edgov or faxed to

202-245-6623 . Please specify the

complete title of the information

collection when making your request .

Comments regarding burden and/or

the collection activity requirements

should be electronically mailed to

ICDocketMgrc~ e d.go v . Individuals who
I
Appendix B: Recommendations Cited

6 7

Number Date Title

94-1 May 26, 1994 Improved Schedule for Remediation in the Defense Nuclear

Facilities Complex

95-2 October 11, 1995 Safety Management

97-2 May 19, 1997 Continuation of Criticality Safety at Defense Nuclear Facilities

in the Department of Energy

98-2 September 30, 1998 Safety Management at the Pantex Plant

2000-1 January 14, 2000 Prioritization for Stabilizing Nuclear Materials

2000-2 March 8, 2000 Configuration Management, Vital Safety Systems

2001-1 March 23, 2001 High-Level Waste Management at the Savannah River Site

2002-1 September 23, 2002 Quality Assurance for Safety-Related Software

2002-3 December 11, 2002 Requirements for the Design, Implementation, and

Maintenance of Administrative Controls

2004-1 May 21, 2004 Oversight of Complex, High-Hazard Nuclear Operations

2004-2 December 7, 2004 Active Confinement Systems

2005-1 March 10, 2005 Nuclear Material Packaging

2007-1 April 25, 2007 Safety-Related In Situ Nondestructive Assay of Radioactive

~1 ;llCll ;1~,~

Appendix C : Reporting Requirements

6 9

Date Addressee Site or Topic

January 10 Ass't Secy . Environmental Mgt . Salt Waste Processing Facility, Savannah River

January 18 Secretary of Energy Transuranic waste operations, Los Alamos

March 13 Acting Administrator, NNSA 9212 Complex at Y- 12

March 30 Acting Administrator, NNSA Lightning protection, Pantex

April 24 Acting Administrator, NNSA Procedural deficiencies, Pantex

May 10 Acting Administrator, NNSA Expert elicitation process, NNSA complex

May 16 Deputy Secretary of Energy Risk assessment policy and guidance

July 16 Acting Administrator, NNSA Startup of weapons activities, Pantex

July 30 Secretary of Energy Implementation of Rec. 2002-3

September 10 Administrator, NNSA Materials Accountability, Los Alamos

October 16 Administrator, NNSA Safety systems, Los Alamos

October 23 Administrator, NNSA Chemistry & Metallurgy Research, Los Alamos

Idaho National Engineering Laboratory

January 24 letter to the Assistant Secretary for Environmental Management regarding design and

construction of the Integrated Waste Treatment Unit .

Los Alamos National Laboratory

January 18 letter to the Secretary of Energy imposing a 45-day reporting requirement regarding

specific action plans for transuranic waste operations .

February l letter to the Acting Administrator, NNSA, offering observations and suggested actions

for improving safety at Los Alamos National Laboratory .

September 10 letter to the Administrator, NNSA, imposing a 90-day reporting requirement on

strategy and milestones for the upgrade of the Materials Accountability and Safeguards System .

October 16 letter to the Administrator, NNSA, imposing a 60-day reporting requirement

regarding efforts to improve safety systems .

October 23 letter to the Administrator, NNSA, imposing a 60-day reporting requirement

regarding the continued safe operation of the Chemistry and Metallurgy Research Facility .

Oak Ridge National Laboratory

September 14 letter to the Assistant Secretary for Environmental Management regarding the

uranium downblending and disposition program in Building 3019 .

Pantex Plant

March 30 letter to the Acting Administrator, NNSA, imposing a 30-day reporting requirement

regarding the potential threat posed by direct and indirect lightning effects .

April 24 letter to the Acting Administrator, NNSA, imposing a 30-day reporting requirement for a

briefing on the quality of technical procedures used to conduct nuclear explosive operations .

July 16 letter to the Acting Administrator, NNSA, imposing a 30-day reporting requirement for

safe startup of weapons program activities .

July 30 letter to the Manager, Pantex Site Office, regarding control of the authorization basis .

Nevada Test Site

October 15 letter to the Principal Deputy Administrator, NNSA, regarding the management and

operating contractor assuming full responsibility for all nuclear and radiological facilities .

Appendix D : Correspondence

7 1
Savannah River Site

January 10 letter to the Assistant Secretary for Environmental Management imposing a 30-day

reporting requirement on geotechnical and structural engineering issues for the Salt Waste

Processing Facility.

January 29 letter to the Assistant Secretary for Environmental Management regarding the

Container Surveillance and Storage Capability project .

February 1 letter to the Chief Operating Officer for Environmental Management regarding highlevel waste management .

June 1 letter to the Assistant Secretary for Environmental Management expressing satisfaction

with DOE's path forward for the Salt Waste Processing Facility design .

June 26 letter to the Congress forwarding a copy of the Fourth Annual Report, Plutonium Storage

at the Department ofEnergy's Savannah River Site .

August 29 letter to the Assistant Secretary for Environmental Management regarding the plans for

Tank 11 .

Y-12 National Security Complex

March 13 letter to the Acting Administrator, NNSA, imposing a 6-month reporting requirement

regarding assessments of the 9212 complex .

August 9 letter to the Administrator, NNSA, regarding the conceptual design activities and

associated safety basis development for the Uranium Processing Facility .

Other Correspondence

January 4 letter to the Deputy Administrator of Naval Reactors, NNSA, acknowledging receipt of

reports and noting the first successful cruise of USS Virginia .

January 18 letter to the Secretary of Energy accepting the revised schedule of deliverables for

Recommendation 2005-1 .

January 22 letter to the Secretary of Energy acknowledging receipt of letter requesting formal

closure of Recommendation 2002-3 .

January 29 letter to the Assistant Secretary for Environmental Management regarding worker

protection during transuranic waste activities .

January 30 letter to the Deputy Secretary of Energy regarding improvements in the operational

readiness review process .

February 15 letter to the Secretary of Energy forwarding the Board's First Quarterly Report to

Congress on the Status of Significant Unresolved Issues with Department of Energy's Design and

Construction Projects .

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February 28 letter to the Secretary of Energy forwarding a copy of the Board's 17`" Annual

Report to Congress .

March 13 letter to the Secretary of Energy accepting the revised Implementation Plan for

Recommendation 2004-2 .

April 19 letter to the Deputy Secretary of Energy regarding justifications for continuing

operations at defense nuclear facilities .

April 25 letter to the Secretary of Energy transmitting Recommendation 2007-1, Safety-Related In

Situ Nondestructive Assay of Radioactive Materials .

May 10 letter to the Acting Administrator, NNSA, imposing a 30-day reporting requirement

regarding expert elicitation, expert judgment, and peer review processes .

May 16 letter to the Deputy Secretary of Energy imposing a 45-day reporting requirement on

DOE's risk assessment policy .

June 6 letter to the Secretary of Energy recognizing Robert C . Seal as 2006 DOE Facility

Representative of the Year and Elizabeth D . Sellers for being named DOE's Facility

Representative of the Year for three consecutive years .

June 20 letter to the Secretary of Energy forwarding a copy of the Board's Second Quarterly

Report to Congress on the Status of Significant Unresolved Issues with Department of Energy's

Design and Construction Projects .

June 26 letter to the Deputy Administrator of Naval Reactors, NNSA, acknowledging receipt of

reports and commending the program's outstanding performance.

July 19 letter to Congress enclosing the joint Board-DOE report Improving the Identification and

Resolution of Safety Issues During the Design and Construction of DOE Defense Nuclear

Facilities

July 30 letter to the Secretary of Energy imposing a 45-day reporting requirement regarding

implementation of Recommendation 2002-3 .

August 8 letter to the Secretary of Energy closing Recommendation 2000-2 .

October 17 letter to the Departmental Representative to the Board forwarding a copy of the

Board's Third Quarterly Report to Congress on the Status of'Significant Unresolved Issues with

Department of Energy 's Design and Construction Projects .

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