SEVENTEENTH ANNUAL REPORT

TO CONGRESS

DEFENSE NUCLEAR FACILITIES

SAFETY BOARD

FEBRUARY 2007
A.J . Eggenberger, Chairman

John E. Mansfield

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

Seventeenth 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 2006,

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

and safety problems .

Respectfully submitted,

Mansfield

Member

DEFENSE NUCLEAR FACILITIES

SAFETY BOARD

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

(202) 694-7000

February 28, 2007

A.J . Eggenberger

Chairman

Ij

L~

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 .

On September 29, 2006, House Conference Report 109-702 on the National Defense

Authorization Act for Fiscal Year 2007 (H .R . 5122) was approved by both houses of Congress .

Section 3201 of this report directs the Board to provide to the congressional defense committees

quarterly reports to identify and report the status of significant unresolved issues . The first of

these reports was submitted by the Board to Congress on February 15, 2007 .

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

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

Plant . There are outstanding safety issues associated with many defense nuclear projects that

need to be resolved early during the design phase . The Board and DOE are working to arrive at

an agreed-upon path forward for resolving these outstanding issues at an early stage in the

process .

3
Table of Contents

Summary of Accomplishments in 2006 	 7

Outstanding Safety Problems of Defense Nuclear Facilities 	14

Section 1 : Introduction	 19

1 .1 Background	 19

1 .2 Oversight Strategy	 19

1 .3 Strategic Plan	 20

Section 2: Nuclear Weapons Operations	 23

2.1 Safe Conduct of Stockpile Management 	 23

2.1 .1 Pantex Plant	 23

2.1 .2 Y-12 National Security Complex 	 26

2.1 .3 Savannah River Site Tritium Operations	 28

2.1 .4 Nuclear Material Packaging 	 28

2.2 Safe Conduct of Stockpile Stewardship	 29

2.2 .1 Los Alamos National Laboratory 	 29

2.2 .2 Lawrence Livermore National Laboratory	 30

2.2 .3 Nevada Test Site	 31

2.2 .4 Sandia National Laboratories 	 33

2.2 .5 Research and Development for Explosives Safety 	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 .1 .4 Neptunium	 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	 38

3 .3 .1 High-Level Waste	 38

3 .3 .2 Low-Level Waste and Transuranic Waste	 39

3 .4 Facility Deactivation and Decommissioning	 41

3 .4 .1 Overview	 41

3 .4 .2 Fernald Closure Project	 41

3 .4 .3 Miamisburg Closure Project	 41

3.4 .4 Savannah River Site	 42

3.4 .5 Hanford Site	 42

3.4 .6 Idaho Cleanup Project	 42

Section 4: Nuclear Facilities Design and Infrastructure	 45

4.1 Introduction	 45

4.2 Hanford Site	 45

4.3 Savannah River Site	 47

4.4 Y-12 National Security Complex	 48

5
4.5 Los Alamos National Laboratory 	 49

4 .6 Pantex Plant	 49

4.7 Idaho Cleanup Project	 50

4.8 Nevada Test Site	 50

4.9 Seismic Hazard Analysis	 50

Section 5 : Nuclear Safety Programs and Analysis 	 53

5.1 Federal Oversight	 53

5.1 .1 Overview	 53

5.1 .2 Recommendations 95-2 and 2004-1	 53

5.1 .3 DOE Oversight Policy and Order 	 54

5.1 .4 Vital Safety Systems 	 55

5 .1 .5 Activity-Level Work Planning 	 55

5 .1 .6 Small Business Contracting 	 55

5 .2 Health and Safety Directives	 55

5 .2 .1 Improvement of Directives	 55

5 .2 .2 NNSA Policy Letters	 56

5 .2 .3 Natural Phenomena Hazards	 56

5 .2 .4 Worker Safety Rulemaking	 56

5.2.5 Hazard Categorization	 57

5.2 .6 Scope of the Directives System	 57

5 .3 Safety Programs	 57

5.3 .1 Administrative Controls	 57

5.3 .2 Active Confinement Systems	

I

58

5.3 .3 Quality Assurance	 58

5.3 .4 Software Quality Assurance	 59

5.3 .5 Risk Assessment Methodologies	 59

5.3 .6 Criticality Safety	 59

5.3 .7 Readiness Reviews	 60

5.4 Technical Competence	 61

5.4 .1 Federal	 61

5 .4 .2 Criticality Safety Engineers	 61

5 .4 .3 Federal Facility Representatives	 62

Section 6: Public Outreach and Agency Administration	 63

6.1 Public Hearings	 63

6 .2 Responding to Public Requests	 63

6 .3 Electronic Access	 63

6 .4 Inquiries Into Health and Safety Issues 	 63

6 .5 Site Representative Activities	 63

6.6 Human Resources	 64

6.7 Information Technology and Security	 64

6.8 Dispute Resolution Programs	 65

6.9 Financial Management	 65

Appendices

A. Recommendations Cited	 67

B . Reporting Requirements	 69

C. Correspondence	 71

6
Summary of Accomplishments in 2006

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 2006, DOE has taken actions to upgrade the safety

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

facilities, achieving safe packaging of nuclear 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. Cross-references are provided to sections in

the body of this report where further details can be found .

7
Multiple Sites :

•

DOE is implementing improved requirements for development, evaluation, and

documentation of nuclear weapon response to external stimuli . (Recommendation 98-2 ;

Board letter dated December 14, 2005)(Sec . 2 .1 .1)

•

DOE is revising two principal deliverables of its implementation plan for

Recommendation 2005-1 : (1) the repackaging prioritization methodology, and (2) the

nuclear material packaging manual . (Recommendation 2005-1 ; Board letters dated

April 24 and May 1, 2006)(Sec . 2 .1 .4)

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

• As a part of the implementation plan for Recommendation 98-2, DOE implemented

Seamless Safety for the 21 51 Century processes for weapons programs with insensitive

main charge high explosives (the W87, B61, and B83 programs) . (Recommendation

98-2)

• DOE completed the safe dismantlement of all W56 war reserve units, including certain

units that required the development of new tooling and procedures . (Recommendation .

98-2; Board letter dated July 20, 2004)

•

DOE is taking a more comprehensive approach toward evaluating multi-unit

operations . (staff-to-staff meeting, April 2006)

• DOE completed a three-year effort to implement more than 200 Technical Safety

Requirements. (Recommendation 98-2)

• DOE identified actions to improve the nuclear explosive safety process in response to

the Top-Down Review advocated by the Board . (staff-to-staff meeting, June 2005)

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

• DOE is performing maintenance-related structural fixes in the 9212 Complex and plans

to increase maintenance funding and pursue other facility infrastructure improvements

to reduce material-at-risk in this facility . (Board letter dated April 20, 2005)

•

DOE upgraded the classification of key fire protection systems in the 9212 Complex to

safety-class . (Board letters dated May 13, 2002 and February 28, 2006)

• DOE developed a plan to improve conduct of operations . (Site Representative Weekly

Reports)

• DOE is improving the Uranium Holdup Survey Program . (Site Representative Weekly

Reports)

8
Los Alamos National Laboratory (Sec . 2 .2 .1) :

•

DOE took actions to ensure the continuity of the laboratory's institutional corrective

actions programs as the laboratory transitioned to a new prime contractor . (Public

Hearing, March 22, 2006)

•DOE is examining deficiencies in confinement ventilation at the Plutonium Facility .

(Recommendation 2004-2 ; Board letter dated May 31, 2005)

•DOE developed plans to address deficiencies in fire protection . (Board letters dated

March 31, 2003 and May 31, 2005)

• DOE eliminated a single point of failure vulnerability in the high-voltage transmission

lines that provide off-site power to the laboratory . (Board letters dated May 5, 1995 and

September 22, 1999)

Lawrence Livermore National Laboratory (Sec . 2.2 .2) :

•

DOE was able to resume normal operations in the Plutonium Facility after ensuring

that safety-related findings by the Board and DOE's Office of Independent Oversight

had been investigated and procedures revised as needed for safe operations . (Board

letters dated November 3, 2004 and March 8, 2005)

•DOE developed a revised documented safety analysis for the Plutonium Facility that

represents a significant improvement over previous versions of the safety basis for this

facility . (Board letter dated May 10, 2006)

•DOE developed procedures and processes to identify and record the configuration of

vital safety systems and to begin the process of maintaining a configuration

management program for these systems . (Board letter dated November 3, 2004)

Nevada Test Site (Sec . 2.2 .3) :

•DOE is performing rigorous reviews of the safety bases for subcritical experiments, the

Criticality Experiments Facility Project, and defense nuclear facilities . (Board letters

dated March 27, 2006 and September 22, 2006)

•

DOE continued to make improvements in the facilities and processes necessary to

dispose of a damaged nuclear weapon . (Board letter dated June 19, 2006)

• DOE is assessing vital safety systems and safety management programs at the Device

Assembly Facility . (Board letter dated November 28, 2005)

• DOE is mapping cracks and water leaks, fixing water leaks, and completing key

seismic-related analyses at the Device Assembly Facility . (Board letters dated March

18, 2005 and August 16, 2006)

9
Sandia National Laboratories (Sec . 2.2 .4) :

•

DOE has continued to correct deficiencies in safety analyses and to remedy significant

shortfalls in the site's integrated safety management system . (Board letters dated

September 27, 2004 and October 8, 2004)

Nuclear Materials Processing and Stabilization

This area of work includes oversight of DOE's efforts 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 . Materials included in DOE's stabilization efforts are

liquid high-level radioactive wastes, spent nuclear fuel, inactive radioactive actinide materials

(which include uranium and plutonium), low-level wastes, and transuranic wastes .

Some of the Board's reviews in this area focused on specific issues at individual facilities,

while others involved safety topics with broad implications for multiple defense nuclear

facilities. Specific examples of safety improvements made by DOE in response to the Board's

actions are given below. Cross-references are provided to sections in the body of this report

where further details can be found .

Complex-wide Safety Issues :

• DOE acknowledged safety issues associated with the processing of transuranic waste

and drafted a new standard designed to achieve consistency and enhanced safety in

handling of transuranic waste across the complex . (Transuranic Waste Authorization

Basis Workshop, March 2006 ; Board letter dated January 29, 2007)(Sec . 3 .3 .2)

•

DOE established a testing program and a new expert panel to study corrosion

mechanisms in tanks that store liquid high-level wastes . This currently impacts

primarily the Hanford Waste Storage Tanks . (Board letters dated January 18, 2005 and

June 1, 2005)(Sec . 3 .3 .1)

• DOE conducted analyses and identified new safety controls for hydrogen deflagrations

in piping and vessels that contain high-level wastes at the Hanford and Savannah River

Sites . (Board letters dated November 4, 2002 and October 17, 2005)(Sec . 3 .3 .1)

Fernald Closure Project:

•

DOE safely completed final site closure at the Fernald Site in Ohio . DOE's Office of

Environmental Management transferred responsibility for the site to the Office of

Legacy Management. (Board letters dated August 7, 2003 and February 2, 2005)

(Sec. 3 .4 .2)

1 0
Hanford Site:

•

DOE directed that transuranic waste drums found to contain hydrogen gas be vented

until the hydrogen dissipates to below 5 percent by volume, instead of 15 percent,

which was far greater than the lower flammability limit . (staff-to-staff meeting, March

2006)(Sec. 3 .3 .2)

• DOE postponed excavation of a burial ground containing spent nuclear fuel and other

radioactive material . DOE plans to improve work planning and criticality safety prior

to conducting the work . (Site Representative Weekly Reports)(Sec . 3 .3 .2)

Savannah River Site:

•

DOE removed combustible materials from the K-Area Material Storage facility,

improving the fire protection posture there . (Annual Reports to Congress on Plutonium

Storage at Savannah River Site, 2004, 2005, 2006)(Sec. 3 .1 .2)

•

DOE finished the stabilization of pre-existing neptunium solutions, marking the

completion of all Recommendation 94-1 and 2000-1 milestones at the Savannah River

Site. (Recommendations 94-1 and 2000-1)(Sec . 3 .1 .1 and 3.1 .4)

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, there has been a substantial increase in the number of design and construction projects

under the Board's jurisdiction . 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 designs for defense nuclear facilities incorporate multiple layers of safety controls

commensurate with the hazards .

DOE is not consistently addressing safety issues early in the design process . Moreover, in

an increasing number of new projects, DOE planned to make use of closely-coupled "designbuild" techniques for large-scale facilities, including some that will require hazardous processes

that lack definition . This approach entails considerable risk when combined with DOE's

shortage of personnel qualified to adequately manage such projects . To highlight these problems

and to gain further information, the Board began a series of public hearings in December 2005

on incorporating safety into design and construction . The series continued through 2006, and the

Board is preparing for a third public hearing to be held in the first quarter of 2007 . This latest

hearing will focus on early issue identification, improved communications between the Board

and DOE, and timely resolution of safety issues early in the design effort .

Specific examples of safety improvements in design and infrastructure accomplished as a

result of the Board's work are given below . Cross-references are provided to sections in the body

of this report where further details can be found .

II
Hanford Site (Sec . 4 .2) :

•

DOE continued working to correct potential safety flaws in the design of the Waste

Treatment Plant . Progress was. made in coating of structural steel for fire resistance and

the development of design bases for mitigation systems used to prevent hydrogen

deflagrations and detonations . DOE also has undertaken a seismic borehole project .

The Board expects that ground motion modeling using data due to this drilling program

will effectively validate the seismic design ground motion . DOE also developed new

structural design criteria to address structural design issues raised by the Board . (Board

letters dated October 17, 2005 and September 7, 2006)

•

DOE has improved the design for confinement of radioactive materials and worker

protection for the Demonstration Bulk Vitrification Project . (Board letter dated

September 7, 2005)

•

DOE is developing a revised safety basis for the Sludge Treatment Sub-Project of the

K-Basin Closure Project . When this work is finished in early 2007, the Board can

complete its review of the project's design . (Board letter dated January 5, 2006)

Idaho National Laboratory (Sec . 4 .7) :

•

DOE directed the Integrated Waste Treatment Unit project to use a more conservative

and commonly-used computer code for estimating radiological consequences for

co-located workers and the public from postulated accidents . Further, the project

conducted a review of key safety analysis inputs and subsequently changed them for

many of the postulated accidents . These changes resulted in a more technically

defensible safety design basis . (Board letter dated January 24, 2007)

Los Alamos National Laboratory (Sec . 4 .5) :

•

DOE decided to classify the fire suppression system and the active confinement

ventilation system for the Chemistry and Metallurgy Research Replacement Project

facility as safety class and safety significant, respectively . This will be the first DOE

facility to be designed and constructed with a safety-class fire protection system . If

properly implemented, this action should result in acceptable safety controls for this

facility . (staff-to-staff meetings ; Site Representative Weekly Reports)

Nevada Test Site (Sec . 4.8) :

•

DOE is performing a new structural and seismic analysis, plans to address water leaks,

and is preparing a new safety analysis for the Critical Experiments Facility . However,

the facility structure still has numerous cracks that are considered abnormal for a

nuclear facility . The Board is considering further action on this subject . (Board letter

dated March 18, 2005)

1 2
Savannah River Site (Sec . 4 .3) :

•

DOE undertook an extensive geotechnical site characterization program at the Salt

Waste Processing Facility site, involving drilling and sampling of subsurface data,

laboratory analysis of samples, and geotechnical analyses . Completion of the

geotechnical engineering work at the Salt Waste Processing facility, including

comprehensive DOE and peer reviews, will be critical to demonstrating that the design

is adequate to withstand seismic hazards . Significant improvements in the structural

analysis methodologies are also being implemented . (Board letters dated August 27,

2004 and January 10, 2007)

•

DOE successfully and safely started up the Tritium Extraction Facility . (Board letter

dated December 19, 2002)

• DOE corrected weaknesses in the hazards analysis for the 3013 Container Surveillance

and Storage Capability Project . (Board letter dated January 29, 2007)

Y-12 National Security Complex (Sec . 4 .4) :

•DOE assigned additional personnel to monitor construction activities at the Highly

Enriched Uranium Materials Facility and initiated other corrective actions in response

to the Board's observations . (Site Representative Weekly Reports)

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 2006, DOE has taken actions to strengthen the

technical competence of its contractors and federal employees, to establish and implement safety

standards, and to improve the quality of engineered safety 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 . Cross-references are provided to sections in

the body of this report where further details can be found .

•

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

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

(Recommendation 2004-1 )(Sec. 5 .1 .2, 5 .1 .3)

•

DOE developed a new integrated safety management manual to clarify its expectations

concerning implementation of integrated safety management by DOE personnel .

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

1 3
• DOE developed and implemented a process and criteria for delegating authorities to

field personnel for fulfilling assigned safety responsibilities . (Recommendation

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

•

DOE developed and executed a Senior Technical Safety Manager Course .

(Recommendation 2004-1 )(Sec. 5 .1 .2, 5 .4 .1)

•DOE developed a directive on "operating experience" and provided direction and a

schedule for implementation . (Recommendation 2004-1 )(Sec . 5 .1 .2)

•

DOE established two Central Technical Authorities with associated support staff that

centralize technical expertise and operational awareness to assure adequate and proper

implementation of nuclear safety requirements . (Recommendation 2004-1 )(Sec . 5 .1 .2)

•

DOE strengthened the oversight of nuclear criticality safety through more effective

reviews by the Criticality Safety Support Group . (Recommendation 97-2)(Sec . 5 .3 .6)

•

DOE restructured and strengthened the Corporate Technical Intern Program .

(Recommendation 2004-1)(Sec. 5 .4 .1)

•

DOE developed and issued a Ventilation System Evaluation Guidance document that

identifies a set of design and performance attributes that ventilation systems are being

evaluated against for identification of potential upgrades . (Recommendation

2004-2)(Sec. 5 .3 .2)

Outstanding Safety Problems of Defense Nuclear Facilities

Integration of Safety in the Design of New Defense Nuclear Facilities

The Board believes that improvement in the incorporation of safety in design of new

defense nuclear facilities is necessary . Therefore, the Board began a series of public hearings,

one in December 2005 and a second in July 2006, concerning the integration of safety in design .

During the initial public hearing, the Board focused on the adequacy of DOE's existing

directives related to the design of new facilities . As a result of the Board's first public hearing,

DOE acknowledged that safety was not being integrated consistently into the early stages of the

design of new defense nuclear facilities . DOE is revising its relevant directives . These directives

are expected to mandate an appropriate set of requirements designed to better integrate safety

into the design of new defense nuclear facilities at the earliest stages of project management .

During the second public hearing, the Board further explored integration of safety in design

and the progress being made in implementing DOE's safety in design initiatives. DOE has made

some progress in revising its directives . The Order was recently revised to reflect senior DOE

management's objective of early integration of safety into the design process. In particular, DOE

Order 413 .3A, Program and Project Management for the Acquisition of Capital Assets, requires

that safety design reports be prepared at the conceptual design and preliminary design stages, in

addition to the preliminary documented safety analysis prepared at the final design stage . These

1 4
reports are envisioned to contain an evaluation of the safety aspects of the design . The Order

delineates the need to charter an Integrated Project Team led by the Federal Project Director at

the conceptual design stage and further clarifies the safety role of DOE's Central Technical

Authority, Chief of Defense Nuclear Safety, and Chief of Nuclear Safety . These are positive

changes that will enhance safety in design .

The Board is being proactive with DOE in promoting the timeliness of issue resolution .

The Board's staff has met with DOE headquarters personnel, federal project personnel, and

contractor personnel to discuss several key projects, including the Uranium Processing Facility

at the Y- 12 National Security Complex and the Integrated Waste Treatment Unit at Idaho

National Laboratory. These meetings have been aimed at . developing a mutual understanding of

the safety requirements for these new facilities and establishing common expectations for early

design maturity and early identification of safety issues and their resolution .

Finally, the Board has scheduled a third public hearing for March 2007 . This hearing will

be devoted to early issue identification, communication of Board issues to DOE, issue

management, and timely issue closure or resolution .

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 measures to protect the public, workers, and the environment from nuclear, chemical,

and physical hazards . The identification of hazards and development of protective measures

should be integrated .

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

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 has been made in 2006, overseeing the execution of DOE's implementation plan will

continue to be a major focus of the Board's work in 2007 .

1 5
Reliable Operation of Safety Systems

The Board remains committed to ensuring that DOE properly maintains safety systems at

defense nuclear facilities . Many defense nuclear facilities were constructed decades ago .

Especially in light of the aging of these facilities, protective features must be maintained in a

serviceable and effective condition . For new facilities, on the other hand, the Board focuses its

attention on ensuring that safety systems are correctly identified, designed, and constructed .

Unfortunately, the Board continues to identify weaknesses in programs critical to

continued reliable operation of safety systems : maintenance, testing, surveillance, quality

assurance, detection and removal of counterfeit parts, configuration management, training,

conduct of operations, and confinement strategies . DOE is working to make improvements in

many of these areas in response to related recommendations from the Board, such as

Recommendations 2000-2; 2002-1, 2004-1, and 2004-2 . However, as DOE continues to extend

the life of aging facilities, and budgets tighten, there is constant pressure to reduce the number of

safety systems, to provide less effective maintenance, or to defer necessary infrastructure

improvements .

A typical example of this issue exists at the 9212 Complex at Y-12 National Security

Complex. This collection of structures, built between 1947 and 1958, has numerous seismic

deficiencies, including missing bolts, missing or structurally inadequate braces, and inadequate

beam supports . The Board highlighted these issues in letters dated April and November 2005 .

DOE's response indicated that the main long term action necessary to support safe operation is

to construct the planned Uranium Processing Facility, which will be designed to efficiently meet

modem safety and security requirements . However, DOE has not fully defined the remedies

required to keep the 9212 Complex operational prior to completion of the Uranium Processing

Facility. The Board will continue to stress to DOE the importance of ensuring the long-term

reliability of vital safety systems and the infrastructure needed to maintain them .

Safe Retrieval, Handling, and Stabilization of Nuclear Materials

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 some

sludge in suitable containers to prevent release to the environment but faces new challenges in

safely treating the sludge in a timely fashion .

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

storage 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 waste

levels in the tanks continue to make transfer and treatment operations difficult . Potential waste

leaks and mistransfers threaten the safety of workers and the environment. The Board works

with DOE to ensure that it continues to focus on the highest priority safety issues .

1 6
Many of DOE's facilities around the nation store large quantities of transuranic wastes in

drums, a significant portion of which are buried under soil and in poor condition . The drums

pose safety hazards, including contamination, high radiation, and potential explosions from the

generation of hydrogen gas and volatile organic compounds . The Board has urged DOE to

improve the consistency and rigor of the safety controls for these hazards . (Board letters dated

January 5, 2006, January 17, 2006, January 18, 2007 and January 29, 2007) Improved safety

becomes more important as DOE begins to retrieve and treat remote-handled transuranic wastes

that generate very high radiation fields and must be handled by remote-controlled equipment .

DOE is planning to ship remote-handled wastes from the Idaho Cleanup Project to the Waste

Isolation Pilot Plant in 2007 .

In 2006, the Board reviewed two principal deliverables of DOE's implementation plan for

Recommendation 2005-1 : (1) nuclear material packaging requirements and (2) a repackaging

prioritization methodology. The Board found that fundamental errors in analyses and narrowing

of scope had substantially precluded the intended benefits of both documents . The Board

identified these errors in analysis and reasoning in letters dated April 24, 2006 and May 1, 2006 .

DOE's responses, provided in letters dated June 8, 2006 and July 21, 2006, were not satisfactory

to the Board . Discussions between the Board and DOE resulted in a DOE letter dated July 27,

2006, rescinding several of its responses . Further discussions between the Board and DOE have

resulted in substantial progress toward resolving the Board's concerns . DOE subsequently

revised its implementation plan for Recommendation 2005-1 in a letter dated November 22,

2006, to reflect the delays in completing these two principal deliverables . The Board will

continue to hold DOE to commitments it made to improve nuclear material packaging for

protection of workers .

Deactivation and Decommissioning Operations

DOE continues to deactivate, decontaminate, and decommission many facilities at sites

such as the Idaho Cleanup Project, Hanford Site, Savannah River Site, Oak Ridge National

Laboratory, and the Miamisburg Closure Project . In the past, the Board has noted that operating

contractors lack the expertise to plan and conduct deactivation and decommissioning work .

(Examples include the Board's letters dated February 11, 2005 and February 14, 2005 .) In these

cases, DOE must bring in managers and workers who are familiar with the unique hazards of

these activities and who understand the continually changing nature of a facility undergoing

decommissioning . Specialists are needed in nuclear criticality safety, fire protection,

contamination control, and remote measurement of nuclear materials in piping, vessels, and

systems. The Board will continue to provide close oversight of these projects .

1 7
1.1 Background

The Defense Nuclear Facilities Safety Board is an independent federal agency established

by Congress in 1989. Simply stated, the Board's mandate under the Atomic Energy Act is safety

oversight of 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 . The site offices

provide the Board with a continuous presence 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 17 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 .

This Annual Report summarizes the Board's work during calendar year 2006 . 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 lists all

recommendations cited in this report, Appendix B lists all reporting requirements imposed on

DOE in 2006, and Appendix C contains a full list of the Board's 2006 correspondence .

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 .

1. Introduction

1 9
• 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 Competence - 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 specific hazards . Work instructions that are clear,

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

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

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

ensure a smooth transition from deactivation 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 48 formal recommendations, comprising 221 individual subrecommendations . In that same period of time, the Board has issued 184 reporting requirement

letters and held 94 public hearings .

1 .3

Strategic Plan

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

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

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

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

2 0
• Tons of radioactive and toxic materials throughout the defense nuclear complex,

some stored in an unstable state .

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

safety .

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

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

criticality events .

•

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

lightning .

Given these 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 .

21
2. Nuclear Weapons Operations

2.1 Safe 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 2006, the Board sought health and safety improvements in weapons

operations, requirements for the evaluation of weapons response to external stimuli,

implementation of the special tooling program, and implementation of multi-unit operations .

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

DOE 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 . On

November 2, 2006, the Assistant Deputy Administrator for Military Application and Stockpile

Operations issued a corrective action plan to implement 11 of the 20 recommendations from the

Top-Down Review . The Board is conducting its own review of the nuclear explosive safety

process and has identified a number of additional issues to be addressed in 2007 .

W88 Cell Operations . During 2006, Los Alamos National Laboratory requested that the

W88 program take steps to restart cell operations to perform disassembly and inspection on a

limited number of units to support a high priority, safety-related significant finding investigation .

In order to meet this request in a timely manner, the Pantex Plant contractor requested a

temporary exemption from the documented safety analysis requirements of 10 CFR (Code of

Federal Regulations) Part 830, Nuclear Safety Management, subpart B . In a letter dated

August 9, 2006, the Board requested that the Deputy Administrator for Defense Programs

consider compensatory measures for the proposed disassembly and inspection operations . In

addition, the Board requested justification for proposed rebuild operations and any additional

operations performed beyond the three units identified by Los Alamos, and that NA-10 consider

the impact of the proposed operations on the timely implementation of a Seamless Safety for the

21" Century process for W88 cell operations . The Deputy Administrator provided the requested

information to the Board and issued a temporary exemption limited to the disassembly and

inspection and rebuild of three specific units . Direct observation of sensitive operations by

laboratory experts was instituted as an additional safety measure .

To ensure a safe approach to restart of W88 cell operations, the Board observed the

limited scope nuclear explosive safety study, DOE's readiness assessment, and disassembly of

the first W88 unit, which was in process at the end of 2006 . The Board is continuing to press

DOE to develop a firm schedule for implementing an SS-21 process for W88 operations.

23
Recommendation 98-2 . NNSA management continued to provide the Board with

regular briefings on the status of commitments in the implementation plan for Recommendation

98-2. DOE completed the commitment to implement an SS-21 process for a weapons program

with insensitive main charge explosives by implementing such a process for the B61, B83, and

W87 programs in 2006.

In May 2006, DOE issued a revision to Hazard Analysis Reports for Nuclear Explosive

Operations (DOE-STD-3016), which was intended in . part to close the commitment in the

implementation plan for Recommendation 98-2 to provide further guidance on expectations for

the development and documentation of weapons response information . In a letter dated August

16, 2006, the Board provided comments to DOE on the revision to the standard . DOE briefed the

Board on its responses to the Board's comments and described its planned approach to ensuring

that hazard analysis reports and weapons response information were adequate . However, followup reviews by the Board found that there was still no clear plan for implementing improved

processes for developing and documenting weapons response information . Therefore, in a letter

dated December 15, 2006, the Board requested that the Final Assessment Report required by the

implementation plan for Recommendation 98-2 include an explicit description of DOE's plans

and criteria for review and approval of the design agencies' processes for expert elicitation,

expert judgment, and peer review as required by DOE-STD-3016.

Cell Gap Analysis. The Board evaluated calculations of leakage through gaps in cells .

These calculations were performed to better understand the consequences of potential accidents

at the Pantex Plant. Based on these calculations, leakage through cell gaps does not appear to be

an issue for accident scenarios involving single-unit operations. However, there is still a concern

that accident consequences for multi-unit operations involving certain systems in certain

facilities could challenge the evaluation guidelines . DOE will perform additional analyses to

provide assurance that the evaluation guidelines will not be challenged for multi-unit operations .

Electrostatic Discharge. The Board evaluated efforts by DOE and the weapons design

agencies to characterize potential electrostatic discharge effects and the response of sensitive

components to them . Progress has been made in defining the environments and the associated

hazards ; however, the Board has identified the need for additional clarification with respect to

furniture (e .g ., tooling and equipment), capacitive coupling between the insulting objects and

other nearby charged objects, the assumption of electrical isolation of tools within the

established standoff boundary, and resonance conditions and effects .

Special Tooling Program. In a letter dated December 15, 2004, the Board expressed

concern that continuing weaknesses in the Special Tooling Program could have an adverse

impact on the safety of nuclear explosive operations that rely on specially designed tools to

eliminate or minimize hazards . In response, DOE conducted a comprehensive, independent

review of tooling program deficiencies and committed to implementing corrective actions . The

Board reviewed the program in March 2006 and determined that the safety and efficiency of

nuclear explosive operations had been enhanced .

Seamless Safety for the 21st Century . In 2006, the Board evaluated the start-up of the

Seamless Safety processes for the W87 and B61 Disassembly & Inspection and Rebuild

Programs and the B83 Disassembly & Inspection Program . The enhanced processes utilize

24
upgraded procedures, redesigned tooling, and fewer handling and lifting steps . These

improvements make the operations significantly safer and more efficient than their predecessors .

Safety of Dismantlement Operations . The Board evaluated process development and

execution of the W56 dismantlement campaign at Pantex. The Board urged DOE to ensure that

laboratory expertise, both active and retired, was applied to resolve technical challenges that

arose to help ensure the safe and successful completion of the dismantlement campaign .

Dismantlement of all W56 war reserve units was safely completed in June 2006 .

The Board continued to evaluate DOE's plans to dismantle an older weapons system not

protected by modem safety controls . The Board expressed concern to DOE regarding proposed

disassembly activities at non-DOE facilities that did not have adequate safety programs and

systems. DOE no longer plans to use such facilities ; dismantlement operations are now planned

for Pantex facilities .

Conduct of Operations . In response to a Board letter issued in May 2005 identifying

deficiencies in the conduct of nuclear explosive operations at Pantex, DOE initiated efforts to

address the cause of the deficiencies and to develop both near- and long-term plans to improve

the conduct of operations . After a follow-up review, the Board issued a letter to DOE in March

2006, re-emphasizing the importance of a consistently high degree of formality in the conduct of

nuclear explosive operations, and favorably noting the extensive involvement of senior

contractor management in developing and implementing improvements in conduct of operations

at Pantex. As proposed improvements are implemented and the process matures, the Board

expects to see continued improvement in this area . The Board is continuing to evaluate

improvements in the formality of work through daily operational oversight provided by its site

representatives .

Multi-Unit Operations. The Board is evaluating the safety implications of the

implementation of multi-unit nuclear explosive operations at Pantex, which are being pursued in

support of increasing throughput . In response to the Board's observations, Pantex is taking a

more comprehensive approach to evaluating the implementation of multi-unit operations,

including analyzing human factors considerations . In addition, the Board has urged Pantex to

become more closely involved with studies being performed by the design agencies that will aid

in evaluating the increase in risk associated with performing multi-unit operations .

Technical Safety Requirement Implementation . In October 2006, the contractor at

Pantex completed the implementation of more than 200 Technical Safety Requirements .

Continued engagement by the Board during this three-year effort resulted in the implementation

of some new controls and improved the overall quality of the safety basis documents . DOE has

so far verified implementation of 138 of these controls . The Board will continue to monitor

implementation of Technical Safety Requirements .

2 5
2.1 .2 Y-12 National Security Complex

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. Production activities include manufacture or re-manufacture of unique nuclear

weapons components . The Board's most recent efforts to improve safety at Y-12 concentrated on

highly enriched uranium processing, conduct of operations, fire protection, and the safety of

several new or modified processing capabilities .

9212 Complex Seismic Deficiencies . The 9212 Complex at Y-12 is a collection of

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

the.complex's safety basis in 2004, DOE noted numerous seismic deficiencies, including

missing bolts, missing or structurally inadequate braces, inadequate beam supports, and designs

that are deficient when measured by current design requirements for nuclear facilities . In

addition to the facility structure, internal systems are subject to seismic failure, including tall

glass columns and sight glasses, can restraints, storage racks, and storage tanks .

In response to Board letters issued in April and November 2005, DOE agreed to perform

maintenance-related fixes and other practical facility modifications to the 9212 Complex and to

perform a review to identify other actions needed to support safe operations . DOE provided the

results of this review to the Board in November 2006 . The reviewers concluded that the most

practical approach to improving the safety posture of the 9212 Complex is to reduce the

inventory of nuclear materials in the facility . DOE plans to increase maintenance funding and

pursue other facility infrastructure improvements while working to accomplish that inventory

reduction .

DOE's response also indicated that the main long term action necessary to support safe

processing of highly enriched uranium at Y-12 is to construct the planned Uranium Processing

Facility, which will be designed to efficiently meet modern safety and security requirements . By

year's end, however, DOE had not defined the point at which more aggressive remedies would

be required to keep the 9212 Complex operational, should this facility be delayed, and what

those remedies would entail . The Board is continuing discussions with DOE on this matter .

9212 Complex Safety Analysis . The Board reviewed a draft version of the documented

safety analysis for the 9212 Complex, the final Y-12 facility to implement a safety basis in

accordance with 10 CFR Part 830 . The Board noted weaknesses associated with the calculation

of off-site consequences that resulted in improper classification of safety systems, including

certain fire protection systems . The Board communicated these issues to DOE in a letter in

February 2006 . In response, DOE upgraded the classification of key fire protection systems to

safety-class . Discussions continue with DOE on the safety analysis methodology for Y-12

facilities .

Conduct of Operations. The Board had noted overall improvement in the proper

conduct and formality of nuclear operations at Y-12 during recent years . However, following

several operational errors and events at this facility, the Board urged DOE to consider special

action to achieve consistent, disciplined operations in Y-12 nuclear facilities. Examples included

2 6
failure to adhere to criticality safety requirements, an inadvertent hazardous gas release, and

conduct of a nuclear operation without proper authorization . DOE evaluated the concerns and

concluded that the events were generally caused by lack of adherence to procedures or nonconservative decisions by operations personnel upon encountering an unanticipated condition .

DOE developed a plan in December 2006 that outlines actions to address these causes . With

proper implementation, the plan should improve conduct of operations at Y-12 .

Uranium Holdup Survey Program . The Y-12 Uranium Holdup Survey Program is used

to monitor accumulations of enriched uranium in process systems to protect against an

inadvertent criticality . DOE developed a corrective action plan to address issues identified by

both DOE's and the Board's assessment in 2005 and for operational events in 2006 where the

program failed to identify fissile material accumulations . During 2006, DOE made progress on

equipment upgrades and in improving the formality in identifying and responding to high

accumulations of enriched uranium. DOE also implemented a new approach to evaluate uranium

holdup using design features, periodic cleanout, and routine hold-up monitoring in combination

for all uranium process operations that rely on the holdup program.

Criticality Safety. In April, the Uranium Holdup Survey Program indicated a large

holdup in a filter in a system providing vacuum to uranium casting furnaces . Initial criticality

safety assessments concluded that lack of moderation was the only remaining contingency

precluding a criticality accident. Subsequently, a moderator (oil) was observed to have leaked

from the filter housing . This represented a serious safety concern . The Board provided input

regarding assay procedures, criticality calculations, and the approach to filter cleanout for DOE's

consideration in developing a recovery plan . The Board's input resulted in a more demonstrably

safe recovery operation .

Fire Protection. In response to Board correspondence in 2002, DOE developed a

ten-year comprehensive improvement plan for fire protection at Y-12 . Significant improvements

were subsequently made in many facets of fire protection, such as maintenance of systems,

analysis of fire hazards, and inspection of fire barriers . Progress stalled in 2006 due to a cut in

funding for the project . The Board queried DOE on plans for completing the project . DOE

committed to provide a revised plan in early 2007 .

Quality Assurance . Because of quality assurance problems found during construction of

the Highly Enriched Uranium Materials Facility, and other site-wide quality assurance problems

identified in early 2006, DOE developed a site-wide corrective action plan . The Board reviewed

the plan and provided specific comments . Based on this feedback, DOE chartered a local

steering group to review the effectiveness of completed corrective actions, and the contractor

provided corporate-level resources to conduct a review of corrective action progress .

Conduct of Engineering. In 2005, Y-12 personnel discovered that the design of a new

vessel installed for blending enriched uranium materials would not preclude a criticality accident

in a water intrusion scenario. A design change was necessary to correct this deficiency .

Subsequently, the Board found that a planned Y- 12 investigation of this engineering deficiency

had not been completed. In response to an inquiry by the Board, Y-12 completed the

investigation and developed corrective actions . The Board found that the corrective actions did

not fully address the lack of an appropriate design review of the new installation. At year's end,

27
Y-12 was evaluating its engineering protocols regarding performance of design reviews for the

installation of new process equipment and systems .

2.1 .3 Savannah River Site Tritium Operations

Tritium Extraction Facility. The Tritium Extraction Facility will be used to extract

tritium from target rods irradiated in commercial light water reactors . The extracted tritium will

be used to replenish tritium reserves for the nation's nuclear weapons stockpile . During 2006,

the Board reviewed startup preparations, observed readiness reviews conducted by the contractor

and by DOE, and as the year ended, monitored the startup of nuclear operations . During the

readiness reviews, the contractor demonstrated the ability to safely perform extraction

evolutions, but did not demonstrate the ability to routinely conduct these evolutions without

frequent work interruptions or compensatory actions to address equipment reliability issues .

Frequent problems were encountered with the ventilation system, the Tritium Rod Preparation

Module, various cranes, several electronic procedures, and the Tritium Air Monitoring System .

While these problems were handled correctly, the Board encouraged the Savannah River Site to

take full advantage of site programs for System Health Reports and performance monitoring,

because repeated equipment problems can lead to complacency (i .e ., deficient conditions

become viewed as normal) and other conduct of operations problems .

2.1.4 Nuclear Material Packaging

Recommendation 2005-1. The Board issued Recommendation 2005-1 to provide more

reliable protection for workers from the hazards associated with storage and handling of nuclear

materials. The recommendation stated, and DOE accepted, the fundamental principle that this

would be achieved by issuing a requirement that "nuclear material packaging meet technically

justified criteria for safe storage and handling ." In 2006, the Board reviewed two principal

deliverables of DOE's implementation plan for Recommendation 2005-1 : (1) a methodology for

assigning priorities to repackaging operations, and (2) a manual for these operations .

The methodology was issued by DOE on March 31, 2006 . In a letter dated April 24,

2006, the Board pointed out errors in analysis and reasoning . DOE's response, provided in a

letter dated July 21, 2006, was not satisfactory to the Board and was partially rescinded by DOE

in a letter dated July 27, 2006, pending further discussions between DOE and the Board . DOE

subsequently revised its implementation plan for Recommendation 2005-1 in a letter dated

November 22, 2006, noting that the methodology was being further evaluated based on

comments from the Board and would be revised and reissued, if warranted, by February 28,

2007.

In its implementation plan, DOE committed to issuing packaging requirements for

"materials that are stored outside of an approved engineered contamination confinement barrier,

such as a glovebox or packages meeting DOE-STD-3013 and/or DOE-STD-3028 ." These

requirements are to be issued as a new DOE Nuclear Material Packaging Manual, a draft

version of which was sent to Board for comment on March 31, 2006 . In a letter to DOE dated

May 1, 2006, the Board identified deficiencies that would undermine the safety benefits of the

manual if not appropriately resolved, such as wording that would allow the sites to exclude many

hazardous nuclear materials from the scope of the manual without ensuring that adequately

28
engineered protection would be provided for workers . DOE's response, provided in a letter dated

June 8, 2006, was not satisfactory to the Board . Further discussions between the Board and DOE

have resulted in substantial progress toward resolving the Board's comments on the draft

packaging manual . DOE's revised implementation plan for Recommendation 2005-1 commits to

submitting the packaging and storage requirements document into DOE's Directives System by

February 28, 2007 . The Board will continue to ensure that DOE meets its commitment to

improve nuclear material packaging for protection of its workers .

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 DOE weapons

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

In 2006, a new contracting structure was put in place for management of the laboratory . The

Board focused its attention on institutional corrective actions, federal oversight, active

confinement ventilation, nuclear criticality safety, fire protection, and transuranic waste

operations .

Institutional Corrective Actions . The Board spent considerable effort, including

holding a public hearing on March 22, 2006, reviewing DOE's institutional corrective action

programs and heightening awareness of the need to maintain these programs through contract

transition. Corrective actions focus on key areas including safety, quality assurance, software

quality assurance, conduct of engineering, safety bases, conduct of operations, environmental

risk management, and training . The Board has urged DOE to adequately fund corrective action

plans .

Federal Oversight. On October 1, 2006, DOE began a two-year pilot of a new federal

oversight model at the Los Alamos Site Office . The pilot increases the federal presence in

nuclear and high hazard facilities and relies on the contractor's assurance systems to monitor less

hazardous operations . The Board objected to the concept of the pilot and raised specific concerns

including the lack of compensatory measures in oversight for the period of time it takes for the

contractor's assurance system to reach full effectiveness and maturity ; the absence of federal

oversight of radiological facilities under the pilot ; and significant weaknesses in the technical

capability of the federal workforce .

Confinement Ventilation at the Plutonium Facility . The current safety basis for the

Plutonium Facility relies on a passive confinement strategy that does not credit active

confinement ventilation for protecting the public from postulated accidents . In response to issues

raised by the Board, a comprehensive set of airflow calculations was performed to estimate

29
potential releases under accident conditions . The analysis demonstrated that the passive

confinement strategy was inadequate, and the laboratory developed preliminary compensatory

measures and alternatives for the confinement strategy . Under the implementation plan for the

Board's Recommendation 2004-2, confinement ventilation at this facility is now being assessed

on a high priority basis with an accelerated schedule . The Board will continue to review and

provide feedback to DOE.

Fire Protection. On May 15, 2006, the Board received DOE's response to issues

previously identified by the Board regarding the need to define a multi-year strategy for timely

resolution of all fire protection deficiencies and achievement of site-wide improvements . Issues

requiring resolution included incomplete documentation and delays in the completion of

inspections, tests, and maintenance ; untimely implementation of fire hazard analysis

recommendations ; no formal plan to address the Baseline Needs Assessment for fire and

emergency services; no long-term contract for fire and emergency services with Los Alamos

County; and fire alarm systems in several defense nuclear facilities still requiring upgrades . DOE

is currently updating the strategy to reflect additional scope and funding adjustments . Overall,

the Board has succeeded in increasing management attention to the fire protection problems, but

these problems will take additional analysis, time, and attention to fully resolve .

Transuranic Waste Operations . The Board has been closely following efforts to safely

dispose of the laboratory's large inventory of transuranic waste, which is packaged in drums and

other containers within several hundred meters of the site boundary . Some of the highest

consequence accidents postulated at the laboratory involve this transuranic waste inventory . The

Board has urged DOE to expeditiously develop a viable disposition pathway for this waste .

Support of Nuclear Weapons Operations at Pantex . In August 2006, the Board

assessed the laboratory's protocols for support of operations at the Pantex Plant . With respect to

elements of the Board's Recommendation 2002-2, the Board found a lack of succession planning

for weapons system experts . The Board also observed a lack of progress toward developing a

formalized expert elicitation (or expert judgment) process for review of weapons response

information, which in part led to the Board's December 15, 2006, letter to DOE requesting its

plans for the review and approval of these essential design agency processes .

Power Grid Infrastructure Upgrade Project . In reports dated May 5, 1995, December

5, 1996 and September 22, 1999, the Board noted that a single-point failure vulnerability existed

in the high-voltage transmission lines that provide off-site power to the laboratory . A failure at

this single point, where aerial transmission lines from each of the independent feeds crossed,

could have isolated the laboratory from off-site power for an extended time until repairs could be

performed. In response, DOE initiated a project to eliminate this single-point failure

vulnerability by providing an independent power feed to the existing Western Tech Area

substation . Construction of the independent power feed was completed in 2006, and overall

project completion is scheduled for spring 2007 .

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

3 0
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 2006, the Board conducted reviews of resumption of operations in the

Plutonium Facility, configuration management of vital safety systems at the Superblock

facilities, criticality safety, fire protection, and conduct of operations .

Resumption of Plutonium Facility Operations. In January 2005, DOE's Office of

Independent Oversight and Performance Assurance issued a report identifying serious

deficiencies in the administrative control programs mandated by the Technical Safety

Requirements for the Plutonium Facility (including the configuration management program), as

well as deficiencies in the supporting analyses for safety systems . Because of these findings, the

laboratory suspended programmatic operations in the Plutonium Facility . The Board issued a

letter to DOE on March 8, 2005, cautioning against resuming operations until the assessment

report's findings had been adequately studied and requesting a report on planned corrective

actions . On October 11, 2005, DOE authorized the resumption of limited operations in the

Plutonium Facility using a process for achieving and verifying readiness found generally

acceptable by the Board . In April 2006, the Board observed the laboratory's readiness

assessment to remove the remaining compensatory measures and return to normal operations,

and determined that operations could safely resume . On May 23, 2006, DOE authorized the

laboratory to resume normal operations .

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

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

facilities . DOE responded on January 4, 2005, agreeing that prompt action needed to be taken to

review the configuration and condition of all vital safety systems in defense nuclear facilities at

the laboratory. During 2005, DOE completed evaluations of the application of configuration

management for the vital safety systems at Lawrence Livermore defense nuclear facilities and

developed plans to establish the needed configuration management program . During 2006, the

laboratory established procedures and processes to maintain an interim configuration

management system. The Board reviewed this system and found it to be reasonably adequate to

support operations while a more durable institutionalized program is developed and

implemented.

Criticality Safety. In response to the Board's Recommendation 97-2, DOE established

an interim capability at the laboratory in 2006 for hands-on criticality safety training that meets

DOE- STD- l 135-99, Guidance for Nuclear Criticality Safety Engineer Training and

Qualification . Training classes previously held at Los Alamos National Laboratory had been

halted pending the establishment of a suitable location . Lawrence Livermore conducted the first

hands-on training class in September 2006.

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

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

The Board seeks to ensure that if testing is resumed, it will be done safely . During 2006, the

Board focused its attention on the Device Assembly Facility, test readiness posture, capability to

dispose of a damaged nuclear weapon, subcritical experiments, and conduct of transuranic waste

operations.

Device Assembly Facility . The Device Assembly Facility is a key structure at the

Nevada Test Site, intended to house diverse operations including nuclear explosive operations

and criticality experiments . In 2004, the Board requested that DOE assess the Device Assembly

Facility's safety systems and management programs . DOE attempted to respond by using the site

office's assessment program, but this was ineffective in delivering a comprehensive assessment .

The Board wrote to DOE 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 the Device Assembly Facility is ready for planned increases in the scope of work .

In response, DOE developed assessment plans for each vital safety system and safety

management program and began assessments in 2006 . Assessments and corrective actions will

continue in 2007 .

The Board evaluated the physical condition of the Device Assembly Facility and found

extensive rainwater leakage and extensive cracking in the facility's walls and floors . The Board

advised DOE in a letter dated March 18, 2005, that an immediate and thorough evaluation was

needed. DOE has taken suitable remediation actions, but the Board is still concerned that the

extensive cracking might have been the result of poor construction practices that adversely

affected the concrete's in situ strength . The Board has advised DOE that it would be prudent to

evaluate the in situ concrete compressive strength using non-destructive investigation

techniques, assess the potential for long-term rebar corrosion, and assure confinement and leak

tightness of the bays and cells . However, DOE has declined to perform in situ testing of the

concrete . The Board is considering further action on this subject .

Damaged Weapons . The Board has consistently highlighted to DOE the need to develop

the programs and infrastructure necessary to safely dispose of a damaged nuclear weapon or

improvised nuclear device . G Tunnel at Nevada Test Site is the location DOE has selected for

these activities . In a March 28, 2005 letter to DOE, the Board noted the slow progress in defining

and executing an action plan for addressing known problems with G Tunnel . The Board

subsequently determined that DOE no longer had a clear plan for meeting this programmatic

need. In a June 19, 2006 letter to DOE, the Board requested that DOE explain the required state

of facility readiness and its plans for safety improvements, because it did not appear the mission

and hazards had changed . DOE responded with a new statement of policy for the disposition

mission at the Test Site, including a new scope of operations at G Tunnel . In follow-up

discussions, DOE stated that a revised safety analysis is being developed that will identify safety

controls and upgrades appropriate for the new scope of operations . The Board expects the new

analysis to be available for review in 2007 .

Subcritical Experiments. The Board reviewed preparations for subcritical experiments

at the Test Site and identified inadequate nuclear safety management programs . DOE made

improvements for the UNICORN experiment in 2006 in areas such as safety basis reviews,

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

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

DOE that it is essential to carry the improved practices and formality forward for future

subcritical experiments and as part of maintaining nuclear test readiness .

Safety Basis Reviews. The Board continued to review the safety bases for nuclear

facilities and activities, including the Device Assembly Facility, Criticality Experiments Facility

Project, Ula Complex, Radioactive Waste Management Complex, G Tunnel, subcritical

experiments, and onsite transportation . Although the safety bases are improving substantially, in

2006 the Board identified deficiencies in submitted documented safety analyses and technical

safety requirements, classification of a facility, and in a Transportation Safety Document .

Several iterations of DOE review and document revision are needed to develop and implement

adequate safety bases .

Lightning Protection and Electrical Systems. In 2003 and 2005, the Board noted

deficiencies in lightning protection and in electrical systems . In the past three years, DOE has

made gradual improvements . In 2006, a site-wide directive for the lightning protection program

was completed, as well as lightning protection studies . As a result, the Test Site now has a

technical basis to identify appropriate controls for lightning protection for hazardous operations

and has implemented a site-wide lightning protection program and controls . Remaining electrical

safety issues include oil-insulated transformers at the Device Assembly Facility, an antiquated

ventilation system in G Tunnel, and the need to demonstrate the adequacy of the Faraday cage in

the operations alcove in G Tunnel .

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 . In September 2004, the

Board issued a letter questioning the adequacy of safety bases at Sandia . Subsequently, the

Board issued a letter asking for a schedule of actions to be taken to ensure that integrated safety

management is fully implemented at Sandia . Follow-up reviews performed by the Board during

2006 found that DOE has continued to make progress toward completing the corrective actions

for the identified deficiencies .

2.2 .5 Research and Development for Explosives Safety

The Board reviewed research and development on high explosives and weapon detonator

safety for Pantex Plant operations, as conducted at both Los Alamos and Lawrence Livermore

National Laboratories. The laboratories are testing detonators for electrostatic discharge hazards

and reviewing the safety of operations with certain detonators at Pantex . One very positive

outcome has been the installation of special static dissipative flooring in certain Pantex Plant

facilities as an engineered safety control to mitigate electrostatic discharge concerns for a

weapons system. The Board also reviewed work at Los Alamos and Lawrence Livermore to

determine the effects of aging on weapon explosives . Low-velocity impact and mechanical

strength testing are being used to model and predict the properties of aged explosives . The Board

observed from these data that a certain aged explosive was safe for planned operations .

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DOE briefed the Board on the Enhanced Surveillance Campaign in December 2006 . This

campaign has funded significant research and development on the effects of aging on numerous

stockpile components with safety implications . Recent accomplishments include research and

development support for stockpile transformation and infrastructure, significant finding

investigations, annual assessments of weapons systems, and new diagnostics for stockpile

surveillance.

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3. Nuclear Materials Processing and Stabilization

3.1Stabilization and Storage of Remnant Materials

3.1 .1 Complex-Wide Program

Nuclear Material Stabilization . The Board provided significant oversight of DOE

efforts to improve the safety posture of remnant nuclear materials throughout the DOE complex .

HB-Line operators at the Savannah River Site stabilized the final quantities of neptunium

solutions included in the scope of Recommendation 2000-1 . This activity marks the completion

of all commitments under this recommendation at the Savannah River Site . However, the Board

continues to monitor the safety of unstabilized materials still in storage at the Hanford Site and

the Los Alamos National Laboratory . Details of these activities are provided in later sections of

this report .

Nuclear Material Consolidation, Storage, and Disposition . For several years, DOE has

attempted to develop a coordinated plan for the consolidation and disposition of nuclear

materials that are excess to national security needs . Some activities have proceeded on an

individual basis, but an integrated, complex-wide plan does not yet exist . In March 2005, the

Secretary of Energy chartered the Nuclear Material Disposition and Consolidation Coordination

Committee to develop such a plan . This committee continues to assemble parts of the plan, but

progress has been slow . The Board meets regularly with the chairman, of the committee and

provides feedback on potential safety issues .

This year, the committee approved an implementation plan for the consolidation of

plutonium-239 materials from several DOE sites to one location. However, the plan is

considered predecisional until DOE submits its fiscal year 2008 budget request to Congress . If

implemented, this plan will represent a significant step forward in material consolidation . The

plutonium-239 plan is the first of eight plans to be approved . The second plan, addressing the

consolidation and disposition of uranium-233 materials, is in draft form . The other plans,

addressing the consolidation of plutonium-238 and removal of excess materials from specific

DOE sites remain at the conceptual planning stage .

3.1 .2 Plutonium

Plutonium Stabilization, Los Alamos National Laboratory . Operators at the Los

Alamos National Laboratory are 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 . The materials

include metals, residues, and oxides of both weapons grade and non-weapons grade plutonium .

Many of these items are stored in containers not suitable for long-term storage, and therefore,

continue to warrant stabilization or repackaging on a priority basis . The Board continues to

closely monitor the storage conditions and stabilization efforts at the Los Alamos National

Laboratory.

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Adequacy of Plutonium Storage at the Savannah River Site . In 2006 the Board issued

its third annual report to Congress on plutonium storage at DOE's Savannah River Site . DOE

completed all but one of the actions required to improve storage conditions at the site, including

removing combustible materials to improve the fire protection posture . The unfinished task

(suggested by the Board) is to upgrade the fire protection system in the K-Area Materials

Storage Facility. While DOE has planned to complete this activity, it is unclear whether funding

will be available to do the work in fiscal year 2007 .

3.1 .3 Uranium

Oak Ridge National Laboratory. The Board began its design review of the rebaselined

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

Laboratory. Following direction from Congress, DOE will continue the primary mission of

downblending the material for disposition but will no longer extract thorium-229 for medical

use. Current plans call for most of the downblended material to be disposed of at the Waste

Isolation Pilot Plant as remote-handled transuranic waste, with the remainder going to the

Nevada Test Site . The project design is about 90 percent complete . Building 3019 equipment

removal and facility modifications required prior to project construction will not begin until

Critical Decision-3A approval . The Board reviewed the revised preliminary documented safety

analysis to support Critical Decision-2/3A and advised DOE of deficiencies in fire protection

controls, ventilation and confinement, and administrative controls . The Board will provide

oversight to ensure that adequate safety controls are provided for this project .

3.1 .4 Neptunium

Oxide Production and Storage . The Board assessed the adequacy of the actions taken

by DOE to develop controls to ensure the purity of neptunium oxide at the HB-Line facility at

the Savannah River Site . Subsequent to the Board's inquiries, analysis of archived samples

revealed higher moisture content than anticipated . The presence of elevated levels of moisture or

other contaminants could lead to container pressurization, as well as concerns over flammability

and corrosion during storage . The suspect containers were restabilized, and additional process

controls and verification sampling have been implemented . The Board found that the enhanced

process controls, moisture sampling, and periodic impurity analysis provide adequate assurance

of product quality for parameters that could impact safe storage . DOE plans to store the

neptunium oxide at the Idaho National Laboratory and use it as feed to support the production of

plutonium-238 for use in radioisotope power systems .

Safe Storage at the Idaho National Laboratory. The Board continues to monitor the

storage of neptunium at the Materials and Fuels Complex at the Idaho National Laboratory . The

Board reviewed the neptunium storage plans and provided feedback to DOE regarding the

adequacy of the storage plans. As a result, DOE developed a new surveillance and maintenance

plan for this activity . DOE also continues the preparation of a Final Environmental Impact

Statement for the consolidation of plutonium-238 activities from across the complex to the Idaho

National Laboratory .

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3.2

Stabilization of Spent Nuclear Fuel

3.2 .1 Hanford Site

Nearly 50 cubic meters of radioactive sludge, including the corrosion products of spent

nuclear fuel, still reside in the K-East and K-West Basins at the Hanford Site . This sludge is the

only material at Hanford that remains to be stabilized under the Recommendation 2000-1

program. 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 . At the Board's insistence, DOE developed

a new implementation plan for Recommendation 2000-1 based on a formal risk assessment

process and more realistic assumptions . DOE issued the new implementation plan on November

28, 2005 . DOE completed the consolidation of bulk sludge, the first milestone in the revised

plan, on schedule . DOE also prepared and completed a rigorous readiness review process for the

startup of the system to transfer sludge between the basins . While DOE demonstrated adequate

procedures and operations, several equipment problems hampered operations after start-up .

Many of these problems required design changes and equipment modifications, and this is an

area the Board intends to follow closely .

The development of the system to treat sludge and package it for disposal has not had

similar success . DOE authorized procurement at the contractor's discretion . The Board found

that the incorporation of safety into design was behind schedule and posed an increasing risk to

the project . DOE conducted an independent review of this situation and rescinded the

contractor's procurement authority. DOE also considered a proposal to accelerate the closure of

the Hanford K-Area by transferring sludge to the T Plant at Hanford for storage and treatment.

The Board concluded that the proposal represented a change in the project baseline without a

supporting conceptual design or preliminary hazards analysis . DOE reached a similar conclusion

and determined that the lack of this information posed risks that did not justify the change in

approach. The Board plans to continue its close oversight of this project .

3.2.2 National Spent Nuclear Fuel Program

The Board monitored DOE's efforts to plan for spent fuel packaging and storage . DOE

plans to ship aluminum plate fuel from the Idaho Cleanup Project to the Savannah River Site for

reprocessing in H-Canyon beginning in 2010 . DOE plans to ship its stainless steel and Zircaloy

clad fuel from the Savannah River Site to the Idaho Cleanup Project for packaging and storage

pending shipment to the geological repository for disposal . These decisions were proposed at a

national program strategy meeting in July 2006 followed by an Energy Systems Acquisition

Advisory Board meeting, which approved the decision . The decision will require an amendment

to the Record of Decision removing melt-and-dilute as the preferred method of handling

aluminum plate fuel . The need for a packaging and shipping facility at Idaho was acknowledged .

Two alternatives being considered are a dry storage option previously designed under a

privatization contract and licensed by the Nuclear Regulatory Commission, and a direct

packaging option proposed by the current contractor at the Idaho Cleanup Project . An

independent cost evaluation team will evaluate the options and report by spring 2007 . DOE plans

to ship spent fuel from the Fast Flux Test Facility at Hanford to the Idaho Cleanup Project in

2007. The Board reviewed the safety of spent fuel storage at the Idaho Cleanup Project and

found the facilities and systems adequate to protect worker and public safety.

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3.3 Waste Management

3.3.1 High-Level Waste

Hanford Tank Farms

Tank Integrity. The high-level waste storage tanks at both the Hanford and Savannah

River Sites contain millions of gallons of radioactive waste that DOE plans to vitrify and put into

long term storage . Current forecasts are for continued use of these tanks for storage of the

radioactive waste until about 2040 . Corrosion controls are in place to extend the lives of these

tanks, and in general, these controls are working reasonably well . However, over the years, there

have been anomalous occurrences of pitting, crevice corrosion, and cracking in the tank walls .

These occurrences have caused the Board to encourage DOE to conduct fundamental studies to

better understand the ongoing corrosion mechanisms and improve corrosion controls to provide

greater assurance that the tanks will not develop leaks during their service lives . DOE has

responded positively . Activities in 2006 regarding tank chemistry and corrosion are noted below .

The Board questioned DOE's plans to change chemistry controls used to mitigate

corrosion in tanks at Hanford . DOE responded by establishing a corrosion testing program to

determine optimum waste chemistry limits for maintaining tank integrity . The first phase of this

program studied the effect of pH on corrosion . The results showed the pH could as be as low as

pH 10 without significantly increasing corrosion . To confirm the laboratory results, a corrosion

probe has been installed in double-shell tank AN-107 to continuously monitor in-tank corrosion .

In response to the Board's letter of June 1, 2005, citing unusual corrosion observations in

the vapor space of waste storage tanks at both the Hanford and Savannah River Sites, an expert

panel workshop was held at Hanford . The expert panel identified several mechanisms by which

corrosive species could concentrate on tank walls . A series of laboratory experiments to evaluate

these mechanisms will be conducted during 2007 .

Savannah River Site

High-Level Waste Management . The Board continued to monitor the high-level waste

system at the Savannah River Site . DOE is faced with many challenges while balancing the

priorities of safe storage of high-level waste, retrieval and treatment of the waste, and support for

facilities that depend on the waste system to remain operational . The Board reviewed DOE's

three-pronged strategy to remove and process the low-activity portion of wastes in the high-level

waste system. The first step includes operation of the Deliquification, Dissolution, and

Adjustment process, a small-scale waste treatment capability that removes low-activity liquid

waste from the tanks, thereby allowing greater flexibility in many aspects of tank farm

operations . Steps two and three include the design, construction, and testing of the Actinide

Removal Process and the Modular Caustic Side Solvent Extraction Unit (pilot-scale waste

processing facilities), which will operate until the Salt Waste Processing Facility comes on line .

DOE completed the construction of the pilot-scale waste processing facilities . Low-level

radioactive waste operations are expected to commence in fiscal year 2008 . The Board also

reviewed the safety of the design of the Salt Waste Processing Facility . Based on delays in

3 8
permitting and regulatory activities, the step one process has been delayed but is expected to

start up soon. DOE plans to update and reissue its high-level waste planning documents (i .e .,

Disposition Processing Plan and System Plan) to reflect these delays, and the Board plans to

review these documents .

Several of the original problems that led the Board to issue Recommendation 2001-1

continue to affect the Savannah River Site . These problems include limited tank space in highlevel waste tanks, delays in waste processing, mixed evaporator performance, and the fact that

one of the former In-Tank Precipitation tanks (Tank 48) has remained out of service for eight

years after the suspension of a failed precipitation process .

The Board believes that substantial progress must be made in 2007 or the lack of tank

space will begin to jeopardize important operations such as those at the H Canyon and the

Defense Waste Processing Facility . The Board continues to provide oversight of these high-level

waste systems.

Hydrogen Gas in Process Systems. Last year, the Board began reviewing the risks of

hydrogen accumulation in the piping and equipment at the Defense Waste Processing Facility .

The concern was that a hydrogen explosion could rupture the equipment and the resulting

fragments could damage nearby safety equipment . After significant discussion between the

Board and the Savannah River Site on the analyses, the Savannah River Site developed an

acceptable path forward : (1) pipes that could fail without fragmenting would have their design

credited ; (2) seal pots that could fail with fragmenting would be reinforced with a carbon/epoxy

composite wrap (approved for high pressure piping repairs) ; (3) components in personnel

corridors would be upgraded, reinforced, contained, isolated, or removed ; and (4) a safety

management program would be implemented to ensure proper safeguards during maintenance.

Idaho Cleanup Project

High-Level Waste Tank Closure. During 2006, the Board completed its review of

DOE's cleaning of high-level waste tanks and found the level of cleanliness adequate to protect

the public and the environment . Seven of eleven 300,000 gallon tanks and four 30,000 gallon

tanks were cleaned and found acceptable for closure by the State of Idaho . Concurrently, the

Nuclear Regulatory Commission issued its decision that the residual waste in the tanks was

incidental to reprocessing and concurred in DOE's decision under Section 3116 of the National

Defense Authorization Act of 2005 that the tanks could be closed in place with cement grout .

DOE grouted and closed three of the smaller tanks before the end of the year . The Board plans to

observe future tank closure operations at Idaho .

3.3.2 Low-Level Waste and Transuranic Waste

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 2006, DOE has successfully shipped more than 14,000 cubic meters of transuranic

waste to the Waste Isolation Pilot Plant . However, many thousands of cubic meters of waste

remain to be packaged and shipped . The Board remains concerned about the safety of the

3 9
workers there, who could be at risk from potential deflagrations and fires in transuranic waste

drums. The Board discussed these concerns with DOE, and site managers began to take action to

improve the safety controls associated with handling transuranic waste drums . The Board

expects to review these corrective actions in 2007 .

Accelerated Retrieval Project. DOE operates a second activity 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 performance

at the Accelerated Retrieval Project following a drum fire there in November 2005 which caused

an interruption in retrieval of transuranic waste drums until May 2006 . Site personnel made

several equipment and procedural changes to improve worker and public safety . However,

following resumption of retrieval activities, site personnel noted that one corner of the structure

covering the waste trench had settled into the ground . The corner settled far enough to cause

concern for the structural integrity of the facility . DOE took corrective action to stabilize the

foundation of the structure, but additional settling may occur . Additional Board review is needed

to assess the structural stability of this facility .

Oak Ridge National Laboratory Tank W-1A. Tank W-1A collected radioactive wastes

from analytical facilities at Oak Ridge National Laboratory between 1951 and 1986 . Leakage

from a pipe supplying this underground tank caused soil and groundwater contamination around

the tank. Due to the high projected radiation levels, the Board carefully examined work planning

for a campaign to retrieve contaminated soils for sampling and characterization in support of

eventual removal and disposal . In a January 2006 letter to DOE, the Board identified weaknesses

in various aspects of the integrated safety management program for the sampling effort . In

response, DOE took corrective actions including practicing the sampling process prior to startup

and employing improved radiological soil handling equipment and improved radiological

controls to minimize worker exposure . DOE safely completed the Tank W-1A soil sampling

effort in the summer of 2006 . Future efforts to complete all soil removal around Tank W-IA will

require additional Board oversight .

National Transuranic Waste Program . DOE stores large quantities of transuranic

waste on concrete pads and in soil-covered trenches at many sites, and is actively retrieving this

waste for shipment to the Waste Isolation Pilot Plant for disposal . Noting that significant

differences exist in the safety requirements governing such work at the various sites, the Board

encouraged DOE's initiative to develop a draft standard for the safe retrieval and

characterization of transuranic waste at these sites . The Board reviewed a draft of the standard

and will continue to interact with DOE to ensure that a consistent and enhanced approach to

safety is taken during transuranic waste retrieval, characterization, and shipping operations .

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 2006, the site

received and deposited more than 1,100 shipments of transuranic waste with a total volume in

excess of 10,000 cubic meters . Throughout 2006, the Board verified that these operations were

conducted safely . In late 2006, the Board reviewed preparations for remote-handled (high

activity) transuranic waste operations, including observation of a DOE operational readiness

review. As DOE makes final preparations for and begins receipt of the remote-handled

transuranic waste in 2007, the Board plans to provide direct oversight .

40
Soil Remediation at Hanford . The Board reviewed DOE's safety documentation and

work planning process for the 118-K burial ground at Hanford . DOE plans to exhume wastes

from the burial ground, repackage the waste, and dispose of it in modem waste facilities . The

Board found (1) confusing nuclear criticality safety controls and (2) safety documentation that

did not comply with guidance from DOE . The Board provided this feedback to DOE, which

resulted in DOE making the necessary changes to address these issues .

Transuranic Waste Drum Handling at Hanford . The Board reviewed hydrogen

controls for vented transuranic waste drums at Hanford and found the controls to be nonconservative. DOE was using a control level of 15 percent hydrogen, while the safe and

commonly accepted control level is 4 percent (the lower flammability limit for hydrogen) . After

this concern was communicated, DOE reduced the control level for hydrogen concentration in

vented drums to 5 percent. This action represented a significant improvement in worker safety

for these operations .

3.4Facility Deactivation and Decommissioning

3.4 .1 Overview

DOE's Office of Environmental Management continues to pursue accelerated

deactivation and decommissioning at some defense nuclear facilities, while other such work has

been delayed due to funding shortfalls . DOE completed closure activities at the Fernald Closure

Project and made significant progress in the cleanup of the Miamisburg Closure Project

(formerly called the Mound Site) . The Board observed much of the ongoing deactivation and

decommissioning work and found that weaknesses exist in the areas of nuclear criticality safety,

fire prevention, and conduct of operations . Although DOE has taken corrective actions to

strengthen these programs, additional improvement is needed . Lessons learned from completed

work are not always implemented at new closure sites . A positive observation is that a number of

personnel trained in deactivation and decommissioning have moved from existing and closed

sites to sites with new work, bringing with them valuable experience and lessons learned . The

Board has encouraged DOE to maintain the experienced deactivation and decommissioning

work force within the defense nuclear complex .

3.4.2 Fernald Closure Project

The Board reviewed and provided comments to DOE on the safety of final

decommissioning and closure project work at the Fernald Closure Project . In response, DOE

made changes to improve safety during the demolition of the silos waste treatment facilities and

during placement of low-level wastes in the on-site disposal cells . DOE completed all site

closure work in fiscal year 2006 . DOE transferred responsibility for continued site stewardship

from the Office of Environmental Management to the Office of Legacy Management .

3.4 .3 Miamisburg Closure Project

The Board reviewed the safety of closure activities at the Miamisburg Closure Project,

including the demolition of former production buildings and removal of contaminated soil from

site landfills . No significant safety issues were identified . Site closure work is complete, except

41
for the removal of contaminated soil from one landfill and the rail car loading area. The Board

plans to follow the deactivation and decommissioning activities on site through completion,

expected in fiscal year 2007 . Ownership of the site will be transferred to the Miamisburg Mound

Community Improvement Corporation for commercial use after all site cleanup work is

complete.

3.4 .4 Savannah River Site

The Board reviewed DOE's efforts to conduct deactivation and decommissioning work at

the Savannah River Site and concluded that the program is reasonably well run . DOE completed

deactivation and decommissioning in the T and D Areas and the Naval Nuclear Fuel complex .

The F-Canyon and FB-Line have been de-inventoried and placed in a cold, dark, and dry status .

The remaining decommissioning work is scheduled to be completed by 2025 .

3.4.5 Hanford Site

The Board conducted several reviews of deactivation and decommissioning projects at

the Hanford Site . DOE is engaged in a number of such activities at Hanford including demolition

of buildings in the 300 Area (former Pacific Northwest National Laboratory facilities),

decontamination at the Plutonium Finishing Plant, extensive soil and groundwater remediation,

and planning for deactivation and decommissioning of the K-Basins and the large "canyon"

facilities on site .

Due to the redirection of funding to higher risk projects, the Plutonium Finishing Plant

has been put into a reduced deactivation and decommissioning mode . DOE plans to continue

deactivation and decommissioning work during fiscal years 2007 and 2008 at about one-fourth

the previous level . All plant operating and vital safety systems will continue to be operated

during this reduced work period . DOE plans to resume this work at higher levels in fiscal year

2010 with a target of demolishing the facility to "slab-on-grade" by fiscal year 2016 . The

Board's reviews found that idle areas of the plant have been placed in safe condition. Life

extension studies of plant systems are in progress to determine upgrades that might be necessary

to keep the systems operating until fiscal year 2016 . The Board's reviews of these life extension

studies indicate that the vital safety systems should be adequately maintained .

The Board had noted high numbers of nuclear criticality safety nonconformances,

including violations of mass and spacing controls, that were occurring during operations . DOE

made significant progress in reducing these nonconformances from approximately five per

month 18 months ago to a current rate of approximately one per month . The techniques for

achieving this improvement were innovative and will provide valuable lessons learned for other

facilities with fissile material holdup .

3.4.6 Idaho Cleanup Project

The Board reviewed the deactivation and decommissioning activities at the Idaho

Cleanup Project and found an aggressive program to remove surplus facilities . The level of

staffing was judged optimum for this work. It consisted of a combination of experienced workers

from other sites, such as the Rocky Flats Environmental Technology Site, and experienced

42
personnel from Idaho. The Board found the work to be conducted in a manner that was

protective of the workers, the public, and the environment . The most hazardous facility is the

former Idaho Chemical Processing Plant, which was used to process spent nuclear fuel from the

on-site test reactors and from the U .S . Navy until 1992. DOE initiated characterization and

planning for deactivation and decommissioning of the Idaho Chemical Processing Plant in fiscal

year 2006. The Board plans to closely monitor this high risk deactivation and decommissioning

activity .

4 3
4. Nuclear Facilities Design and Infrastructure

4.1 Introduction

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 . There has

been a substantial increase in the number of design and construction projects under the Board's

jurisdiction . DOE has undertaken design and construction projects with a projected total cost of

about $20 billion. The Board continues to expend extensive resources to ensure that designs for

defense nuclear facilities incorporate multiple layers of safety controls commensurate with the

hazards presented .

The Board is required by statute to review the design and construction of defense nuclear

facilities, which must be designed and constructed in a manner that will support safe and

efficient operations for 20 to 50 years . This demands an exacting design process, guided by

integrated safety management principles, that will ensure appropriate safety controls are

identified early in the design. The Board expects the design and construction process for defense

nuclear facilities to demonstrate clear and deliberate use of integrated safety management

principles, core functions, and manuals of practice .

The Board began a series of public hearings in 2005, continuing through 2006,

concerning the integration of safety in design. As a result of these public hearings, DOE has

established new expectations for identifying and resolving safety issues earlier in the design

process, revised the existing DOE Order for project management, and is developing more

detailed guidance for project management. Further, DOE is developing a new standard to

implement a more rigorous approach to safety-in-design. The Board is preparing for a third

public hearing on integration of safety into design that will consider early issue identification,

communication between the Board and DOE, and timely resolution of issues .

House Conference Report 109-702, issued September 29, 2006, directed the Board and

DOE to continue discussion on the timely identification and resolution of technical differences

over design standards and other issues at DOE's nuclear facilities . The Board is required to

provide quarterly reports to the Congressional defense committees to identify and report the

status of significant unresolved issues .

4.2Hanford 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, as well as

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 will be

transferred to the Low-Activity Waste facility, where it is mixed with glass-forming materials

and converted to a stable borosilicate glass, or "vitrified ." The glass canisters from the LowActivity Waste facility are subsequently placed in an onsite, near-surface disposal facility . The

high-activity waste stream is transferred from the Pretreatment facility to the High-Level Waste

45
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 . Work on the Pretreatment and High-Level Waste

facilities has been temporarily halted by DOE to address budget issues . In the meantime, the

Board has continued its review of the design and construction of important-to-safety structures,

systems, and components . During 2006, the Board's activities primarily consisted of considering

the resolution of previously identified issues .

Structural Design . In response to a finding by the Board that seismic requirements were

not sufficiently conservative, DOE determined that these requirements had been underestimated

by about 40 percent. DOE is now evaluating the effect of this increase on the design of the

structure and equipment and, using state-of-the-art techniques, is developing new data to resolve

some uncertainty in the modeling used to predict the seismic hazard . DOE has undertaken a

seismic borehole project under the direction of the Pacific Northwest National Laboratory . Three

deep boreholes and one deep corehole have been drilled adjacent to the construction site . Once

all of the subsurface data is collected, confi oratory ground motion calculations will be

performed. Pacific Northwest. National Laboratory is expected to form a peer review panel that

will review the subsurface data and recommend how these data should be used to estimate

earthquake ground motion . In a September 6, 2006 letter to DOE, the Board reiterated its belief

that the updated ground motion criteria provide a reasonably conservative basis for validating the

design. This conclusion was based on an analysis (using a conservative selection of soil and rock

properties) that addressed recognized uncertainties in subsurface material properties . The Board

anticipates that ground motion modeling using data from the drilling program will validate the

seismic design ground motion . The Board raised several issues specifically regarding the

structural design : inadequate modeling, no clear seismic load transfer capability in the structure,

and an inadequate finite element analysis . DOE developed new structural design criteria that

addressed the issues raised by the Board .

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 is completing calculations to

determine which steel members must be coated . The Board is also reviewing DOE's effort to

repair weather damage to coatings, and the validation of the fire rating of coatings applied by a

method not meeting code requirements .

Hydrogen Gas Hazards . DOE significantly underestimated the impact of hydrogen

hazards on pipes and small process vessels and components . At the urging of the Board, DOE

has continued to evaluate design solutions to address the issue and re-evaluated and issued new

design criteria to ensure the design remains fully protective of the public's health and safety .

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 . In a letter to DOE

46
dated September 7, 2005, the Board pointed out weaknesses in the design for confinement of

materials and worker protection . DOE subsequently conducted an independent review and

further analyses of hazards, leading to improvements in the design .

K-Basin Closure Project Sludge Treatment. Sludge treatment is a sub-project in the

overall K-Basin Closure Project . The Sludge Treatment Project is a major modification to two

operating facilities that will provide capability to treat waste sludge from corroded spent fuel and

package it for disposal . The project is approaching what would be Critical Decision-3 (Start of

Construction) . The Board has identified portions of the preliminary documented safety analysis

that are based on the conceptual and preliminary design instead of the final design . A revised

analysis based on the final design is expected to be delivered in early 2007 . At that point, the

Board can complete its review of the adequacy of the design .

Interim Secure Storage Facility . The Interim Secure Storage Facility was a new project

at Hanford to store the site's inventory of plutonium until 2035 . The Board questioned DOE's

application of project management requirements to the project. DOE's project team subsequently

developed a critical decision package for approval which, upon further review, revealed that the

mission need was not justified . DOE eventually terminated the project in favor of consolidation

of plutonium storage off-site .

4.3

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 reviewed the preliminary design of the facility, focusing on the preliminary hazards

analysis, proposed safety systems, and criticality safety strategy. The Board identified

weaknesses in the hazards analysis, which the contractor agreed to address . Based on the Board's

Recommendation 2004-2, the contractor discovered that the preliminary facility design did not

protect safety-related filters from excessive soot loading during fire events . The design and

functional classification of the ventilation and fire protection systems were subsequently

modified, though DOE has not yet approved the new design . The Board also encouraged DOE to

ensure that its decision regarding exclusion of criticality accident alarms in the facility takes into

account the revised design requirements found in DOE Order 420 .1B, Facility Safety .

K-Area Interim Surveillance Project. The K-Area Interim Surveillance project will

provide the capability to conduct non-destructive and destructive surveillance of 3013 containers

in the Building 105-K slug vault until the 3013 Container Surveillance and Storage Capability

facility becomes operational (in about 2010) . The Board reviewed the final design of this

facility, focusing on the ventilation and fire protection systems, and found it acceptable . The

Board identified several deficiencies in the documented safety analysis and nuclear criticality

safety evaluation; the contractor corrected these in later revisions. The Board also identified a

potential threat to the safety-significant ventilation system from an old non-seismically qualified

ventilation duct in Building 105-K . DOE removed the duct.

47
Salt Waste Processing Facility . The Board continued its review of the Salt Waste

Processing Facility's design and processes . The Board had previously identified weaknesses in

the performance categorization and potential seismic interactions of various portions of the

facility. As a result, DOE directed its contractor to design a more robust structure, which will

provide the confinement required by the DOE safety basis . This facility is of particular concern

to the Board because of observed technical shortcomings in the design process . The geotechnical

requirements have not been finalized, the as-designed structure's ability to transfer imposed

loads is not well defined, the structural analysis to date is incorrect and less than adequate, and

the structural models developed to advance the design may not be valid. DOE is taking action to

address these issues with the Board's assistance to minimize impacts on the Savannah River

Site's high-level waste program .

Pit Disassembly and Conversion Facility . In 2006, the Board continued to review

safety aspects of the design of the Pit Disassembly and Conversion Facility . The Board reviewed

the surface settlement profiles at the building foundation due to the presence of soft zones unique

to the Savannah River Site . Based on this review, the Board found that, although the final

predicted surface settlement is deemed adequate, the methods used to analyze surface settlement

need to be improved . The Board will address this concern with the Savannah River Site

separately. The Board also suggested several improvements in the electrical design . The Board

observed that the design rating of the diesel generator may not be adequate to handle the

necessary startup loads following a loss of offsite power .

Tritium Extraction Facility. The Tritium Extraction Facility will be used to extract

tritium from target rods irradiated in commercial light water reactors . The extracted tritium is

used to replenish tritium reserves for the nation's nuclear weapons stockpile . DOE successfully

started up this facility in 2006 .

4.4

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 . DOE began construction in early 2005, with completion now

projected in 2008 . In late 2005, the Board noted that quality assurance and control practices for

placement of concrete were deficient . In response, DOE assigned personnel to monitor

construction and initiated other corrective actions . In January and February 2006, however,

shortly after DOE initiated corrective actions, DOE's contractors identified numerous

construction errors in concrete placement . DOE then shut down construction activities and

initiated short-term compensatory actions including a review by outside construction experts .

Subsequently, DOE developed and implemented long-term corrective actions to address the

quality assurance and control deficiencies .

Uranium Processing Facility . The Uranium Processing Facility is a new project

intended to replace a number of aging facilities that process enriched uranium . In 2006, the

project's completion schedule was in doubt due to funding reductions . DOE's review and

approval of Critical Decision-l authorizing preliminary design is being delayed until project

management problems at the Highly Enriched Uranium Materials Facility are sufficiently

48
resolved . The Board has raised concerns with the development of the preliminary hazard

analysis and selection of a conservative set of safety-related controls . The Board has also

questioned the level of detail developed for the conceptual design of the safety systems and the

risks this may pose for the project .

4.5 Los Alamos National Laboratory

Chemistry and Metallurgy Research Facility Replacement Project. The Board

continued its review of the Chemistry and Metallurgy Research Replacement Project facility

design. To expedite the schedule, DOE is planning to use a design-build approach for the final

design and construction of this facility . DOE proposes to combine Critical Decision-2 (Approval

of Performance Baseline) and Critical Decision-3 (Start of Construction). For this strategy to be

successful, the preliminary design package needs to be more developed than would typically be

expected. This approach will also require a completed preliminary documented safety analysis

with a DOE safety evaluation report . The Board has stressed that for this plan to be successful,

aggressive oversight will be required by federal and contractor personnel experienced in the

management and oversight of large, complex projects. There are many safety-related issues and

concerns with this project that remain to be resolved . The Board will continue its efforts to

achieve resolution in a timely manner .

Pit Manufacturing, Technical Area-55 . Upgrades are currently underway to improve

the pit manufacturing capability at Technical Area-55 . Overall, the objective of these efforts is to

install manufacturing equipment necessary to produce increased numbers of pits and establish

the capability to manufacture legacy pit types or a Reliable Replacement Warhead . The Board

has found that this activity is not being managed as a formal project with design milestones in

accordance with DOE Order 413.3A, Program and Project Management for the Acquisition of

Capital Assets . Rather, modifications to the pit manufacturing facilities and equipment are

ongoing and funded on an annual basis . The Board is currently evaluating whether the lack of

adherence to DOE Order 413 .3A is adversely affecting safety integration within the design .

4.6 Pantex Plant

Component Evaluation Facility. The Component Evaluation Facility is a new project at

Pantex intended to provide additional capability for qualifying, certifying, and inspecting

assembled weapons and components . This project is presently on hold while NNSA is revisiting

the Program Requirements Document and Mission Need to ensure compatibility with the

Reliable Replacement Warhead and the Complex 2030 vision . This facility was scheduled to be

operational in 2012 .

Special Nuclear Material Component Requalification Facility . The Board has

continued its review of the Special Nuclear Material Component Requalification Facility. The

project team has completed construction and system testing and is currently resolving

Operational Readiness Review findings from the recently completed contractor review . The

critical path for this project is controlled by the Laser Gas Sampling System, which is not

required immediately for stockpile work and is expected to lag production startup . The Board

conducted reviews of the ventilation and fire protection systems and of safety basis

documentation . The Board noted that though the facility is equipped with an active ventilation

49
system, this system is not credited in the safety analysis . This issue will be evaluated in

connection with Recommendation 2004-2 .

4.7 Idaho 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 major aspects of the project's organization, preliminary design, and safety basis

development. Primary areas of focus included process design and confinement strategy, safety

strategy as detailed in the preliminary documented safety analysis, and pilot plant testing . In

response to the Board's concerns, DOE will use a more conservative and commonly used

computer code to estimate radiological consequences of postulated accidents for co-located

workers and the public . Further, DOE conducted a review of key safety analysis inputs and

subsequently changed these inputs for many of the postulated accidents . The Board is continuing

to review major aspects of the design as they are developed, including the distributed control

system, waste characterization and radionuclide inventory controls, geotechnical engineering

work supporting the design of Performance Category 3 structures, and additional pilot plant

testing.

4.8Nevada Test Site

Criticality Experiments Facility . The Criticality Experiments Facility is a major

modification of the Device Assembly Facility. This modification will permit transfer of

criticality machines and fuel from Technical Area-18 at Los Alamos to the Nevada Test Site .

Design is about 90 percent complete on modifications to the rooms within the Device Assembly

Facility that are needed for this project. The Board reviewed the preliminary documented safety

analysis and developed a significant number of comments and concerns . Many of these concerns

were shared by DOE's Safety Basis Review Team . DOE now plans to perform a new structural

and seismic analysis, address water leaks, and prepare a new safety analysis . However, as noted

in Section 2, the Device Assembly Facility structure has numerous cracks that are considered

abnormal for a nuclear facility .

4.9

Seismic Hazard Analysis

The Board is reviewing a number of DOE studies and reports on seismic ground motion .

DOE Order 420 .1B, Facility Safety, requires that a review of natural phenomena hazards

assessments be conducted at least every 10 years, and that this review include recommendations

to DOE for updating the existing natural phenomena hazard assessments based on significant

changes that have occurred in methods or data . As a result of this requirement, a number of DOE

sites are updating their probabilistic seismic hazard analyses . These analyses will be used to

establish the site-specific design basis earthquake ground motion. During the past 10 years, the

practice for establishing earthquake ground motions has advanced, particularly with respect to

understanding the impact of local site conditions on ground motions . Local site conditions can

have a significant impact on either amplifying or reducing ground motions depending on the

geologic stratigraphy and related material properties of the site .

50
Probabilistic seismic hazard updates are underway at the Savannah River Site, Los

Alamos National Laboratory, and the Nevada Test Site . These updates were undertaken to

incorporate the most recent data regarding seismic sources, including the Charleston, South

Carolina source at Savannah River Site and the Pajarito Fault source in New Mexico . Studies to

better understand the impact of local site conditions are also underway at the Hartford Site

(Waste Treatment Plant) and at the Idaho National Laboratory (Integrated Waste Treatment

Unit) . Given that the state of practice is evolving, one key concern of the Board is that DOE

perform an adequate review, including independent peer review, of both the site specific

acquisition of data and the subsequent analysis . This will ensure that design basis earthquake

ground motions are based on accurate scientific knowledge . The Board will continue its review

of this ongoing work during 2007 .

5 1
5. Nuclear Safety Programs and Analysis

5.1

Federal Oversight

5.1 .1 Overview

To meet its statutory health and safety mandate, the Board must continuously assess

DOE's ability to achieve 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 Recommendations 95-2 and 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 is being further developed and

implemented 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 2006, the Board issued a technical

report, Integrated Safety Management: The Foundation for an Effective Safety Culture

(DNFSBII ECH-36) . This report documents a detailed examination of the current status and

effectiveness of integrated safety management systems at the seven NNSA weapons sites,

summarizes failures and good practices, and proposes changes to enhance the effectiveness of

these systems .

DOE completed the following actions in 2006 :

•

designated a chair for the Integrated Safety Management Council ;

• established two Central Technical Authorities with associated technical support staff; • issued a new DOE policy and order on DOE oversight ;

• implemented a nuclear safety research function ;

• strengthened the technical qualification program for Federal safety assurance personnel ; • implemented a formal safety delegation and assignment process ; and

• took steps to improve the implementation of the "feedback and improvement" function,

including issuance of a new DOE Order describing the Operating Experience Program .

5 3
DOE also performed a review of Recommendation 2004-1 implementation plan

commitments. Based on the results of the reviews and experience with implementation to date,

DOE developed a revision to the plan that the Board found acceptable . The Board also took this

opportunity to close Recommendation 95-2 . The Board concluded that the Recommendation

2004-1 plan and the recently-issued DOE Manual 450 .4-1, Integrated Safety Management

System Manual, contained the actions necessary to reinvigorate integrated safety management .

5.1.3 DOE Oversight Policy and Order

In accordance with the implementation plan for Recommendation 2004-1, DOE issued a

new policy and order (Order 226 .1, Implementation of Department of Energy Oversight Policy)

on federal oversight, bringing together for the first time specific guidance and detailed

requirements for federal oversight of safety, security, and business operations . In development is

an oversight guide providing more detailed guidelines and lines of inquiry . These steps are

intended to ensure a more uniform process for oversight of DOE's activities .

The order was scheduled to be implemented by DOE and its contractors by September

2006. In early 2006, the Board's reviews showed that most sites needed to fill a substantial gap

to fully implement these safety requirements by the required date . In March 2006, the Board

provided to DOE the results of a detailed review of the technical assessment, safety system

oversight, and management walkthrough programs at the Savannah River Operations Office. The

Board's report noted a substantial gap between current performance and the requirements of

Order 226 .1, and expressed concern with the limited actions taken at that time to implement the

new order.

In response to the Board's March 2006 letter, DOE assigned a lead at Savannah River for

implementing the new requirements, conducted a formal gap analysis, and developed an

implementation plan . In addition, DOE developed a new Integrated Performance Assurance

Manual and plans to conduct structured and comprehensive assessments of the contractor's

performance starting in 2007 . While significant improvements were made in 2006, progress was

hindered by a number of DOE staffing deficiencies . The Board is also concerned that the

decision to increase the number of contractors at Savannah River and the increased use of small

business contracts in the future will make the situation even more challenging.

The Board's March 2006 letter also requested that DOE provide its implementation plans

for the new directives across the complex and encouraged DOE to take aggressive steps to

implement the 226 series of directives . These steps could include assigning a lead for

implementing the new requirements, performing a formal gap analysis, and developing an

implementation plan . Without these, or similar positive steps, the Board had little confidence

that the programs would be implemented within the one-year requirement. DOE provided plans

to the Board for implementing the directives in June 2006, and more detailed implementation

plans in September 2006 . At the end of 2006, however, implementation of the new directives

was still not complete . The Board will continue to follow implementation and effectiveness of

the federal oversight programs in 2007 .

54
5.1 .4 Vital Safety Systems

In response to Recommendation 2000-2, DOE has taken steps to ensure the operability of

vital safety systems . During 2006, at the request of the Board, DOE reported its progress . Based

on a detailed review of the information provided, the Board has concluded that two sites,

Lawrence Livermore National Laboratory and the Los Alamos National Laboratory, have not

fully implemented a program to verify configuration management of vital safety systems .

5.1 .5 Activity-Level Work Planning

The Board has continuously emphasized 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 individual 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 . In 2006, the Board continued to

provide technical oversight of activity-level work planning within the DOE complex . Reviews of

three activities at the Hanford site and one at Oak Ridge National Laboratory were conducted .

At both of these sites, DOE had made significant improvements, but it is too early to tell if these

changes have been fully captured in institutional policies and procedures .

5.1 .6 Small Business Contracting

Section 6022(c) of Public Law 109-13 mandated that the Administrator of the Small

Business Administration, Chief Counsel for Advocacy of the Small Business Administration,

Chairman of the Defense Nuclear Facilities Safety Board, Secretary of Energy, and

Administrator of NNSA jointly conduct a study on means to promote opportunities for small

business participation in DOE's contracting system . While the study covered contracting for all

DOE facilities, the Board limited its involvement to contracts at defense nuclear facilities .

The Board provided its input to DOE for the report on September 2, 2005 and DOE

issued the final report on June 27, 2006 . The Board noted that in exercising its safety oversight

responsibilities, it has no preference on the size of contractors managing defense nuclear

facilities or activities . The Board expects defense nuclear work to be conducted safely . Hence,

regardless of the size of the contractor, work should be conducted under the same contractual

requirements, with the same degree of formality, and with the same level of safety oversight by

DOE and the Board . The Board noted that substantially increasing the number of prime

contractors increases the number of DOE staff necessary to discharge non-delegable safety

functions. DOE is already short of trained staff .

5.2Health and Safety Directives

5.2 .1 Improvement of Directives

In 2006, as part of its ongoing review of new and revised DOE directives, the Board

evaluated and provided constructive critiques of 38 directives dealing with nuclear design

criteria, maintenance management, worker protection, emergency management, and project

55
management. At year's end, the Board's staff was working to resolve safety issues on 23

directives. Work was completed on these directives :

•DOE Order 15 Comprehensive Emergency Management System

• DOE Order 2 Directives Program

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

Assets

•

DOE Order 420.1 B, Facility Safety

• DOE Guide 424 .1-1A, Implementation Guide for Use in Addressing Unreviewed Safety

Question Requirements

•DOE Order 452 .1C, Nuclear Explosive and Weapon Surety Program

• DOE Order 452.2C, Safety of Nuclear Explosive Operations

• DOE Standard 1104, Review and Approval of Nuclear Facility Safety Basis Documents

• DOE Manual 450 .5-1, Integrated Safety Management Manual

5.2 .2 NNSA Policy Letters

On several occasions the Board expressed concern over a new family of directives called

"policy letters" that had no standing in DOE's directives system . In response, NNSA agreed to

suspend applying these documents to defense nuclear facilities until a satisfactory directives

system architecture was developed . Changing course, NNSA decided to eliminate the policy

letter system entirely and replace it with a new directives system . In 2006, NNSA presented to

the Board its plans for new directives to be issued in 2007 .

5.2.3 Natural Phenomena Hazards

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 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,

DOE-STD-1189, Integration of Safety into the Design Process .

5.2 .4 Worker Safety Rulemaking

On December 8, 2003, DOE published in the Federal Register a proposed rule on worker

protection, 10 CFR Part 851, Worker Safety and Health. This action was required under the Bob

Stump National Defense Authorization Act, Public Law 107-314, which directed DOE to

promulgate regulations on worker safety and health, rather than rely exclusively on a contractual

approach. On January 26, 2005, DOE published a revised proposed rule for public comment . The

Board's comments on this rule stressed tightening the proposed exemption criteria, strengthening

the tailoring process, and complying with the oversight themes of Recommendation 2004-1 .

DOE modified the proposed rule considerably based on input from the Board, and published the

5 6
final rule on February 9, 2006 . The Board also provided oversight of DOE's development of

DOE Guide 440 .1-8, Implementation Guide for Use with 10 CFR Part 851, Worker Safety and

Health Program, which was issued in January 2007 . The rule's full implementation is required

by May 2007 .

5.2 .5 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, the interaction

between hazard categorization and criticality safety, and poorly defined technical bases for

threshold values . Improper application of the standard can result in non-conservative facility

hazard categorization and a reduced set of safety requirements and controls . DOE responded on

October 25, 2006, with a letter committing to the establishment of a working group to address

these and other weaknesses in the standard and develop a path forward for resolution, which will

be available by March 2007 .

5.2.6 Scope of the Directives System

In response to previous input from the Board, DOE offered changes to DOE Policy

251 .1, Directives Program Policy, DOE Order 25

DOE Directives Program, and DOE

Manual 251 .1-1X, Directives Program Manual. The Board's oversight resulted in a significantly

improved series of directives that provide the framework for the development of all other safety

directives . The directives in the 251 series were published in August 2006 .

5.3 Safety Programs

5.3.1 Administrative Controls

Contractors at defense nuclear facilities are required by DOE's principal nuclear safety

rule (codified in 10 CFR Part 830) to submit documented safety analyses and controls for

approval . To meet this requirement, many contractors have developed new safety analyses and,

perhaps more importantly, new safety controls . In many cases, the choice of these new safety

controls was limited because the installed equipment had been built years or even decades ago .

This led some contractors to reclassify existing equipment as safety-related and to rely on safetyrelated administrative controls rather than engineered features . In Recommendation 2002-3, the

Board advised DOE to improve its guidance for the use of administrative controls at defense

nuclear facilities .

Responding to the recommendation, DOE developed and implemented a plan to improve

the reliability and effectiveness of administrative controls that serve important safety functions .

As a key step in the implementation plan, DOE developed and issued a new standard, Specific

Administrative Controls (DOE-STD-1186), and in 2006, completed the commitments outlined in

the implementation plan for Recommendation 2002-3 . Of particular note, DOE revised the safe

harbor methodology associated with the performance of safety analyses (DOE-STD-3009,

57
Preparation Guide for U.S. Department of Energy Nonreactor Nuclear Facility Documented

Safety Analyses) to reflect the requirements associated with specific administrative controls . The

Board intends to conduct independent verification reviews to assess the effectiveness of

implementation.

5.3.2 Active Confinement Systems

The Board issued Recommendation 2004-2 to ensure that a reliable and effective control

would be available to mitigate the consequences of potential accidents at defense nuclear

facilities that rely on confinement ventilation systems . DOE has now screened all Hazard

Category 2 and 3 defense nuclear facilities against criteria designed to identify those with the

potential for benefitting from the intent of the recommendation . DOE also completed another

major milestone in February 2006, developing and issuing its Ventilation System Evaluation

Guidance document. This document identifies a set of design and performance attributes that

ventilation systems should be evaluated against for identification of potential upgrades . Several

pilot facilities have been identified by DOE to which these attributes will be applied, in order to

identify potential improvements, before the guidance document is applied to the rest of Hazard

Category 2 and 3 facilities that were identified earlier in the year . The evaluation process will be

completed over the next two years, resulting in significant improvement in the safety posture of

defense nuclear facilities across the complex .

In 2006, DOE submitted a revised implementation plan to reflect delays that have

occurred . The Board objected to these changes in an August 2006 letter, noting that DOE had

removed the Central Technical Authority from the review and concurrence process and

eliminated the Central Technical Authority's responsibility for ensuring technical adequacy .

The Board also objected to the removal of the Program Secretarial Officer from the review and

approval process for exceptions, giving that authority over to the site manager . Over the Board's

objections, DOE elected to follow the revised implementation plan . The Board has been

informed that the Office of Environmental Management and the National Nuclear Security

Administration have provided guidance to explain the coordination and level of reviews

expected by these program offices for ventilation system evaluations, including review and

oversight by the Central Technical Authorities and subsidiary offices . The Board is evaluating

DOE's implementation plan and will closely follow the implementation of the recommendation

in 2007 .

5.3 .3 Quality Assurance

During 2006, the Board continued to urge DOE to improve the implementation of quality

assurance programs. In accordance with its Quality Assurance Improvement Plan, DOE is

reviewing quality assurance processes at its various sites and developing corrective actions

where needed. The Quality Assurance Working Group (under the auspices of the Energy Facility

Contractors Group) continues to assist DOE in making these improvements . The actions taken as

part of NNSA's "Quality Assurance Roadmap to Excellence" also continue to have a positive

effect. The Board also provided representation at the biannual meeting of the American Society

of Mechanical Engineers' committee devoted to NQA-1, Quality Assurance Program

Requirements for Nuclear Facilities .

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5.3.4 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 force significant changes in 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 . During 2006, the

newly revised DOE Order 414 .1C, Quality Assurance, that contained new software quality

assurance requirements, was added to NNSA contracts . At this point, DOE has completed all but

one action in the implementation plan . DOE performed a gap analysis on its toolbox of codes to

determine the actions needed to bring them into compliance with software quality assurance

qualification criteria. However, the funding to upgrade codes based on the gap analysis results

has not been available. DOE will brief the Board on its plan for correcting this deficiency in

2007.

5.3.5 Risk Assessment Methodologies

Previously, the Board conducted a comprehensive assessment of DOE's policies,

programs, processes, and procedures with respect to 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 risk

management plans, risk mitigative actions, and residual risk identification to be inadequate . 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 has chartered a working group comprising representatives from

the major program offices, field elements, national laboratories, and major contractors to guide

the efforts in this area . This group has developed a draft policy, along with draft implementation

guidance, which is scheduled to be released for general comment in early 2007 . The Board will

continue to oversee DOE's progress in developing an effective policy and useful implementing

guidance to govern the use of risk assessment methodologies at DOE facilities .

5.3 .6 Criticality Safety

The Board continued to monitor DOE's progress in improving nuclear criticality safety

programs. The Board reviewed a DOE report entitled Status of the Department of Energy

Nuclear Criticality Safety Program for Calendar Year 2005 (February 8, 2006), and in a letter

dated June 28, 2006, noted favorably the positive influence of the Criticality Safety Support

Group, the improved stability of funding for the criticality program, and the increased frequency

'of reviews under the Criticality Safety Monitoring Program . However, the Board was concerned

about several items that are fundamental to the health of DOE's nuclear criticality safety

program and requested that DOE provide an estimate of when critical experiments would be

started at Nevada Test Site and a status report on staffing and training . In October 2006, DOE

responded to the Board that critical experiment operations at Nevada Test Site are planned to

resume in late 2009, and the experimenters will undergo requalification in accordance with a

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training plan to be finalized in 2007 . DOE also identified sites that require additional criticality

safety resources to provide effective oversight and has taken action to acquire and qualify these

resources . Finally, a number of engineer training courses devoted to criticality matters were held

at Lawrence Livermore National Laboratory this past summer, after a nearly two-year hiatus

throughout the complex.

The Board has also closely followed efforts by Los Alamos National Laboratory to

correct program deficiencies identified during an October 2005 review . A review in early August

found that progress in completing the corrective actions had stalled . Subsequently, the Board

issued a letter on September 22, 2006, asking DOE what compensatory measures would be put

in place until the laboratory's program deficiencies could be corrected . DOE responded in a

letter dated November 2, 2006, stating that it has increased oversight of the laboratory's program

and assigned a full-time individual to oversight . A limited review of compensatory measures

taken for current operations determined that there were no immediate criticality safety concerns .

DOE will meet periodically with contractor management to monitor progress on corrective

actions . The Board will continue to monitor progress and oversight effectiveness .

At Lawrence Livermore's Plutonium Facility, a review by the Board identified two

noncompliances with requirements of American National Standards Institute/American Nuclear

Society Standard 8 .19, Administrative Practices for Nuclear Criticality Safety . The Board

described these noncompliances to DOE in a letter dated October 11, 2006 . On November 22,

2006, DOE directed the laboratory to take action ; improvements in the laboratory's criticality

safety program have now been made .

5.3 .7 Readiness Reviews

In a September 14, 2005 letter to DOE, the Board highlighted some instances of reduced

rigor in the selection of readiness review processes for defense nuclear facilities . Such reduced

rigor affects the application of design requirements and preparation of safety documents . One

cause for this situation appeared to be inconsistent interpretation and implementation of rules

and orders that apply to new Hazard Category 1, 2, and 3 nuclear facilities and major

modifications to existing nuclear facilities . In the cases noted by the Board, DOE used nonconservative interpretations that could lead to less vigorous readiness reviews and omission of

required reviews of design and safety documentation . As a result, DOE conducted a focused

review at two sites and found inconsistent interpretation and application of these nuclear safety

definitions . DOE will brief the Board before these definitions are revised in the DOE directive .

The Board had also identified several problems with the planning and conduct of startup

readiness reviews at the Savannah River Site in late 2005 . As a result, the Board provided

extensive oversight of the 17 contractor and DOE readiness reviews that were conducted at the

Savannah River Site during 2006 to ensure the subsequent corrective actions were producing the

desired effect . In general, a significant improvement was observed . That being said, the Board

disagreed with a contractor decision in a particular case in which a readiness review commenced

before the supporting authorization basis had been approved . The Board also identified other

problems with specific readiness reviews : frequent equipment reliability issues, lack of

prerequisites in a plan of action, disclosure of an emergency drill scenario ahead of time, and

6 0
reviewer actions that could bias their review . Feedback from the Board on these issues allowed

corrective actions to be taken to ensure they remained isolated cases .

Similarly, the Board identified weaknesses with the Idaho process for determining

readiness to begin venting of remote-handled transuranic waste drums . DOE-Idaho gave

approval to perform a readiness assessment for a new Hazard Category 2 activity instead of a

more rigorous operational readiness review as required by DOE Order 425 .1C, Startup and

Restart of Nuclear Facilities, without receiving an exemption from DOE headquarters . DOE's

Office of Environmental Management issued a memorandum to all of its sites providing clear

expectations for implementing the requirements of the order .

5.4 Technical Competence

5.4 .1 Federal

In accordance with the implementation plan for Recommendation 2004-1, DOE prepared

a corrective action plan in August 2005 to address 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 plans to

revise its Federal Technical Capability Manual to incorporate changes in federal technical

capability expectations developed as part of the implementation plan . DOE will also conduct a

follow-on line management review of the effectiveness of their corrective action plan .

DOE achieved several successes in pursuing the corrective action plan. In May 2006,

DOE conducted the initial accreditation review of the Technical Qualification Program at the site

office for the Y-12 National Security Complex . The Y-12 Site Office had a solid program and

served as a good benchmark for this accreditation process . DOE budgeted $2 million for fiscal

year 2008 to reestablish the Corporate Technical Intern Program, which would fund ten interns .

DOE developed and executed a Senior Technical Safety Manager overview course in

Albuquerque in February 2006 for qualified managers in the process of requalification and for

new manager candidates to assess gaps in their knowledge level . DOE will use lessons learned

from this course to improve its next scheduled course . DOE is also strengthening its qualification

criteria with mandatory performance activities through a significant revision to DOE-STD-1075,

Senior Technical Safety Manager Functional Area Qualification Standard. DOE expects to issue

this standard later in 2007 .

5.4 .2 Criticality Safety Engineers

In 2006, the Board assessed the nuclear criticality training and staffing at several DOE

site offices in the area of nuclear criticality safety oversight . The Board found that several DOE

site offices continue to be either understaffed or not staffed at all in the area of oversight . Some

of the problems with contractor programs can be traced to ineffective oversight by DOE site

offices. By October 2006, DOE was actively seeking to fill criticality safety positions at the

6 1
Nevada Site Office, Los Alamos Site Office, and Savannah River Operations Office . In the

meantime, technical support in the criticality safety area is being provided to these sites through

DOE's Albuquerque Service Center . At the Los Alamos Site Office, a general engineer has also

been assigned as a full-time criticality safety engineer . He is required to complete qualification

as an expert by April 2008, but DOE is exploring mechanisms to accelerate his qualification

progress .

5.4.3 Federal Facility Representatives

The Board conducted on-site reviews of the staffing levels and training of DOE's facility

representatives at the Pantex, Sandia, and Los Alamos Site Offices. The Board found that both

staffing and training were inadequate in all three offices . DOE agreed and took steps to improve

its activity-specific hazard training and to develop a more rigorous means of establishing a

minimum staffing level at each office . However, DOE continues to experience difficulty

maintaining the desired number of qualified facility representatives at too many sites .

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6. Public Outreach and Agency Administration

6.1

Public Hearings

During 2006, the Board conducted two public hearings . The Board held its first public

hearing in March at Los Alamos, New Mexico, at which it received testimony from DOE and its

operating contractors for Los Alamos National Laboratory . The Board's interest was focused on

improvements in safety management at the laboratory's defense nuclear facilities . The second

public hearing, held in July in Washington, D .C ., was the second in a series regarding DOE's

incorporation of safety into design and construction projects . This hearing explored actions taken

by DOE to further improve incorporation of safety early in the design process .

6.2

Responding to Public Requests

The Board answered numerous public requests for documents and information and

responded to eight requests filed under the Freedom of Information Act. The average response

time for 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 requests

processed since 2001 .

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 .

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, review of documents, and site

visits, are continued until the Board is able to reach a technical judgment on the issues raised . If

the Board finds that a health or safety hazard exists, it takes prompt action to inform DOE and

closely monitors DOE's corrective actions . When the Board receives information on matters

outside its jurisdiction, such as alleged criminal activities or unlawful personnel practices, it

refers the information to the appropriate federal agency for action. During 2006, the Board

directed inquiries into health and safety issues at Hanford, Idaho, Los Alamos, and Pantex . 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 . There are 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

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National Security Complex in Oak Ridge, Tennessee ; two at Los Alamos National Laboratory in

New Mexico ; and one at Lawrence Livermore National Laboratory in Livermore, California.

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 .

6.6 Human Resources

In the second half of 2006, the Board instituted an aggressive hiring initiative to replace

retiring and otherwise departing technical staff . In addition, the Senate confirmed nominees for

the two vacant Board member positions . As a result, the Board increased its personnel strength

to 89 (including Board members) with four more technical staff members scheduled to arrive in

early January 2007 .

The Board has assembled a professional staff of exceptional technical capability . Staff

members' expertise covers all major aspects of nuclear safety: nuclear, mechanical, electrical,

chemical, fire protection, and structural engineering, as well as physics and metallurgy. Most

mid- to senior-level technical staff members possess practical nuclear experience gained from

duty in the United States Navy nuclear propulsion program, the nuclear weapons field, or the

civilian nuclear reactor industry. Both the Board and its staff include individuals experienced in

environmental impact assessments and regulatory processes . Four of the Board's attorneys have

technical degrees, and one is also a licensed professional engineer . 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-five percent of the Board's

technical staff holds advanced science and engineering degrees, with 17 percent at the doctoral

level .

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 is one entry-level employee in this program . The Board will continue its vigorous

recruitment program to attract the brightest engineering students from colleges and universities

across the country .

6.7 Information Technology and Security

The Board has 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 is implementing the processes called for by Homeland

Security Presidential Directive 12 and has begun issuing cards compliant with this directive .

The Board has continued to increase its use of advanced information technology .

Desktop hardware, software, and network servers provided to the staff are continually upgraded

to ensure that the latest tools are available . In 2006, the Board continued to improve its

information technology infrastructure to allow the adoption of emerging technologies, such as

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the conversion to IPv6 and the use of credentials for logical access compliant with Homeland

Security Presidential Directive 12 . The Board also continued to develop more robust technology

capabilities at its alternative facility. These capabilities will allow the Board to continue to

operate effectively in the event of an emergency or flu epidemic . The Board's internet website is

continuously updated to ensure that public documents are available for viewing and

downloading . Access to documents has been improved by the installation of a better search

engine.

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 .

6.9 Financial Management

The Board received its first unqualified audit opinion on its financial statements and

made progress in resolving other issues associated with its annual independent audit . This

represents a significant milestone in the Board's efforts to fully comply with financial

management laws and practices .

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Appendix A: 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

2002-2 October 3, 2002 Weapons Laboratory Support of the Defense Nuclear Complex

2002-3 December 11, 2002 Requirements for the Design, Implementation, and

Maintenance of Administrative Controls

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
Appendix B : 2006 Reporting Requirements

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Date Site or Topic Response Due

January 5 K-Basins at Hanford Briefing 90 days

January 17 Work Planning at Oak Ridge Briefing

March 3 DOE Oversight Policies Report 90 days

March 27 Criticality Experiments Report 60 days

March 27 Vital Safety Systems Report 60 days

April 24 Rec. 2005-1 Repackaging Methodology Report 30 days

May 1 Comments on DOE Manual 441 .1 Report 30 days

June 19 NNSA plans for G-Tunnel Report 60 days

June 26 DOE Standard 1027 Report 120 days

June 28 Nuclear Criticality Safety Report 90 days

August 15 DOE Order 226.1 Report 30 days

September 22 Critical Experiments Facility Report --

September 22 Criticality Safety at Los Alamos Report 45 days
Appendix C : Correspondence in 2006

Hanford Site

September 7 letter to the Assistant Secretary for Environmental Management on

structural issues in the Waste Treatment and Immobilization Plant .

April 24 letter to the Assistant Secretary for Environmental Management on review of the

implementation of activity-level work control by Fluor Hanford, Inc .

January 5 letter to the Secretary of Energy imposing a 90-day reporting requirement on sludge

stabilization and packaging at the K-Basins .

Lawrence Livermore National Laboratory

October 11 letter to the Administrator, NNSA, regarding the Board's review of the nuclear

criticality safety program.

May 10 letter to the Administrator, NNSA, on the development of the authorization basis

documentation for the Plutonium Facility .

Los Alamos National Laboratory

September 22 letter to the Secretary of Energy imposing a 45-day reporting requirement on the

site's nuclear criticality safety program.

Nevada Test Site

September 22 letter to the Administrator, NNSA, imposing a reporting requirement, the report to

be submitted when the Critical Decision-3 package is submitted, describing how previously

identified safety-related issues are being addressed at the Critical Experiments Facility .

August 16 letter to the Deputy Administrator for Defense Programs, NNSA, on building leaks

and structural cracks in the Device Assembly Facility .

June 19 letter to the Administrator, NNSA, imposing a 60-day reporting requirement to describe

plans for staging, assessing, and disposing of a damaged nuclear weapon or improvised nuclear

device at the G-Tunnel .

March 27 letter of the Administrator, NNSA, imposing a 60-day reporting requirement on the

issues pertaining to the Critical Experiments Facility .

Pantex Plant

December 15 letter to the Deputy Administrator for Defense Programs, NNSA, requesting a

completion date for the Final Assessment Report on the implementation plan for

Recommendation 98-2 .

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August 9 letter to the Deputy Administrator for Defense Programs, NNSA, on the restart of W88

cell operations .

March 27 letter to the Administrator, NNSA, on formal conduct of operations .

Savannah River Site

September 26 letter to the Administrator, NNSA, on surface settlement profiles for the Pit

Disassembly and Conversion Facility .

July 12 letter to Secretary of Energy forwarding a copy of the Board's Third Annual Report to

Congress on Plutonium Storage at DOE's Savannah River Site .

March 3 letter to the Secretary of Energy imposing a 90-day reporting requirement on the plans

for implementing DOE Policy 226 .1 and DOE Order 226 .1 .

Oak Ridge National Laboratory, Y-12 National Security Complex

February 28 letter to the Administrator, NNSA, on the documented safety analysis for the 9212

Complex at Y-12 .

January 17 letter to the Assistant Secretary for Environmental Management imposing a reporting

requirement for a briefing on the steps planned to ensure worker protection during Tank W-1A

soil characterization .

Other Correspondence

November 21 letter to the Secretary of Energy accepting the revised implementation plan for

Recommendation 2004-1 and closing Recommendation 95-2 .

August 21 letter to the Deputy Secretary of Energy on observations from the Board's second

public hearing on the integration of safety into design .

August 16 letter to the Administrator, NNSA, on the resolution of issues regarding DOE-STD3016-2006 .

August 15 letter to the Secretary of Energy imposing a 30-day reporting requirement to provide

the previously requested plans for implementing the safety requirements in DOE Order 226 .1 .

August 15 letter to the Secretary of Energy requesting revision and re-submission of the

implementation plan for Recommendation 2004-2 .

June 28 letter to the Deputy Secretary of Energy imposing a 90-day reporting requirement

regarding DOE's nuclear criticality safety program .

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June 26 letter to the Secretary of Energy on the reorganization of DOE's Office of Environment,

Safety and Health .

June 26 letter to the Acting Assistant Secretary for Environment, Safety and Health imposing a

120-day reporting requirement to address issues associated with DOE-STD-1027-92.

May 1 letter to the Acting Assistant Secretary for Environment, Safety and Health establishing a

30-day reporting requirement to respond to the Board's comments on Draft DOE Manual 441 .1,

Nuclear Material Packaging Manual.

April 24 letter to the Secretary of Energy imposing a 30-day reporting requirement to address

comments on the Draft Repackaging Prioritization Methodology for Recommendation 2005-1 .

March 27 letter to the Secretary of Energy imposing a 60-day reporting requirement on vital

safety systems .

January 20 letter to Secretary of Energy transmitting DNFSB/1 hCH-36, Integrated Safety

Management: The Foundation for an Effective Safety Culture.

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