ANNUAL REPORT

TO CONGRESS

DEFENSE NUCLEAR FACILITIES

SAFETY BOARD

APRIL 1993
John T. Conway, Chairman

A.]. Eggcl'lberiS'er, Vice Chairman

John W. Crawford, Jr.

Joseph]. DiNunno

HcrbertJohn Cecil KQul.-~

DEFENSE NUCLEAR FACILITIES

SAFETY BOARD

625 Indiana Avenue, NW, SuIte 700, Washington. D.C. 20004

(202) 208-6400

April 2, 1993

To the Congress of the United States;

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

third annual report, covering activities of the Board during calendar year 1992.

An independent executive branch establishment, the Board provides advice and

recommendations to the President and the Secretary of Energy regarding public health and

safety issues at Department of Energy (DOE) defense nuclear facilities. The Board also

reviews and evaluates the content and implementation of health and safety standards, as well

as other requirements, relating to the design, construction, operation, and decommissioning

of DOE defense nuclear facilities.

As required by statute, the Board's report to Congress summarizes activities during

the past year, assesses improvements in the safety of DOE defense nuclear facilities, and

identifies remaining safety problems at DOE defense nuclear facilities.

During this reporting period, the Board made progress in discharging its health and

safety review responsibilities while addressing the many managerial issues associated with the

operation of a relatively new agency.

Respectfully submitted,

~rV"k t7~OhnT.~ I

Chairman

~~ .57~ ~~~ft '

</~~~l; .. Crawford, Jr.tJ :fl

Member

Jr~~ Q. ah~Nh~ j!JOseph J. 4BiNunno

Member

A. J. Eggenberger

Vice~Chairman

. ~~~~c

Herbert John Cecil Kouts

Member
CONTENTS

REPORT OF BOARD ACTIVITIES DURING 1992

Page

10 INlRODUCTION 0 0 •••••••• 0 •••••••••••••••••••••• 0 • • • • • • •• 1

A. OVERVIEW OF BOARD FUNCTIONS 1

B. ANNUAL REPORTING REQUIREMENTS

UNDER 42 U.S.C. SECTION 2286e 0 ••••••••••••• 0 2

n. REPORT TO CONGRESS REGARDING SAFETY AND

HEALTH AT DEFENSE NUCLEAR FACILITIES 2

A. BOARD ACTIVITIES DURING 1992 0 ••••• 0 • • • • • • • • • • • • • •• 2

1. Recommendations Issued in 1992 2

a. Recommendations 92-1 (Closed) and

92-3, Operational Readiness of the

HB-Line at the Savannah River Site 2

b. Recommendation 92-2, DOE's Facility

Representative Program at Defense

Nuclear Facilities 4

c. Recommendation 92-4, Multi-Function

Waste Tank Facility at the Hanford Site 5

d. Recommendation 92-5, Discipline of

Operation in a Changing Defense

Nuclear Facilities Complex 0 ••••••••••• 0 • • • • • • • • •• 7

e. Recommendation 92-6, Operational

Readiness Reviews (ORRs) . . . . . . . . . . . . . . . . . . . . . .. 8

f. Recommendation 92-7, Training and

Qualification 0 • • • • • • • • • • • • • • • • • • • • • • • • •• 8

2. DOE Efforts to Implement Board Recommendations

Issued in 1991 and Follow-up Board Action. . . . . . . . . . . . . .. 10

a. Recommendation 91-1, Strengthening the

Nuclear Safety Standards Program for

DOE's Defense Nuclear Facilities (Closed) 10

b. Recommendation 91-2, Closure of Safety

Issues Prior to Restart of K-Reactor at

the Savannah River Site (Closed) .. 0 ••••••••• 0 • • • •• 10

c. Recommendation 91-3, DOE's Comprehensive

Readiness Review Prior to Initiation of the

Test Phase at the Waste Isolation Pilot

Plant (WIPP) (Closed) 11

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Page

d. Recommendation 91-4, DOE's Operational

Readiness Review Prior to Resumption of

Plutonium Operations at the Rocky Flats

Plant (Closed) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. 11

e. Recommendation 91-5, Power Limits for

K-Reactor Operation at the Savannah

River Site . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. 12

f. Recommendation 91-6, Radiation Protection

for Workers and the General Public at DOE

Defense Nuclear Facilities. . . . . . . . . . . . . . . . . . . . . . .. 12

3. DOE Actions to Implement Board Recommendations

Issued in 1990 and Follow-up Board Action ..... , . . . . . . . .. 13

a. Recommendation 90-1, Operator Training

at Savannah River Site Prior to Restart

of K, L, and P Reactors (Closed) 13

b. Recommendation 90-2, Design, Construction,

Operation and Decommissioning Standards

at Certain Priority DOE Facilities . . . . . . . . . . . . . . . . .. 13

c. Recommendation 90-3 (Closed) and

Recommendation 90~7, Safety at SingleShell Hanford Waste Tanks. . . . . . . . . . . . . . . . . . . . . .. 14

d. Recommendation 90-4, Operational

Readiness Reviews at the Rocky Flats Plant 15

e. Reconunendation 90-5, Systematic

Evaluation Program at the Rocky Flats Plant " 15

f. Recommendation 90-6, Criticality Safety

at the Rocky Flats Plant 16

4. Public Hearings, Public Comment, and

Interaction with Board 17

5. Official Site Visits by Board Members and

by Staff. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. 18

B. SAFETY AND HEALTH STATUS OF DEFENSE

NUCLEAR FACILITIES , .. , 18

1. Board Perspective on Outstanding Issues of

Health and Safety , , .. , . . . . . . . . . . . . . .. 18

a. Ov"erview , ,. .. . . .. . . .. . . .. .. 18

b. DOE Identification of Significant Safety

Issues Remaining at Defense Nuclear

Facilities . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. 19

c. Initial Review of SafetywRelated Issues

at Nuclear Weapons Assembly, Disassembly

and Testing Facilities "............... 20

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Page

d. Importance of Qualified DOE Technical Staff. . . . . . . .. 23

e. Importance of DOE Facility Representatives . . . . . . . . .. 25

f. Development and Implementation of Safety

Standards 25

g. Systems Engineering and Systems Approach . . . . . . . . . .. 27

2. Overview of Improvements in Safety at DOE

Defense Nuclear Facilities . . . . . . . . . . . . . . . . . . . . . . . . . . .. 28

3. Board Activities and Improvements at More

Than One Facility . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. 28

a. Operator Training . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. 28

b. Operational Readiness Reviews . . . . . . . . . . . . . . . . . . .. 29

c. Standards, Including DOE Order Compliance 31

d. Continuing Emphasis on Seismic and

Systems Engineering . . . . . . . . . . . . . . . . . . . . . . . . . . .. 32

e. Conduct of Engineering and Construction 32

f. Unusual Occurrence Reporting (DOR) 33

4. Board Activities and Improvements at the

Rocky Flats Plant 33

5. Board Activities and Improvements at the

Savannah River Site 36

6. Board Activities and Improvements at the

Hanford Site . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. 39

7. Board Activities and Improvements at WIPP . . . . . . . . . . . . .. 42

8. Board Activities and Improvements at Fernald,

Mound, and West Valley. . . . . . . . . . . . . . . . . . . . . . . . . . . .. 43

9. Board Activities and Improvements at Idaho

Nuclear Engineering Laboratory (INEL) 44

10. Board Activities and Improvements at

Oak Ridge Y-12 Plant . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. 45

C. ADMINISTRATIVE AND MANAGEMENT ISSUES. . . . . . . . . .. 45

1. Litigation........................................ 45

2. Investigations..................................... 46

3. PersOIUlel and Recruitment . . . . . . . . . . . . . . . . . . . . . . . . . .. 47

4. Technical Intern Program 47

5. Regulatory Agenda. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. 48

m. LEGISLATIVE CHANGES AFFECTING BOARD

PLANNING FOR 1993 AND BEyOND 48

A INCLUSION OF PAN1EX PLANT

AND NEVADA TEST SITE WITHIN

BOARD'S JURISDICTION 48

B. OTHER CONGRESSIONAL MEASURES

CONCERNING BOARD ACTIVITIES. . . . . . . . . . . . . . . . . . . . .. 49

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Page

1. Resumption of Plutonium Operations in

Buildings at the Rocky Flats Plant . . . . . . . . . . . . . . . . . . . . .. 49

2. Nuclear Waste Storage and Environmental

Remediation . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. 49

APPENDIX A

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I. INTRODUcnON

A. OVERVIEW OF BOARD FUNCTIONS

Congress created the Defense Nuclear Facilities Safety Board (Board) to provide

advice and recommendations to the Secretary of Energy regarding public health and

safety at Department of Energy (DOE) defense nuclear facilities. The President

nominated the initial five members of the Board in 1989, and the Senate confirmed

those nominations in October of that same year. In June 1992, Mr. Joseph J. DiNunno

was nominated by the President to join the Board after the death of Board member

Edson G. Case on September 14, 1991. Mr. DiNunno was confirmed by the Senate on

August 12, 1992. This is the third Annual Report provided to Congress by the Board,

and it covers activities during calendar year 1992.

Broadly, the Board reviews operations, practices, and occurrences at DOE

defense nuclear facilities and makes recommendations to the Secretary of Energy that

are necessary to protect public health and safety. The Board also assesses safety

management and personnel effectiveness both within DOE and the various operation

and management (O&M) contractor organizations. If, as a result of its reviews, the

Board determines that an imminent or severe threat to public health or safety exists, the

Board is required to transmit its recommendations directly to the President, as well as

to the Secretary of Energy.

The Board's enabling statute, 42 U.S.c. § 2286, explicitly requires the Board to

review and evaluate the content and implementation of health and safety standards,

including DOE orders, rules, and other safety requirements, relating to the design,

construction, operation, and decommissioning of DOE defense nuclear facilities. The

Board must then recommend to the Secretary of Energy any specific measures, such as

changes in the content and implementation of those standards, that the Board believes

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

The Board is also required to review the design of defense nuclear facilities before

construction begins, as well as modifications to older facilitiest and to recommend

changes necessary to protect health and safety. Board review and advisory

responsibilities continue throughout the construction, testing, and operation of new

facilities.

The Board may conduct investigations, hold public hearings, gather information,

conduct studies, establish reporting requirements for DOE, and take other actions in

furtherance of its review of health and safety issues at defense nuclear facilities. These

ancillary functions of the Board and its staff all relate to the accomplishment of the

Board's primary function, which is to assist DOE in identifying and correcting health and

safety problems at defense nuclear facilities. The Secretary of Energy and contractors

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

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B. ANNUAL REPORTING REQUIREMENTS UNDER 42 U.S.C.

SECTION 22800

By statute, the Board must submit an Annual Report to the Committees on

Armed Services and on Appropriations of the Senate and to the Speaker of the House

of Representatives at the same time that the President submits the budget to Congress.

The report must include a review of the activities of the Board during the preceding

year, including all recommendations made by the Board. An assessment is required of

the improvements in safety at DOE defense nuclear facilities during the previous year.

The report must also assess safety problems remaining at DOE defense nuclear facilities.

The Board is hereby submitting its third Annual Report to Congress in fulfillment of

these requirements.

II. REPORT TO CONGRESS REGARDING SAFElYAND HEALTH AT DEFENSE

NUCLEAR FACILITIES

A. BOARD ACTIVITIES DURING 1992

I. Recommendations Issued in 1992

The Board discharges its primary responsibility by issuing recommendations to the

Secretary of Energy, and if necessary, the President, regarding public health and safety

issues at defense nuclear facilities. HigWighting their importance, Congress specifically

requires that a discussion of recommendations be included in the Board's Annual

Report. 42 U.S.c. § 2286e. During 1992 the Board made seven sets of

recommendations, consisting of 23 specific recommendations. Since its inception, the

Board has issued a total of 20 sets of recommendations, consisting of 84 specific

recommendations. The Secretary of Energy has accepted each of the Board's

recommendations. The following summarizes Board activities relative to

recommendations during calendar year 1992. Verbatim copies of the recommendations

are included in Appendix A.

a. Recommendations 92 w l (Closed) and 92-3, Operational Readjness of the

HB-Line at the Savannah River Site

On March 11, 1992, the Board's staff conducted a review of selected health and

safety issues at DOE's Savannah River Site (SRS). A site worker interviewed on that

date discussed potential problems with leak test data for heat exchangers at the KReactor, as well as other safety concerns. He informed the Board's staff of the name

of a worker at the site who believed that there were potentially serious problems with

the Westinghouse Savannah River Company (WSRC) and DOE Operational Readiness

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Reviews (ORRs) performed at the HB-Line in 1991. The HB-Line is used in the

processing of Pu-238.

The Board's General Counsel was directed by the Chairman of the Board to

conduct an inquiry and followup on the allegations. Staff periodically briefed the Board

on the progress of the informal inquiry from March 16 through March 27. WSRC

persOIUlel involved in the HB-Line readiness reviews raised questions regarding the

adequacy of the readiness reviews prepared by WSRC and DOE, as well as persistent

health and safety issues at the HB~Line. During the week of March 22, 1992, the Board,

based on those briefings, determined that an investigation should be made into the

conduct of the HB-Line readiness reviews and associated safety issues. The Chairman

of the Board directed the General Counsel to establish an investigative team of legal and

technical staff. The investigation was conducted pursuant to 42 V.S.c.A. § 2286a(2),

which states that the Board "shall investigate any event or practice at a Department of

Energy defense nuclear facility which the Board determines has adversely affected, or

may adversely affect, public health and safety," and 42 V.S.C.A. § 2286b(b). The Board

scheduled a closed Board meeting for April 3, 1992, to review preliminary information

on the investigations.

The investigative team periodically reported to the Board the results ofits reviews

of potential safety problems at the Jill-Line due to alleged deficiencies in the readiness

review process and possible failures by WSRC and DOE to correct safety issues

adequately prior to the July 1991 restart of the facility, which had been shut down since

1987. Particularly troubling were the Pu-238 contaminations of personnel which

occurred seven days after the July 1991 resumption of operation. Those contaminations

resulted in operations being suspended until October of 1991. The HE-Line was again

operated until shutdown on November 20, 1991, after a prohibited material (Zirconium)

was discovered in the HB-Line. The HB-Line resumed operation again on

December 13, 1991, and continued until March of 1992 when operations were again

halted due to an unreviewed safety question pertaining to H~Canyon's ventilation system.

The investigative team's review of an incident noted as Unusual Occurrence Report,

SR-WSRC-SEPGEN-1992-0002, for Separations facilities, indicated that DOE intended

to again resume operations at the HB-Line some time in May 1992. Therefore, the

Board wrote to the Secretary of Energy on April 20, 1992, and requested that he inform

the Board no later than 10 days prior to the intended resumption date. The Secretary

agreed by letter of May 7, 1992.

To obtain an independent view of the status of DOE's and WSRC's efforts to

correct and close safety issues at the HE-Line, the team also conducted an on-site visit

and technical review of selected safety issues from May 5 to May 8, 1992. On May 21,

1992, after a briefing by the investigative team, the Board unanimously voted, by use of

notational voting, to issue Recommendation 92-1 to the Secretary of Energy. 92-1

recommended that DOE defer resumption of processing at the HB-Line, pending

- 3 -
issuance of the report of the Board's investigation, resolution of the safety issues, and

possible further Board action. The full text ofBoard Recommendation 92-1 is contained

in Appendix A. Further action was taken on May 29, 1992, when the Board unanimously

voted, by use of notational voting, to issue Reconunendation 92-3 to the Secretary of

Energy. Reconunendatiol1 92-3 recommended that, prior to resuming operations at the

HB-Line, DOE direct WSRC to reopen its ORR, and that WSRC and DOE conduct

adequate ORRs in accordance with previous Board recommendations and DOE

implementation plans. Recommendation 92-3 also presented seven other elements that

the Board believed should be incorporated into the recommended ORR process to

enSure that it was adequate. The full text of Board Recommendation 92-3 is contained

in Appendix A.

On July 14, 1992, the Secretary responded formally to Recommendation 92-1,

requesting an extension of time for the Department to respond. The Secretary believed

that the Department needed to review ttthe draft investigative report" which was

scheduled to be issued on July 17, 1992, "to ensure we provide an adequate response"

to the reconunendations. The Board granted a 45-day extension on July 17, 1992, and

transmitted the investigative team's Preliminary Report to the Secretary of Energy for

his review and for classification clearance.

After incorporation of DOE factual comments on the Preliminary Report, the

Board issued the investigative team's Final Report on September 8, 1992. The Secretary

accepted Recommendation 92-3 and submitted the Implementation Plan on

September 15, 1992. On October 27, 1992, the Board agreed with the Secretary's letter

of October 19, 1992, that Recommendation 92-1 had been superseded by further action

of the Board in issuing Recommendation 92-3.

ORRs were conducted by both WSRC and DOE during September, October, and

November of 1992. The Board held an open meeting and hearing on December 15,

1992, in Aiken, South Carolina, to address both the contractor's and the Department of

Energy's Operational Readiness Reviews and other safety matters related to the

proposed restart of the HB-Line. This was followed by a closed meeting held by the

Board on December 17, 1992, to deliberate upon safety issues related to the HB-Line,

including, but not limited to, consideration of testimony and documents received at the

public meeting on December 15 and other matters related to the proposed restart of the

HB-Line. At the close of the calendar year, the Board scheduled further deliberations

on the HB-Line for January 5, 1993.

b. Recommendation 92.2, DOE I S Facility Representative Program at Defense

Nuclear Facilities

At contractor-operated defense nuclearfacilities, the DOE Facility Representative

is responsible for monitoring the performance of the facility, and selVes as the primary

·4-
DOE contact with the contractor. Recognizing the importance of DOE Facility

Representatives with regard to ensuring adequate protection of public health and safety

at DOE defense nuclear facilities, the Board reviewed existing department-wide guidance

on the selection, training, and responsibilities of DOE's Facility Representatives. The

Board found that DOE Order 5000.3A and DOE Order 5480.19 provide only limited

details concerning duties and responsibilities of DOE's Facility Representatives;

moreover, there are no orders that prescribe any guidance for selection and training of

DOE's Facility Representatives, nor any effective guidance for establishing the duties

and responsibilities associated with these positions.

The Board noted that DOE's managers for several facilities in the defense nuclear

complex bad begun to establish formal Facility Representative programs. However,

these programs were operating without centralized direction. Generally, this resulted

in widely differing qualifications, duties, and responsibilities for DOE Facility

Representatives from facility to facility, even at the same site.

Based on these factors, the Board issued Recommendation 92-2 on May 28, 1992.

This recommendation addressed the need for a comprehensive analysis of existing DOE

facility representative programs and the establishment of a formal program for the

selection, training, and assignment of DOE representatives at defense nuclear facilities.

The Secretary accepted the Board's recommendation on July 20, 1992, and submitted the

Implementation Plan on November 5, 1992. The full text of Board Recommendation

92-2 is contained in Appendix A.

c. Recommendation 92-4, Multi-Function Waste Tank Facility at the Hanford

Site

The Board performed reviews of the Multi-Function Waste Tank Facility

(MWTF) project to be located at the Hanford Site in the State of Washington. The

MWTF is an element of the Hanford Tank Waste Remedial System (TWRS) Program,

which is intended to provide for the ultimate treatment and preparation for disposal of

the nuclear waste stored in tanks at the Hanford Site. The Board reviewed information

received in the form of briefings and presentations by DOE Headquarters personnel,

DOE Richland personnel, Westinghouse Hanford Company personnel, and Kaiser

Engineers Hanford personnel, as well as analysis of relevant documents. The Board

detennined that the process for design and construction of the Hanford MWTF did not

clearly present and delineate those aspects that ensure that the public health and safety

could be adequately protected.

As conceptual design of the M\VTF project neared completion, the Board

believed that it was appropriate to assure that the designs of the MWTF and other new

defense nuclear facilities incorporate engineering principles and approaches, detailed

- 5 -
engineering criteria, and practices that are essential to ensure adequate protection of

public health and safety. These include:

• The design needs to be appropriately conservative with respect to safety;

The design bases (criteria) need to be clearly defined, coherent, and

compatible with the facilities' perceived lifetime functions (Le., Functional

Design Criteria) and documented;

• The design bases and the resulting facility design need to reflect and

incorporate the requirements of appropriate standards as that term is used

in the Board's enabling statute, and thus to include DOE Orders and

directives and commercial nuclear practices, as well as any other national

and international standards that may be required for the safe and reliable

operation of the facility throughout its entire life;

The design, construction, and start-up activities need to be perfonned by

those who will ensure that the completed project is of the quality necessary

to provide adequate protection of public health and safety;

The design effort needs to be organized such that there is continuity

through all phases (conceptual design, preliminary design, final design,

construction, testing) so that all aspects of the process that affect safety are

clearly delineated and consistent, and that line responsibility is clear;

• The DOE organization responsible for the project needs to have personnel

in numbers and technical competence sufficient to provide direction and

guidance to contractors performing all phases of the effort and to assess the

effectiveness of contractor efforts;

• The project organization and operations need to reflect a clear and effective

chain of command with responsibility, authority, and accountability clearly

defined and assigned to individuals within the respective project

organizations; and

• The functions and responsibilities of all DOE and contractor organizations

involved in the project need to be delineated in writing in a single

document.

The Secretary accepted the Board's recommendation on August 28, 1992, and

included the Department's comments on the recommendation. Pursuant to the Board's

- 6
approval of DOE's request for an extension of time, the Implementation Plan was due

on February 5, 1993.1

d. Recommendation 92-5, Discipline of Operation in a Changing Defense

Nuclear Facilities Complex

In 1992 the Secretary announced that, in light of international developments,

plutonium production operations would not be resumed at the Rocky Flats Plant.

Future activities at Rocky Flats will be confined to cleanup and decontamination of the

site, decommissioning ofsome facilities and parts of others, and placing ofsome facilities

and parts of others in a state of readiness for resumption of operations in the future, if

necessary. Thus, for most facilities at Rocky Flats there is now a major change from the

mission and activities previously planned. Moreover, Board recommendations and DOE

implementation plans specific to the Rocky Flats Plant had· been predicated upon

resumption of plutonium production.

At a number of other defense nuclear facilities, similar changes are taking effect.

Many facilities are now scheduled for cleanout, shutdown, and decommissioning. Some

are to be devoted to aspects of cleanup and decommissioning of sites and of facilities

located within sites. Some are slated to be placed in a standby mode, available for

restart at a later date if needed. Some are to continue to operate, either to reduce the

stockpile of nuclear weapons or to maintain a reduced stockpile while improving safety.

Therefore, the Board requested that the Secretary decide the future status of

individual defense nuclear facilities and inform the Board, designating which facilities

are to continue in operation and their mission, which are to be shut down for

decommissioning within a short time period, which are to be used for an extended time

period and then shut down for decommissioning, and which are to be moved to a

standby mode. The Board also requested DOE's schedule for accomplishing these

actions.

Regardless of the category, the Board believes that operation and maintenance

of defense nuclear facilities in all modes should be in accordance with the Nuclear Safety

Policy statement that the Secretary issued on September 9, 1991, as SEN-35-91, and the

safety goals stated therein.

The Board also believes that, to the extent practicable, facilities that are to be

shut down and decommissioned should be cleaned up, and hazards and radiological

exposures sufficiently reduced, so that access can be made freely without need for

1DOE submitted its Implementation Plan for 92·4 on February 5, 1993.

- 7 -
unusual precautions. Facilities meant for standby status should be placed in such a

condition that sudden need to reactivate them would not subject a new operating group

to unacceptable radiation or other hazards.

Based on these considerations, the Board issued Recommendation 92-5 on

August 17, 1992. Recommendation 92~5 deals with discipline of operations in a changing

nuclear facilities complex. The full text of Board Recommendation 92-5 is contained in

Appendix A. The Secretary simultaneously accepted the recommendation and issued

DOE's Implementation Plan to the Board on December 16, 1992.

e. Recommendation 92-6~ Operational Readiness Reviews (ORRs)

Several of the Board's recommendations to the Secretary have referred to

Operational Readiness Reviews (ORRs), and some have been specifically directed to

such activities. In this way, the Board has shown that it holds these reviews, whether by

the contractor or by DOE, in high regard as important measures in verifying readiness

of new activities to be started safely or of previously conducted activities to be safely

resumed after an appreciable shutdown.

The Board recognized the advances in defining ORR requirements made by DOE

in SEN-16B-91, "Approval for Restart of Facilities Shut Down for Safety Reasons and

for Startup of Major New Facilities", dated November 12, 1991, and the attached

tlprocess for Secretary Approval of Nuclear Facility Restart or Startuptl. However, the

Board believes that guidance could be improved by specifying the required features of

a satisfactory ORR, and by stating specifically on what occasions an ORR will be

required. Also, ORRs should not serve as a substitute for the line management's

responsibility to assure the readiness of facilities for safe and reliable operation.

Therefore, on August 27, 1992, the Board issued Recommendation 92-6, in which

the Board specified features that it believed were essential to an acceptable ORR and

recommended that DOE develop uniform orders, guidance, and directives to govem the

ORR process. The full text of Board Recommendation 92-6 is contained in Appendix

A The Secretary accepted the Board's recommendation on October 19, 1992. DOE's

Implementation Plan was due on February 4, 1993.2

f. Recommendation 92-7, Training and Qualification

Since its inception, the Defense Nuclear Facilities Safety Board has emphasized

that a well-constructed and documented program for training and qualifying personnel

and supervisors for operations, maintenance, and technical support is an essential

2DOE's Implementation Plan was received on January 19, 1993.

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foundation of operations and maintenance and, hence, the safety and health of the

public, including the facility workers. A substantial portion of the Board's efforts has

been devoted to on-site observation and review of personnel and supervisor selection,

training, qualification, certification and facility operation.

Despite the long-standing requirements of DOE Orders, neither DOE nor the

contractors have provided sufficient management attention and resources for training

and qualification commensurate with the health and safety implications of their defense

nuclear programs. Each of the sites evaluated by the Board has demonstrated

wealmesses in contractor training programs that have potential negative safety

consequences.

Recommendation 90-1, issued in February, 1990, called for the development of

an effective training program at Savannah River Site K-Reactor. Despite the successful

application of Reconunendation 90-1 to K-Reactor, and application of its principles to

the Replacement Tritium Facility, DOE has not followed up with improved training of

corresponding technical personnel at some other Savannah River Site defense nuclear

facilities. Also, the Department has been slow to extend the underlying principles of

Board Recommendation 90-1 to other defense nuclear sites.

On the basis of assessments conducted by the Board's staff at the Hanford Site,

the Pantex Plant, the Savannah River Site non-reactor facilities, the Oak Ridge Y-12

Plant, and the Rocky Flats Plant, and, to a lesser extent, reviews conducted elsewhere

in the defense nuclear facilities complex, the Board believes DOE needs to take action

to further strengthen training of technical persormel at defense nuclear facilities.

Therefore, in keeping with the Board's statutory requirements and recognizing the

priority DOE has placed on the facilities listed above, the Board, on September 22, 1992,

recommended that several strong actions be taken to improve qualification and training

at these specific sites. The full text of Board Recommendation 92-7 is contained in

Appendix A On November 19, 1992, the Secretary requested a 45-day extension to

respond to the recommendation. The Board granted the extension, making the

Secretary's response due on January 21, 1993.3

3'Jbe Secretary responded and accepted the Recommendation on January 21, 1993.

The Implementation Plan is due by April 28, 1993.

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2. DOE Efforts to Implement Board Recommendations Issued in 1991 and

Follow-up Board Action

a. Recommendation 91-1, Strengthening the Nuclear Safety Standards

Program for DOE's Defense Nuclear Facilities (Closed)

The Board's Recommendation 91~1, entitled IlStrengthening the Nuclear Safety

Standards Program for DOE's Defense Nuclear Facilities,1l was reproduced verbatim in

the Board's second Annual Report to Congress. DOE's actions during 1991 to

implement the recommendation are summarized in the Board's second Annual Report

to Congress at pages 2 to 4.

TIle Department's Implementation Plan for Recommendation 91-1, which was

received by the Board on August 16, 1991, provided for preparation of an Action Plan

based on an internal DOE study of the standards program scheduled for completion in

1992. DOE briefed the Board and its staff on progress and initial conclusions during

March and June 1992.

The Action Plan was received by the Board in mid-August 1992. After DOE

agreed to revise the Plan to clarify statements in several places and to provide quarterly

reports on progress in implementing the Action Plan, the Board fonnally closed

Recommendation 91-1 by its letter dated October 27, 1992.

During 1992, DOE's program for the development and promulgation ofstandards

improved. Several new or significantly revised DOE Orders bearing on safety were

issued. The Department is actively reviewing the qualifications of personnel involved

in development and implementation of standards, in accordance with provisions of its

Action Plan. The effective use of technical standards at DOE facilities was expanded,

and an improved program for Order compliance and self-assessment has been instituted.

However, the task is substantial, and much remains to be accomplished. The Board

intends to continue to monitor closely DOE's progress in the standards arena as the

Department proceeds with its Action Plan for implementing Board Recommendation

91-1.

b. Recommendation 91-2, Closure of Safety Issues Prior to Restart of

K-Reactor at the Savannah River Site (Closed)

The Board's Recommendation 91-2, entitled "Closure of Safety Issues Prior to

Restart of K-Reactor at the Savannah River Site," was reproduced verbatim in the Board

second Annual Report to Congress. DOE's actions during 1991 to implement the

recommendation are summarized in the Board's second Annual Report to Congress at

pages 4 and 5.

- 10 -
At its public meeting of December 21, 1991, the Board concluded that the

Department's actions in resolving issues identified in the Reactor Operations

Management Plan (ROMP) issued by the Savannah River Site operator were completed

satisfactorily, and that no further Board actions were required at that time. Except for

continued monitoring of DOE and contractor actions as restart proceeded, the Board

considered Recommendation 91-2 as completed. Accordingly, the Board formally closed

91-2 in its letter to the Secretary of Energy dated October 27, 1992.

c. Recommendation 91-3, DOE' s Comprehensive Readiness Review Prior to

Initiation of the Test Phase at the Waste Isolation Pilot Plant (WIPP)

(Closed)

The Board's Recommendation 91-3, entitled "DOE's Comprehensive Readiness

Review Prior to Initiation of the Test Phase at the Waste Isolation Pilot Plan (WIPP),n

was reproduced verbatim in the Board's second Annual Report to Congress. DOE's

actions during 1991 to implement the recommendation are sl1nunarized in the Board's

second Annual Report to Congress at pages 5 and 6.

In the Spring of 1991, the Board issued Recommendation 91-3, calling for the

conduct of a complete Operational Readiness Review before commencement of the test

phase for the Waste Isolation Pilot Plant (WIPP). As noted in the Board's second

Arumal Report, the Department moved rapidly and effectively to respond to the Board's

concern. The Board documented its conclusion that no further Board action was called

for in its letter dated November 24, 1991. The Board formally closed Recommendation

91-3 in its letter to the Secretary of Energy dated October 27, 1992.

d. Recommendation 91-4, DOE' s Operational Readiness Review Prior to

Resumption of Plutonium Operations at the Rocky Flats Plant (Closed)

In September 1991, the Board issued Recommendation 91-4, which made

recommendations for improving ORR activities concerning Building 559 at Rocky Flats

Plant prior to the resumption of plutonium processing operations. This recommendation

was issued as a result of the Board's detennination that DOE's initial ORR for Building

559 was premature and inadequate. The Board's Recommendation 91-4, entitled

"DOE's Operational Readiness Review Prior to Resumption of Plutonium Operations

at the Rocky Flats Plant," was reproduced verbatim in the Board's second Annual

Report to Congress. DOE's actions during 1991 in accepting and implementing the

recommendation are summarized in the Board's second Annual Report to Congress at

pages 6 through 10.

During a public meeting held on January 16, 1992, the Board considered the

adequacy of the second set of ORRs conducted by the Department and its contractor,

EG&G, in preparation for restart of Building 559. The Board determined that DOE

- 11 -
had adequately implemented relevant Board recommendations prior to restart, and that

no further Board action was required at the time. Recommendation 91-4 was formally

closed by the Chainnan's letter to the Secretary of Energy, dated May 1, 1992.

Recommendation 90-4 regarding ORRs in general at Rocky Flats, and DOE's

corresponding implementation plan, remain in effect for ORRs conducted for other

plutonium processing facilities at Rocky Flats.

e. Recommendation 91-5, Power Limits for K-Reactor Operation at the

Savannah River Site

The Board's Recommendation 91-5, entitled "Power Umits for K-Reactor

Operation at the Savannah River Site," was reproduced verbatim in the Board's second

Annual Report to Congress. DOE's actions during 1991 to implement the

recommendation are summarized in the Board's second Annual Report to Congress at

pages 10 and 11.

Recommendation 91-5 was issued on December 19, 1991. It expressed the

Board's view that the K-Reactor at the Savannah River Site should not be operated

above 30% of the nominal historical power unless and until certain specified thermalhydraulic studies and accident analyses were completed satisfactorily.

The Secretary accepted the recommendation in his letter dated February 7, 1992.

During a series of briefings on this matter held during the spring and slunmer of 1992,

the Department stated that it had no plans to operate K-Reactor above the 30% power

level. While the Board agreed with this position, it indicated to DOE that

Recommendation 91-5 would be carried in an open status, pending any future DOE

decision to increase power above that level.

f. Recommendation 91-6, Radiation Protection for Workers and the General

Public at DOE Defense Nuclear Facilities

On December 19, 1991~ the Board issued Recommendation 91-6 calling for a

major reexamination of DOE's radiation protection program. The Board's

Recommendation 91-6, entitled "Radiation Protection for Workers and the General

,Public at DOE Defense Nuclear Facilities," was reproduced verbatim in the Board's

second Annual Report to Congress. The Secretary of Energy accepted the

recommendation on January 31, 1992. On June 17, 1992, DOE submitted its

Implementation Plan for Recommendation 91-6 to the Board. The Board, citing

deficiencies in the Implementation Plan, returned it to DOE for major revisions on

August 5, 1992. As of the end of 1992, an acceptable Implementation Plan had not been

submitted to the Board.

- 12 -
3. DOE Actions to Implement Board Recommendations Issued in 1990 and

Follow-up Board Action

a. Recommendation 90-1, Operator Training at Savannah River Site Prior to

Restart of K, L, and P Reactors (Closed)

The Board's Recommendation 9Q..1, entitled ItOperator Training at Savannah

River Site Prior to Restart of L, and P Reactors," was reproduced verbatim in the

Board's first Annual Report to Congress. DOE's actions during 1990 and 1991 to

implement the recommendation are summarized in the Board's second Annual Report

to Congress at page 16.

During 1992, the Board and its staff continued to monitor the progress made by

the Department in implementing Board Reconunendation 90-1 regarding reactor

operator training. Most of the substantive actions called for by the 90-1 Implementation

Plan had been implemented satisfactorily by DOE prior to the Board's public meeting

held in Washington, DC on December 20, 1991, regarding the restart of K-Reactor at

SavaIU1ah River. Based on that progress, the Board concluded at that public meeting

that no further Board action was required at that time.

On October 24, 1992, in response to correspondence from the Department during

the late summer and fall, the Board formally closed Recommendation 90-1, noting that

it would continue to monitor the training and qualifications of operators.

b. Recommendation 90-2, Design, Construction, Operation and

Decommissioning Standards at Certain Priority DOE Facilities

The Board'sRecommendation 90-2, entitled t1Design, Construction, Operation and

Decommissioning Standards at Certain Priority DOE Facilities," was reproduced

verbatim in the Board's first Annual Report to Congress. DOE's actions during 1990

and 1991 to implement the recommendation are summarized in the Board's second

Annual Report to Congress at pages 16-18.

On January 24, 1992, the Board infonned the Department that the DOE

Implementation Plan for Recommendation 90-2, on Standards Content and

Implementation at selected defense nuclear facilities, did not meet the criteria for an

acceptable implementation plan contained in Board Policy Statement 1. The Board then

established a staff task group, headed by the Technical Director and the General

Counsel, to work with representatives of DOE's Defense Programs and Environmental

Restoration and Waste Management in developing an adequate implementation plan.

The Department provided Revision 2 of its 90-2 Implementation Plan with the

Secretary's letter dated June 15, 1992. Following review of the newly revised plan, the

- 13 -
Board determined that the plan remained inadequate in several important respects. The

Board's task group met again with DOE representatives and identified areas needing

revision. After its consideration of the Board's and the task group's comments, DOE

elected to completely revise Revision 2 of its Implementation Plan.

Revision 3 of the 90-2 Implementation Plan was received by the Board on

December 30, 1992, and at year-end that revision was under evaluation by the Board and

its staff.

During 1992, the Board, its staff, and support contractors have also reviewed

DOE's use ofstandards at certain defense nuclear facilities, including the K-Reactor and

the Replacement Tritium Facility at Savannah River, Buildings 559 and 707 at Rocky

Flats, and selected facilities at the Pantex Plant and Y-12. The selected subject areas of

these reviews were: quality assurance, training, general design criteria, maintenance,

radiation protection, nuclear criticality safety, fire protection, emergency preparedness,

and safety analysis.

These reviews of how standards are utilized have disclosed an increased emphasis

by DOE and O&M contractor managers on employing key aspects of safety standards

in both written operating procedures and in direct application of the standards at the

facilities visited. Review and analysis of standards activities at the facilities by the

Board's staff have been resource intensive. The Board continues to strongly encourage

DOE to utilize the lessons learned from review of these facilities and to apply them to

other facilities.

c. Recommendation 90-3 (Closed) and Recommendation 90-7, Safety at

Single-Shell Hanford Waste Tanks

The Board's Reconunendations 90-3 and 90-7, entitled "Safety at Single-Shell

Hanford Waste Tanks," were reproduced verbatim in the Board's first Annual Report

to Congress. DOE's actions during 1990 and 1991 to implement the recorrunendations

are summarized in the Board's second Annual Report to Congress at pages 18 and 19.

Recommendation 90-3, issued in late March and Recommendation 90-7, issued

in mid-October, 1990, were both aimed at expediting DOE's actions to better

characterize and control the waste stored in certain single-shell tanks in the Hanford

Tank Farm. The Department's Implementation Plans for these reconunendations were

accepted by the Board on August 10, 1990, and March 7, 1991, respectively.

The Board fonnally closed Recorrunendation 90-3 in its letter to the Secretary

dated May 1, 1992, recognizing that Recommendation 90-7 had superseded the previous

Reconunendation and Implementation Plan. The Board remains concerned by the slow
pace of progress in implementing 90-7, and has scheduled a public hearing near the

Hanford Site for early 1993.4

d. Recommendation 90.4, Operational Readiness Reviews at the Rocky Flats

Plant

Recommendations 90-4 and 91-4 both deal with deficiencies identified in the

Operational Readiness Review Program originally planned for restart for Plutonium

operations in Building 559 at the Rocky Flats site. In May, 1990, the Board issued

Recommendation 90A, which recommended that DOE conduct operational readiness

reviews (ORRs) at the Rocky Flats Plant prior to the resumption of operations in

plutonium processing buildings. Recommendation 90-4 is presented in its entirety in the

Board's first Annual Report to Congress.

In June, 1990, the Secretary accepted this recommendation. The Board reviewed

a draft Implementation Plan and provided conunents for the Plan's improvement prior

to DOE's issuance of the final plan on November 30, 1990. Initial DOE ORR activities

for Building 559 were conducted in mid-1991. In September, 1991, the Board issued

Reconunendations 91-4 related to the ORR for that building. See Section n.A2.d.

above.

Board and staff activities related to ORRs at Rocky Flats in 1992 are summarized

in Section II.BA of this report.

e. Recommendation 90·5, Systematic Evaluation Program at the Rocky Flats

Plant

In May, 1990, the Board issued Recommendation 90-5, which recommended that

DOE establish a Systematic Evaluation Program (SEP) at the Rocky Flats Plant to

assure the proper evaluation and coordination of proposed long-term safety

improvements. Recommendation 90-5 is presented in its entirety in the Board's first

Annual Report to Congress.

In June, 1990, DOE accepted this recommendation and provided the Board with

an Implementation Plan which the Board accepted on October 24, 1990. Following its

acceptance of the recommendation, DOE initiated an SEP for the K-Reactor at the

Savannah River Site, in addition to the Rocky Flats SEP.

During 1992, the identification of topics to be evaluated in the Rocky Flats SBP

was completed, as were the individual topic evaluation plans. General acceptance

~at public hearing was held on February 11, 1993.

- 15 -
criteria were developed for evaluating structures, systems, and components. DOE

concentrated its efforts on supporting the evaluations for Buildings 559 and 707, the two

buildings to be used for plutonium operations to support the cleanup. Topic evaluation

was initiated for Building 559, including the identification of "as built" information, such

as drawings, design calculations, applicable specifications and performance ofwalkdowns

of certain structures, systems, and components. DOE has initiated similar activities for

Building 707.

In 1992, progress on the SEP for the Savatmah River K-Reactor included the

assembly of a full-time technical staff and the identification of topics for evaluation after

review of relevant DOE and commercial nuclear information. Individual topic

evaluation plans were begun. They should be completed during 1993.

The Board and its staff met on a number of occasions with DOE and its

contractors in 1992 to review progress on the SEP programs for facilities at the Rocky

Flats Plant and the Savannah River Site. A~ a result of the change in mission at both

the Rocky Flats Plant and the Savannah River K-Reactor, the Board anticipates that

DOE will propose changes to its implementation of the SEP in 1993.

f. Recommendation 90-6, Criticality Safety at the Rocky Flats Plant

The Board's RecommendatioIl 90-6, entitled "Criticality Safety at the Rocky Flats

Plant," was reproduced verbatim in the Board's first Annual Report to Congress. DOE's

actions during 1990 and 1991 to implement the recommendation are summarized in the

Board's second Annual Report to Congress at pages 21 and 22.

In June, 1990, the Board issued Recommendation 90-6, which proposed that DOE

establish a program to address the accumulation of fissile and other materials in

ventilation duets and related systems prior to the resumption of plutonium operations

at Rocky Flats. The short-term objectives of the recommendation were to ensure the

prevention of criticality accidents and to make an initial reduction in the amount of

fissile material in the ducts in the interest of protecting public health and safety. TIle

long-term objectives of the recommendation were to reduce substantially the remaining

fissile material in the duets and to prevent significant additional accumulation of fissile

material upon resumption of plutonium operations. DOE accepted Reconunendation

90-6 on July 26, 1990, and submitted an Implementation Plan on November 30, 1990.

In 1992, progress was made on the major tasks in the DOE program for

addressing accumulation of fissile material in the ducts at Rocky Flats. These major

tasks include detennination of the extent of fissile material accumulation, evaluation of

criticality safety and potential worker radiation exposure, removal of fissile and other

materials from the ducts, and prevention of significant additional fissile material

accumulation.

- 16 -
DOE's contractor assessed the potential for a criticality accident due to fissile

material accumulation measured in the ducts and related systems. The contractor

concluded that the planned removal of fissile material from the ducts would prevent

criticality even in the event of catastrophic flooding accompanied by other highly unlikely

events that could cause material to accumulate in a small volume.

Due to the change in mission at Rocky Flats from predominantly production to

predominantly cleanup, DOE focused efforts under Recommendation 90-6 on Building

707, where limited plutonium processing operations are planned in support of cleanup.

Remediation of Building 707 has been accomplished, including removal of the material

or replacement of ducts. This work eliminated the potential for criticality from fissile

material accumulation in ducting and reduced worker radiation exposure levels resulting

from the ducting in the building. To prevent significant additional fissile material

accumulation, the contractor inspected, repaired, or refurbished gloveboxes, exhaust

filters, and alarm systems as necessary. Operating procedures were reviewed and

upgraded. After resumption of plutonium operations in Building 707, the duets are to

be closely monitored for accumulation of additional fissile material.

DOE proposed a revision to the 90-6 Implementation Plan to change the

numerical factor applied to fissile material measurements to account for uncertainties.

The Board reviewed the proposal and concluded that the revised factor would

adequately compensate for measurement uncertainties.

Members of the Board and its staff reviewed monthly DOE status reports from

DOE and met several times in 1992 with DOE and its contractor to discuss the progress

in meeting the objectives of this reconunendation. The Board and its staff will continue

to monitor progress in the implementation of this recommendation.

4. Public Hearings, Public Comment, and Interaction with Board

During 1992, Board Members traveled to defense nuclear sites on 24 occasions,

where they met with contractors, DOE representatives, members of the public, labor

unions, and public interest groups. The Board conducted five public meetings, hearings,

and briefings at various sites throughout the country. The 1992 highlights from the

Board's efforts to include and inform the public of Board activities follows:

• Notices of Public Meetings and Recommendations

to the Press and the Public 1,246

• Responses to Inquiries from the Public and News Media 280

17 -
5. Official Site Visits by Board Members and by Staff

From the establishment of the Board in October, 1989, through December 31,

1992, Board Members, its staff, or its contractor experts made 298 site visits to DOE

defense nuclear facilities. In 1992 alone, 155 site visits were made to DOE defense

nuclear facilities by Board Members, its staff, or its contractor experts. These visits

focused primarily on selected facilities that both the Board and DOE consider to be

urgent in light of DOE's mission, primarily the Savannah River Site, the Pantex Plant,

the Hanford Site, the Rocky Flats Plant, and the Waste Isolation Pilot Plant.

The Board reviewed firsthand the health and safety issues at each of these sites.

In 1992, the Board Members spent a combined total of 76 work days at DOE defense

nuclear facilities conducting these reviews. During these visits, the Board gathered the

bases for its recommendations to the Secretary of Energy and monitored the

implementation of recommendations that have already been made, while seeking to

avoid unduly interfering with DOE's program to manage the site or facility.

B. SAFETY AND HEALTH STATUS OF DEFENSE NUCLEAR FACILITIES

1. Board Perspective on Outstanding Issues of Health and Safety

a. Overview

The Board, assisted by its staff, expanded the scope of detailed technical reviews,

formal investigations, and in-plant audits to include nearly all of the more important

DOE defense nuclear sites.

In late 1991, Congress amended the Board's enabling Act, broadening the Board's

jurisdiction over defense nuclear facilities to include the assembly, disassembly, and

testing of weapons and weapons components. With this increase in responsibility, the

Board revised its priorities to include reviews of additional facilities, including principally

Pantex, Y-12, Nevada Test Site, and the weapons design laboratories, and also

encompassing Pinellas, Kansas City, the tritium facilities at Savannah River Site, and pit

storage areas at Rocky Flats Plant and Savannah River Site. During 1992, the Board

and its staff conducted initial reviews and site visits at these facilities. These have led

to changes in technical review plans and associated resource commitments. Projections

for future needs were incorporated in the Board's recent budget request to address the

increased scope of the Board's mission.

In assessing priorities, the Board also considers problems brought to its attention

by various sources, including Members and staff of the Congress, the General

Accounting Office, and the public. Priorities are assigned for oversight activities at

specific sites on the basis of: (1) potential risk to public health and safety, (2)

- 18 -
effectiveness of DOE management in managing those risks~ (3) timeliness in relation to

DOE programmatic or operational goals and objectives, and (4) urgency in terms of any

imminent or severe threat to public health and safety. If an imminent or severe threat

to public health and safety were identified at a DOE facility, the Board would respond

and adjust priorities as necessary.

The Board's recommendations emphasized those factors which are important to

the safe and efficient operation of defense nuclear facilities. Among those activities

receiving priority to date are the identification, assessmen4 and application ofstandards;

the selection, training, and qualification of operations, maintenance, and technical

support personnel; the development of systematic approaches to evaluating and

upgrading existing facilities; the development of a comprehensive radiation protection

program including the control of radioactive sources and contamination; the need for

adequate operational readiness reviews (ORRs); the selection, training and assignment

of DOE Facility Representatives at defense nuclear facilities; the use of the systems

approach for conducting projects; and substantive actions to improve safety. The Board

also reconuneuded that a standard for the conduct of ORRs be developed, including a

requirement that ORR teams be composed of senior, experienced individuals. The

Board indicated that ORRs should be conducted before the start-up of new facilities, the

restart of greatly altered facilities, or restart of facilities shut down due to safety issues.

As a result of its ongoing activities, the Board at times develops information

which warrants being brought to DOE's attention promptly while it is being assessed

further by the Board. In such calies, the Board communicates the information to DOE

through letters which are placed in the Board's public document room. In late 1992, the

Board developed and issued Policy Statement 2 regarding "Board Policy on Transmittal

of Trip Reports and Other Safety Infonnation to the Secretary of Energy."

b. DOE Identification of Significant Safety Issues Remaining at Defense

Nuclear Facilities

Throughout this report, in earlier Annual Reports, and in Board

recommendations and other communications with the Department, the .Board identified

a number ofsignificant safety issues affecting defense nuclear facilities. Naturally, as an

extemal oversight agency, the Board is not the only, or for that matter, the primary

source for identifying safety issues at defense nuclear facilities. DOE, its contractors,

and line organizations, in particular, are closest to pressing safety problems. The Board

is heartened to note that safety matters are now receiving higher priority attention from

DOE and contractor management.

Improvements in safety awareness and responsiveness to identified safety issues,

particularly within the past year, are evident at several major defense nuclear facilities,

most notably at the Savannah River K Reactor and at the Rocky Flats Plant. Much

- 19
remains to be done at those facilities, but desirable change is occurring, and the rate of

change is positive. Some examples of the Department's increasingly introspective

involvement in substantive safety matters appear in the following sections.

DOE itself recognizes that in several important areas the Department has failed

to correct long-standing safety problems. In the area of safety standards development

and implementation, DOE, Congress, and the Board all agree that more needs to be

done. DOE has noted, for example, that some DOE facilities are not accepting and

implementing standards as quickly or as comprehensively as they should. Based on its

statutory obligations in the standards area, the Board has made several recommendations

regarding standards and shares the views expressed by the Office of Nuclear Safety

(ONS): "Adherence to standards is particularly important at a time when DOE's mission

is changing dramatically and the nuclear safety challenges associated with aging facilities,

high level waste management, and decontamination and decommissioning are only

beginning to be fully understood and addressed."

The subject ofthe Department's training and qualification program received close

attention from the outgoing Secretary, who noted in a January 19, 1993 letter to the

Board that t1[l]ike many of our new policies, training and qualification programs are not

yet implemented to the degree we expect, and these programs require high~level

attention. We must seek continuous improvements in these efforts for our training and

qualification programs at the defense nuclear facilities. .. It is unacceptable for us to

allow a return to those days when there existed as described by NAS [National Academy

of Sciences], I a marked imbalance in technical capabilities and experience between the

contractors and the DOE staff. ' II

The Department's acknowledgement of these and many other problems in DOE

reports to Congress and other official statements is an important first step towards their

correction. The outgoing Secretary observed in his January 1993 Posture Statement that

although much progress has been made, there is still more to be done. We agree.

Although the Department's position on these matters is commendable, we believe their

resolution will entail a sustained effort, within DOE, its contractor organizations, as we])

as on the part of the Board and its staff.

c. Initial Review of Safety-Related Issues at Nuclear Weapons Assembly,

Disassembly and Testing Facilities

Amendments to the Board's enabling legislation were enacted on December 5,

1991, as part of the National Defense Authorization Act for Fiscal Years 1992 and 1993.

One major change expanded the statutory definition of a "DOE defense nuclear facility"

to include facilities and activities involved with the assembly, disassembly, and testing of

nuclear weapons. As a consequence, additional technical activities were conducted at

the following plants, sites and laboratories:

- 20 -
•

•

•

•

•

•

•

•

Pantex Plant

Oak Ridge Y-12 Plant

Los Alamos National Laboratory

Tritium Facilities at the Savannah River Site

Building 991 at Rocky Flats

Nevada Test Site

Sandia National Laboratories (Albuquerque and Livermore)

Lawrence Livermore National Laboratory

Pinellas Plant

The Board went to these facilities to familiarize itself with the activities at the

facilities and to explore an assortment of safety-related issues. To meet its near-term

needs regarding weapons activities, the Board formed a group of experienced staff

members, hired additional persOIUlel, and contracted for outside technical experts with

nuclear weapons expertise. One of these new personnel was assigned to the Pantex site

as a Board site representative. To effectively execute its charter and meet the challenges

presented above, the Board plans to hire additional personnel with experience in

nuclear-chemical processing, in conventional and nuclear explosive technology and safety,

in electrical power generation and distribution, in storage of nuclear materials and

criticality safety, and in waste management and enviromnental restoration. In addition,

the Board will need to contract for additional outside technical expertise, as required to

meet its health and safety responsibilities in the weapons assembly, disassembly, storage,

and testing areas.

Recent decisions to accelerate the extent and rate of nuclear weapons disassembly

at DOE facilities led the Board to focus particular attention on the Pantex and Y-12

plants. The Board conducted activities and was briefed at each of these sites. In

addition, the Board's staff and outside technical experts made a total of 155 trips to

these facilities.

These reviews led to a number of safety~related issues being presented to DOE

in the areas of standards utilization, safety analyses, training, and conduct of operations.

In addition, on December 31, 1992, the Board requested that DOE report on aspects of

nuclear criticality safety at the Pantex Plant by the end of January 1993.

Although the weapons assembly, disassembly and testing facilities, and the defense

production facilities are different in kind, the topics of review for both types are similar.

For example, the Board will analyze the following technical areas, among others:

• DOE and Contractor Analysis of Safety Conditions

Safety analyses and reports

Process for identification of potential safety problems

- 21 -
Accident analysis

Occurrence Reporting and Root Cause determinations

Operational Safety

Conduct of Operational Readiness Reviews

Conduct of operations and maintenance

Quality assurance

Operator training

Radiological protection and emergency preparedness

Systems Engineering

Engineering, including civil and structural design, configuration

management, and systematic evaluation programs

• Standards Development and Implementation

Implementation of rules, regulations, and standards (including DOE

Orders and consensus standards)

Envirolll1lental Management

Safety aspects of waste minimization and environmental restoration

• Management and Organization Pertaining to Safety

The Board's initial reviews in these areas have highlighted certain analytical and

operational matters that need to be upgraded in the long term. For example, at Pantex

alone, nwnerous safety analysis reports need to be written or upgraded for a large

number of facilities. At some other sites, safety analyses do not exist or they

are deficient. Those that are available are often not prepared in accordance with

current accepted industry guidelines and the recently issued DOE Order for safety

analyses, and do not incorporate current methods of analyzing the safety of facilities and

operations.

Previous Board actions to effect a change in the safety culture at other facilities

(e.g., SRS K-Reactor and RFP Building 559) are beginning to have an effect on

operations at these weapons sites. For example, standards and DOE Order compliance

programs have recently been initiated at the facilities listed above. Most sites have

strengthened existing training programs or established new training programs in

accordance with recently revised DOE Orders and industry standards used for operating

nuclear power plants, including INPO Guidelines and NRC regulations and standards.

However, important areas will receive further evaluations by the Board and its staff, and

a sustained effort will be made to ensure that the "lessons learned" at SRS K-Reactor

and RFP Building 559, and DOE's upgrading of operations in response, are transferred

to the weapons facilities.

- 22 -
Most of the weapons assembly facilities were designed and constructed in the

period between the late 1940~s and early 1960~s. DOE is taking several actions to

address issues associated with these aging facilities. Various actions are also being

planned as a function of expected future use of the facilities. Some actions include

refurbishing facilities intended for continued use (e.g., installing new electrical

distribution systems), changing the functions of some facilities (e.g.~ conversion of a

manufacturing facility to a storage facility) and placing some facilities in standby. The

Board intends to evaluate DOE's facility modernization plans~ related system test

requirements, and facility configuration documentation, and will evaluate how existing

plant systems are placed in a safe and stable condition prior to transition to standby.

Many DOE facilities previously managed by DOE's Office of Defense Programs

are being transferred to DOE's Office of Environmental Restoration and Waste

Management (EM). The status of these facilities needs to be well-characterized prior

to their transfer to EM for decontamination and decommissioning. This then allows a

determination to be made if additional measures are required for ensuring safety during

a state of standby or decontamination and decommissioning.

d. Importance of Qualified DOE Technical StatT

The Board continues to believe that the single most serious and far-reaching

problem affecting the safety of DOE defense nuclear facilities is insufficient numbers of

highly qualified technical and management personnel within the DOE work force. That

deficiency hinders DOE in providing fully effective technical direction and management

of its contractors. The Board discussed this problem in its two previous Annual Reports.

A number of earlier independent assessments also noted the same deficiency, including

the 1981 post-Three Mile Island DOE review of the safety of its reactors (the Crawford

Report) and the 1987 Report of the National Academy of Sciences.

The Board recognized DOE's attempts to correct the problem. Unfortunately,

they have not been effective enough, and the problem persists. The Board addressed

the qualifications problem in several of its fonnal recommendations~ and frequently

communicated its concern on this matter to senior DOE officials over the past three

years.

The problem is pervasive. Such deficiencies exist to varying degrees not only in

organizational units in Headquarters but also in the Field organizations of DOE. The

Board believes that a root cause of this shortcoming in DOE staff qualifications lies in

a deep-seated conviction among many senior DOE career managers that program

management capabilities, and perhaps only general technical familiarity, are adequate.

Those who hold this belief elevate financial management, project scheduling, cost

accounting, and other administrative management capabilities above technical

competence in assigning people to positions of responsibility for managing technological

- 23 -
programs of DOE. As a result, too many individuals without adequate technical

qualifications are assigned jobs crucial to the safety of defense nuclear facilities.

Contributing causes include: limited capability of DOE to attract technically

competent professionals to nuclear weapons activities and assignments as career choices;

the lack of "excepted seIVice" hiring authority by DOE, particularly for key technical

management and direction positions; lack of an aggressive recruitment and retention

policy for technical career personnel within DOE; insufficient attention by internal

monitoring elements of DOE to this problem as a contributor to off-nonnal events; and

the lack of an effective program for interchange of technical staff between Headquarters

and Field organizations within DOE.

The Board recognizes that it is much easier to identify this problem than to

correct it. The Board also recognizes that some senior DOE technical managers are

indeed very well qualified and that those managers usually share the Board's frustration

in coping with the problem.

The Board believes that resolution of this serious problem will require not only

fundamental change in the plan of attack of DOE, but also the assistance of Congress

over the long term. For its part, the Board will continue to identify specific instances

in which the lack of qualified persoIUlel at the DOE contributes to less-than-adequate

protection of public health and safety, to call those to the attention of DOE and, where

appropriate, to issue formal recommendations to the Secretary on those matters, as well

as to exercise its other authorities as necessary to meet its statutory obligations.

The lack of sufficient numbers of qualified technical personnel in DOE is a

serious issue in itself. It also has adverse consequences for the Board, which has a

limited number of staff. The ability to meet its responsibilities and to expand its

coverage are directly related to DOE's performance in taking prompt and effective

remedial action on safety problems which are called to DOE's attention by the Board.

If Board personnel must make repeated assessments of one facility or activity in order

to assure that needed improvements are made, the Board's ability to expand its activities

may be jeopardized. Further, the Board is sensitive to the need to ensure that its

resources are not used as a substitute for DOE persoIUlel and capability, both in line and

internal oversight organizations, for detecting and correcting safety problems.

During 1992 DOE issued a new Order on quality assurance (5700.6C), which

provides a powerful means by which DOE will be required to affirm for each DOE

position that personnel are qualified, technically and otherwise, to perfonn the tasks

associated with that position. Recognizing the opportunity thus provided, the Board

intends to follow closely the activities of DOE line and oversight organizations) as well

as Operational Readiness Reviews, to help assure full compliance with this Order.

- 24 -
e. Importance of DOE Facility Representatives

As a means for achieving closer DOE technical scrutiny of contractor operations

of major DOE facilities, DOE instituted a program for detailing DOE personnel as

Facility Representatives to specific facilities for direct oversight duties. As discussed

previously, DOE needs to upgrade its Facility Representatives program across the DOE

defense nuclear complex. Moreover, because many personnel are involved, the Board

expects that intensive effort will be needed to ensure that initial DOE efforts are focused

on the fundamental problems, to develop a single, formal DOE Facility Representative

program. See discussion of Recommendation 92-2 in section II.A.l.b.

f. Development and Implementation of Safety Standards

Most engineering professionals would agree that the development and

implementation of safety standards, orders, rules, and guidance are important elements

of a sound nuclear safety program. Congress also considered safety standards to be

essential for ensuring the public health and safety at DOE defense nuclear facilities in

amending the Atomic Energy Act to create the Defense Nuclear Facilities Safety Board.

As stated in its enabling legislation, the Board is required to review and evaluate the

content and implementation of the standards relating to the design, construction,

operation, and decommissioning of defense nuclear facilities of the Department of

Energy at each of its defense nuclear facilities, and to make appropriate

recommendations to DOE in light of its review.

The development and implementation of safety standards, orders, rules, and

guidance by DOE for defense nuclear facilities has been neither as extensive nor as

systematically accomplished as the programs of NRC and the nuclear community for the

commercial industry. This observation has been well documented in independent studies

of nuclear safety at DOE facilities, including two reports by the National Academy of

Sciences.

One of the reasons often cited by DOE for this difference is that there were few

nuclear industry standards available when many of the DOE facilities were constructed

and first operated over 40 years ago. Contractors in the early years of operation often

had to use non-nuclear industry standards and, in some cases, formulate ad hoc technical

standards to meet unique applications.

Other, more valid and critical, explanations for not including safety standards in

the design, construction, operation, and decommissioning of these facilities include: lack

of understanding among DOE managers of the importance of standards to safety;

resistance by contractors and national laboratories to the use of standards; and the past

lack of exercise of authority over DOE field offices by appropriate DOE officials in
Headquarters. For reasons such as these, a set of coherent nuclear safety standards is

neither well-developed nor in systematic use at DOE defense nuclear facilities.

The Board's approach to improving the development and use of safety standards

within the DOE has been to initiate a program to assess the adequacy of DOE's

standards effort and to issue recommendations that require DOB to make improvements.

The Board issued two recommendations that deal explicitly with standards at the DOE

defense facilities. In Recommendation 90-2 the Board recommended that DOE identify

the applicable standards, assess their adequacy, and examine the extent to which they

have been implemented at each DOE defense nuclear facility.

Revision 3 of the DOE's Implementation Plan for Recommendation 90-2 was

submitted to the Board in December, 1992. In it, DOE proposed to develop

Requirement Identification Documents (RIDs) for each of its defense nuclear facilities.

These documents are intended to document, for the first time, the sum of individual

requirements applicable to the life cycle phases of design, construction, operation, and

decommissioning. The requirements will include standards established by statutes,

regulations, DOE Orders, national consensus codes and standards, and other

requirements imposed by DOE on the Operating and Management (O&M) contractors

and laboratories at its defense nuclear facilities. The Board is following this

development with great interest.

In Recommendation 91-1 the Board recommended that DOE examine the extent

to which it has the organization and personnel in place to develop and implement

standards effectively and to begin the process of upgrading its safety standards. In

response to Recommendation 91-1, DOE developed a program for strengthening its

nuclear safety standards. DOE issued several new safety orders, and is reviewing the

staffing and qualifications of personnel involved in standards development and

implementation. DOE also begun to expand the role of technical standards applicable

to its facilities. The Board is also following DOE's progress in this important area.

Until the Requirement Identification Documents are developed, DOE orders are

the primary mechanism used by DOE to impose requirements on its employees, its

O&M contractors, and its laboratories. These orders contain many requirements related

to health and safety and the environment. DOE instituted an order compliance and self~

assessment program to inform DOE management of the status of implementation of

DOE orders at its facilities. Self-assessments were perfonned by Defense Programs and

its O&M contractors at several defense nuclear facilities.

As mentioned earlier, the Board instituted its own program for assessing the

adequacy of requirements and standards at DOE defense nuclear facilities. In 1992, the

Board, its staff, and several of its contractors reviewed the status and use of safety

standards at several DOE defense nuclear facilities. In particular, the Board's staff

- 26-
conducted reviews and prepared reports on the use of safety standards in areas such as

quality assurance, training, general design criteria, maintenance, radiation protection,

nuclear criticality safety, fire protection, emergency preparedness, and safety analysis at

the following DOE defense nuclear facilities: the K-Reaetor, the HB-Line, and the

Replacement Tritium Facility at the Savannah River Site; Building 559 and 707 at the

Rocky Flats Plant; and selected facilities at the Pantex Plant and the Y-12 Plant.

In these reviews, the Board has seen increased emphasis by DOE and its O&M

contractors on key aspects of safety standards in both the written standard operating

procedures and the application of the standards at the facilities. The Board continues

to encourage DOE to examine the lessons learned at these facilities and to apply them

to other facilities within their cognizance.

The Board staff also reviewed the adequacy of requirements imposed in several

new draft DOE orders. Staff reviews and comparisons of proposed DOE requirements

with those applicable to licensed commercial facilities regulated by the Nuclear

Regulatory Commission have shown a need for improvements in safety requirements

issued by DOE.

Frequent technical interchanges among Board staff, DOE, and DOE's O&M

contractor personnel continue to emphasize that one of the Board's criteria for judging

the safety of DOE defense nuclear facilities is the extent to which DOE uses adequate

safety standards. The Board and its staff continue to monitor DOE's progress in this

important area.

g. Systems EngineeIing and Systems Approach

Many of the safety issues and concerns at DOE facilities result from the

complexity of the facilities, processes, and missions. For these complex systems, DOE

or contractor actions taken to change or affect a part of the system can easily influence

or interact with other parts of the system. Therefore, any action related to one part of

the system must be evaluated for its potential effect on other parts of the system.

Examples of such actions are design, construction, maintenance, operation, and

decommissioning. Furthermore, activities which comprise these processes or actions are

linked and are interactive.

The most complex system being contemplated by the DOE at this time is the

Tank Waste Remediation System (TWRS) at the Hanford Site. The Board believes that

the systems approach and systems engineering in the TWRS project could be

considerably strengthened. Therefore, in Recommendation 92~4, the Board

recommended to the Secretary that actions be taken on the Multi-Function Waste Tank

Facility (MW1F) project at Hanford to incorporate principles of systems engineering

- 27 -
into the project. The M\VTF project is a component of the overall TWRS system and

appears to be scheduled for completion prior to other parts of the system.

Furthermore~ Recommendation 92-4 involves possible modification of longstanding practices within DOE. These long-standing practices include segregation of the

design processes, construction, and operation of facilities. See discussion of

Recommendation 92-4 in Section ILAtc.

2. Overview of Improvements in Safety at DOE Defense Nuclear Facilities

The Board endeavors to ensure public health and safety by issuing formal

recommendations to the Secretary of Energy, and then tracking DOE's implementation

of those recommendations. Nevertheless, the recommendation process is not the only

way in which the Board's actions and activities have had a positive impact on procedures

and practices for ensuring nuclear safety by the Department of Energy. For example,

technical reviews, investigations, questions, and comments by individual members of the

Board or its staff and technical experts during briefings and site inspections also have

their effects. These frequently highlight issues and lead to self-initiated changes and

improvements in DOE's practices and technical directions.

The Board believes that its activities have made significant contributions to

improving the level of DOE and contractor performance at defense nuclear facilities.

In the following sections, improvements are listed in which Board recommendations,

actions, and activities played substantial parts. As stated ill last year's Annual Report

to Congress, it is seldom possible to define which organization made the primary and

which the subsidiary contributions to initiating improvements. TIle process that was

defined in the enabling legislation empowers the Board to recommend, while the

decisions and the actions to implement belong to DOE. Some improvements are the

results of parallel initiatives in DOE and the Board. DOE must file its own separate

report to Congress that details the Department's views regarding safety improvements

within the complex.

3. Board Activities and Improvements at More Than One Facility

a. Operator Training

In its second Annual Report, the Board recognized the improvements made in

training and qualification of operators and supervisors at the K-Reactor at Savannah

River, Building 559 at the Rocky Flats Plant, and at WIPP, following the issuance of

Recommendation 90-1 and the Board's oversight of training at those sites. The

K-Reactor has an effective operator training and qualification program. At some

facilities, such as the Replacement Tritium Facility at the Savannah River Site, DOE and

its contractor have followed the K-Reactor's example and have successfully applied the

principles of Board Recommendation 90-1 in developing effective operator training and

- 28 -
qualification. However, other defense nuclear facilities reviewed by the Board and its

staff continue to exhibit deficiencies in training and the level of knowledge of their

operators and supervisors. DOE Orders on training and qualification provide the sound

primary requirements from which an adequate training and qualification program may

be developed. Nevertheless, the Board continues to find inadequate attention to training

by some senior DOE and contractor managers at many facilities.

Primarily as a result of assessments at the Hanford Site, the Pantex Plant, the

Savannah River Site non~reactor facilities, the Oak Ridge Y 12 Plant, and the Rocky

Flats Plant, the Board determined it was necessary to issue Recommendation 92-7, which

called for systematic improvements in the training and qualification programs of

contractor and DOE employees throughout the defense nuclear facility complex. DOE's

response to Recommendation 92-7 was due on December 28, 1992. At year's end, the

response had not been received by the Board. The full text of Recommendation 92-7

is presented in Appendix A of this report.

b. Operational Readiness Reviews

Responding to a Board recommendation, DOE instituted a commendable process

covering operational readiness reviews (ORRs) for the start of new facilities or the

restart of those that have not been operated for some time. The Board believes that

such a carefully devised and executed process can add measurably to the assurance of

operational safety.

DOE and its contractors made improvements in the conduct of readiness reviews

during 1991, and continued to make improvements during 1992, in the selection of

qualified ORR teams, the development and execution of adequate ORRs, and

documentation of ORR results. DOE plans to select and train additional personnel to

properly conduct ORRs in the future.

Significant safety improvements were made at several facilities, partly as a result

of the Board's oversight of ORR activities. DOE conducted several ORRs during 1992

at facilities in the nuclear weapons complex. Several key ORRs have been discussed

previously. At the Savannah River Site, ORRs were conducted to review proposed

processing of Plutonium-238 at the HB-Line and to initiate chemical operations at the

Defense Waste Processing Facility with non-radioactive feed. Also at Savannah River,

preparations were made for an ORR to be conducted at the Replacement Tritium

Facility (RTF) in 1993. An ORR was conducted for Building 707 at Rocky Flats. At

the Idaho National Engineering Laboratory an ORR was conducted for the restart of the

New Waste Calcining Facility within the Idaho Chemical Processing Plant.

The Board's staff also reviewed the process to be used for conducting planned

ORRs for several facilities at the Hanford Site; several improvements to the process

- 29 -
were made following discussions with Hanford Site personnel. In particular, the ORR

plans were significantly upgraded for the Uranium Oxide facility and the Fuel

Encapsulation Facility at the K-East Basin. Also, ORR plans were developed by DOE

for the Plutonium Reclamation Facility and the 242-A Evaporator, incorporating lessons

learned through interactions between DOE and the Board's staff at other sites.

During 1992, the Board'sstaff closely monitored preparations for these ORRs and

observed their conduct. The staff reported to the Board on several aspects of the ORR

process as implemented by DOE throughout the complex. These included the following

important points:

• The state of readiness of a facility to resume operations at the time an

ORR was initiated differed widely among facilities, with no apparent

rationale for the differences;

• The conduct of the reviews by the ORR teams (Le., did they follow their

review procedures) was not always consistent, nor was it as comprehensive

as might be indicated by the procedures;

In many instances, the ORR was used more to compensate for management

weaknesses (i.e., by generating checklists for facility operations or Board

recommendations) rather than as a tool for management to confinn that a

facility is ready and safe to operate;

ORRs by DOE should be performed only after the operating contractor

certifies that the facility is ready to operate;

• The ORR teams' technical capabilities were not consistently adequate.

Independence of ORR persOImel from line responsibility was not always

present; and

• The discipline and methodology used by DOE and its contractor to close

out ORR findings associated with starting operations varied greatly.

The Board)s review of ORRs led to the important conclusion that DOE lacked

effective standards for the conduct of ORRs. Such standards should address the points

just enumerated.

While certain improvements were made by DOE and its contractors in the use

of ORRs during 1992, the inconsistencies in the conduct of ORRs at defense nuclear

facilities led the Board to issue Reconunendation 92-6, which is presented in Appendix

A and discussed in Section ItA.1.e. This recommendation urges DOE to develop

effective standards for the conduct of ORRs. Consistent with the Board's enabling Act,
DOE agreed to inform the Board in the future whenever an ORR is anticipated for a

defense nuclear facility. The Board will continue to evaluate the DOE personnel

selected to participate in ORRs, review the standards used to conduct the ORR, and

assess the adequacy of ORR perfonnance.

c. Standards, Including DOE Order Compliance

Some progress WdS made in 1992 by DOE in improving its safety standards

program. Much remains to be accomplished. Development of a full compendium of

suitable safety standards by DOE and a commitment to ensure that those standards are

effectively implemented at DOE defense facilities in design, construction, operation, and

decommissioning will require substantial effort. Nevertheless, commitment to these

objectives is necessary to achieve the improved safety culture which the Secretary is

endeavoring to establish in DOE.

Examples of the progress made by DOE in the standards arena during 1992 are

as follows:

• The Implementation Plan for Board Reconunendation 90-2 was re-worked

by DOE and re-submitted to the Board as Revision 3 in late December.

The Implementation Plan calls for the development of site and facility

specific requirements identification documents (RIDs) for all major defense

facilities with defined missions. The plan is being reviewed by the Board;

• Some new and revised DOE Orders have reached the promulgation stage;

Three new DOE Orders on important safety subjects have been issued, and

several existing Orders have been revised alld updated;

• Understanding of the relationship of adequate standards to safety is

improving, particularly among the staffs of the DOE field offices and the

management and operating contractors;

There is evidence of heightened awareness among officers of parent

companies of DOE contractors of the importance ofstandards and the need

for establishing clear, corporate-level policies for their use; and

Pending the development of the RIDs per the Implementation Plan for

90-2, order compliance reviews are being conducted, and compliance with

Orders is being independently assessed by ORRs.

The above DOE actions represent positive steps toward the achievement of a

satisfactory DOE standards program.

- 31 -
d. Continuing Emphasis on Seismic and Systems Engineering

As part of its ongoing oversight activities, the Board continues to devote attention

to the design adequacy of defense nuclear facilities. In particular, it will continue to

review the seismic and systems engineering aspects of new facilities and those older ones

with defined missions for continued use or standby roles. This emphasis arises from the

conviction that properly conceived and executed designs provide the foundation for safe

operation of facilities. The oversight activities follow a logical sequence of review of

safety analysis to ascertain design bases; review of the implementation of the design to

evaluate conformance with design bases; and review of the adequacy of the construction

process, the facility startup. and facility operation.

Progress has been made by DOE and its contractors at selected sites by taking

steps to review the adequacy of the existing facility designs, as for example, the

K-Reactor, and new facilities which are scheduled to start operation in the near future.

In particular, DOE and the Westinghouse Savannah River Company have been

conducting an intensive review of the adequacy of seismic and systems engineering

design at the HB-Line and the Replacement Tritium Facility. As stated previously, DOE

has accepted Recommendation 92-4, which deals with the organizational structure and

implementation of the Department's safety goals at the Multi-Function Waste Tank

Facility at the Hanford Site, and is developing an implementation plan for that

recommendation. The design adequacy of the existing facilities at INEIACPP to safely

store spent nuclear fuel, and the facility modifications necessary to store additional spent

fuel in the existing facilities, are under detailed scrutiny by the DOE and its contractor.

e. Conduct of Engineering and Construction

As required by its enabling legislation, the Board conducts reviews and

evaluations of the design of new DOE defense nuclear facilities before and during their

construction. A~ just stated, the Board performed reviews of the Multi-Functional Waste

Tank Facility (MWTF) project to be located at the Hanford Site in the State of

Washington. A detailed discussion of the Board>s review of the MWTF, and Board

Recommendation 92~4 which resulted from that review> is presented in Section II.A1.c.

The Board plans to review other DOE defense nuclear construction projects using

similar criteria to those used for MWTF in the interest of protecting public health and

safety. The recommendation, and the principles upon which it is based, address a

continuing problem related to project execution by DOE. See Section ItA.1.c. Current

procurement and contracting systems divide projects into several parts usually with

different parties responsible for each. This practice causes a lack of continuity within

the project, and has historically been the cause of serious problems at several DOE

facilities. A number of the facilities constructed in this way function only poorly or not

at all, due to inadequate design and construction.

- 32
f. Unusual Occurrence Reporting (UOR)

DOE has been implementing a major change in its occurrence reporting system

through Secretary of Energy Notices and DOE Order revisions. This is an important

system for determining the causes of events and ensuring that effective corrective actions

are taken. In late 1990, the Board by letter identified its concerns regarding

implementation of the revised occurrence reporting system throughout DOE, and

requested follow-up briefings and additional information on specific procedures being

developed for the various defense nuclear facilities. In its December 19, 1991

Recommendation 91-6, the Board recommended that changes be made in the DOR

system to ensure that the root causes of unusual occurrences related to radiation

protection would be determined. During 1992, the Board continued to review the

implementation and effectiveness of the new DOE occurrence reporting system. Since

new DOE practices will take some time to become fully effective, the Board will

continue to review their implementation.

4. Board Activities and Improvements at the Rocky Flats Plant (RFP)

The Board continues to review a number of facilities and issues at RFP, with the

goal of adequate protection of public health and safety. The Board's reviews were

structured around evaluating proposed resumption of plutonium operations on a

building-by-building basis; ensuring compliance with Board recommendations; and

assessing public health and safety aspects of the transition process being initiated at

RFP.

As reported previously in Section n.A.3.d., the Board's Recommendations

regarding ORRs at Rocky Flats led to improvements in the ORR process for Building

559, which ultimately allowed resumption of operation in that Building. ORR activities

during 1992 focused on Building 707.

In February 1992, the Secretary of Energy announced that in light ofinternational

developments, plutonium production operations at RFP would not be resumed.

Accordingly, DOE planned to confine future activities at RFP to cleaning out and

stabilizing process system'); decontaminating certain facilities; processing plutonium

residues; possibly transferring non~plutonium manufacturing to other locations;

maintaining a production contingency status in Building 707 pending completion of the

reconfiguration Programmatic Envirorunental Impact Statement (PElS); and providing

technical assistance in developing the design of a replacement facility to be evaluated

in the PElS. The Board followed DOE's activities in these areas, including development

of the RFP Mission Transition Program Management Plan, submitted to Congress in

July 1992.

- 33 -
With a new mission, and the contingency of possible future production needs,

Building 707 is the next building at RFP in which DOE has indicated its intent to

resume certain plutonium operations. The Board, its staff, and outside technical experts

followed DOE's preparations for and conduct of an ORR for this building. The

readiness review was limited to the operations planned for tbennal stabilization of

plutonium residues to achieve a safer fonn for storage. The Board's staff provided

continuous coverage of the ORR through its completion in November 1992. The

Board's staff is scheduled for on-site presence up to and during startup operations.

The Board reviewed the team assigned to conduct the ORR and was satisfied that

the team was composed of competent individuals capable of providing a technically

sound and independent review of proposed operations. The Board, its staff, and outside

experts reviewed the criteria and the methodology for conducting the Building 707 ORR.

Based on staff review and discussions with DOE, improvements were made to the ORR

team's criteria and the methodology for reviewing DOE Order Compliance.

In September 1992, the DOE-Rocky Flats Office and EG&G reported readiness

to proceed with the Building 707 ORR. The ORR was started and completed in

November 1992, after a break allowing several of the team members to participate in

a readiness review of the HE-Line at Savannah River. The Board's staff and outside

experts monitored the conduct of the ORR. DOE's compliance with DOE Orders and

application of industry and consensus standards, as envisioned in Recommendation 90-2,

received particular attention.

In December, 1992, the ORR team issued its report and briefed the Board on the

findings and observations from the review. At the end of 1992, DOE notified the Board

that it was close to concluding the corrective actions necessary for resumption as a result

of the ORR. The Board scheduled a public meeting and hearing to be held in Boulder,

Colorado in early 1993 to review final ORR results for Building 707.5

Several other Board recommendations of particular relevance to RFP were the

subject of ongoing review by the Board, the staff, and outside technical expert.

Recommendation 90-5, issued in May 1990, recommended that DOE develop and

establish a Systematic Evaluation Program (SEP) at RFP to ensure proper evaluation

and coordination of proposed long-term safety improvements and to address all

outstanding safety issues. Recommendation 90-6, issued in June 1990, recommended

that, prior to the resumption of plutonium operations at RFP, DOE prepare a program

5Subsequent to the close of calendar year 1992l DOE completed its ORRs, the Board

conducted public hearings on Building 707, and the Board determined that corrective

actions taken by DOE and the contractor were adequate responses to the Board's

recommendations.

- 34 -
to address the accumulation of fissile and other materials in ventilation ducts and related

systems. This was intended to reduce the potential for a criticality accident; to reduce

the amount of fissile material in order to improve radiation protection, and to remove

or substantially reduce the amount of fissile material that might be accidentally released

from the ducts. The subject ofsafety standards was addressed in Recommendations 90-2

and 91-1. These recommendations were borne in mind during the Board's review of

standards used in buildings at the RFP in which plutonium operations were proposed for

resumption and other buildings there that DOE slated for transition.

Through regular site visits and the review of relevant documentatio~ the Board

will continue to carefully monitor DOE's progress in implementing each of these

recommendations.

The Board will continue its review of other important safety issues including:

• Standards for the design, construction, and operation of nuclear facilities;

Training and qualification of plant operators;

Fire protection program;

Radioactive waste stabilization;

• System start-up test programs;

Implementation of procedures for system operation, maintenance, and

surveillance in accordance with a tlconduct of operationsll philosophy;

RFP safety analysis reports (SARs); and

• Criticality safety.

The Board plans to expand its review to other areas of RFP while continuing to

monitor long-term improvement of the kinds previously identified. Topics that will

receive increased emphasis include:

Transition of facilities from an operational to a decommissioned status;

• Size reduction and storage of radioactive and mixed waste;

• Preparation and storage of pondcrete;

- 35 -
Structural adequacy of plutonium storage facilities to meet hazards of

natural phenomena; and

• Facility decontamination and site remediation.

The Board's activities were significant contributions to the following achievements

at Rocky Flats (in many cases, they were the initiating and/or determining factor):

Reduction of plutonium concentration in ventilation dueting;

Improved assessment of routine releases of plutonium from operations

(past, present, and future);

• Improved storage of pits and other plutonium components;

• Assurance that operations in Buildi.ng 559 will be useful in future cleanup;

• Improved safety analysis; and

Adequacy of training and procedures for operations being restarted, or for

new operations being started.

5. Board Activities and Improvements at the Savannah River Site

This and previous Annual Reports detailed some of the improvements which were

made at the Savamlab River Site as a result of DOE's having implemented Board

recommendations. See sections 1I.A.3.a; 1I.A3.b; II.A.3.e; n.A2.a; and II.A.2.b. In

addition to the actions and follow-up activities associated with Recommendations 90-1,

90-2, 90-4, 90~5, 91-1, and 91~2, as they affect the SRS in whole or in part, the Board and

its staff continued to perform reviews of numerous major technical issues that can have

a direct impact on public health and safety and that may affect operation of the SRS

facilities. DOE made improvements in a number of technical areas, but the degree of

improvement varies from facility to facility in the following areas:

• Operational Readiness Reviews;

• Seismic Design Basis and Adequacy;

• System Definition and Design Basis;

Effectiveness of Radiological Protection;

Basis and Adequacy of Fire Protection;

- 36 -
Effectiveness of Configuration Management and Quality Assurance; and

• Conduct and Discipline of Operations.

While the Board initially focused its review on restart of the K-Reactor during

1991 and 1992, the other defense nuclear facilities at SRS also received attention. These

include:

Separations Facilities including the F-Canyon, FE-Line, H-Canyon and

HB-Line;

• Tritium Facilities including the Replacement Tritium Facility (RTF);

• Waste Management Facilities including the Tank Farms, Defense Waste

Processing Facility, and other waste processing facilities;

Material Storage Facilities; and

Weapons Component Storage Facilities.

In March 1992, the Board began an investigation into the ORR process and other

safety issues related to the restart of the HB-Line in the SRS separations facility. (See

Section II.A.l.a.) Early findings of the investigation led the Board to issue

Recommendations 92-1 and 92-3, requesting that DOE not restart the HB-Line until the

completion of the Board's investigation and until DOE completed a proper ORR for

restart. DOE accepted these recommendations and conducted its ORR in October 1992.

As a result, numerous safety improvements were made at HB-Line, with corrective

actions being taken in the areas offire protection, operator training, radiation protectio~

and order compliance. The Board closely followed these restart efforts and held a public

hearing on December 15, 1992, to consider the restart of the HB-Line. The Board and

its staff will continue to monitor the actions of DOE and WSRC during the restart and

operation of the lIB-Line facility in 1993 and 1994.

The Board noted that the t1essons learned" during the Board's reviews of the SRS

reactors have not been used effectively at other SRS facilities. Because of the above

concerns, the Board intends to monitor a number of other SRS facilities that DOE plans

to start up and operate during 1993 and 1994. These include the following:

- 37 -
H-Canyon;

• Defense Waste Processing Facility (non-radioactive chemical testing at the

outset);

F-Canyon and FB-Line;

•

•

•

1m

•

•

•

•

•

•

•

In-Tank Precipitation (non-radioactive chemical testing at the outset);

Replacement Tritium Facility; and

In-Tank Precipitation (radioactive operations).

New-Waste Transfer Facility;

F-Area Analytical Lab;

Plutonium Storage;

HB-Line Phase II;

Uranium Solidification Facility;

Defense Waste Processing Facility (radioactive operations); and

Consolidated Incineration Facility.

Continued Board attention to operator training and conduct of operations,

including on-shift technical capabilityl led to noticeable improvement in the level of

knowledge of the K-Reactor operators and in the technical ability of the K-Reactor

watch teams. Board effort and resources will continue to be applied to these and other

areas. If the "lessons learned" from the experience at K-Reactor will be transferred

across the sitel the Board's review efforts could be reduced accordingly and the

personnel involved in the reduction used at other sites.

The Board's activities were significant contributions to the following achievements

at K-Reactor (in many cases, they were the initiating and/or the determining factor):

- 38 -
• A safe upper limit to K-Reactor power, and assurance that operation will

not exceed such power;

• Safety rods that will not melt in a conceivable accident;

Development and institution of consistent and acceptable operating

procedures, including emergency procedures. The Board followed training

in the procedures and ensured their use;

Improved seismic resistance:

Air filters

Sub-surface grouting

Piping analysis

Equipment qualification

Stack

Structure reinforcing

• Systematic improvement of heat exchangers;

• Improved wiring of electrical systems important to safety, to cause them to

meet environmental demands;

• Assurance that K-Reactor now meets commercial reactor site criteria;

• Assurance that the core adequately meets specifications; and

• Startup that ensured attention to the possibility of power oscillations from

layering of coolant and established that this did not occur.

6. Board Activities and Improvements at the Hanford Site

The Board continues to review a munber of facilities and issues at the Hanford

Site with respect to public health and safety. Health and safety problems of most

concern at the Hanford Site are related to K-East Basin and the monitoring and storage

of high-level waste in underground tanks. Tank issues previously identified and pursued

by the Board include:

Ascertaining whether ferrocyanide compounds in single-shell tanks,

previously added to induce precipitation of fission product cesium, could

burn or explode under any realistically possible conditions, and cause fission

products to be released from the tanks; and

- 39
• Determining if the hydrogen and nitrous oxides released periodically from

some double-walled tanks (e.g., 101~SY) in a flammable and possibly

explosive mixture could react in a hazardous manner.

In these regards the Board documented its concerns in Recommendation 90-3

(March 1990) and expanded its views in Recommendation 90-7 (October 1990). In them

the Board recommended that DOE act expeditiously to quantify and mitigate these

safety concerns. Since then, the Board followed DOE's progress toward understanding

these issues and associated physical phenomena and reaction chemistry.

While progress addressing these issues has been slower than desired, technical

investigations and assessment efforts have been accomplished. Studies on the

ferrocyanide tanks to date indicate very low probability for burning or explosions. As

a mitigating measure for Tank 101-SY, a mixer pump was developed and prepared for

installation. The pump is scheduled for installation and experimental operation in early

1993.

Additional high~level waste tank safety problems which have received and will

continue to receive increased attention from the Board include:

• The release of vapors from some tanks (e.g., 103-C) containing significant

amounts of organic materials. Workers in the vicinity of such tanks

experienced adverse physical reaction caused apparently by the vapors;

Under certain conditions, a flammable mixture could develop in the vapor

space of one of the tanks which contains organic material;

• Fissile material inventories of many of the tanks are not sufficiently well

established for complete assurance that a criticality could not occur;

• Several tanks (e.g., 106-C) contain high concentrations of fission products

that generate substantial beat and require cooling to keep temperatures

below boiling; and

• Sixty-seven of the 149 single-shell tanks are suspected of leaking liquids to

the soil (On October 4, 1992, Tank lOl-T was declared to be "an assumed

leakert

').

TIle Board encouraged DOE to proceed expeditiously in obtaining the

information needed for the resolution of these issues. The Board intends to continue

to evaluate the possibility of safety hazards from the high-level waste storage tanks as

more information becomes available. In addition, the Board intends to ensure that the

- 40 -
standards applicable to these facilities (Recommendation 90-2) are identified and will

monitor DOE's progress in accordance with DOE's 90-2 Implementation Plan.

The Board also initiated reviews of planned new construction projects intended

for use in treating the high-level wastes. In 1992, these were the Hanford Waste

Vitrification Plant (HWVP) and the Hanford Multi-Functional Waste Tank Facility

(MWTF). The Board expressed its concern as to the viability of the structural design

of the MWTF in Reconunendation 92A, issued on July 6, 1992.

Regarding the longer term objective of recovery and vitrification of the high level

wastes in the tanks, the Board encouraged and is following closely DOE's attempts to

use a systems approach in defining and executing a program leading to waste

vitrification. DOE is in the process of defining a system concept that includes tank

storage, waste retrieval and processing, vitrification, and product storage as an integrated

Tank Waste Remediation System. A re-baselining study of site efforts is scheduled for

completion in early 1993.

TIle Hanford Site contains other major defense nuclear facilities, such as the

PUREX Plant, the Plutonium Finishing Plant (PFP), and the N-Reactor. These facilities

can be classified in three groups:

• Those that will be returned to limited operation for purposes of material

stabilization or waste treatment;

Those that are shut down or have no identified mission, and for which

major efforts are anticipated to place them in a long~term lay-up condition;

and

• Those that are in long-term lay-up awaiting decontamination and

decommissioning (D&D).

The Board is particularly interested in the activities associated with the

resumption of limited processing for deanout purposes, scheduled to occur at PFP in

mid-1993. Such limited operations are intended to stabilize materials that are residuals

of the production era for this facility. Throughout the preparation, induding the DOE

ORR and subsequent start~up, the Board, its staff, and outside technical experts will

monitor and review DOE's related activities. Among other things, attention will be paid

to compliance with DOE Orders and applicable industry and consensus standards, as

envisioned in Recommendation 90~2.

Several other facilities are also scheduled to be returned to operation for limited

use in 1993, such as the Uranium Oxide Facility, the 242-A Evaporator, and the K-Ea~t

Basin (Fuel Encapsulation). There is a particular need to operate the latter facility due

- 41 -
to the continued deterioration of irradiated fuel elements. The Board will continue to

evaluate activities at these facilities for potential impact on public health and safety.

DOE and hence the Board have not yet initiated any major efforts for facilities

destined for shut-down and lay-up. For the time being, the Board will monitor the

condition of these facilities at reasonable intervals.

The Board also perfonned several major broad-based reviews at the Hanford Site

related to subjects that have applicability across the site and the defense nuclear facility

complex. Topics include the use of codes and standards (Recommendation 90-2),

radiological protection (Recommendation 91-6), training and qualification

(Reconunendation 92-7), and ORRs (Recommendation 92-6). Future work will include

updates at Hanford to assess status improvements in these areas as well as reviews of

additional topics such as formal conduct of operations and improvements in the DOE

Facility Representative program (Recorrune}J.dation 92-2).

The Board's activities were significant contributions to the following achievements

at Hanford (in many cases, they were the initiating and/or determining factor):

• Start of installation of new thennocouple trees in nuclear waste tanks,

particularly those containing ferrocyanide compounds. Repair and return

to service of many existing thennoconples;

• Accelerated chemical characterization of waste in tanks containing

ferrocyanide compounds, leading to some degree ofreassurance concerning

safety of this waste against the possibility of explosion;

Heightened attention to tanks undergoing slurry growth, especially l01-SY,

has led to improved understanding of the processes causing slurry growth,

and to plans to remediate the growth; and

• Introduction of on-line recording of temperatrnes in watch list tanks.

7. Board Activities and Improvements at WIPP

During 1992 the Board, assisted by its staff and outside technical experts,

broadened its oversight of WIPP. The staff continues to track overall WIPP

developments and research to keep the Board fully informed about WIPP-related public

health and safety issues.

In 1991, DOE prepared a database describing the standards applied during design

and construction of WIPP in partial response to Recommendation 90-2

(safety standards). A report to the Board was issued in 1992. Subsequently, DOE

- 42 -
prepared an overall Recommendation 90-2 Implementation Plan and schedule for all

facilities under the Assistant Secretary for Environmental Restoration and Waste

Management) including WIPP.

On April 25) 1991, the Board issued Recommendation 91~3, recommending that

an independent and comprehensive DOE ORR be carried out at WIPP prior to

initiation of the plaWled test phase. As stated previously, tbe Secretary of Energy

accepted the Board's recommendation, and an ORR was satisfactorily completed.

The Board's staff continues to track the closure of a number of ORR findings

requiring long-term corrective action. A site visit was made in February 1992 in

conjunction with this effort. A second site visit was made by Board staff and outside

technical experts in March 1992 to follow-up on a readiness review finding involving the

organization, qualifications, and training of safety personnel at the WIPP site.

In July, 1992, the Board's staff and outside technical experts made an initial review

visit to WIPP for the purpose of gathering documents related to safety standards.

Docwnents were collected regarding design standards) quality assurance, safety analysis,

configuration management, fire protection, maintenance, radiation protection, and waste

management. Review of these documents by the Board's staff and outside experts

indicated that substantial progress was made in these areas by DOE and its contractors

at the site. In addition, the Board's staff examined quality assurance issues relevant to

scientific data collection in connection with long-term performance assessment issues at

the site.

The Board and its staff are continuing to track the overall progress at WIPP, and

will monitor the technical and scientific aspects at WIPP as they relate to public health

and safety through and beyond completion of the planned test phase, which could begin

as early as July 1993. The Board's staff plans to observe and track the WIPP readiness

reviews to take place prior to the startup of the test phase.

8. Board Activities and Improvements at Fernald, Mound, and West Valley

The Board's staff conducted initial visits to the Fernald Environmental

Management Project (FEMP) and the Mound Plant in November 1991. These visits

were intended as initial scoping visits to obtain information for formulation of future

review plans.

After these initial visits) the Board's staff and outside technical experts conducted

several reviews of FEMP's preparations for stabilization of Uranyl Nitrate Hexahydrate

(UNH) liquid waste. Also, the Board's staff followed DOE's plans for removal and

disposal of other radioactive wastes at FEMP. These activities will continue into 1994.

43 -
Because of the presence of defense wastes at the West Valley Demonstration

Project in New York and because of the waste vitrification efforts conducted there, the

Board believed it necessary to have its staff assess the activities at the site. The staff

made an initial visit in February of 1992 to become familiar with the vitrification process.

Additional reviews, on a limited basis, are planned in 1993 and 1994.

9. Board Activities and Improvements at Idaho Nuclear Engineering

Laboratory (INEL)

During 1992 the Board staff intensified its scrutiny of activities at the Idaho

National Engineering Laboratory (INEL) with primary emphasis placed on the Idaho

Chemical Processing Plant (ICPP). Site visits to the INEL by staff and outside experts

occurred in May, October, November and December.

The May visit emphasized seismic and systems evaluation of the high level waste

(HLW) tanks and vaults, HLW calcine storage bin sets, fuel storage basins, and

associated facilities and components of the JCPP.

During and subsequent to the May visit, staff and outside experts:

• Pursued the issue ofstructural integrity ofthe eleven 300,000 gallon stainless steel

HLW tanks, which are enclosed in concrete vaults;

• Reviewed severe accident scenarios analyzed in the plant safety analysis,

particularly the potential for a release of calcined high-level radioactive waste to

the environment, with associated potential dose consequences;

• Reviewed the seismic qualification of both the CPP-603 and CPP-666 basins;

• Probed the physical condition of the older, unlined concrete fuel storage basins

at CPP 603, in view of the possibility of deterioration due to exposure to water

with a high chloride concentration;

• Briefly reviewed the condition of groundwater at the site; and

Identified for future review the issue of the potential impact on criticality safety

of re-racking plans for the newer CPP-666 basins.

The October, November, and December trips focused on progress of operational

readiness reviews for restart of the New Waste Calcining Facility following an extended

shutdown. Questions from the Board's staff prompted DOE to conclude that a more

comprehensive readiness review than originally planned was appropriate. Findings made
during the enlarged readiness review led to improvements in the safety of calciner

operations.

10. Board Activities and Improvements at Oak Ridge Y~U Plant

Board Members and staff made fOUf trips to Y-12 during 1992. Technical

subjects addressed include radiological controls, waste management, emergency

preparedness, training and qualification of personnel, criticality safety, safety analysis,

material storage, and compliance with DOE Orders and other standards. An area of

particular importance is the role played by Y-12 in the dismantlement of nuclear

weapons.

Other Board activities included reviews of documents in connection with such

issues as conduct of readiness reviews at Y-12, disassembly operations, environmental

monitoring, and modifications to the electrical distribution system. Information gained

from evaluations concerning Y-12 was factored into a nnmber of Board

recommendations, including 92-2, 92-5, 92-6, and 92-7.

The Board plans to expand its oversight of operations at Y-12 in the coming year

and follow up on issues previously raised. Additional reviews of chemical hazards,

environmental remediation and restoration, and special nuclear material storage are

planned for the near future.

c. ADMINISTRATIVE AND MANAGEMENT ISSUES

1. Litigation

In early 1990, the Energy Research Foundation and the Natural Resources

Defense Council (Petitioners) challenged the Board's position that it was not an "agency"

for purposes of the Sunshine Act and the Freedom of Infonnation Act (FOIA).

Petitioners initially sought an injunction against Board activities, including site visits,

until Board regulations implementing the Sunshine Act and FOIA were promulgated.

Faced with Board opposition, the Petitioners dropped this aspect of their request for

relief. The District Court ruled in favor of the Board on all issues, finding that the

Board was not an agency. Energy Research Foundation v. Defense Nuclear Facilities Safety

Board, 734 F. Supp. 27 (D.D.C. 1990). On appeal, the Circuit Court of Appeals

reversed, ruling that lithe Board ... must be considered an 'agency' within the meaning

of both statutes." Energy Research Foundation v. Defense Nuclear Facilities Safety Board,

917 F.2d 581, 585 (D.C. Cir. 1990).

The Board did not await an order from the district court on remand, but

immediately began developing Sunshine Act rules. In accordance with the Circuit Court

of Appeals' ruling and mandate of December 14, 1990, the Board promptly published

- 45 -
proposed rules implementing the Sunshine Act. After receipt of a single set of public

comments from the same Petitioners, the Board amended certain aspects of its rules,

published its response to the comments, and promulgated its final Sunshine Act rules.

Petitioners then filed a Petition for Review with the D.C. Circuit Court of Appeals

challenging a single provision of the Board's rule which allows closure of Board meetings

involving fonnal recommendations to the Secretary of Energy or the President. Both

sides briefed the issues and oral argument was conducted by the Court on November 14,

1991.

On July 24, 1992, the D.C. Circuit Court of Appeals decided that the Defense

Nuclear Facilities Safety Board's enabling statute permitted closed Board meetings on

recommendations for the President or the Secretary of Energy regarding health and

safety issues at DOE defense nuclear facilities. NRDC/ERF v. Defense Nuclear Facilities

Safety Board, No. 91-1199 (D.C. Cir., July 24, 1992). The Board's enabling statute

provides for public availability ofBoard recommendations "after receipt by the Secretary

of Energy" or the President in appropriate cases. 42 V.S.c. §2286d(a); g(3). Therefore,

the court concluded that Board discussions on such recommendations could be held in

closed meetings under the Government in the Sunshine Act, 5 U.S.c. §552b (1988).

Petitioners became aware of the adverse decision on July 24, 1992, and chose to

petition the Court of Appeals for rehearing, with a suggestion that the rehearing be

conducted en banco That petition for rehearing was denied on October 9, 1992.

NRDC/ERF v. Defense Nuclear Facilities Safety Board, No. 91-1199 (D.C. Cir., October

9, 1992). Pursuant to the Board's bill of costs, the Court of Appeals awarded costs

against the Petitioners, Natural Resource Defense Council and Energy Research

Foundation, on November 16, 1992. Costs were subsequently paid in full by Petitioners.

On December 23, 1992, Petitioners requested that the Supreme Court grant an extension

of time (30 days) in which to file a petition for certiorari with the Supreme Court. The

Petitioners have been allowed through February 8, 1993, to file a petition for certiorari

to the Supreme Court.

2. Investigations

During 1992, the Board directed the General Counsel to establish a legal and

technical investigative team and conduct four formal investigations of health and safety

issues at defense nuclear facilities pursuant to 2286b(b). One of the investigations

disclosed safety deficiencies sufficient to cause the Board to issue recommendations to

the Secretary of DOE regarding ORRs at the HB-Line, Savannah River Site. See pages

3 to 4 above. Separate reports were issued on the investigations.

- 46 -
3. Personnel and Recruitment

The identification and hiring of professional persormel with outstanding

qualifications is critical to the successful accomplishment of the Board's mission.

As of December 31, 1992, the Board had hired 84 full-time employees including

a full-time Site Representative at the Department of Energy's Pantex facility, Amarillo,

Texas. During 1992, the Board reviewed 2,263 applications for employment and

conducted 84 sets of interviews. This effort is necessary to recruit highly-qualified

employees with exceptional scientific, engineering, or legal backgrounds who can

effectively carry out the specialized work required.

Due to the excepted appointment authority granted by Congress, the Board has

been able to achieve progress in hiring engineering and scientific persolUlel of the

highest calibre to address the health and safety questions associated with the design,

construction, operation, and decommissioning of DOE's defense nuclear facilities. This

excepted appointment authority has enabled the Board to significantly strengthen its

ability to compete with other excepted Federal agencies and the private sector for the

talent to properly perform its mission. Prior to this authority the Board was unable to

significantly increase its technical staff.

The Board has been able to hire outstanding technical talent with extensive

backgrounds in nuclear, mechanical, electrical, chemical, and metallurgical engineering

and physics, using a nationwide recruiting campaign. As an indication of the Board's

technical talent, 18 percent of the staff hold degrees at the Ph.D. level and 61 percent

have degrees at the Masters level. In addition, almost all technical staff members,

except Interns, possess practical nuclear experience gained from duty in the U.S. Navy's

nuclear reactor program or the civilian reactor industry. Additionally, three other senior

members of the Board's staff have law degrees (JD) as well as degrees in a technical

specialty. The Board plans to continue its aggressive program to attract and hire

additional technical staffwith backgrounds conunensurate with the Board's public health

and safety responsibilities.

4. Technical Intern Program

In September 1991, the Board initiated a Technical Intern Program designed to

aid in the recruitment and development of the Nation's top engineering graduates. After

an extensive recruitment and interview program, eight interns with superior academic

accomplishments in an engineering discipline and other attributes that indicate the

potential for effective performance joined the Board's technical staff during the latter

half of 1992. The recruitment and selection methods used have proven very effective as

the Intems all have demonstrated themselves to be outstanding in their work and

- 47 -
academic programs. Board staffing projections include the recruitment of three technical

interns in 1993.

5. Regulatory Agenda

The Board aggressively pursued its agenda for promulgating administrative

regulations required by law for operation of an agency. Although time-consuming and

resource intensive, substantial progress was made. The Board now has final rules

covering the Government in the Sunshine Act, the Freedom of Infonnation Act (FOIA),

Contractor and Consultant Conflicts of Interest, and the Privacy Act. During 1992,

preliminary work was also completed on the following regulations: Employee Standards

of Conduct and Conflicts~of-Interests and Equal Employment Opportunity.

III. LEGISLATIVE CHANGES AFFECTING BOARD PLANNING FOR 1993 AND

BEYOND

A. INCLUSION OF PANTEX PLANT AND NEVADA TEST SITE WITIIIN

BOARD'S JURISDICTION

Two new responsibilities were assigned to the Board late in 1991 that have had,

and will continue to have, a significant impact on the Board's mission, both short-term

and long-term. First, Congress amended the Board's enabling Act, broadening the

Board's jurisdiction over defense nuclear facilities to include the assembly and

disassembly of weapons and the testing of weapons. The significant reduction in nuclear

arms by the Soviet Union and the United States projected for the next several years

caused an increase in weapons disassembly activity at certain defense nuclear facilities,

particularly the Pantex facility.

Second, the Board plans substantial expansion of activities related to

decontamination and decommissioning (D&D) of defense nuclear facilities within the

DOE complex during the next year and for the foreseeable future. Because of the

President's and the Secretary of Energy's plans to consolidate and modernize the nuclear

weapons complex, oversight of D&D activities is currently plaIUled for certain facilities

at Fernald, Mound, Savannah River, Hanford, and elsewhere throughout the weapons

complex. Until the President's plans are finalized, however, the Board's oversight

planning for D&D activities caIUlot be completed.

The Board's activities were significant contributions to the following achievements

at Pantex (in many cases, they were the initiating and/or the determining factor):

- 48 -
• Institution of a practice whereby the responsible DOE laboratories (Los

Alamos, Livermore, Sandia) review procedures for disassembly of nuclear

weapons, for identification of potential safety questions;

• Improved conduct of operations in disassembly of nuclear weapons;

• Safety analysis initiated for some facilities where none had been done

before, and up-dated safety analysis where it had been done some years

ago; and

• Start of engineering analysis of competence, under enviromuental stress, of

facilities for storage of pits and nuclear weapons awaiting disassembly.

Included in the analysis are effects of possible aircraft crashes.

B. OTHER CONGRESSIONAL MEASURES CONCERNING BOARD

ACTIVITIES

1. Resumption of Plutonium Operations in Buildings at the Rocky Flats Plant

Section 3133 of Public Law 102-190 of the recently enacted Defense

Authorization Act for Fiscal Years 1992 and 1993 provided the following:

(a) RESUMPTION OF PLUTONIUM

OPERATIONS.-The Secretary of Energy may not resume

plutonium operations in a plutonium operations building at

the Rocky Flats Plant, Golden, Colorado, until the Defense

Nuclear Facilities Safety Board detennines, to the

satisfaction of the Board, that the Secretary's response to

the Board's recommendations numbered 90-2, 90-5, and 91-1

adequately protects public health and safety with respect to

the operation of such building.

At the close of 1992, the Board scheduled activities, including public hearings and

meetings, designed to allow the Board to fulfill this statutory obligation regarding the

proposed resumption of plutOnium operations in Building 707 at Rocky Flats.

2. Nuclear Waste Storage and Environmental Remediation

Congress also called for expansion and acceleration of Board activities related to

nuclear waste storage, and safety and health issues associated with environmental

restoration activities at defense nuclear facilities. The Board's statutory employee ceiling

was raised from 100 to 150 full-time equivalents. Congress deemed this change

necessary to accommodate the Board's increased responsibilities in 1992 and beyond.

- 49 -
APPENDIX A
22732 Federal Register I Vol. 57, No. 104 I Friday, May Z!.l. 1992 I Notices

DEFENSE NUCLEAR FACILITIES

SAFETY BOARD

(RecomfMi\dlltlon 92-1)

Operational Readiness 0' the HB--Une

at the savannah River Site

. AGENCY: Defense Nuclear facilitiea

Safety Board.

ACTlOH: Notice; recommendation.

SUMMARY: The Defense Nuclear

Facilities Safety Boai'd has made Ii

recommendation to ,the Secreta!)' of

Energy pursuant t6 42 U.S.C. 2286B

concerning operational readiness of the

HB-Line at the Savannah River Site. The

Board requests public comments on this

recommenda tion..

DATI:S: Comments. data. views, or

arguments concemlng this

recommendation are due on or before

June 29. lOO2.

ADDRESSES: Send comments. data,

views. or arguments concerning this

recommendation.to: Defense Nuclear

Facllilies Safety Board. 625lndiana

Avenue. NW., suite 700. Washington.

DC 2009'1.

FOR FURTHER INFORMAnON CONTACT:

Kenneth M. Pusal~ri or Carole J.

Council, al the address above or

telephone (202) 208---6100.

Dated: May 22. 1992.

John T. Conway,

Chainnan.

Dated: May 21, 199Z.

The Board is presently completing an

investigation of the readiness of

resumption of operations at the HB-Line

atlhe SavaIUlah River Site. This

investigation raises a number of

significant safety issues that the Board

believes taust be discussed and resolved

before the resumption shoUld OCCllr.

Therefore, the Board recommends

thal:

• DOE defer resumption of processing

ot the HIH.ine for the present, pending

issuance of the report of the Board's

invesligation, resolution of the issues.

and possible further Board scHon.

In order that this mailer can be deall

with expeditiously. we are giving high

priority to completing the report

embodying the results of Ihe

investigation.

John T. Couw"y.

Chairman.

AppeDdix-TpaoOlX'lUal Lou".. 10 lbe

Secretory of

Delen6e Nuclear Fac:iliti~ Safety Board

Moy 21. 1992-

The HQnQrob/(J james D. Wat1cins.

Secrctary of Energy. Wethington. PC 2OS8SDear Mr. Secreta!")': On Mey 21. 1092. the

Dof~nse Nuclear Facilities Sar~ty Boord. In

accord:mce with 42. U.s.c. 22889(5).

ullonlmou&ly appro\'ed Recommendation !lZ-1

which is cnclOllcd Cor your considerlltion.

Rccommcod9tion 02-1 deols with operalionol

readiness of the HB--Line I'll the Savannah

River Sileo

42 U.S.C. 2286d(a) requires the Board. ofter

receipt by you. to promptly moke thls

recommendation tlvail"able to the public in

the Department of Energy's fSSlonal public

reading room6. The Board believe6 tha .

Iilcommendation contoms no informo.tion

which Is classified or olhcm·lse restricted- Tu

the extent this recommel\d~lion does not

include Wcmnation restricted by DOE under

l.he AtolIiic Energy Act of 1954.42 U.s.C.

2161~. as amended. please lllTanse to have

this recommendotioll promptly placed on file

in your regiuno.l public reading rooms.

TIll~ Board will publish thl6

recommendation In the Federal Register.

Sincerely.

John T. Conway.

Chairmo.rr,

Enclosure.

IFR Doc. 92-12514 Filed 5-28-92: 8;45 oml

6lWHO c:OOE ~2G-KD-¥
23576 Federal Register I Vol. 57. No. 108 I Thur3day, June 4, 1992 I Notices . .

DEFENSE NUCLEAR FACILITIES

SAFETY BOARD

(Recommendation 92-21

DOE's Facility Representative Program

at Defense.Nuclear Facilities

AGENCY: Defense Nuclear Facilities

Safety Board.

ACTlON: Notice; recommendation.

SUMMARY: The Defense Nuclear

Facilities Safety Board has made a

recommendation to the Secretary of

Energy pursuant to 42 U.S.C. 2Z86a

concerning DOE's .facility representative

program al defense nuclear facilllies.

The Board requesls public comments on

Ihis recommendaUon.

DAns: Comments. c;Iata. views•. or

arguments concerning this

recommendation are due on Of before

July 6, 1992.

ADDRESSES: Send comments. data,

views. or arguments concerning this

recommendation to; Defense Nuclear

Facilities Safety Board, 625 Indiana

Avenue NW., suite 700, Washington. DC

20004.

FOR FURTlIER INFORMATlON CONTACT.:

Kenneth M. Pusateri or Carole J, Council,

at the address above or telephone (W2)

208-6400.

Oaled: MllY 29, 1992-

Johc T. Conway,

Choirmon.

DOE's Facility Representative Ptogr<;lm

at Defense Nuclear Facilities

D<lleo: MlJY 28. 1992-

Deportment of Energy (DOE) Orell!r

5OOO.3A. Occurrence Reporting'ond

Processing ofInformation. estobljsh~s II

policy ·'10 a.ssure thaI both DOE and

DOE contractOr line munagement.

including lhe Office of the Secretory,

[bel kepI fully llnd currently informed of

all events which could affect the health

and safety of the public." As a ccrotral

fe:Jlure of the measures used (0

implement Ihis poli~y. the order ucfinl!s

(he position "DOE Facility

Representative" as follows:

.. DOE Facility Represent.otivt~_ For each

major racility or 8rouP of lesser facilities, un
federal Reg,lster I Vol. 57, No. 108 I Thursday. June 4. 1992 I NOlices 23577

individual' •• 8"isned responsibility by vigilance nccessary to assure the slife

the Jlead of the Field Organiutlon for operation of the departmenl's defense

monitoring the perfonnance 01 the focilily nuclear facilitic8. The Board believes

lind i19 operotlona.. This IndlviduJ)1 ~h61l be that the N>rfonnance of the 'interrelated tIle primary point ofcontoct with the rCOJllrBClor ona will be respo~ible 10 the safely. technical. and management

appropriate Program Secretarial Officer functions by DOE Facility

(PSO) and Head or Field OrganiUllion' • Representativc8 would be enhanced if a

lemphasis added) formal qualification program for these

In addition. DOE Order 5480.19. positions, commensurate with their

Conduct ofOperations Req(firemonts for' ,importance. was pr0m.ulgated at the

.DOE Facilities•. direcls that "operatlons deJlartment level and Implemented...

at DOE facilities be' •• conducted in throug~out the defense nuclear facIlitIes

a manner to assure an acceptable level complex.

of safety," and specifies that DOE Therefore. the Bo.rd.r~~mmends thai

Facility Represcntatives be "assigned for defense nuclear fa,clhtles:

responsibility Ito) oversee the day. to· l. The Secr~l~ry of the Department of

day conduct of operations· •• in Energy expeditiously <:arry out a , .

accordance with' •• direction comprehensive analYSIS of the eXIsting

received from the Program Manager." DOE Facility Representative programs.

Secretary of Energy Notice SEN-6E-9z.. a. The an?IY81.5 should be,conducted

Departmenlal Organi:tation nnd under the du-cctlon of senior

Management Arrangements, extends indi'll.dual ~ho has demon8t~tedhigh

this chain of responsibility. holding technical and managerial ability and has

Program Managers accountable to demons~~ed an underst~nding of the

Program Secretarial Officcrs (PSOs). usc of faClbty r~presentatlves. .

who in tum are ·'accountable to {the . b. ~~e a?alysls should emphaSize the

Secretary} for their respective programs. Id~nt.lhcahon,of those 8~pects of the

induding safety of the workers and the eXisting programs that either support or

pubUc· • .:. impede the achievement of DOE

Recognizing the imporlance of these obje~tives for assuring the pro!ectio~ of

positions w.ith regard to assuring pubhc beat~ and safety. ~onslderat.lOn

adequate protection of the public health should be gIVen to evaluatmg:

and sofety at DOE defense nuclear (1) QualificaUon requirements and

facilitics, the Board reviewed' existing recruitment practices employed in

department.wide, guidance on the selecting prospective DOE Facility

selection. training and responsibilities of Representatives;

DOE Facility·Representatives. DOE (2) General lind facility-specific

Order 5000.3A and DOE Order '5400.19 training and examination requirements

(both cited above). provide only limited and practices necessary,to prepare

details concerning DOE Facilities prospective DOE'Facility ,

Represcntative duties and Representatives for field assignments.

responslb'i1ities: moreover. there <Ire no and to maintain their proficiency;

orders that prescribe 'any guidance for (3) DOE F.acility Representative duties.

selection and training of DOE Facility and responsibilities:

Representatives. nor any effective (4) Existing supervision and

guidance for establishing the duties and management of the Facility

responsibilIties associated with these Representative position. now provided

positions. (See Appendix A) by several individuals irl some facilities.

Having made numerous reviews especially inquiring whether there are

lhroughout the DOE defense nuclear clear lines of responsibilities with both

facilities complex. the Dosrd notes that the contractor end DOE line

,the DOE managers for several f~cilHics man~8emenl:

in the defense nuclear complex have (S) Critcria and practices for (l$signing

begun to establish formal Facility DOE Facility Represento tives \0 c<Jch

Representative programs. However. defense nuclear facility; and

these programs are opera ling wilhout (6) DOE personnel practices and

centr<llized direction. Cenerally. this is procedures that provide incentives and

resulting in widely differing impediments to making the position of

Cju"lifkations. duties. nnd DOE Facility Rep~sentative attractive

responsibilities for DOE Facility and C4lrcer.enhancing. At a minimum.

Reproscnta·tives from f<Jcility to facility. restmints imposed by the practice of

even at the slimc site. for example. DOE measuring responsibility predominnnlly

F<lcility Represcntatlve6 encountered by in tenns of numbers of individuals

the Board have ra'nged from personnel supervised'should be addrelJsed.

holding doctoral degrees to summer c. The analysis should identify

interns (college students)_ practices employed in successful

This situation could tenuit in fail\U'C Facility Representative programs

by DOE to achieve the level of technical outside or tbe defense nuclear fuciHties

complex that nre appropriate for lhe

DOE Facility Represenlative Program.

d. At the conclusion of the analYllis.

an estimate should be prepar:ed of the

pef30nnel and. management reSOurces

that would be required to establish and

maintain an effective DOE Facility

Representative Program. and which

reflects the results of thc analysis,

2. Utilizing the rcsults of the

comprehensivc ~naIY$ls"theSecretary

of the Department of Energy establish 8

formal program to select. train. and

sS(jjgnDOE Facility Representatives for

the defense nuclear fac.ililies.

a. ln establishing thi~ program. DOE

should bc prepared to modify personnel

practices and programs as necessary to

est ablls.h ,9 beneficial and effective DOE

FacilitylRepresentalive Program.

b. TIlis program should give

consideration to:

(l) Dclineating DOE Facility

Representative selection requirements.

including specified standards of

educational achievement. profllssional

. experience. technical aptitude. and

forcefulness;

(2) Establishing DOE facility

Representative training requirements.

including 8 fonnal centralized core

training prog~am. a fonnal site- and

facllity(s)-specific training program. and

a continuing education and

Improvement program. each,including

periodic objective examinations;

(3) Defining DOE Facility

Representatives duties and

responsibilities, liOth generically and

with regard to each facility in every

mode of operation including transition

stales such as· between PSO's; and

(4) Establishing formal req'uirements

to specify those activitles or facilities

, requiring the assignment of DOE Facility,

Representatives.

John T. Conway.

ChnirmcIII,

Appcndix A-Review of 00£ Fadlit)'I

Site Representative Position

Dcscriptions

The DNFSn ShIff hKS reviewed sever,,1

current or proposed posilion oe~cription~,

defining the dUlie9 and responsibililit~3 of

OOf. Fucilily/Sl1C Reprellent<ltives at

Sa.MlnlSh River. Richland. Idono NlSlional

Enilineering Laboralory (IN£L). Rocky flo Is,

lind the Waste Isolation Pilot Plant [WIPP),

DU:lCd 00 th~8e pO!Jlllon descriptions. there

Ilppeor'$ to b. 8 wide (Hspari!y In the duties

lind qualifications for DOE r'acilitylSile

Repre$eotallvc; from facility 10 focilily. The

lock of any tffectlve guidllnce In establishing

the duties and responsibilitie8 88sociut~d

with theBe po$iUon~ is supported by the

follOWing ob&erYalions.
23578 Federal Regi81er I Vol. 57. No. 108 I Thursday. June 4. 1992'J Notices

The pooliion descriptIon [or lh~ FociHly

RepresentoUve. WIPP Projecl Office.

(General Engineer CM--801-13) most closl!ly

trocks lhe'definltlon Qf B "DOE Facility

Representallvu~118 defined In DOE Order

5OOO.3A. The poollion description properly

·summo.l'i:teB thEfmnjor dulies of toe facility

represenl81ive as follows:

"Conducu, daily on-sHe eVlllua!ion,of

controctor operations with emphasIs on

personnel heohh and safety. nucleor oafely, ,

environmental protection. facility

modiflClltio~ o'nd maintenance. and

fonnallty of opera lions. Assures sore

operations nlthe facility at ell times. This 18

accomplished by frequent walk-through

InspectioM of nil facility splices. obsen:ntion

of facility activities. and conHnuous Interlace

with contractor personnel at all levels.

Deficiencies or COncerns Bre resolved directly

with the contraclor Facility Manager (with

11mely appropriate notification to DOE

management of the IIcHons taken) or. as

nBC(!ssary. are elevated through DOg line

manllgemenl up 10 the Operations Office

Manager and the Headquarters Program

Manager.

~Servea as the primarY conduil of

information concemlng facility operations for

DOE management. Malntllin~ awar~e~s of

all activities. oll8Oing ond planned. at the

facility Ihrough discussions ·with personnelot

all levels. ihrough participations In meetings

on dlilily oJXlr8lions end problem reso\.uUon•.

as well as short and·lollg "mge plannIng, lind

through problem Idenllfication and resolution

resulting from jnierfaclng with personnel 01

all levels on walk-througn inspections and

obsc·rvoUon of opera·tions. Is responsible for

assuring thot Inspections. observations. and

discussions ON: 8ufficlently· frequenl and

timely 10 ensure currenl knowledgc of

operations at 1111 limes.

-Is nonnany the first point of cOl'llacl for

DOE in·aU ~vent nollflc:lllons and is '

available to.respond to tile facility around-

'he-clock. Serves as the primary DOE expert

regarding oper8tional activities snd problem

Idcntlfication and resolution.-

In contr"t.' the position description for the

Site Represenfetive. Chemical Processing

Plant Branch. INa includes the following

deflnlllon of dulie~

"Performs surveillance of .he racilities to

assure that work is being done in accordance

with" applicable ~H)fety standards <lnd

specifications. 3nci approved opera ling and

\vork conlrol pl"lXedures. Facility shutdown

authority rests with lhe Assi3tMll Manager

for Nuclear Programs. The Site.

Representollvc moy exercise this authorilY.

after conloctiJlg the AM/NP. when in his

opinion. operotions may result in undue risk to health. safety. or lhe environment. If time

permils.. such IIcHon wlll be coonlh'\8ted with

the MPO Oire<:tor. AM/fS&H. und 10

manager. In cas~ ·other than immll'lent

danger. the Site R~pre8entati\'e will first

bring the matter to the 311ention of f3CfHty

mon.ogemenl.1f re:JOlutioll is not reoched. the

Sile Representative wlll'go through normal

OOE-IO line management for dlrectinllsny

change in operaliona..':

The level of knowle<ise required or

Individuale a"igne<l to lhe~ ~itions vllries

widely among Ihe position de3crlptione

reviewed. All of Ihe position dC&C1iplions

suffer from Q lack of specificity u to how an

appHCllnl or on incumbent..in I~ posltioTl.9

will be requlrec:lto demonslrnte his or her

proflclency in meeting any of the ~Knowtedge

Requirements Motated in the position

description. III fact. no level of ed~tional

achievement is cited In allY of posilion

tlcscriptiornl- The Fncllily Rep~ntalive

p09ltion description for Ihe WlPP Project

Oroce does dte II Professional £ng.ineer

1icen~ as being highly desir..ble. but not

required. This position description also

eSlsblishes eeveral perfonnance crilen3.

indudlng:

'The obilily to compl~leeralniDg on Bafety

tlnd environmental regulolory issues. and to

opply general.and sHe-specific training

loward the demo~strationof detailed

knowledge of So3fety·related systems.design

basis. functions. lind operationlll

characlerlstlcs.M

The position descriptions reviewed are nol

consistent III lIle ass.i8nm~nt 'of .

rll9poJlslbililiea and compeM3tiOJl incentives.

II is nol readily t1lscemable as to how urtoln

DOE facility/Site Represenlative:! art: given

Ceneral Schedule classifications le.g. GS-13)

whereas selected DOE FacJ1ily/Site

Reprcsentll!ives are included In the DOE

Perform:lnce Management Roco8nition

Syslem. This lalter system. balled on lIle

concept of pay. for performance. is U3ed fOr

Individuals as!igned to &upervil'JOry or policy

influencing JIO'Sltions. A convinciDs al'8ument

«;.an be made that a DOE facility/Site

Representolive innuen~ the operational

policies and procedures for assigned factllres

and. Iherefore. should be 08slgned to thi, pay

for performonce incentive system.

AppeDdix B-:-Tranornl1l31 Letter 10 the

Secretary of Energy

DEFtNSE NUa..EAR FAClUl1ES SAFETY

DOARO

625/ndiano Avenue. NW. Suite 700.

Wash;·n8wn. o.G. 2OtXH. (2IX!) 2OIJ-.M()(} A FTS

:!6IJ-(;4{)(J

John T. Conway: Ch(lirman. A.J. Essenberger.

Vice Clwirman. Joh~ w. Cs-owford.lr~

Herbert John Cecil Kouts

MIlY Z8, 1992.

The Honorable James D. Watkins.

Secrelory af Enersy,

Washington. DC2OS!J5

Dear Mr. Secretory, On May 2R 1992. the

Oefen~c Nuclear Facilitis3 Safely Boord, En

Hccordancc with 42 V.S,c. ZUl63(5).

unonlmously approved Recommendation 92r-2

whIch is enclosed for your consideralion.

Recommendlltion 92-Z deab with DOE's

foclllly represenlative progr3m al defense

nuclear facililic$.

42 V.S.c. 2Z86<J1~) requiru the Boon.!. lifter

receipt by you. to promptly make this

recommendation available to Ihe public in "

the Deportment or Energy's ~Ionlll public

reoding roo~. The Doon.! believe1l the

recommendation conlalnll no infom)8lion

which i8 claMlfied 01' otherwis.e realrieled. To

lhl!r extcnt lhlll recommend(ltion does not

include InfonnBtion tellttict«! by DOE uooer

\he Atomic Energy ACI Qf 1954. 42 USc.

2161-68,'08 omendcd. please arrange TO!'ulve

this recommendation promptly placed on file

III your regionol public reodlng room$..

The Board wUl publish tMs

recommendolion In Ihe Feder:)1 Regl$ler.

Sincerely.

'ohn R. Conway.

ChoirnlOn.

Enclosurp.

IFR Ooc. 92-12998 Fjleo B-3~92.; 8:45 <lml

BILLING COOE 6e~KO-'"
23578 Federal Rcgiater I Vol. 57. No. loa I Thursday. June 4. 1992 ., Notlces

Inecommendallon 92-3)

Operational Readiness Reviews for the

HB-Une at the Savannah RIver Site,

Aileen, SC

AGENCY: Defense Nuclear Facilities

Safety Board.

ACTION: Notice recommendation.

SUMMARY: Th~ Defense Nuclear

Facililies Safety Board has made 8

recommendation to the Secretary of

Energy pursuant 1042 U.s.C. 2200a

concerning operational readiness

reviews for the HB-Line at the Savannah

River SHe. Aiken. South Carolina. The

Doard requests public comments on this

recommendation.

DATES: Comments. dala. views, or

arguments concerning this

recommendation are due on or before

July 6. 1992-

ADDRESSES: Send' commenta. data,

views. or arguments concerning this

recommendation 10; Defense Nudesr

Facilities Safety Board. 625 Indiana

Avenue NW.. suite 700. Washington. DC

20Q()4.

FOR fURTHEnlNFORMATJON CONTACT;

Kenneth M. Pusateri or Carole J.

Council. at the address above or

telephone (202) 200-6400.

Dated JUM 1. ]goz.

John T. Col'lwoy.

Chairman.

IReeommp.ndation 92-3]

Operational Roadiness Reviows for tbe

HE-Line 31 the Savannah River Sile,

Aiken. Soulh CaroH.na

O,,:ct!; M~y 2D. 1W2.

As indica teo in our rvcent

Recommendation 92-1. the Boord is

continuing its oversignt and

investigation of heolth and safely issues

related to the proposed resumption of

plulonium processing in the riB-tine at

thc Savannah River Site. South Ulrolino.

Our review of Department or Energy

(DOEl and controctor documents. as

well as other information obtained

during thc investigation to date. leads

the Board to conclude thQtlhe

Operational Readines6 Review (ORR) of

the HB-Line conducted by We~tinghouse

Savannah River Comp;:lfly (WSRC)
Fcdernl negister I Vol. 57, No. lOB / Thursday, June 4, 1992 / Notices 23579

during the summer of 1991, /lnd DOE's

subsequent review called on "ORE",

were premnlure, limiled in scope. and

inadequate. Moreover. some of the

conclusions reached seem suspect The

Ji30ard was particularly concerned tha l

some safety issues requiring resolution

prior to resumption oi operations

(Category 1) were reclassificG <IS postresumption issues ICa tegory 2). without

the concurrence of ceriain DOE team

members. raising a question regarding

the supportability of the findings. The

ORRs did not ensure adeque te

resolution and closure of safety and

health issues associated with the HB·

Line, which had not been operateJ since

1987. When attempts were mede to

resume operations in the HB-Line during

the summer OfIm, following the ORRs.

a. series of radiological exposures to

workers and other safelY incidents

OCCUlTed. causing operations to be

suspended. In October of 1m. the HBLine resumed operations until March of

1992. when operations were again

suspended due 10 an unre\'iewed safety

quesllon. The Office of Nuclear Safety's

review, as well as other assessments of

HB-Line; identified safety Issues which

atiU have not been resolved.

The Department has placed n priori ly

upon lIafety resuming HB-wne

operations to meet commitments made

to NASA. While recognizing that the

HB-Linc may not pose en undue risk to

the off-sile public. the Board remains

concerned with protection of on-silp.

personnel. since an adequate

assessment of operatlonal readiness has

not been conducted. nor has an

adequate assessment of nn accidental

ground level release been performed.

The Board has determined that the

conduct of adequate and thorough

ORRS by WgRC and DOE are essentiul

for identifying and resolving remaining

health and safety issues,sffec1ing

workers. and nl the same time promptly

achieving readiness for.restatl.

Therefore. Ihe BO;lrd recommcnds

that. prior to resuming opcrDtions in lhl~

HIJ·Line;

1. OOf. direct WSRC to reopell its

ORR, and th<ll WSRC llnd DOE ConcJucl

udequate ORRs in occordancc wilh

previous Board recommenthJlions nnd

DOE implementation plans for ORRs ::t

other facilities.

2. Comprehen~ive criteriu docufOents

be established for judging and

me<)s\lnng readiness to reslart. The

criteriu documents should include lh~

bases for judging which safely issues

must be resolved prior 10 resumption.

and which issues may be defem~d for

, resolution ::n.bsequent to restnrt.

3. WSRC Issue a Readiness to Proceed

Memorandum requesting DOE approval

for resumption of operali~ns after

WSRC no, completed its ORR and has

determined that $afely issue6

appropriate for closure prior to

resumption have been adequately

resolved.

1. DOE provide whatever assistance It

deems appropriate to WSRC during the

contractor's conduct of its ORR.

recognizing that such assistance is

separate and distinct from DOE's

subsequent and independent execullon

of its own ORR.

5, A OOE·ORR team, including a

Senior Advisory Croup, conduct an

independent and comprehensive ORR

for HB-Line after (a) WSRC has

conducted an adequate ORR and issued

a Readiness to Proceed Memorandum

requesting DOE approval for resumption

of approval of resumption of operations.

and (bl DOE has sufficient reason to

believe that significant deficiencies

affecllng the resumption and safe

operation of HB-Line have been

corrected by the contractor.

G. The DOE ORR teBm consist of

experienced individuals whose

backgrounds collectively include all

important facets of the operations

involved; that the majority of the team

members be independent of HB-Line

direct line management responsibilities

10 ensure an independent and unbiased

IlSSeSSmeTlt.

7. In preparing for the Operational

Readiness Review for the HB-Une. DOE

and WSRC should reexamine the HBLine Safety Analysis Report (SAR) to

ensure that: la) The lIccident analyses

adequ2tely consider all credible

scenarios: (b) all appropriate engineered

safety syslems which are necessary to

prevent accidents or mitiga te the on-site

and off-sile consequences of those

,lccidents are idenlified: and (e) the

information obfained from the updated

Fire H3l:.lrds Analysis is consislcnl with

Ihl: aecidenl analyses.

O. W$RC .Ilild DOE should complete

lhr:ir assessment of compliance wilh

DOE S:Jfcly orders <1: HI3-tine. and

finish their review. approval. and

implemenlillion of any compensatory

measures lhal are necessary and

<Jppropriale to achieve the objeclives of

onll:r compliance /lnd safe resumption

of operations al HB-Une.

John T. C<Jnwey,

r.hnirnmn.

Appcndix-TransmitU;1 Letter to the

Secretory of f.nergy

DEFENSE NUCLEAR FACIUTIES SAFETY

DOARD

{)25 indiana Avenue. NW. Suite 700.

WoshinS/Qn. D.C. 20004. (202J 2.08--6400

• FTS 268-6400

John 1'. ConwlIy. ChalrnHlfl. A,). Eggeobelller.

Vice Chairman.jol:n W. CrowforO. Jr~

Herber1 John CedI Kouts

May 29.1992

The Honorable jUlnes D. WaikiM.

Secretary 61 Energy. Woshing/o/l. DC 205IJS

Dear Mr_ Secretary: In accordance with 41

U.S,C, 228(311) the Board haa conducted an

InveSI)gallon of DOB.end contraclor

activilies III the H&Line at the Sevannah

River Site, Pursuant 10 thaI hwesligallon

which.is drawing to a close. the Board 8cnllo

you Re'commendation 92-1 by leller dated

Moy 21. '992.

In furtheronce of that recommendation. lh~

Defense Nuclear Facilities Safely Board, in

eccordance wilh 42 U,S.C. 22863(5).

unanimou6ly approved Recommendation 92-3

which is enclosed for your consideration.

Recommendation 92-3 deals with Openllional

rendiness reviews for the HB-Une 81 the

$.wannllh river Sileo Aiken. South Carolina.

~2 U.S,C. Z286cl(e) requires the Boord. ofler

receipl by you. to promptly make tbis

recommendation ovoilable to the public in

Ihe Deportment of Energy's regional public

reeding rooms, The Board believes the

recommendiltion confains no information

which is claseified or otherwIse ~strlcted. To

the exlent this reccmmeodelion does not

include Information l'e$trlcte<t by DO£ under

the Atomic. Energy Act of '954.42 U.S.c.

:Z161~. u amended. please arrange to have

thIs recommendation promptly placed on file

III your regiooel public reading rooms.

The Doard wlll publish this

recOmmend~llonin the Federal Register.

Sincerely.

John ·T. Conway.

Chairman.

Enclosure

IFR Doc. 92-13061 Filed 6-3---$2: 8:45 amI

DIUJ>IC COOl U20-"~N
Federal Regi6ter I Vol. 57. No. 135 I Tuesday. July H. 1992 I Notices 31177

DEFENSE NUClEAR FACtUnES

, SAFETY BOARD

I Recommem1ation 92-4}

Multi-Function Wa,s1f Tank Facmty at

the Hanford Site

AGEHCV: Defense Nuclear Fadllties

Safety Board.

Jt.cncm: Notice: recommendation.

SUMMARY: The Defense Nuclear

Facilities Safety Board (Board) has

made' a recommendation.to thil

Secretary of Energy pursuant to.42-

U.S.c. 2286a concernjng the Mulli:

Function Waste Tank Facility at the

Hanford Site. The Board request:& public

comments on this recom.mcndation,

DATES: Comments. data. view$. or

arguments concerning this

recQmmendation are due on or before

August 13. 1991.

ADPRl:SS£S: Send comments. data.

views or arguments concerning this

recommendation to: Defense Nuclear

Facilities Safety Boar<l625lndiana

Avenue. NW:. suite 700. Washir-ston..

DC 20004..

FOR FUR'rn'EJt INFORMA~ CONTACT:

Kenneth M. Pusateri or Carple J.

Council, at the address above or

telephone (202) 206--MOO.

Deled: luly 8. 1992..

)oh.o T. (;cKIway.

Chairman,

Multi-functioo Waetc Tonk Facility at

t~ll Hardord Site.

Dilled: July 6. 199iL

As required by the Atomic Energy

I'\Ct. the Defenac Nuclear Fl!cilities

Sllfely Board (DNFSB). conducts

reviews and cvaluatioiu of the design of

new Department of Energy defense

nuclear Iacilitic8 before and du.ring r..heir

construction. Under this Btatute. the

DNFSB is also required to recommend 10

the Secrelary ofE.oergy. within II

reosonable time. such modifications of

the desisn as tbe ONl-'b'"B considel'1l

necessary to ensure adequQte protection

of public health and safety.

The Board hall perfOimed reviews of

the Multi-Function Waste Tank Facility

(MWTf') project to be lOcated at tbe

Hanford Site in tbe State of WQllhingtOll,

The MWTF i8 an elWient of the Bonford

Tank Waste Remedial Sy5tem (1WRS)

Program which cventually will provide

for the ultimote treatment and disposal

of the Hanford SHe tank waste. We have

reviewed information received in the

form of briefin~ and presentations by

DOE Headquarters personnel DOE

Richland penonnel. Westinghouse

Hanford Company personnel. and

Kaiser Engincers Hanford personnel as

well us analysis oJ relevant dcx:wnents.

The Doard's reviews to dale have been

concerned with'such maHers as the

application of standards. including DOE

orders and directives. and commercl~1

nuclear industry practices as well as

othe.. llspects of the project which relate

to ensuring adequate protection of the

health:and safety of the public.

The cOpceptual design of the MWTF

project is now nearing completiOn.- The,

Board belleveo that it ia appropriate 81

this time to assure Ihat,lhe design of the

lvfWTF' and other new defense nuclear

facilities incorporates engineering

principles and approachca. detailed

engineering criteria. and practices that

are essential 10 ensure adequate

protection of public health and safety.

Thelle include:

• The dellign needs to be

approprill.teiy conservath::e with respect

to safety.

• The design bese1l (criteria) need to

be· clearly· defined. coherenl ~nd

compatible with the facilities< pen:eived

lifetime functions (i.e~ f"'tIDctional Destgn

Criteria) Bnd documented

. • The design bBS~ the reaulting

facility design need to reflect and

incorporate the requirements of

appropriate standards aathet tenn is,

used in Ibe Board's enablingstatule and

lhus including DOE orders and

directives and commercial nuclear

practices. as well as.any other factors

Ihat may be required for the safe and

reliable optiration of tbe facility

throughout its entire life.

• The design. construction. and atartup activities need 10 be performed by

tho/l.C who will ensure the completed

project 15 of the Quality necessary to

provide adequate protection of public

healLh and l).3fety,

• The design effort needs to be

orgenned such that theN!: is continuity

through all phases (conceptuol design.

preliminllry design. fmal de$ign.

conlllruction. testing) lKl that aU 3specb

of the process that affect safety are

clearly delineated and that line

responsibility ill clear.

• The OOE orgonizaHon respon.sible

for the project, needs to have tecbnicnUy

qualified pel'Bonnel in numbefll ,

sufficient to prpvide diret:tion and

guidonce to conlrnctOl'1l perfonning o.tI
31178 Fadei'lll Register I Vol. 57, No. 135 I Tuesday. July'H. 1992 / Notices

phaDes of the effort and to allseSD the

effectiveness of contractor efforts. .

• The project organization and

operationB need to reflect a clear and

effective chain of command with

responaibllity. authority, and

accountability clearly defined and

ussigned to individuals within the

respective projecl organizations.

• The functions and responsibilities

of all DOE and contractor organiz.ations

involved in the project need to be

delineated in· writing in a single

document.

The Board's view of the Hanford

MWJFs conceptual design performed to

date is that the design doee not clearly

present and delineate those aspects that

ensure that tile public health and safety

can adequately be protected. IIi

particular,the MWTF appears' to be a

project (1) without a well-defined

mission or functional requirements [e.g..

waste treatment or sto'rage), (2)

.predetermined 10 cOn6ist of four onemillion-gallon timks regardless of their

intended uses, and (3) mana·sed without

sufficient regard for technicallss\les and

engineering involvement. The continuing

phases of the design and construction

are about to. begin and the Board seeks

to be assured that the design of th.e

tanks as they. are bullt incorporates the

appropriate levels ·of nuclear.safety.

Further. the Board recognizes that many

of the nuclear safety concepts and

assuranceS would normally be provided

in the series of-facility Safety Analysis

Reports and would include design bases.

safety s'yste.ID analyses. analysis

methods and accident analyses,

However, to ensure that appropriate

n\lclear safely characteristics are

included in the design efforts. the Board

recommends the fol~owing to the

Secretary of Energy:

l. Establish·o pllm and rTJethodology

Ihal resl-dts In B project management

organization for the MWTF project team

that assures that both DOE and the

contractor organization have personnel

of the technical and managerial

competence to ensure ~ffective proiect

execution. This should emphasize

management nspe!=ts of the project

necessary to eosure adequate protection

of public health and safety and should

include the integralion of professional

engineering and quality assurance as

necessary into the project. the

application of appropriate stani:lards

and approved Department of Energy

requirements. and the establishment of

clear lines of responsibility lind

accountability.

2. Identify the design bases and

engineering principles and approaches

for the MWTF project that provide the

data and ralionale to show that the

design for the MWTF conservatively

meets.the quantitative safety goals

descril?ed in the Departments' Nuclear

Safety, Policy [SEN-3S-9'i). The Board

believes that would include items

related to standards, identification of

safety related items. detailed design

bases. funclional design criteria, and

safety analyse8.

John T. Conway.

Choinnan.

Appendix-Transmittal J...ettCl( 10 the

Socrotmy of EnetID'

July fl. 1992.

The Honorable James H. Watkins.

Secretory ofEnergy. WCJShinston. DC 20S85

Dear Mr. SeQ"eI.ary; On July 1,1002. the

Defense Nucle·ar FaciHlieaSafety Board. in

llccordance with 42 U.S.c. 2200a(S).

unanimously app,roved Recommendation 92-4

which is encloeed for your Consideration.

Rei;QmlJleDdation 92-4 deals with the Multifunction Wasle Tank Facility at the Hanford

Site. . 42 U.S.c. 2288d(a) requireS the Boa(d. afler

r~eipt by you. to promptly make this

recQmmepdatioD IIvailable 10 the public In

\h·e Department ofEDergy's regional p·ublic

reeding rooms. The Board believes the

recommendation contains· no Information

which is classified or otherwise restricted.. To

the extent thi" recommendation doe!! not

include information restricted by DOE wxler

the Atomic Enef8Y Act of 19M. 42 U.S.c..

2] 61~ 8a 8mend~ ~leB8e 8mlnge 10 have

this recommeDdatlon promptly placed on file

in ·your rigjorial public rea ding roOms..

The Board will publish this .

recolIlIitendation in the Federal Register.

Sincerely.

John T. Conwoy,

Chairmafl.

tF'R Doc.. 92-16465 me<! 7-13--92; 8:45 am)

DILlIHG COOE $ll2'CH(Q-M
f'eaer<ll Register / Vol. 57, No. 168 / Friday. August 23. 1992 I Notices 39191

DEfENSE NUCLEAR FACIUTIES

SAFETY BOARD

IRecommend;}tlon 92-5J

Discipline of Operation in 3 Changing

Defense Noclear FacUitles Complex

AGICNCV: Defense Nuclear Facililies

Safety Board,

ACTION: Notice: recommendation.

SUMMARY: The Defense Nuclear

Facilities Safely Board (Board) hus

made a recommendation to the

Secretary of Energy pursuant 1042 .

U.S.c. 2286a concerning Ihe Discipline of

Operation in a Changing Defense

Nuclear Facilities Complex. TIle Board

requests public comments on this

recommendation.

DATES: Comments. data. views. or

argume:n1s concerning thIs

rccommendation are due on or before

September 28,1997_

ADDRESSES: Send comments. data.

views or arguments concerning this

recommendation 10: Defense Nuclear

Facilities Safety Board, 625 Indiana

Avenue. NW.. Suite 700. Washinston.

DC 20004,

FOR AJRTHER INFO~~ATIONCONTACT:

Kenneth M. Pusateri or Carole J.

Council. at the addres9 above or

telephone (202) 20l}-6400.

Dated: Augusl 24. 1992.

john i. Conw<lY.

Chairma(l,

Discipline or Operation iu I) Changing

Dere~ NU9FT Facilities Complex

IRecommendation 92-5)

Daled: Augusl17, 1992-

The changes In defense-related plans in the

Department of Energy are beginnIng to have a

profound dfeci on the activities directed 10

systematic upgrading of the conduct of

operations al defense nucleadacilities. plans

that ha\'O often been discussed between the

Board and its stafr. on Ihe one Iland. and

members of your staff on the other.

The'Rocky Flats Plant presents an

exceUent example of the major changes being

made by DOE while reconfiguring the nuclear

weapons compJel<-lt"h'ad been planned Ihal

as the Rocky Flals Planl moved toward

resumption of production cf plulOnfu.(J).

components of nuclear weapons, a

succession Qf facilities would be' readied for

renewed operalion. beginning with BuildIng

559 (the llnalyllcal chemistry laboratory). and

followed by Bullding 7fJ7 and then others..

This process was 10 incl\!de s~'s~emallc

upgrading of.th~. quality of opera lions In eEleh

case. including Op~ralionalReadiness

Reviews by the contractor and by DOE to

verify Ull)l the desired improvements had

been accomplished by line management.

Reswnption of operollons Is now proceeding

in Building SS9, In accordance with Ihis

,process and following Ihe path proposed in

your lmplementaiion PIon for the Board's

Recommendations 90-4 and 91-4.

You hll\'2 announced. however. Ih;;1 in ligh1

of inlemationel developments. plutonium

production operations will not be resumed 01

the Rocky Flbts Plant, and luture acUvilies

there will be confined 10 cleanup nnd

deeonlomination of the site. decommi~sjonin8

of some facilities and Pllfts of others. llnd

placing of 60me facilities llnd paris o( olhers

in 9 stole of te<luiness for resump!ion of

operations in Ihe fulure In 1heevcnt such II

Illep should be nccdeti. Thun (or most

raciliti~ 01 Rocky Flats Ihere Is now (I major

change from the mission ond octivitles

previously planned and for which the Booro's

Recommendations and your Implemen,lotion

plana !l~fjc to the Rocky Flots Plont \Verc

1o be applied. (or Iho~e recommendl)!l"n,

Wl':f"e pn..dicnted upon re8umption of

plutonium pr-oducUon, .

At 0 nUD'lber of Qthl!f defense nl-lclear

bcllitlf'..a.. al!nilar changen are t~klng effect.

Mlilny faciliilcs ore now scheduled for
39192 Federal Regi$te.r I. Vol. 57. No. 168 I f'rid<lY. Augusl 2a. ]992 I Notices

c1eaooul. 9hutdown. and deoomml$$loning.

Some are to be devoted to e$~cb 01 cleanup

and decollllnissloning of alle$ ond of Cacllitic$

located within aites. Some ore alated to be

p.laced in a standby mode, llveHlIble for

re9tart llt a later dale if ~ed. Some are 10

be continued iD operation 'either In reduction

of the stockpile of nuclear weapons. or In the

ma:nlenl>rice of a reduced stockpile on improvement of ita safety.

'Some: of Ih~e facilili~ have been it'lOctive

ror long periods of time. Some are to be1:-ome

Involved in opct'9t.ion8 tbat differ from past

usage. Experience shows that when

operatlons are Nl&umt:d at a Iacility lhl)! h30

been idle for an extended period. or a hu;ility

is operated in a new mode, there Is in an

300ve-average pO$siblllty of ml9lsl<es..

equipment failure$. and vlolatiotls of safety

requiremen~. that <Xluld ~usc oeddents. We

,believe that special atte~tlon is needed at

such times.1"he appropriate m~sures to be

followed depend on specific features of the

facility. the nature of the planned ~mp&lgn

of use, and the IODg~tenn plaD for the f3Cility.

For example. one needs to Icnow If furthrocampaigns are Ukely. of the lIDme or diffe.rent

kinds: if the f3cillty is to be decommiS$\oned

after the planned use; Or !f It i.9 to be placed

in a ~tandby mode.

The Board has found. through experience :it

the Savannah River Sites and the Rocky F1et3

Plant and other defense nuclear racilitil!s,

that an extended period oftlme has been

re-qulred afmajor facilities to dmoelop an

occeptable :style and level of conduct of

operations. Aceompli$hing the cultural

changes you have required and meeling

safety standards comparuble to tholle

~,(jwred of the civilian nuclear mdulltry

,~iruJ an ongoing challenge. Major

improvements haVe been necessary inc!odulg

development of configuration control. revised

and acceptable sofety analysis. revi$ed

UlllHing C-ondltion8 ofOpCTIltion derivative

from the safety onolysis.. operating

proccdUJ'1!3 consistent with the COl'lfiguration

and Ihe s~fety analysis. and tra!"ing and

quali~c;)tionof operators for Ihe new mode

of operalion. Conlinulld imp~ment has

been ~ught by the Board.

The Board has been Infomled that DOE:

doe9 not intend 10 devote.equivalenl time lind

resourCC'$ 10 Improving Ihe quality of

operation Ilt B facility being ~Iorted only 'or iI short campaign or inlended for use only in

a short campal!:n In II difJCI-ent moot:. bul

would on a cost·oonefit'basis u*' 0 sra.ded

<lpprooch. alway, being sure. howeve~. 10

wkc whatever compensatory'ancl other

rneasurea are needed to en$ut~ the

::Jccepl'lblc level of safety.

The ,definition and expo~ition of a &'laded

upproach as il is meal'll to be used in orderi"l;

the conduct of operation, have not b~n

providl;ld. IJl dischuging its reap<lOllibililies in

,the context of the,new defense-relotoXl plans

of the Depart/neot of Energy. the Boor(} ,

Intends 10 carefully review futtu'e operotiOl\8

ot defense nuclear faclllties on a ease-byc.a $() basj,. Gtortin8 in each inGlo..oce from the

best lnfonnalion aa to lhe Intended futvre use

of Ihe 'facility.. Any pro~8la lo'~ special

measures or conlrols to col'llpenaate for

daviali\lrll from those o!'dil'lJlrlly, U&Cd 10

achieve high qUQ!lty'conduct of <>-perotio""

will be closely scro\lJll:w:d- "

Therefore. it 18 requested that a, you

dedde the futurl!' statu. of indhridunl defen3E:

nuclear raciJjli~ you Inform the Boorrl.

de9ignnting which ones are to continullln

operation and Ihelr mission. which are 10 be

9hut do\vrl ror decommissioning within (\

short time period. which are to be used ror on

exlended time period and then lIb!)l down ror

t.!ecommis9ionlng. nnd which are to be moved

to 9 9tandby mode (o[ooS wilh the ~e<lulc

for this).

Regardleu of the category. the Bollrd

bell eves that operation ilnd mainlennoce of

defen${! nuclear fllcilitiet\ In all mOOe1iI ,hould

'be In accordance with the Nuclear Safety

Pol.icy statement that you issued on

Seplember 0.1991 as SE..'II-3S-91. and the

~arety gouls &wted therein.

The Board o.lso believes thaI. to the extent

practicable. facilities thai are to be $hut

down and decommissioned should be '

cleaned up. and hazards from radiological

exposures sufficiently reduced thBl llCCc.M

can be made freely wilhout need for

precautions againsl rad!oacuvjty. lind

fadHties meant for standby statU-' should he

placed in lIuch II condition that sudden need

to reacth'ale them would not subject a hew

operating group to unacceptable ~diation

ha:tartls.

In furtherance of thi$ view it is.

recommended that:

1. For defense nuclear facilities scheduled

Cor 10llg.term CQntinued. p~atic

defense operations. I Qr for other long term

uses such M in cleanup or radiOilcuve

contamination or in storage of nucl~r waste

or other nuclear material'froio programmatic

defense operations. the Department of Energy

should institute a style and level of cooduct

of operations comparable 'to that toward

which DOE bas been working at'Building SS9

at the Rocky Flats Plant end the K·Resctor at

Ihe SaV3M'll! River Site. and wbich is at

least comparable to that required for

commercial nuclear facilities. addre3siJl8 al a

minimmn lhe areas referred to abov~ in

connection with style of conduct of

operations.

2. Where a I<lciHly. after a long period of

idlenes$ ror ..... hatt:ver rea;on, 19 beiog

readied for \'lew U:Il~ or reu,e. ~peciaJ care

should be taken to ensure lhllt the line

orgElniz:;llioo. bOlh DOE and <XlntrllctOr. has

the technical and mllnlJgeria.1 ClljXlbility

n~edcd to carry out lls responsibilities.

Appropriale >lilt! clfC'Ctive Opel'llt)cnal

Headiness Revit~W6 should be con<.l~"':\4)t.!l>y

the contractor <lOt! by DOE before reslnrt o(

the fllcili!y. to establish confidence Ih~lline

manlJE:cment hos provided 'OLJsfaclion of

sllfely requil'Cmcnts. Where noHonal security

requirements lead to urgent need to restart

such focilitie~ before necesnrr Upgrilt.l~ can

be fully compleh:d. compensatory measures

~hoold be instituted ond their adequacY In '

ensuring the d~ired level of 9afety shonlt.! be

confirmed lhrough oppropnOle independe')l

review.

3. For lacilillesdesignatet.l for lhe V3rio~

olherfufure mode:. of U$C lauch as stl\ndby).

I 1'1>1. l"rm 1.5 mcl>tallo ~Drol:n""... ~I>l'cl>..

developm~nt. and p«>duclion for ~tnI>e

lind <>perot ion. n:lalf'd to,I~&ling. .s.embly.

tlionSfcmbl)'. and Ilor.>ge of nuclear _po"" ,,:,,<:1

nuclear weaporu CQ...~Ie.. '

OOE should unoel'take to develop spe-cific

crlleria 309 requiremEnts thai eJl$tlre 'ml!cting

the safel)' SOllls ent.mcillted In your Nuclear

Policy $);llemenllSE.N--3S--9'l).

Aocomplishmenl of,these crileria and

rcqutrel'lIent6 by line ~nllgemeotsoould be

confirmed hy appropriote inde.pendent

review.

John T. Conwoy.

Chairman.

APl'el)(\i:,c-Tl1'Insrnillal Letfer 10 tb~

Secret"ry of Energy

Oefense Nuclear F;tolitie& s.,rety Board

J\~lgust 17. 1992.

The HonorQble lames O. Watkins.

Secretary, of ~nergy. Woshington. DC 2f.K>85.

Dear lI.tr. ~~t<)Jy. On August1i. 1992, the

Defense Nucli!ar Facilities S<lfety Board. 1..'1

ilccorda~ wllh '42 U.s.c. 2286a{S).

unanimously approved Recommendation 92.-5

which 10 enclosed for your consideration.

Recommendation $2..:..5 deals with Discipline

or Operation in a Ch:mg!l\g Defense Nuclea~

F'llcllities Complex.

oJ2 U.S.c. 2286d(a) requIres the Boord, afW

receipt by you, to promptly make this

'recommendation available to the public in

the Oeparlment of Energy', regionsl public

rellding rooms. The Board b£lieves the

recommendation contains no information

which is classified ()r otherwi:le restric1ed. Tc,)

the extcnt this recommendaliQI:l not

include information reslricled by DOE unc~r

the Atomic Energy Act of 1S5-;. 42 U.s.c.

2]61~, a$ amended. please arrange10 hav~

this recommendation promptly placed on file

in your regional public reading rooms.

The Boord will publish this

recommendation in the f'edeTa1 Res:isler,

Sincerely.

lohn T. Conway.

Chairman.

IFR Doc. 92-20590 Filed 8-27-92: 6:·15 !lml

6IW~G com: 6112b-Ko-.M
feder~l'Regislcr I. VoL 57. No. 171 I Wednesday, Se~lember 2. 19~2 I Notices 40181

DEFENSE,NUCLEAR FACILITIES

SAFETY BOARD

IAecommendation 92--6)

,Oper'atiollal Readiness Reviews

AGENCY: Defense Nuclear Facilities

Safety Board. '

ACTION: Notice: recommendation,

SUMMARY: The Defense Nuclear

Facilities Safety Board (Bo'lJrd) hns

made a recommendation 10 the

Secrelary of Energy pursuant 1042

U.S.c. 2266'01 concerning Opera(ionttl

Readiness Reviews. The Board request;

public comments on this

recommendallon,

OATES: Comments. della. views. or

argumenls concerning Ihis

recommendation are due on Or before

Oclober 2. 1992.-

ADDRESSES: Send comments. dala,

views or arguments concerning this

recommendation to: Defense Nuclear

Facilities Safety Board. 62.5,lndiana

Avenue. NW., sult~700. Washington.

DC,~OOO1" .'

FOR'FUI'lTh~'NFORMATION CONTACT;

Kenneth M. Pusateri or Carole J.

Council. Bt.the'address·above or'

telephone {2(2) 208-&400:

Dated: August 27, 1992.

John T. Conw~y,

Chairman.

Operational Readiness Reviews

Deted: Augu:ill 26, 'l99z.

Several or the Board's Recommendations to

you have'referred to Operational'Readiness

Review:l. and some have been specifically

directed IO.Sucl13Cli'·ilie~.I.qthis way. the

l3<>ard has shown thai it holds't11ese review~,

whelher by Ihe contractor or by DOE.. in high

regard a:l important measures in verifying

retld:nc~s of new activities to be slarted

silfe!y or of pre\'io\lsly conducted activities 10

be Sli fely rosumed af:er an appreciable

histus,

The Board r(:cosnizes that the ~clultl

operation of defense nudear facilities is

llccorllJ:.'lished through defense contractors,

VI/hile first line responSibility for safe

operation ;s in diect delCf;Clted through

contract provisions. such delegation does not

relieve DOE management of its responsibility

for cnsurio8 that the operation will be

proteclive of public health ond sMcty. II is

Ihe lJo~ru'lI £inn conviclion that adequOlc

protection of the public hesllh and silfely

m~I:l1 be a,chic\'ed through eustai"ned exercise

of vigilance by line management of DOE {lnd

the cont~ctor. '

TheOperallonlll Readiness Reviews is 9

proce:lO undertaken after the inlermedillte

level' of line m3nagE:ment hall orrlved al il3

cQncluoion ,that 'laic: of readiness hilS been

achieved for safe startup of the activity. It is

a means whereby top manage'ment1n the

contractO!'" ancllpr nOE.can then..arri,ve at the

indep.endent,ly determined conclusiQn that

this readiness exisls. If the line organizations

thai heve,been'de:legated responsibility for

prepllrlng a facUity for operal,lon hava

perfonned effectr.·ely. findings of any ,

shorlfCllls are exp.ected to be few: and of such

acharacter that they can be remedied in

shorl order and on a scheduled basis prior to,

stllrtup.

In ltiis vein: the SO.;lr'd has recognized the

b~ud~l:.le ..d\'3nce tow&rd definition of ORR

requircmeot~ m2de.in SEN-16B-91.

"Appro\'al for Restart of Facilities Shut Down

for S:<f~ty R«a~ol\s lind for StarlUp of Major

~ClV Ff:ciiilie3··. dated Novemoer 12. 199],

:)P.(J :he olt;\chtcl "Process for Se>:relllry

AJ)pro,'r,1 of i\J\lcl(;3~ F~cj:lly Resl~rl 0,

Slurlup". "IClwevc:r, we believe lh~ I gu:dlloce

could be im~rol'cd hy specify;nf: the required

fC<ll'.Lrcs (If 0 sRtisf:,clory ORR. ",,,d by Slating

sptc,ficall)' on ",hill OCCIl5i()ll~ CPo ORR will

I,e reCluir<:,J,

S<',me of the Doards Hccommencalions

h;lve IIlso reflecled recognilion that

comJucling nn Oper~Hon;Jll\eadincssReview

prtnlllturel)'. berore line monagement

responsible for preparing II f"eility for

operation h3:l concluded on 8 sound bllSis

that re3dlness has been achieved. hos

adverse effects on safely. Among these are:

(alit ma:lks possible lack of competence

Gnd other defocts in contrl)Clor and/or DOE'

line manllgement. . ,

(h) 11 be;:omes (l n'lOMgcment tool for

ochieving readinC$:.\ 10 proceed safely rather
40:182 Federal Register / Vol. 57, No. 171 I Wednesday, September 2. 1992 / NOlices

lll.,n verifying 1I. In lhis w~y il becomes a

crutch for line managemenl.

(c) II postpones discovery of safety

deficiencies which effective line management

would h~ve Identified earlier.

{dl It encourages resort 10 actions wh ich

compensate for safely defkiencies. instend or

correcting lhem.

(e) II lIili~tes the value of Ihe Oper~lionlll

Handiness Review as n means of independent

confirmation of readiness. .

The bO:Hd belicvC!s that among lhe fealures

of IIll acceplable ORR are lhe follOwing;

(a} The review team should not Include. as

senior members. individuals who are

responsible for accomplishing the work being

reviewed.

(b) When the contractor perrorms an ORR,

II and lhe DOE's ORR should be carried out

in serial fashion. and lhe laller should not

begin until the contractor hlls informed DOE

in writing thal the facility is ready 10

commence operation..

tc} The criteria governing the review should

include the scope of the review lind the

fllclors 10 be used by individual teclmical

experts In It!c;lg,ing I1liltisfaclory ~onnllnce.

(d} The OOE review should include

assesament of the technical lind m<lnlilgerial

qualifjCl\lions of thO&e in the DOE field

organiUltlon who have been llssigned

responsibilities for direction and guidllnce to

thl! COntractor. including the Facility .

Reprellentatlve. A similar review should be

made of the qUlllifications of con!r.lclOr

personnel responl1ible for facility opernlions.

(e) The review team should be required to

reacb B conclusion as to whether the fllC!l\ty

will be operoled in conformance with

applicable DOE orders. directives.nnd

Sec.retary of ~ergy NoHces; nnd that any

nonconformances or CODlpllance Schedule

Approval5 have been justified in writing,

have been formally approved.. and in the

opinion of the revil!w team do Dol unduly

diminieh protection of the public bcullh lind

safety. [nc!udlll.ll worker safety.

The llbove being recognized. the Doard

recommends thaI:

0) DOE expeditiously develop an effectlvc

set of rules. procedures. orders. directives.

and other requirements to gOvern safety

aspects of the Operational !l.eadiness Re"iew

process. subject '0 the principle thot the

purpose of such a Review is confinnntion of

an I!cceptable sta Ie of readiness.

(2) OOt: dl':w:lop specific criteris fo! when

O"er:JliO/lll1 Rc.-Adine" RcvlcW5 are required

!lnd when they are no1.

(3) The plon for each ORR incorporate the

fC.:llures discussed a bOlle ~s ul':siruble. a~

well as Ihose lhal werc rcco:niT:end~din Ihe

Doard'8 RcComm~DdlltioJ)90-4.

John T. Conway,

ChO;rmoil.

Appendlx-1'ransmill;)1 lAllter 10 Ihe

Se-cret~ry of Energy

Augusl 26. 1992,

The Honorable lames O. Wolkin3..

Secretary of energy. Wosh;na(on. DC 2()5()5.

Dear Mr. Secre1ary; On AugU!lt 2a. 1992. the

Defenae Nuclear Facililies Safety Board. In

accordance wilh 42 U.s.c. Z2OO.a(S).

ummimou,ly 8pprov~d R~mmend.alion

which is enclosed for your consideration.

Recommendation 92--6 deals with

Operlltlonal Reodiness Rev.iews.

4Z US.c. 22.66d(a) requires the J)otlrd.lIftllT

receipl by you. to promplly make this

recommendation avoilable to the public in

the Department of Energy's regional public

reading rooms. The Board believes the

recommendation contaJns nO infonnation

which Is classified or otherwise re&tncled. To

the exlent this recommendation docs not

Include informliltion restricted by DOE under

the Alomic £nergy Act of 1954. 42 U.S.C.

Z161~ aa amended. please Ilrrange to have

thi~ recommendation promptly plilced on file

In your regional publi~ readin~ rooms.

The Doard will publis!:l this

recommendation in the Feder;)! Re-gistcr.

Sincerely, .

John T. Conway.

Chairman.

lFR Doc. 92-2105] filed 9-1-92; 8:45 am)

llIWNoG CODE U2O-I(o-Io!
.t:ederal Register I Vol.. S!. No. W8 I M09dny. September 20.199.2 I Notices 44561

DEFENSE NUCLEAR F~qILlTIES

SAFETY BOARD

IRecommendation 92-7 J

Training and Qualification

AGENCV: Oefensc Nuclear Facili\ics

Safety Doard.

,ACTION: Notice; rccommendCltion.

SUMMAav: The Defense Nuclear

Facilities Safcty Board (Do<lrd) has

made a recommendation to the

Secretary of Energy purS'uant to 42

U.S.C. 2286a concerning'Training and

Ql;Ialification. The Board requests public,

comments on this recommendation,

DArES: Comments. d'Ha. views. or

argumen\sconceming this

recommendation <Ire due on or before

October 28. 1992.

ADDRESSES: Send comments. data.

views or arguments concerning this

recommendation to: Defense Nuclear

Facilities Safety Board. 625 Indiana

Avenue. NW., suite 700. Washington.

DC 2004.

FOR FURTHER INFORMATION CONTACT:

Kenneth M. Pu9ateri Or Carole J.

Council. at the'address above or

telephone (202) 208-6400. '

Dated: September 23. 1.992.

lohn T. Conway.

Chairman,

[Recommendation 92-71

Training and Qualification

Dated: September 22. 1992,

Since it~ inception. the Defense Nuclear

Facilities Safety Boa~d has ell?-phasi~ed thaI a

well,con$li'U~\ed 'ail~.d,ocl.\lD~,:\~ed 'p,roe,ram.

for training'arid 'qualifying o!>era'tiolis:" '

maintenance. and technical' ~up'p'ort

personnel and s\lpel'visors at defense nuclear

facilities L'I an essential foundation of,

operations and mllintenanc;e (lOd. hence. the

safety and health Qf the public. in4(l~ding,the'

facility workel"9. A substanli;,tl p'or~ion of the

Doard's efforts has been devoted to on-site

observation and n!vie,:" 'of peisonnel and

supervisor selection. training. qualification,

certification'and facility operation.

The Goard recognizes <lnci commends

DOE's efforts to date to upgrade training

programs 01 its defense f<lcililies. While the

floard applauds the effort expended in

developing 00£ Oiden ~80,18A.

IlccreditoliQn of Performance-Dosed rroinilt8

for CotegQry A J?eoctol'$ and Nuclear

Facilities cnd 5480.20. Pel'$onnel Selection.

QlIolifir:ation. Training and Staffing

neqviremenLs at DOE Reoctor and Non·

Fleactor Nuclear Facilities. implementation of

these Orde~ to date has been slow and the

DO<lrd conlinues to find common defic'ienclcs

6\ most facilities it vlsl1S. DOE: nuclear

facility Mnlntenance and Operali'ons (M800}

Conlractors were required by DOE: Order

5480.2Q 10 sl.bmit implementallor\ plans

called Tr'Qining lmplemenlalloA Matrices

[TIM$) for ellch'OI~c1el)r, facillly'by November

6.1991, The,Order does not contain 8. time

requiremen't'(or DOE to approve, the TIMs

ilnd. for Ihe r<lCilllies reviewed by lhe Doard

(lnd Its staff. DOE has nol ::lpprovcd Ihe plilns

Ihey have received to d'lIe.

Unllllh'e TIMs are approved. training tlt

tlefense nuclear facilities is governed by more

!:cncrlll re4uiremenls contained in DOE

Orders on sarct), (00£ Ortler 5460,5 Safely of

Nuclear FaciJitius and DOE Order 5~80,O

Sofely of DOE-Owned nooe/ors) Ih31 h:lVe

been in effect since September ZJ. 1900.

Oesplte the long standing requir(!menls of

these Orders. the contr<lctors at the many

different facilities evaluated by the Boord

h,lVe nol yet. in OIJr view. provided

management attention and resources ror

training and qualifiClltion commenSUrDte wilh

Ihe health and silfety ImpliClltions of their

defense nuclear programs. Indic111ions al

each of these tites demonstrllle weaknesse~

in contractor trailling programs that have

potential negative safety consequences. For

example;

-A prima:y me3~ure of an effective lraining

program b t,he'level of knowledge ,of the

personnel.and supcrv[SOI'$. At almo$t'all ,

defense nuclear sites, there arC llunierous

tl!chTflcal perso'nnel and supervisors 6r . defense nuclear activities who do not'

.3d,eQua.l~ly.unders~and.many'basic",

fundamentals of engineering. chemistry.

nuclear physics. lind radiation protection to

the extent requIred tQ ensure safe

operation or maintenance of-the facility to

which they are assigned'.

-Written examinations at many sites <;>ften

consist of unchallenging multiple chOice

and short unswer questions which do not

adequatety assess operator knowledge.

Additionall}< written operator qualification

exams do nol effectively ,correlate

fundamental engineering principles .wilh

job specific kOowledgc requirement~. '!>S a

result. manageolent may not have s'uUicient

information to determine if technical".

personnel,in, a defense n,uclear facility have

3chieved,a.level of expeMis'e required to"

Sllrely'qll)du~t:their activities.

As stated in DOE Order 5480.20:P.rogl'3l1'l

Senior Of!1cials,are responsible for assuming,

"line management responsibility,and '

accountability for reactor and noo·rellc.t~r

nUcle<lf facility personnel quali!icati~n

programs." The contractors' lack of effective

implementation of 00£ Orders concerning

lraining is indicative of the need for more

emph(\sis. direction and gUid~nce on training

by line management at DOE Headquarters

ilnd Field Offices. For example. the

Department has been slow 10 exteno the

underlying principles of 80ard

Recommend<ltion 9(}-1 to other defense

nuclear facHities. Recommendation 9(}-1

called for the development of an effeClive

Iraining program at Savann3h ~iver Site Kreactor. Jl is especially disturbing thal despilc

the successful application of ,

Recommendation 90-1 to K·reactor opd the

Rephlcemenl Tritium Fllcllily. ooe has not

improved training of corresponding tocholC<l1

personnel ot some other Savannah River Site

defense ol,ldeadaci1ities.

Primarily, ~u a ,result, of llssessments

conducted,by the Boord's stafr at the (-lMIoro
44562 Federal·Register.! VoL 57;.No.' .188' I. Monday•. September..28..1994.. /.'Nof;ices

Site. the Panlex Plant. the Sovennoh River

Site nOn-reactor facilities. the Oak Ridge Y12 Plant. und the Rocky Flots Plant. but ol~o

because of reviews conducted c1acwhlln: in

the defense nuclear facilities complex. the

Board bellevcs thcre is a need for DOE 10

take action to further strengthen training or

technical personnel ot defense nuclear

facilities. While the benefits of troining ore

felt In mony woys. the recommendations

below are to be seen lor their positive effects

on assuring public health and safety.

Therefore. in keeping with the Board's

statutory requirements and recognizing tile

priority DOE has placed on the lacilities

listed above. Ihe Board I~commends for these

sites that:

1. The Oepartmetlttoke timely action to

expand senior manogemenl's involvement in

implementing training programs at defense

nuclear facilities ond 10 enhance senior

management's cOmmunication of the

importance' of effectivll training and

qualification programs to atllevels within

relevant DOE and conlraclOr defense nuclear

facilitie~ organizations. particularly within

line organizations. With regard to operations.

maintenance. and lechnicalsupporl

personnel. the Department should determine

what personnel. funding. organizational. or

managerial strengthening actions are needed

to (a) elevote the priority and importance of

training Bnd qualification programs to assure

public heallh and safely: (b) communicate the

Importance of training and qualification from

the highest level of managcmentto oil

approp!iate Department' personnal: (e)

expand personnel and supervisor training

and qualificoHon guidance and increase

program resourCes to facilitate the rapid

review. approval. and implemenlalion of

training and qualifici:ltion programs: ond (oj

make other changes as are walTa'nted.

2. Where It is found to be necessary. the

Department strengthen organizational unils

responsil:>le for training and qualification et

the DOE Field Offices, DOE Area OrriCllS.

and contractor organizations responsible for

defense nuclear facilities at thcse sites.

especially to include the appropriate

technical qualifications of the personnel

assigned to defense nuclear activities. The

inFrastructure. responsibilities. and resources

of the training and quali fico lion progrtlJ'ns of

those organizations need 10 be ~trenglhenr.:d

to explldilC ImplemerWJtion of existing and

additional tr<:lining ond qualification

requirements issued by DOE.

3. The Deparlm~nl occelerllle efforts

intemal to DOE 10 impro\'C'lro:ning and

qualification prosrama of Opera lions.

Tntlinlenance. and technical sl,pport

personnel llt ddcnsc nucleor ftlcilities. I\n

(ntcgral parI of this errorl should be On

assessment of the rolcs .md errecliveness of

lechnical over$ighl groups to ensure lhllt

these grO\1p~' revip.ws. 01 nil orgnnizalions

and levels within thc dcr~nse nucleilr

facilities complex. appropriately recognize

the importance of truining und qu(\lifiClltion

to public health and sofely. The Deportment'a

program ehould also consider restrucluring

on-site technical oversight groups to ensure

thot training and qUllJificolioll are afforded

adequate ollen.ion llnd tenm members

poSOCSS the technicol expertise necessary to

effectIvely evaluate trahling and quollflcatlon

programs of operations. maintenance. ond

technical support personnel. ,

~_ The Department and lis contractors

establish and implement measures 10

improve lrainifl$ and quollfication programs

of operations. maintenance. and technlC61

BUpport personnel ot defen~e nuclce.r

facilities that embody the principles applied

at·the Sovonn3h River Site K-reoctor in

response to Board Recommendation 90-1.

Thesll measures. adjusted cOlumensurate

with the risk associaled ,with operating each

specific facility. should include consideretion

of elements such as:

a. lncollloration of appropriote applicable

guidance on training llnd qU3lifieotion

comparable witb trade. professional. and

industry standards for reactor and nonreactor nuclear facilities. While the BO:lrd

does not necess3rily endorse all guid:lnce

contained In these standards. II believes they

are important sources of Informallon which

can be productively used by OOE in

identifying improvements for DOE's

programs.

b. Identification of differences between

current requirery'cnls and applicable trarle.

professional. and industry standards and

implementotion of supplemental measures

necessary to compensat~ for the differences

Identified until tratning and qualification

programs at defense nuclear facilities achieve

I) level at least cqualto trade. professional

and industry standards.

c- Extens~on of the performance-based

training princip1es described in DOE Order

5480.111A to all defense nuclear facilities,

Parllcularly the requirements to; (1)

Determine the current level of knowledge of

:lppropriate personnel. supervisors. and

manageu of teclU'llcal aCljvilies by means of

written. oral. and practical examintltions

covering job specific process knowledge

requirements as well as fW1damentals

concepts ~ulred to perform a job in 0

manner that p'rotects the safe'ty of the worker

Ilnd the public: (2J delineate! the training

necessary to ensure thaI these personnel

och leve and maintain the qualifications 0 r

their respective pOGltlons: and (3) CVil!U31C

individuals' knowledge level and training

cUlTiculum to ensure thaI the training

progr:lm effectively prepares lhese persOIlncl

to safely operate. maintain. or support Ibe

fucility 10 which they are assigned.

d. Extension of\currcnt contin\ling lraining.

rclention (esting. and periodic requallfication

progrilnlS to rllq\lire these peroorlnelto

demonstrate continulld improvement wilh

increasing experience. '

c. Maintenance of readily oecessiblc.

ouditublc reCONS to identify required lril i'linC

UTld objectively verify training received by

these pe~onncl tlnd.~\lpervisoNl inclutling lhe

degree of lIuccess achieved.

We believe it is e~sentinl thaI the

Department and its c<lnt~octo,., occomplish

the above lor each DOE defense nucle3r

facility. The facilitillS specifically identified in

this Recommendation are thosc which lhe

l30ard understa~d$ 10 be emong those which

ho ve hlsh' prlori tY within ,the Departmllnt, a nd

on which the Doartl hes foeused Its altenlio!l,

John T. Coowoy,

Chairman.

Appendix-Transmittal LeUet' 10 tbo

Secretary of Energy

Delen~e Nuclear Faclllties Salely Boord

625 lndiono Avenue Nw. Suile 700,

Washington. DC 20004. (202)

SCplember 22, 1992.

'The Honorable )amee D. Walkins.

Secretory of Energy. Washington. DC20585

Dear Mr. SeCTetary: On September 22.1992,

the Defense Nuclear Facilities Sa fety Soard.

in accordance with 42 U.S.C. Z2il6a(5j,

unanimously approved Recommendallon 92-7

which'is enclosed for your consideratIon.

Recommendallon 92-7 dC<lls with Training

and Qualificetion. '

42 U.S,C. 2ZS6d(a) requires the Board. after

receipt by you. to promptly make thls

recommendation available to the public in

the Deparlmllnt of Energy's regional public

reading rooms. The Board believes the

recommendation contains no information

which Is classified or otherwise restricted. To

the extent this recommendation does not

Include information restricted by DOE under

the Atomic Energy Act of 1954. 42 U.S.c.

2161~. 6s amended. please arrange to have

this recommendation prompily placed on file

in your regional public reading rooms.

The Board will publish this

recommendation in the Federal Register.

Sincerely.

John T. Conway.

Chairman.

E:nclosure

IFR Doc. 92-2346$ flied 9-25-92: 0:45 am)

lllt..UNG COOE fXl20-Kl>-M