FIFTEENTH ANNUAL REPORT

TO CONGRESS

DEFENSE NUCLEAR FACILITIES

SAFETY BOARD

FEBRUARY 2005
John T Conway, Chairman

A.J . Eggenberger, Vice Chairman

Joseph F. Bader

John E. Mansfield

R. Bruce Matthews

To the Congress of the United States :

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

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

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

necessary, regarding public health and safety issues at Department of Energy (DOE) defense

nuclear facilities .

As required by statute, the Board's report summarizes activities during calendar year 2004,

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

health and safety problems .

John T. Conway

Chairman

DEFENSE NUCLEAR FACILITIESS

SAFETY BOARD

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

(202) 694-7000

February 28, 2005

A. J . Eggenberger

Vice-Chairman

E. Mansfield

R. Bruce Matthews

Member Member
iii

PREFACE

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

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

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

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

inform the public.

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

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

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

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

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

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

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

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

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

Secretary’s decision and reasoning must be published in the Federal Register and provided to

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

implementation of a recommendation is impracticable because of budgetary considerations. 

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

the Board must transmit its recommendation to the President and the Secretaries of Energy and

Defense.

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

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

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

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

issues raised by the Board has regularly resulted in prompt remedial actions by DOE.

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

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

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

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

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

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

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

EXECUTIVE SUMMARY

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

nuclear weapons operations conducted by the National Nuclear Security Administration

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

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

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

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

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

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

public, workers, and environment.

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

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

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

concentration:

! Nuclear Weapons Operations;

! Nuclear Materials Processing and Stabilization;

! Nuclear Facilities Design and Infrastructure; and

! Nuclear Safety Programs and Analysis.

NUCLEAR WEAPONS OPERATIONS

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

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

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

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

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

As a result of the Board’s efforts during 2004, DOE has taken actions to upgrade the

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

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

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

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

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

consequence of the Board’s work are as follows.

All weapons laboratories: 

! DOE established a requirement at each site office to track and ensure closure of nuclear

safety support requirements for weapon laboratories.
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Pantex Plant:

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

interim storage (Recommendation 99-1).

! The project to improve safety and restart nuclear explosive operations in Building 12-

64 now includes seismic enhancements to the facility as well as surge suppression

upgrades.

! Improvements were made in several key safety management programs including

tooling and Unreviewed Safety Questions.

! DOE completed disassembly of the W78 nuclear weapon using the Seamless Safety

process, and is preparing to dismantle other weapons by the same method. 

Y-12 National Security Complex:

! Systems in the Oxide Conversion Facility were enhanced by new safety interlocks,

enhanced seismic reinforcement, and modifications to improve alarm management.

! DOE initiated a project to upgrade the Fire Suppression System in the B-1 Wing of

Building 9212. 

! DOE standardized and reduced the different types of containers used for material

storage, thus simplifying requirements for operators and allowing better long-term

management of nuclear material in storage. 

! The knowledge preservation process was restarted to capture safety-related information

from retiring experts; this effort has already yielded important anecdotal information

for future weapon disassembly activity.

Los Alamos National Laboratory:

! Operations and controls at Technical Area 18 have been improved.

Lawrence Livermore National Laboratory:

! DOE agreed to maintain the ventilation system in the Plutonium Facility as a safety

class system to prevent releases of radioactive material in an accident.

! DOE improved the packaging and storage conditions for programmatic nuclear

materials.

! DOE reviewed the condition and status of vital safety systems.
vii

Nevada Test Site:

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

dispose of a damaged nuclear weapon.

! DOE reclassified as safety class the critical safety equipment used in G-tunnel for the

handling of damaged nuclear weapons and improvised nuclear devices.

Sandia National Laboratories:

! The laboratory is strengthening the safety bases for nuclear operations.

NUCLEAR MATERIALS PROCESSING AND STABILIZATION

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

handling of hazardous nuclear materials and deactivation and decommissioning of unused

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

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

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

decommissioning of defense nuclear facilities.

As a result of the Board’s efforts during 2004, DOE has taken actions to reduce or

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

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

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

bases for new and ongoing activities. 

Specific examples of safety improvements in materials processing and stabilization made

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

Hanford Site:

! DOE completed the stabilization and packaging of several tons of plutonium metal and

oxide to meet the long-term safe storage standard.

! Nearly all spent fuel has been removed from the K-Basins and packaged for eventual

disposal; other safety improvements included enhanced conduct of operations for fuel

container handling and hoisting and rigging operations.

! DOE reconsidered the safety and feasibility of a plan to employ divers in the highlycontaminated K-East Basin; further testing and evaluation will be conducted before

proceeding with this plan.

! DOE conducted an Integrated Safety Management review at the tank farms following a

series of safety incidents.
viii

! The nuclear licensing strategy for a new project to treat transuranic mixed waste was

reevaluated, and a formal safety analysis was started.

! In response to safety issues identified by the Board, DOE conducted tests to identify

safe parameters for chemical decontamination of the Plutonium Finishing Plant at

Hanford.

Waste Isolation Pilot Plant:

! Several new controls were added to the safety basis for mobile transuranic waste

characterization units; an Operational Readiness Review will be conducted prior to 

operation.

Savannah River Site:

! Conversion of neptunium solutions to a stable oxide form commenced.

! Funding for the Salt Waste Processing Facility project was restored, and a program to

accelerate waste stabilization and risk reduction is being pursued.

! Operations involving potentially explosive drums of transuranic waste were halted, and

an investigation into this safety issue was started.

! DOE corrected deficiencies in the site’s process to identify hazards and develop safety

controls for decommissioning work.

Rocky Flats Environmental Technology Site:

! DOE took action to correct significant deficiencies in work planning, analysis and

control of hazards, and fire response for decommissioning work.

Los Alamos National Laboratory:

! A comprehensive nuclear materials packaging and storage plan was developed that will

reduce risk by accelerating the schedule for stabilization, packaging, and improved

storage of nuclear materials.

Lawrence Livermore National Laboratory:

! In March 2004, DOE completed the stabilization and packing of material covered by

Recommendation 94-1. 

NUCLEAR FACILITIES DESIGN AND INFRASTRUCTURE

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

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

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

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

under the Board’s jurisdiction. In addition to an increasing number of new projects, DOE has

undertaken its largest project, the Waste Treatment Plant at the Hanford Site, using a “closecoupled” process in which design and construction occur simultaneously. As the design of each

system or piece of equipment design is completed, construction commences. 

Though this approach can be used successfully with suitable management safeguards,

DOE’s use of it at the Waste Treatment Plant has led to a series of quality problems, all during

the initial stages of construction: (1) improper placement of structural concrete; (2) failure to

maintain control over concrete mix materials; (3) improper rebar installation; and (4) failure to

provide proper procurement specifications to fabricators of safety related equipment.

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

consequence of the Board’s work are as follows.

Hanford Site:

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

corrected. For example, DOE (1) improved the quality of safety basis calculations,

(2) strengthened the electrical design for managing emergency loads, (3) made more

conservative the design basis for mitigation systems used to prevent hydrogen

deflagrations and detonations, and (4) removed and repaired improperly placed

concrete.

! DOE developed a better understanding of the Hanford site seismic ground motion. 

This resulted in an increase of more than 30 percent for the projected seismic loads on

the Waste Treatment Plant. This change will require complete re-evaluation of the

design. 

Pantex Plant:

! DOE corrected the faulty design of the roof of Building 12-64; installation of the new

design is underway.

NUCLEAR SAFETY PROGRAMS AND ANALYSIS

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

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

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

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

issues affecting a variety of defense nuclear facilities.

As a result of the Board’s efforts during 2004, DOE has taken actions to strengthen the

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

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

programs such as Integrated Safety Management. 
x

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

consequence of the Board’s work are as follows.

! The Board prevented DOE from improperly downgrading the existing safety class

ventilation systems at the Lawrence Livermore National Laboratory, and later in the

year, issued Recommendation 2004-2 specifying minimum safety requirements for

such systems at all defense nuclear facilities.

! DOE is re-evaluating its fundamental policies for oversight of complex, high-hazard

nuclear operations and is restructuring line management to more closely align with the

attributes of a highly reliable organization. (Recommendation 2004-1)

! DOE issued a new standard entitled Specific Administrative Controls and developed a

training program for site personnel to ensure the proper application of administrative

controls. (Recommendation 2002-3)

! DOE issued guidance governing the safe use of “toolbox” codes, which are standard

computer software packages meeting minimum quality assurance requirements for

safety analysis. (Recommendation 2002-1)

! DOE revised and strengthened its Federal Technical Capability Manual, providing a

sound basis for the more uniform implementation of safety system oversight throughout

the complex. (Recommendation 2000-2)

OUTSTANDING SAFETY PROBLEMS OF DEFENSE NUCLEAR FACILITIES

Safe Retrieval, Handling, and Stabilization of Nuclear Materials

The Board continues to urge DOE to expedite the stabilization of materials in deteriorating

storage conditions. Of greatest concern are the remaining sludges in the K-Basins at Hanford,

high-level waste in degrading underground tanks at Hanford and Savannah River Site, and large

quantities of nuclear materials at Los Alamos National Laboratory. New hazards are emerging

as DOE increases its efforts to exhume and treat transuranic wastes that have been buried for as

long as 40 years. 

DOE continues to grapple with technological and programmatic difficulties. At the

K-Basins Closure Project at Hanford, the Board uncovered programmatic breakdowns in

engineering and project management that have substantially delayed efforts to retrieve sludge

from the basins. The Board intends to maintain a high priority for the oversight of this effort.

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

Savannah River, Hanford and the Idaho National Engineering and Environmental Laboratory is

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

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

treatment, and disposal of high-level waste.

Significant quantities of nuclear materials remain unstabilized at Los Alamos. DOE did

submit an acceptable implementation plan to meet the requirements of Recommendations 94-1

and 2000-1. However, a recent site-wide shutdown due to safety and security concerns has

placed the new schedule for stabilization and risk reduction in jeopardy.

As DOE expands its efforts to retrieve and package transuranic wastes at many sites,

particular caution will have to be taken to protect the public and workers, as this waste stream

includes very old and sometimes poorly characterized waste containers. Although much

progress has been made in the retrieval and disposal of well-characterized and low-activity

transuranic waste, DOE must develop effective safety controls for the retrieval, handling, and

repackaging of high-activity transuranic waste that still resides at many sites in the DOE

complex.

Vigilance During Deactivation and Decommissioning 

DOE has accelerated deactivation and decommissioning (D&D) work at a number of

cleanup sites. While more rapid cleanup is a laudable goal, it should not be accomplished at the

expense of safety. The Board has observed occasional breakdowns in safety management during

the difficult transition from production operations to D&D. Production operations typically

involve established operating procedures carried out by experienced workers, whereas D&D

operations are often characterized by constantly changing tasks, evolving facility conditions, and

operators new to D&D work. These difficulties are aggravated when DOE relaxes safety

vigilance after bulk quantities of radioactive materials have been removed from the facility. 

Significant quantities of hazardous materials may remain as residues in operating equipment,

process lines, and storage tanks. The temptation to view cleanup work at this stage as routine

must be resisted.

Numerous incidents have occurred during D&D efforts at the Rocky Flats Environmental

Technology Site and at Savannah River. As a result of the Board’s investigations, DOE has

taken effective corrective actions at these two sites. The startup of D&D activities at Hanford’s

Plutonium Finishing Plant was similarly accompanied by faulty procedures, weak training, and

inadequate implementation of safety requirements. DOE was forced to halt the work.

The Board will continue to evaluate the safety of D&D operations at DOE’s defense

nuclear facilities, emphasizing the necessity of effective implementation of Integrated Safety

Management throughout the life cycle of a facility. The perception that D&D work is a lowerhazard activity permitting a more relaxed attitude towards safety is fundamentally erroneous.

Technical Capacity and Highly Reliable Organizations

Information developed by the Columbia Accident Investigation Board with respect to the

loss of the space shuttle, and by the U. S. Nuclear Regulatory Commission in connection with

the “near miss” at the Davis-Besse nuclear power plant, suggests that a weakening of federal

oversight of contractor operations can have dire consequences. Unfortunately, lessening of
iii

federal oversight has been an objective of DOE’s senior management. To examine the hazards

of this course of action more fully, the Board completed a series of eight public meetings

between September 2003 and March 2004. During the public meetings, the Board received

testimony from representatives of the U.S. Nuclear Regulatory Commission, the Naval Reactors

Program, the Columbia Accident Investigation Board, and DOE managers.

Based on its review in this area, the Board concluded that DOE’s reduced-oversight

initiatives could increase the possibility of a nuclear accident in the defense nuclear complex. In

particular, the Board saw evidence of: (1) increased emphasis on productivity at the expense of

safety; (2) loss of technical competence in DOE upper management; (3) insufficient safety

research; and (4) inadequate central oversight of safety. To reset DOE’s course of action, the

Board issued Recommendation 2004-1, Oversight of Complex, High-Hazard Nuclear

Operations. The Recommendation is supported by a technical report entitled Safety

Management of Complex, High-Hazard Organizations. The Secretary of Energy has accepted

this Recommendation. Implementation of this recommendation presupposes that DOE will,

under the Board’s oversight, continue to strengthen its technical competency, support the facility

representative program, and enforce safety requirements.

Adequacy of Design for New Defense Nuclear Facilities

One of the Board’s statutory responsibilities is to ensure that adequate health and safety

requirements are embedded in the design of new defense nuclear facilities and are properly

implemented during construction. Moreover, needed safety controls must be identified early in

the design phase to avoid unnecessary cost and delay during construction. Integrated Safety

Management (ISM) provides the framework for the identification and application of safety

requirements in design and construction. The Board expects that when DOE undertakes to build

a new defense nuclear facility, which may need to operate for as much as 50 years, ISM

principles and core functions will be used in all phases of the project.

DOE has underway design and construction projects with a projected total cost in excess of 

$13 billion. From the Board’s perspective, however, DOE is continuing to struggle with

establishing a conservative design from the beginning of the project. DOE is considering or

planning to make use of design/build techniques for large-scale facilities, including some with

incompletely-designed processes. This approach entails considerable risk when combined with

DOE’s shortage of competent personnel to manage such projects. The Board continues to

expend extensive resources to ensure that designs for defense nuclear facilities incorporate

multiple layers of safety controls commensurate with the hazards presented. 

Reliable Operation of Safety Systems

The Board continues a strong interest in ensuring that DOE properly maintains safety

systems at defense nuclear facilities. Many defense nuclear facilities were constructed decades 

ago. It is thus extremely important that protective features be maintained as serviceable and

effective. For new facilities, on the other hand, the Board focuses its attention on ensuring that

safety systems are correctly identified, designed, and constructed.
iv

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

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

assurance, prevention of counterfeit parts, configuration management, training, and conduct of

operations. DOE is working to make improvements in many of these areas in response to related 

recommendations from the Board such as 2000-2, 2002-1, 2004-1, and 2004-2. However, as

DOE continues to extend the life of aging facilities, and budgets tighten, there is constant

pressure to reduce the number of safety systems and to provide less effective maintenance. The

Board will continue to stress to DOE the importance of ensuring the long-term reliability of vital

safety systems and the infrastructure needed to maintain them. 
xv

TABLE OF CONTENTS

Section Page 

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

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

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

1.3 Strategic Plan............................................................................................... 1-2 

1.4 Human Capital Management ...................................................................... 1-3 

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

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

 

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

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

2.2 Safe Conduct of Stockpile Stewardship ...................................................... 2-4

2.2.1 Recommendation 2002-2 ................................................................. 2-4

2.2.2 Los Alamos National Laboratory ..................................................... 2-4

2.2.3 Lawrence Livermore National Laboratory ....................................... 2-5

2.2.4 Nevada Test Site .............................................................................. 2-6

2.2.5 Sandia National Laboratories ........................................................... 2-8

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

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

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

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

3.1.3 Uranium ........................................................................................... 3-2

3.1.4 Neptunium ....................................................................................... 3-3

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

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

3.2.2 Idaho National Engineering and Environmental Laboratory ........... 3-4

3.3 Waste Management ...................................................................................... 3-4

3.3.1 High-Level Waste ............................................................................ 3-4

3.3.2 Low-Level Waste and Transuranic Waste ....................................... 3-6
xvi

TABLE OF CONTENTS (Continued)

Section Page 

3.4 Facility Deactivation and Decommissioning ............................................... 3-7

3.4.1 Overview .......................................................................................... 3-7

3.4.2 Fernald Closure Project .................................................................... 3-8

3.4.3 Miamisburg Closure Project ............................................................ 3-8

3.4.4 Rocky Flats Environmental Technology Site ................................... 3-9

3.4.5 Savannah River Site ......................................................................... 3-9

3.4.6 Hanford Plutonium Finishing Plant ................................................. 3-9

3.4.7 Hanford K-East Basin ...................................................................... 3-10

3.4.8 Lawrence Livermore National Laboratory ...................................... 3-10

3.4.9 Idaho National Engineering and Environmental Laboratory ........... 3-10

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

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

4.1.1 Hanford ............................................................................................ 4-1

4.1.2 Savannah River................................................................................. 4-4

4.1.3 Y-12 National Security Complex..................................................... 4-6

4.1.4 Los Alamos National Laboratory..................................................... 4-6

4.1.5 Pantex .............................................................................................. 4-6

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

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

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

5.1.2 Recommendation 2004-1 ................................................................. 5-1

5.2 Integrated Safety Management .................................................................... 5-2

5.2.1 Overview ......................................................................................... 5-2

5.2.2 Ongoing Assessments ..................................................................... 5-3

5.2.3 Vital Safety Systems ....................................................................... 5-3

5.2.4 Activity Level Work Planning ........................................................ 5-3

5.3 Health and Safety Directives ....................................................................... 5-4

5.3.1 Improvement of Directives ............................................................. 5-4

5.3.2 Development of New Directives .................................................... 5-5

5.3.3 Worker Safety Rulemaking ............................................................ 5-5

5.3.4 Scope of the Directives System ..................................................... 5-6
xvii

TABLE OF CONTENTS (Conclusion)

Section Page 

5.4 Safety Programs ........................................................................................... 5-6

5.4.1 Development and Implementation of Safety Controls .................... 5-6

5.4.2 Administrative Controls.................................................................... 5-6

5.4.3 Active Confinement Ventilation ...................................................... 5-7

5.4.4 Quality Assurance ............................................................................ 5-7

5.4.5 Software Quality Assurance.............................................................. 5-8

5.4.6 Hoisting and Rigging ....................................................................... 5-8

5.4.7 Criticality Safety .............................................................................. 5-8

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

5.5 Technical Competence ................................................................................ 5-9

5.5.1 Training and Qualification of DOE and Contractor Personnel ........ 5-9 

5.5.2 NNSA Facility Representatives ....................................................... 5-9

6. PUBLIC OUTREACH .......................................................................................... 6-1

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

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

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

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

6.5 Site Representatives Activities .................................................................... 6-2

APPENDICES

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

B. RECOMMENDATIONS CITED............................................................................ B-1

C. REPORTING REQUIREMENTS........................................................................... C-1

D. CORRESPONDENCE............................................................................................ D-1

E. ADMINISTRATIVE ACTIVITIES......................................................................... E-1

F. ACRONYMS AND ABBREVIATIONS................................................................ F-1
1-1

1. INTRODUCTION

1.1 BACKGROUND

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

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

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

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

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

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

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

the public, workers, and environment. 

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

oversight of DOE’s defense nuclear weapons facilities and operations. For that reason, Members

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

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

safety.

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

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

Complex in Tennessee, Savannah River Site in South Carolina, Hanford Reservation in

Washington State, and Lawrence Livermore National Laboratory in California. The site offices

provide the Board with a continuous presence at these locations. At other locations, the Board

maintains safety oversight by means of regular onsite reviews by members of its technical staff.

During the Board’s 15 years of operation, its priorities have evolved with changes in the

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

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

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

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

embodied in this plan. 

This Annual Report summarizes the Board’s work during calendar year 2004. Sections 2,

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

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

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

interactions with the public. Appendices A through F provide additional material: the Federal

Register notices of the Board’s 2004 recommendations (Appendix A), a table of all

recommendations cited in this report (Appendix B), a list of reports requested from DOE

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

human resource activities (Appendix E), and a table of acronyms and abbreviations

(Appendix F).
1-2

1.2 OVERSIGHT STRATEGY

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

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

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

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

principles:

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

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

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

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

actions based on the Board’s insights.

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

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

of nuclear and hazardous material at hand, and hazard of the operations involved.

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

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

management of nuclear activities. 

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

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

line management and workers to safe work planning and performance.

! Clear Expectations - Effective safety management demands that safety expectations

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

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

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

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

ensure a smooth transition from deactivation to environmental regulation.

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

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

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

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

operations, it has issued 47 formal recommendations, comprising 218 individual subrecommendations. In that same period of time, the Board has issued 146 reporting requirement

letters. In 2004 alone, the Board issued 31 such letters to DOE. 

1.3 STRATEGIC PLAN 

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

its statute with the requirements of the Government Performance and Results Act. The Board’s
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Strategic Plan identifies the serious hazards of handling nuclear weapons and weapon materials,

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

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

some stored in an unstable state.

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

safety.

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

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

criticality events.

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

lightning.

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

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

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

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

of high explosives in proximity to radioactive material. 

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

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

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

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

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

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

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

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

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

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

the public.

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

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

workers, are developed and implemented by DOE.

1.4 HUMAN CAPITAL MANAGEMENT

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

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

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

members accordingly. The pay banding and pay-for-performance programs developed and
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implemented by the Board have proven to be effective in hiring technical talent, holding

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

job. This is evidenced by the low turnover rate, which was about two percent in 2004. 

In 2004, the Board operated at 65 percent of its statutory employment ceiling of 150 Full

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

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

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

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

a competitive employment market.

During the year 2004, the Board continued to require its engineers and scientists to

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

challenges. Ninety-three percent of the senior technical staff holds advanced degrees, 23

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

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

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

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

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

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

scientific and technical talent to federal service.
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2. NUCLEAR WEAPONS OPERATIONS

2.1 SAFE CONDUCT OF STOCKPILE MANAGEMENT

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

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

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

2.1.1 Pantex Plant

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

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

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

weapons. In 2004, the Board sought health and safety improvements in weapons operations,

tooling program implementation, facility safety systems, and electrical and lightning protection

systems.

Nuclear Explosive Processes. The Board has encouraged DOE to accelerate safety

improvements to nuclear explosive operations at the Pantex Plant (Recommendation 98-2). In

FY 2004, DOE completed the start-up of an improved process for nuclear explosive operations

on the W78 program. DOE has also continued development of enhanced processes for the B83,

W87, W88, and B61 weapon programs. The prompt completion of re-engineering of the nuclear

explosive processes for the remaining weapon programs will result in substantial safety

improvements.

Safety Bases. The implementation plan for Recommendation 98-2 includes a

commitment to improve safety bases at the Pantex Plant and to implement improved controls

from the safety basis documents, particularly for on-site transportation. Pantex continues to

enhance and strengthen its controls for nuclear explosive operations. 

Quality Assurance for Tooling. In a letter to the National Nuclear Security

Administration (NNSA) dated June 18, 2004, the Board expressed serious concern regarding the

program to design, fabricate, and evaluate tools used during nuclear explosive operations. The

Board noted that an effective quality assurance program is essential to safe design, fabrication,

procurement, inspection, and maintenance of special tooling, and requested that NNSA conduct a

comprehensive review of the tooling program at Pantex. NNSA undertook the review but was

forced to suspend it in November 2004 due to the number and variety of adverse findings. In a

December 15, 2004 letter to NNSA, the Board pointed out that a formal, causal analysis of

deficiencies in the tooling program had not been performed prior to implementing corrective

actions. The Board encouraged the Pantex Site Office and NNSA headquarters to assume some

leadership in restoring the tooling program. The Board requested, and the Pantex Site Office

provided, a report that described the impact of tooling program deficiencies on operational

safety, the compensatory measures being taken while long-term corrections are being made, and

the long-term path forward for improving the tooling program at Pantex. 
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Safe Storage of Nuclear Material. In response to the Board’s Recommendation 99-1, 

DOE has repackaged more than 10,000 pits into robust containers suitable for interim storage. 

The associated container surveillance program has been rejuvenated, and the entire surveillance

backlog was worked off during 2004.

Safety of Dismantlement Operations. In a January 20, 2004 letter, the Board identified

a number of deficiencies that led to a failed dismantlement of a damaged device. As a result of

this incident and the Board’s letter, Pantex has made improvements in training production

technicians, conducting unreviewed safety question evaluations, performing nuclear explosive

safety evaluations, and requiring involvement of process engineers in certain types of operations.

B53 Dismantlement Operations. The Board identified a number of flaws in DOE’s

plans to dismantle the B53 weapon system. As a result, DOE has revised its plans and goals for

the B53 system and has committed to pursue a more disciplined strategy that conforms to

modern safety standards for nuclear explosives activities.

Leak Paths in Cells. As a result of the Board’s inquiries, Pantex has taken additional

actions to reduce the potential for off-site consequences due to an explosive release of

plutonium. Pantex has initiated weld repairs to door gaps that were previously sealed with nonconforming caulking. Other repairs are being investigated, and the use of a knife-edge reduction

factor in the calculated off-site dose is being revisited.

Electrical and Lightning Protection. DOE made progress in correcting deficiencies in

electrical and lightning protection systems. Pantex has committed to installing safety

improvements (surge suppression and cable replacement) suggested by the Board in Buildings

12-44 and 12-64.

2.1.2 Y-12 National Security Complex 

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

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

evaluation, and storage of certain components of nuclear weapons. Production activities include

manufacture or re-manufacture of unique nuclear weapon components. The Board’s most recent

efforts to improve safety at Y-12 concentrated on processing highly enriched uranium, criticality

safety, nuclear material storage, and fire protection.

Fire Protection. In 2002, the Board challenged the adequacy of fire protection in the B1 wing of Building 9212, a wet chemistry process area lacking a fixed fire suppression system. 

Throughout 2004, the Board pressed for progress on the issue. In July, DOE decided to install a

fixed fire suppression system on the first floor, a new shutdown interlock for the process system,

fire-protective coatings on certain structural supports, and modifications to divert combustible

liquids to the first floor. DOE’s contractor began design and planning for the upgrades, which

should be completed by late FY 2005. 

Oxide Conversion Facility. In a December 2003 letter, the Board identified safety

issues attending the proposed startup of the Oxide Conversion Facility in Building 9212. These
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issues included missing weld radiographs, lack of proper designation of certain safety

equipment, failure to analyze a credible criticality scenario, and inadequate protection of worker

safety. DOE re-radiographed significant welds, upgraded the functional classification of safety

system equipment, added seismic reinforcement, added a safety interlock to address the

criticality concerns, and addressed the worker safety concerns. During subsequent reviews, the

Board brought to DOE’s attention concerns regarding error handling for a programmable logic

controller that operates shutdown systems important to safety. In response, DOE changed the

control system to ensure that major logic controller errors were brought to the immediate

attention of process operators. 

Conduct of Operations. The Board has repeatedly stressed the need for formality of

operations at Y-12, including strict adherence to procedures, reporting events and deficiencies,

control of work, and dedicated oversight by management. By late 2003, a project execution plan

had been developed to improve operations. Efforts to tighten adherence to procedures and to

ensure proper reporting of events and deficiencies resulted in some improvements. The site also

enacted a management observation program and chartered an independent group of oversight

personnel to provide increased on-the-floor observations of nuclear operations and more intense

mentoring of operations personnel.

Independent Validation of Safety Basis Controls. In July 2003, the Board highlighted

the lack of a process to ensure implementation of new or revised safety basis controls. In

response, DOE instituted independent validation protocols. Initial reviews conducted in 2004

revealed the need for several enhancements in the protocols and in personnel training. 

Adequacy of Safety System Design. In October 2003, the Board questioned whether

several fire suppression systems in Building 9212 met current standards. In response, DOE

evaluated the differences between the code of record and current fire safety codes and

documented the basis for acceptance of the systems. The Board is also aware that the Y-12

contractor led an effort under the auspices of the Energy Facility Contractor Group to develop 

guidance for the evaluation of designs. In August 2004, this group submitted a proposed

guidance document to DOE headquarters.

Work Planning for Infrequent, Hazardous Operations. The Board identified

weaknesses in the hazard analysis for a drum venting operation that led to inadequate definition

of safety controls. This incident suggested that work planning for similar infrequent but

hazardous operations might be deficient. In response, protocols were developed to ensure higher

levels of review and approval of work planning for such evolutions. A successful trial

application is being expanded for use by all major nuclear facilities at Y-12.

Standardization of Fissile Material Container Designs. In 2002, the Board directed

DOE’s attention to the need to simplify and standardize storage techniques for fissile materials. 

In September 2004, DOE developed a project execution plan that should result in a high level of

standardization of enriched uranium containers. 

Access to Nuclear Weapons Expertise. In an October 2004 letter to NNSA, the Board

identified a lack of support for commitments made in response to Recommendation 93-6. These
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commitments included a program of personnel interviews and archiving of documents. To

remedy this situation, DOE restarted the Knowledge Preservation Program to identify key

personnel, conduct interviews, and archive the information obtained. 

2.2 SAFE CONDUCT OF STOCKPILE STEWARDSHIP 

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

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

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

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

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

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

2.2.1 Recommendation 2002-2

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

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

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

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

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

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

critical information is then transmitted for use throughout the complex. In 2002, the Board

issued Recommendation 2002-2 with these goals in mind. DOE now requires that each site

office track and ensure closure of safety issues regarding nuclear weapons. 

2.2.2 Los Alamos National Laboratory 

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

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

2004, the Board focused its attention on conduct of engineering, work planning, safety bases,

active ventilation systems, integrating safety into design, the Technical Area 18 Pajarito

Laboratory, and the suspension and resumption of operations.

Conduct of Engineering. The Board, in a letter dated January 27, 2004, suggested that 

complex, high-hazard research, development, demonstration and testing would benefit from: 

(1) a structured application of engineering standards and practices; (2) a formal conceptual

design phase, similar to that for large facility projects; and (3) design reviews following

conceptual and final design. In response, DOE has included in the laboratory’s Operational

Efficiency project measures that should accomplish these goals. In the same letter, the Board

asked the laboratory for an outline of how DOE Order 420.1A, Facility Safety, will be

implemented. The Board has not yet received a reply to this part of the letter.

Safety Basis. In a letter dated May 27, 2004, the Board noted that NNSA has focused

mainly on the safety basis for the facility with the highest predicted accident consequence and

paid much less attention to other facilities and activities. For example, the safety basis for the 

Plutonium Facility was submitted to DOE in April 2002 but is still not approved. Although the
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full disposition of the proposed safety basis for the Plutonium Facility remains to be completed,

DOE has made some progress in reviewing safety bases for other laboratory facilities and

activities.

Ventilation. The Board’s review of the Documented Safety Analysis for the Plutonium

Facility and for the proposed Chemistry and Metallurgy Research Replacement facility revealed

that DOE had made analytical assumptions that were not adequately conservative with respect to

the value of active ventilation during an accident. Because this was the latest of a series of such

missteps by DOE at a number of sites, the Board issued Recommendation 2004-2 to achieve a

broadly-applicable solution.

Operations in Technical Area 18. In a letter dated May 21, 2004, the Board observed

that the unmitigated consequences for worst-case nuclear accidents at this facility are quite high

and are fundamentally different from worst-case scenarios at other laboratory facilities. In

Area 18, a sequence of operator errors could initiate an uncontrolled reactivity excursion leading

to melting and partial vaporization of a plutonium core or sample. DOE relied on correct and

rapid operator actions to avert this accident, but this approach is now being re-examined. 

Suspension and Resumption of Operations. All nonessential activities at the

laboratory were suspended on July 16, 2004, as a result of security and safety failures. 

Following an on-site visit, the Board (in a letter dated September 13) emphasized the need to

closely monitor and appropriately adjust plant conditions to maintain safe and stable

configuration during the stand-down. Most activities at the laboratory have now been resumed

safely. To implement long-term corrective actions identified during the suspension, the

laboratory has developed the Operational Efficiency project.

2.2.3 Lawrence Livermore National Laboratory 

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

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

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

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

conducted in the Superblock complex, which includes the Building 332 Plutonium Facility and

the Tritium Facility. 

The Board significantly intensified oversight of this laboratory in 2004. Members of the

Board conducted three site visits inquiring into integrated safety management, the safety basis

and vital safety systems at the Superblock facility, deactivation of the Heavy Element Facility

(Building 251), and packaging and storage of nuclear materials. The Board also decided to

station a site representative at the laboratory. 

Plutonium Facility Safety Basis. In an April 2004 letter, the Board outlined

fundamental flaws in DOE’s approach to safety basis development at this facility. In particular,

the Board was concerned that DOE had relied on questionable calculations to eliminate the need

for a safety-class ventilation system. In response, DOE commissioned an independent analysis 
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of these calculations and received a report agreeing with the Board. DOE then directed the

laboratory to maintain the Plutonium Facility’s ventilation system as a safety-class system.

Configuration Management. In a November 2004 letter to the Secretary of Energy, the

Board expressed concern over the apparent lack of configuration management of vital safety

systems at the laboratory. DOE responded on January 4, 2005, agreeing that prompt action

needed to be taken to review the configuration and condition of all vital safety systems in the

plutonium facility. DOE is also working to confirm the operability of vital safety systems in all

other defense nuclear facilities at the laboratory.

Deactivation of Building 251. The deactivation of Building 251 involves the removal of

nearly 300 items of radioactive material, some posing a significant risk of radiation exposure to

workers and potential for release of contamination in the building. The project is being carried

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

basis upgrades. A March 11, 2002, letter from the Board discussed the need for comprehensive

planning to support the deactivation effort. By the end of 2004, the laboratory reduced the

nuclear material inventory in the facility by more than 80 percent.

Recommendation 94-1. In March 2004, Lawrence Livermore completed the

stabilization and packaging of material covered by Recommendation 94-1. The plutoniumcontaining materials are now stored in strong, welded containers that meet DOE’s plutonium

storage standard. The laboratory has identified additional material no longer needed for program

activities and continues to characterize, stabilize, and package the inactive material using the

same methods and equipment used in the Recommendation 94-1 campaign.

Nuclear Material Packaging and Storage. During a review by the Board’s staff in

November 2004, it became apparent that nuclear materials not covered by either

Recommendation 94-1 or the inactive materials program are not stored in suitable containers. 

DOE has now directed the laboratory to evaluate this problem and make improvements as

needed to ensure safe storage of these materials.

2.2.4 Nevada Test Site 

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

Vegas. Stockpile activities at the Test Site include test readiness preparations, disposition of

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

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

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

Board seeks to ensure that if testing is resumed, it would be done safely. During 2004, the Board

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

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

operations.

Device Assembly Facility. During 2004, the Board reviewed the implementation of the

recently-approved safety basis, relocation of Technical Area 18 activities from Los Alamos to

the Device Assembly Facility, start-up of a glovebox and downdraft table, and the training and

qualification program. In a November 2004 letter, the Board noted that NNSA plans for a
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significant increase in the scope and operational tempo of activities at the Device Assembly

Facility. Current planning indicated that a number of these activities may be conducted

simultaneously, an operational situation not considered in the design of the facility. In addition,

the Board’s staff had observed significant deficiencies in the facility’s safety management

programs and the physical infrastructure. Given these facts, the Board advised DOE to place

increased emphasis on safety management programs at the Device Assembly Facility.

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

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

qualified to plan and conduct such tests was shrinking, there was no formal safety basis, and

there was no rigorous process to assess safety. NNSA implemented a plan to prepare a safety

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

develop a readiness review process commensurate with nuclear explosive operations. In 2004,

the Board observed that NNSA had made improvements in personnel, facilities, equipment,

training, and safety basis documents.

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

safely dispose of a damaged or improvised nuclear weapon. During 2004, the Board reviewed

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

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

scope of disposition activities. The Board provided feedback on the developing safety basis and

pointed out that the conduct and formality of operations still needed significant improvement for

nuclear explosive operations. 

Subcritical Experiments. The Board reviewed DOE’s assessments and readiness for

subcritical experiments and found inadequate nuclear safety management programs, inadequate

mechanisms for verifying readiness of subcritical experiments and test readiness, and inadequate

commitment to improving the readiness review process for subcritical experiments and nuclear

weapons testing. As a result, NNSA’s Nevada Site Office improved the safety basis documents,

developed a process to resolve Unreviewed Safety Questions, and committed to improving the

implementation of controls and conduct of readiness reviews. 

Safety Basis Reviews. The Board reviewed several of the safety bases for nuclear

facilities and activities, including the Device Assembly Facility, U1a Complex and Subcritical

Experiments, Radioactive Waste Management Complex, G-tunnel, and On-site Transportation. 

Although the safety bases are substantially improving, the Board identified deficiencies that

should be corrected before commencing operations

Lightning Protection. In 2003, the Board advised DOE that improvements in lightning

protection were needed at the Test Site. The Board’s review in 2004 found that lightning

protection controls and features were now included in the safety basis of several nuclear

facilities.

 

Hoisting and Rigging. In a letter dated January 21, 2004, the Board advised DOE of 

deficiencies in hoisting and rigging, maintenance, and practices for nuclear explosive operations. 

As a result, DOE has designated as safety-class the critical safety equipment in G-tunnel used for
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handling damaged nuclear weapons and improvised nuclear devices. Additional measures

include redesigned controls for handling unvented drums of transuranic waste and a revitalized

maintenance program for hoisting and lifting equipment. 

Work Planning and Control. The Board reviewed integrated safety management,

quality assurance, work planning, and worker protection for all NNSA organizations working at

the Test Site. The Board’s review revealed significant deficiencies in the integrated safety

management and quality assurance programs of Los Alamos and Lawrence Livermore National

Laboratories. In response to a letter to NNSA from the Board in May of 2004, the Nevada Site

Office has performed an assessment of integrated safety management, focusing on activity-level

work planning and control. In 2005, the Board will ensure that suitable corrective actions are

taken.

2.2.5 Sandia National Laboratories

Sandia National Laboratories are located primarily in Albuquerque, New Mexico. Major

defense nuclear facilities at Sandia, most of which are located at Technical Area V at the New

Mexico site, include the Annular Core Research Reactor, Hot Cell Facility, Gamma Irradiation

Facility, and Pulsed Reactor Facility.

 In September 2004, the Board issued a letter questioning the adequacy of safety bases at

Sandia. A subsequent self assessment performed by the Sandia Site Office revealed that the site

did not have a currently approved safety basis for onsite transportation of hazard category 3 or

higher materials. As an interim measure, the site office issued an authorization policy and

imposed compensatory controls while an adequate safety basis could be developed. In addition,

the site office commissioned an independent review of the safety bases for nuclear facilities, to

be conducted in December 2004.
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3. NUCLEAR MATERIALS PROCESSING AND STABILIZATION

3.1 STABILIZATION AND STORAGE OF REMNANT MATERIALS

3.1.1 Complex-Wide Program

Inactive Actinide Materials. The Board evaluated NNSA plans for managing nonprogrammatic actinide materials stored at several sites throughout the defense nuclear complex. 

The Board found that NNSA personnel have begun to define and execute adequately a strategy

to characterize materials for storage or disposition, to identify which materials fall under this

effort, and to analyze and upgrade, where appropriate, material packaging and storage facility

conditions. The Board continues to evaluate the approaches taken by each NNSA site, as well as

NNSA’s programmatic direction.

Surveillance and Monitoring Program for Plutonium Storage. DOE’s safety standard

entitled Stabilization, Packaging, and Storage of Plutonium-Bearing Materials (DOE-STD3013) establishes requirements for the long-term storage of plutonium metal and oxides,

including a surveillance and monitoring program to verify safe storage parameters. The

surveillance and monitoring program managed by DOE’s Savannah River Operations Office was

established to monitor the use of this standard. Unfortunately, DOE again under-funded

essential supporting work performed at Los Alamos National Laboratory. At the urging of the

Board, the Assistant Secretary for Environmental Management restored the funding for this

program for FY 2004. The Board also reviewed the scientific and statistical methodology for

surveillance of plutonium in storage and provided input that corrected overly optimistic

assumptions regarding the validity of extrapolations.

3.1.2 Plutonium

Stabilization and Packaging of Plutonium Metal and Oxide. During 2004, several

significant milestones were achieved in DOE’s implementation of the Board’s

Recommendations 94-1 and 2000-1. Operators at the Hanford Plutonium Finishing Plant

completed both stabilization and packaging of plutonium oxide materials to meet DOE-STD3013 and repackaging of containers of plutonium metal to correct weld quality deficiencies. 

These materials are now in a condition suitable for extended safe storage at Hanford or for

shipment and subsequent storage at another suitable site. Similarly, stabilization and packaging

and disposition of plutonium materials at the Lawrence Livermore and Oak Ridge National

Laboratories were completed as promised in DOE’s implementation plans for the Board’s

recommendations.

Nuclear Material Stabilization and Storage. The Board has continued to evaluate

NNSA’s plans for repackaging high-risk materials at Los Alamos National Laboratory into

robust containers. In light of continued slow progress, the Board issued a letter to the Secretary

of Energy in February 2004 urging the pursuit of alternative approaches that could accelerate this

work. In response, DOE has developed a comprehensive plan that will accelerate the schedule

for stabilization, packaging, and improved storage of nuclear materials. Progress was delayed by
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the safety and security stand-down at Los Alamos, but program managers believe the schedule

can be recovered in 2005.

Plutonium-238 Repackaging at Oak Ridge National Laboratory. The Board

evaluated DOE’s plan for repackaging nine items containing approximately 700 grams of

plutonium-238 into special-form capsules for safer storage. Based on the Board’s findings, DOE

made several changes to improve the safety of the repackaging operations for three items that

had suspect seals on the inner container. Changes included requiring respiratory protection

during all work in gloveboxes and conducting the entire operation in the ventilated glovebox

room.

Drums Containing Plutonium-238 at Hanford. In 2003, the contractor at the Hanford

Site began work to retrieve more than 38,000 transuranic waste containers from burial trenches

on site. Within these trenches are 12 drums containing between 44 and 100 grams of plutonium238 per drum that will require special handling to ensure safety. In 2004, the Board continued to

urge DOE to develop an adequate disposition plan. As a result of the Board’s efforts, DOE has

narrowed the options for disposition of this plutonium-238 material and has identified the

programmatic hurdles that must be addressed. The preferred alternative is to ship the drums to

Savannah River for dissolution in H-Canyon and disposition via the high-level waste system.

Hanford Plutonium Finishing Plant. Previously, the Board identified electrical

deficiencies at this facility. Specifically, baseline short circuit calculations, which are used to

confirm the adequacy of installed electrical equipment, were not consistent with the electrical

configuration drawings. During 2004, DOE evaluated this situation and concluded that many of

the electrical system protective devices in the facility have been applied above their rated

capability. This is an unsafe condition and a violation of the National Electrical Code. 

Equipment upgrades have been made to correct the deficiencies.

3.1.3 Uranium

Denitrator Product Repackaging. Operators at the Idaho Nuclear Technology

Engineering Center completed repackaging of 311 drums of highly enriched uranium oxide

product in September 2004. The highly enriched uranium denitrator product was generated from

the reprocessing of naval reactor fuel. It is being shipped to Savannah River and to Nuclear Fuel

Services in Tennessee for blending into lower enrichment fuel for use in commercial reactors. 

Procedural compliance, communications, on the job training, and formality of operations were

excellent.

Uranium-233 Disposition at Oak Ridge National Laboratory. The Board began its

review of the design of the uranium-233 Disposition and Medical Isotope Production project at

the laboratory. This project includes extraction of thorium-229 for medical use and

downblending of the remaining material for packaging and disposition. The Board identified the

potential for ion exchange resin safety issues similar to those previously identified by the Board

at other defense nuclear facilities. The design contractor is using this information in developing

resin safety controls for the project’s design.
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3.1.4 Neptunium

Solution Stabilization at the Savannah River Site. The Board reviewed the

authorization basis and startup activities for stabilization of neptunium solutions at the HB-Line

facility at the Savannah River Site. The neptunium flowsheet is very similar to previous

plutonium operations, and no significant safety-related upgrades were necessary. Issues

identified during the readiness assessment were resolved, and neptunium operations successfully

began in early August 2004. This is the last major stabilization activity to be commenced at the

Savannah River Site under Recommendations 94-1 and 2000-1.

Oxide Storage at the Idaho National Engineering and Environmental Laboratory. 

The Board began reviewing preparations for storage of neptunium oxide in the Fuel

Manufacturing Facility. This material will provide future feed to support the production of

plutonium-238 for use in radioisotope power systems. A review of the adequacy of the storage

configuration and surveillance program is ongoing. In response to the Board’s inquiries, the

contractor procured a more robust cart to improve worker protection during transfer of

containers within the storage facility. 

3.2 STABILIZATION OF SPENT NUCLEAR FUEL

3.2.1 Hanford Site

The Board continued to provide close oversight of spent nuclear fuel removal activities at

the Hanford Site. As the contractor neared completion of the removal of fuel from the K-East

and K-West Basins, more resources were made available to begin removing sludge from the

K-East Basin. However, the latter activity had suffered significant delays due to deficiencies in

project management, design, and engineering; these deficiencies ultimately led to the failure of

the contractor’s Operational Readiness Review in 2003.

In a letter dated March 3, 2004, the Board called DOE’s attention to the lack of effective

corrective actions. Noting that the sludge project was again falling behind schedule, the Board

requested that DOE provide a revised implementation plan for Recommendations 94-1 and

2000-1. This plan was to contain a defined disposition path for each sludge type within the

K-Basins and realistic, firm milestones for commitments. DOE issued a revised implementation

plan on May 3, 2004. The contractor began the transfer of low-activity sludge to a storage and

shipping container in the K-East Basin in June 2004. In October 2004, operators began the

consolidation of high-activity sludge into new containers placed at the bottom of the K-East

Basin.

Subsequent reviews of this project by the Board revealed slow progress on the part of the

contractor to correct deficiencies in the design and engineering process. Several subsystems

within the sludge project required redesign or experienced delays due to inadequate design

specifications, testing inadequacies, and equipment failures. The Board relayed these concerns

to DOE which responded by formulating plans for independent reviews of design and

engineering processes within the sludge project.
3-4

In October, contractor operators completed the milestone for removal of spent fuel from

the K-Basins, one of the major objectives of Recommendations 94-1 and 2000-1. A storage

container partially filled with scrap pieces remains; additional small quantities will likely be

found during the removal of sludge from the basins. The required fuel handling, shipping, and

treatment equipment will remain operational until all remaining fuel and scrap pieces are

retrieved and processed.

The Board noted further discrepancies in spent fuel recovery operations, particularly in

the areas of hoisting and rigging safety, multi-canister overpack handling, and plans for

employing divers in the basin. Because of these inquiries, DOE performed an independent

assessment of hoisting and rigging operations, took actions to improve the conduct of operations

for canister handling, and reconsidered the safety implications of the proposal to use divers in the

highly-contaminated K-East Basin.

3.2.2 Idaho National Engineering and Environmental Laboratory

All spent nuclear fuel previously in wet storage at the Idaho National Engineering and

Environmental Laboratory has been consolidated at the Idaho Nuclear Technology Engineering

Center. This includes accident debris from the Three Mile Island Unit 2 nuclear plant, fuel from

the Power Burst Facility, and residual material from the Materials Test Reactor fuel basin. In

addition, all fuel from the CPP-603 basin has been transferred to CPP-666, a state-of-the-art

lined basin, and seven dry fuel storage casks loaded with spent fuel have been transferred from

Test Area North to the Engineering Center for consolidation. 

3.3 WASTE MANAGEMENT

3.3.1 High-Level Waste

Hanford Tank Farms 

Worker Safety. The Board reviewed a series of occurrences, incidents, near misses, and

other operational events indicating serious weaknesses in work planning, conduct of operations,

and responses to abnormal events or unexpected conditions. The Board concluded that these

problems were the result of deficiencies in the Integrated Safety Management system for work in

the tank farms, particularly in the areas of work planning, conduct of operations, and feedback

and improvement. The Board issued a letter on September 8, 2004, requesting that DOE provide

a report on the weaknesses in integrated safety management at the tank farms and on corrective

actions to improve worker safety. In response, DOE conducted the first phase of a two-part

improvement validation review at the tank farms and committed to perform the second phase in

early 2005.

Contact-Handled Transuranic Mixed Waste Treatment, Packaging, and Storage

Facility. The Board challenged DOE’s position that a Preliminary Documented Safety Analysis 

was not required by the Nuclear Safety Rule (10 CFR Part 830) because this facility was neither

new nor a major modification. As a result, DOE reevaluated the licensing strategy for the

project, determined that it should be identified as a new nuclear facility, and directed the tank
3-5

farms contractor to develop a Preliminary Documented Safety Analysis. This change is expected

to better integrate the safety analysis with the overall design.

Safety Classification of Waste Transfer Valves. The Board discovered that these

valves had not been given a correct safety classification and hence were not being adequately

tested. In response, DOE directed its contractor to classify waste transfer valves that provide

double-valve isolation as safety significant. Improvements that are expected include valve

performance testing and, where valve testing is not possible, additional measures to protect

workers. In a related matter, the Board noted that radiation surveys were not going to be

preformed downstream of the isolation valve despite the expectation stated in the authorization

basis. DOE responded by improving radiation survey plans for some transfers and strengthening

radiological control procedures for general transfers.

Tank Integrity. A letter issued by the Board in August 2000 led to increased efforts by

DOE to protect the integrity of the high-level waste storage tanks. This year, the Board provided

input to a panel of nationally-recognized corrosion experts convened at Hanford to review the

tank corrosion control program. The panel reported that:

. . . due to the paucity and fragmentary nature of the available relevant DST [doubleshell tank] corrosion data, it is not currently possible to provide a clear technical basis

for DST waste chemistry controls, optimum DST waste chemistry specifications or a

series of DST waste chemistry control options.

As a result, DOE has initiated an experimental program to characterize tank corrosion in

high-level waste environments. In response to the Board, the panel reviewed the validity of

characterizing corrosion of an entire tank based on ultrasonic inspection of only a small fraction

of the tank surface and suggested a more in-depth statistical analysis of the data to support

predicting general corrosion and pitting rates. The panel also suggested that in addition to

structural integrity (i.e., preventing catastrophic failure), the leak integrity of the tanks should be

studied in more detail. 

The Board is continuing to evaluate tank integrity programs at Hanford. In particular, the

Board is assessing the safety impact of DOE’s decision allowing a double-shell tank to remain

outside the corrosion control specifications.

Savannah River

Salt Waste Processing Facility. The Board evaluated the safety risks associated with

delays in the design and construction of the Salt Waste Processing Facility and urged DOE not to

eliminate funding for this important work. DOE has since restored funding for this project and is

currently pursuing a program plan that will accelerate waste stabilization and risk reduction. The

Board reviewed design documentation and identified weaknesses in the performance

categorization and potential seismic interactions of various portions of the facility. DOE plans to

upgrade certain structural components to ensure that unqualified components do not damage

qualified components during an earthquake, and perform further analysis of the facility

performance categorization. 
3-6

High-Level Waste Facilities. In August 2004, the Board found that the majority of the

safety-class electrical breakers and disconnects for the high-level waste facilities are installed in

non-safety-rated buildings. As a result, although the documented safety analysis takes credit for

the safety-class electrical breakers and disconnects, there is no assurance that these breakers can

be relied upon to perform a safety function during a seismic event. DOE has identified an

upgrade project to eliminate this vulnerability, but it is not certain this project will be funded in

the near future.

3.3.2 Low-Level Waste and Transuranic Waste

Drum Handling at Savannah River. During a review of transuranic waste retrieval

operations at Savannah River Site, the Board’s staff called DOE’s attention to the hazards of

unvented transuranic waste drums. Experience at other DOE sites has shown that such drums

can contain flammable and explosive mixtures of hydrogen and oxygen gas, thus requiring

controls to protect workers. DOE’s contractor disagreed, arguing that there was no evidence of

flammable or explosive gas mixtures in drums handled so far. Shortly afterwards, however, a

DOE facility representative observed a transuranic waste drum venting operation and discovered

that the drum contained 16.4 percent hydrogen and 13.8 percent oxygen, a flammable mixture.

This situation led to the declaration of a potential inadequacy in the safety analysis and the

issuance of an occurrence report. In a subsequent review of records for previously vented

drums, contractor personnel identified 73 drums that had contained flammable or explosive

mixtures of hydrogen and oxygen prior to venting.

On December 14, 2004, the Board transmitted a letter alerting DOE to the contractor’s

apparent lack of knowledge of the hazards presented by the transuranic drums. DOE halted

operations related to drum retrieval until all hazards could be clearly identified, analyzed, and

controlled.

Waste Isolation Pilot Plant. The Waste Isolation Pilot Plant in New Mexico, commonly

known as WIPP, is a geologic repository utilized for the disposal of defense transuranic wastes. 

WIPP received its first waste shipment on March 25, 1999. During 2004, the site received and

deposited in the underground repository approximately 1,000 shipments totaling in excess of

8,500 cubic meters of contact-handled transuranic waste. The Board closely monitored

operations because the facility operated at nearly full production during a time of significant

turnover in DOE and contractor personnel. Following an accident that nearly caused a fatality in

the underground portion of the plant, the Board strongly encouraged DOE managers to reassess

the safety of operations.

National Transuranic Waste Program. The Board observed increasing weaknesses in

the functioning of the National Transuranic Waste Program, which controls all of DOE’s

transuranic waste disposal projects. The Board encouraged DOE to improve cooperation and

communications between WIPP and various waste storage and waste generator sites. Efforts to

properly characterize and prepare waste for shipment to WIPP have been failing at both the Los

Alamos and Idaho National Engineering and Environmental Laboratory. In a related incident,

inadequate communication and cooperation contributed to radiological exposures to workers 
3-7

operating a mobile waste characterization unit at the Lawrence Livermore National Laboratory. 

The Board expects to review transuranic waste operations in 2005 and beyond.

Mobile Transuranic Waste Characterization Units. The Board reviewed the DOEauthored Basis for Interim Operation for the operation of mobile transuranic waste

characterization units. The Board discovered inadequacies in quantities of material at risk,

analysis of deflagrations, and in controls specified in the technical safety requirements. In

response to a letter from the Board, DOE agreed to add several new controls, including a formal

container inspection program and lid restraints for unvented drums. DOE plans an operational

readiness review for new deployments to ensure sites receiving the units are ready to operate

them safely.

Advanced Mixed-Waste Treatment Project. The Board provided technical oversight

of a review of the confinement ventilation system for the Advanced Mixed Waste Treatment

Project at the Idaho National Engineering and Environmental Laboratory. In response to the

findings of this review, DOE committed to make improvements to the surveillance and

maintenance requirements for this vital safety system. The project has also been plagued by

software problems which must be resolved before waste may be shipped offsite. Retrieval of

transuranic waste containers from beneath an earthen berm was underway in the first half of

2004, governed by strict worker protection rules to avoid inhalation of plutonium. This project

is currently on hold until problems with recordkeeping are resolved.

Melton Valley Waste Treatment Project. The Melton Valley Waste Treatment Project

at Oak Ridge is designed to process liquid and solid transuranic waste and low-level radioactive

waste for offsite disposal. The Board observed DOE’s operational readiness review in January

2004 in preparation for solidifying high-activity, low-level liquid wastes. The Board noted

weaknesses in conduct of operations during a replacement of a ventilation system filter. 

Problems included a failure to reference the procedure during the course of the activity, lack of

supervision, and a radiological control technician performing tasks outside his area of

responsibility. DOE management ensured that corrective measures were taken prior to startup. 

Liquid processing operations began later in January and were successfully completed in October

2004.

3.4 FACILITY DEACTIVATION AND DECOMMISSIONING

3.4.1 Overview

Accelerated deactivation and decommissioning (D&D) activities are occurring at more

and more DOE sites as a result of DOE’s accelerated cleanup initiative. Successful D&D work

has reduced or eliminated hazards at a number of defense nuclear facilities, but the Board has

observed difficulties in maintaining a high standard for work planning and safe work execution

in several facilities that are making the transition from production operations to D&D. 

Production operations typically involve established operating procedures carried out by

experienced workers. The shift to D&D involves constantly changing tasks and facility

conditions. Work may be carried out by operators lacking significant experience in such

operations. Making this transition is a large effort that is generally not complete before D&D 
3-8

operations begin. This problem has been aggravated by a tendency of DOE and its contractors,

particularly at the level of the first line supervisor, to view D&D work as routine and to relax

safety vigilance once bulk quantities of radioactive materials have been removed. The

perception that work control procedures need to be “streamlined” for greater efficiency has

contributed to the observed problems.

3.4.2 Fernald Closure Project

Work at DOE’s Fernald site, currently known as the Fernald Closure Project, involves an

accelerated effort to decontaminate and demolish structures, remove and dispose of nuclear

waste, and complete environmental remediation of the site by the end of FY 2006. In 2002 and

2003, the Board observed that the number of reportable occurrences and near misses at Fernald

was on the rise and, in August 2003, sent a letter to DOE documenting these and other worker

safety issues. More recent evaluations conducted by the Board in 2004 indicate that worker

safety across the Fernald site has improved and that DOE has strengthened its oversight of

contractor work.

During 2004, the Board reviewed hazard categorization, safety analysis methodology,

and readiness review plans for removal of uranium waste products in Silos 1, 2, and 3. The

Board concluded that the resulting safety controls and startup review plans were acceptable. The

Board then observed the readiness reviews performed by the contractor and by DOE for these

activities. The Board found that the readiness review teams were qualified and conducted

thorough reviews, and that safe operations could begin after pre-start findings were addressed. 

(The Board did observe, however, that the contractor had prematurely commenced the readiness

review.) The Board is pressing DOE and the contractor to make sure facilities are ready to

operate before commencing future readiness reviews.

3.4.3 Miamisburg Closure Project

Activities at the Mound site, currently known as the Miamisburg Closure Project, include

cleanout and demolition of buildings formerly used for nuclear materials and explosives

research; development, testing, and production activities; removal of contaminated equipment

and soil from the site; and environmental restoration. Nine buildings are being transferred to the

Miamisburg Mound Community Improvement Corporation, which will operate the site as a high

technology industrial park after DOE’s cleanup activities are completed. The scheduled

completion date is March 31, 2006. 

In 2003, DOE took action to correct weaknesses identified by the Board, such as

insufficiently detailed work procedures, and established a team of project managers, safety

personnel, and radiological protection personnel to review all work procedures before they are

approved for use. Reviews by the Board in 2004 indicate that the contractor is providing

adequate safety oversight of work activities. There have been relatively few reportable

occurrences or injuries to workers.

In late 2004, the Board began a review of the internal dosimetry program for bioassay

analyses; this review will be completed in early 2005.
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3.4.4 Rocky Flats Environmental Technology Site

D&D activities are continuing at the Rocky Flats Environmental Technology Site and are

on schedule for completion by the end of FY 2006. During 2003, however, a number of

significant safety incidents occurred, including a fire in a highly contaminated glovebox. On

December 2, 2003, the Board issued a report to DOE pointing out a serious weakness in DOE’s

oversight of its contractor. The Board also identified the need for an independent review of the

contractor’s integrated safety management program. In January 2004, a review team coordinated

by an outside consultant conducted this review on DOE’s behalf and found that implementation

of integrated safety management was not effective in integrated work control, fire response, and

assessments of safety management programs.

On May 4, 2004, the Secretary of Energy transmitted to the Board the final corrective

action plan; this plan was found by the Board to be adequate. Corrective actions included

restricting the use of generic work packages to simple tasks, instituting more comprehensive

review of work packages, improving procedures for chemical decontamination and control of

combustible materials, retraining workers on the proper response to fires, and improving daily

briefings to better communicate hazards and controls to the workers. To confirm that DOE

carried out its plan, the Board visited the site several times in 2004. Lessons learned from the

problems experienced at Rocky Flats have been shared with other DOE sites performing D&D

work.

3.4.5 Savannah River Site

DOE issued a major contract modification in June 2003 to accomplish D&D of 252

buildings at Savannah River by the end of FY 2006. The contract modification incorporated an

accelerated schedule with performance incentives for meeting goals. Much of the work so far

has occurred without incident; however, the Board noted several events resulting from

significant lapses in work planning and control. In one event, radioactive material was released

when a supervisor authorized a subcontractor performing asbestos removal work to cut out and

remove tritium-contaminated piping with no precautions for contamination control. In another

event, workers were exposed to an unshielded cesium-137 source when a work crew cut open the

shielded container.

The Board provided technical oversight to ensure that suitable corrective actions were

being taken. In a review of work planning and control of D&D work in August 2004, the Board

found deficiencies in defining the scope of work and the identification of hazards. In October

2004, DOE acknowledged these deficiencies and requested that its contractor take additional

corrective actions. In December 2004, the Board issued a letter detailing the areas for

improvement in work planning.

3.4.6 Hanford Plutonium Finishing Plant

DOE plans to demolish this facility by 2009, leaving only a slab on grade. The Board

reviewed D&D activities in late 2004 and found that two important elements of work package

preparation—hazard analyses and identification of controls—were confusing and difficult to 
3-10

follow. Moreover, firefighting guidance provided to operators did not adequately cover the 

hazards of D&D work. Finally, the Board noted a downward trend in management attention to

criticality hazards, despite the large quantity of fissile material remaining. Two serious errors in

estimating plutonium mass occurred during 2004. The Board also evaluated a test program to

characterize the reactivity of materials used in decontaminating gloveboxes. These experiments

found that cellulose rags exposed to decontamination chemicals continued to undergo

exothermic reactions even after chemical neutralization. This condition would present a hazard

during storage and disposal of these materials. The Board is pursuing improvements in

operations and safety attitudes at this facility.

3.4.7 Hanford K-East Basin

D&D began in September 2004 with the grouting of the K-East Basin discharge chute,

and is scheduled to be complete by September 2006. Additional D&D work will be limited until

the sludge is removed from the basin. After the sludge is removed, the contractor plans to

prepare the K-East Basin to be cut into sections for disposal at the low-level waste facility at the

Hanford Site. Highly radioactive components on the basin floor will be removed, and the

remaining components and debris will be encased in a 6-foot thick layer of grout. Surface

contamination on the basin walls will be reduced using hydrolasing. Six-foot wide strips on the

basin floor, along the proposed cut lines, will also be hydrolased. Prior review by the Board had

indicated that the contractor’s concept for lifting the cut sections of the basin could lead to

sections fracturing and falling. DOE now plans to provide support underneath the cut sections

during lifting, which should eliminate the failure mode identified by the Board. The Board

reviewed this project in October 2004 and found no new safety problems. 

3.4.8 Lawrence Livermore National Laboratory

There are 49 gloveboxes and enclosures with a wide range of elemental and isotopic

contamination to be decontaminated and decommissioned at the Heavy Element Facility. In

general, this work requires removal of equipment from the gloveboxes, followed by

decontamination of the internal surfaces to low-level waste limits to allow disposal at the Nevada

Test Site. The Board has reviewed the readiness assessments for this work and passed along

experiences from the Rocky Flats Environmental Technology Site. 

3.4.9 Idaho National Engineering and Environmental Laboratory

The laboratory began an aggressive D&D program in 2004 to demolish unused facilities. 

The Board has been monitoring this work for indications of safety problems. While operational

events have occurred, the Board has not identified significant adverse trends.
4-1

4. NUCLEAR FACILITIES DESIGN AND INFRASTRUCTURE

4.1 NUCLEAR FACILITY DESIGN REVIEWS

The Board is required by statute to review the design and construction of defense nuclear

facilities, which must be designed and constructed in a manner that will support safe and

efficient operations for 20 to 50 years. This demands an exacting design process, guided by ISM

principles, that will ensure appropriate safety controls are identified early in the design. The

Board’s expectation is that the design and construction phases of defense nuclear facilities will

demonstrate clear and deliberate use of ISM principles and core functions, and development of

ISM-based manuals of practice to be followed throughout design and construction.

4.1.1 Hanford

Waste Treatment Plant

The Waste Treatment Plant is a multi-facility complex designed to treat Hanford’s highlevel radioactive liquid wastes. It consists of three primary nuclear facilities known as

Pretreatment, Low-Activity Waste, and High-Level Waste. The Pretreatment facility receives

high-level waste from Hanford’s tank farms and separates it into high and low activity streams. 

The low activity portion will be transferred to the Low-Activity Waste facility where it is mixed

with glass-forming materials and converted to a stable borosilicate glass, or “vitrified.” The

glass canisters from the Low-Activity Waste facility are subsequently placed in an onsite, nearsurface facility. The high-activity waste stream is transferred from the Pretreatment facility to

the High-Level Waste facility where it is also vitrified. After vitrification, high-level waste glass

logs are temporarily stored at the Hanford site in the Canister Storage Building until shipment to

DOE’s high-level waste repository. 

DOE has reported to the Board that the Waste Treatment Plant as a whole is 43 percent

complete; engineering is 76 percent complete; procurement 72 percent complete; and

construction 36 percent complete. Construction progress varies among the facilities. Currently, 

the Low-Activity Waste facility is furthest along—most of the structural concrete has been

placed and considerable progress has been made in erection of the structural steel. Progress on

the Pretreatment facility includes completion of the concrete walls and floors of the major

below-grade and nuclear process areas. Many of the large process vessels are already in the

facility. For the High-Level Waste facility, construction below grade is complete, and work on

the above-grade concrete structure has commenced. Fabrication of modular piping systems is

currently underway and much of the mechanical equipment is in the final stages of design or

procurement. However, very few of the mechanical and electrical systems have been installed.

The Waste Treatment Plant project is being designed and constructed in a close-coupled

or “fast track” fashion. This method is characterized by conducting design and construction

activities simultaneously. For example, initial construction of the High-Level Waste facility

(basemat and walls to grade) was initiated prior to approval of the structural design immediately

above grade. The design-construct process has been used successfully in the past, but is best

suited to simple structures and processes that have minimal technical risk. 
4-2

The Waste Treatment Plant is not a simple structure, and many of the processes

employed in this design are unique or have never before been used before in the DOE complex. 

Not unexpectedly, then, the project has encountered significant quality problems. Among these

have been: (1) failure to develop proper controls for placement of concrete during extreme

climatic conditions; (2) failure to maintain quality control over concrete mix materials; (3)

failure to install the correct rebar per design; (4) use of incorrect weld rod material; and (5)

failure to provide tank fabricators with the proper specifications for testing weld adequacy. This

last problem led to the discovery of poor weld quality in a safety related vessel that had already

been installed. DOE has corrected each of these problems and has taken steps to ensure that they

will not recur. Notwithstanding these corrective actions, projects of this scope require

continuous, intense vigilance by management.

The Waste Treatment Plant project has entered its most critical period. Construction has

progressed beyond the point where simple changes to the design or structure are feasible if safety

problems should arise. Major changes in the design of any major nuclear system would

significantly impact the project’s cost and schedule. This uneasy situation can cause reluctance

to admit safety concerns, in part because the design and construction contract incentivizes

minimization of costs and maintenance of schedule. For example, the Board’s experienced great

difficulty in overcoming DOE’s reluctance to investigate problems with the seismic design. 

When DOE finally undertook careful study of the Board’s concerns, it agreed that the initial

seismic design specifications were incorrect. Altering the seismic design of the project at this

late date will require DOE to evaluate the entire Waste Treatment Plant design, possibly leading

to changes in existing equipment and in the design of piping designs. Fortunately, this issue is

being addressed by DOE while design solutions still exist. 

Structural Design. The Board’s structural review focused on the Low Activity Waste

Vitrification facility, the Pre-Treatment facility, and the High Level Waste Vitrification facility. 

Due to the complexity of the High Level Waste building, the Board requested that DOE prepare

summary structural reports to ensure that the analysis results validate the adequacy of the design. 

These summary analyses explain the predicted behavior of the building and the resulting loadresisting mechanisms by examining structural deformation plots and interpreting building

response, using fundamental principles of structural mechanics.

On April 15, 2004, DOE released the first draft of the summary structural reports for the

High Level Waste facility. The report addressed some but not all of the Board’s concerns; it did

not adequately cover overall design margin, seismic load path distribution in the east-west

direction, effects of concrete cracking, and finite element mesh refinement. The next revision of

the report to be completed by the end of January 2005 is expected to cover these topics.

DOE issued the final version of its summary structural report for the Low Activity Waste

facility on August 2, 2004. The Board, in its letter of August 24, acknowledged that this report

satisfied the requirements of the original request. The Board also complimented the Office of

River Protection’s Peer Review Team, a group of structural experts empaneled to review the

design of the Waste Tank Project’s buildings. The Board noted that the team’s rigorous reviews

resulted in significant design improvements to the Low Activity Waste building.
4-3

Fire Protection. The Board discovered that the project planned to eliminate most of the

fire protective coating for structural steel. In letters sent to DOE in March and July of 2004, the

Board pointed out that this action was inconsistent with DOE requirements and industry practice

and constituted a significant safety issue. DOE subsequently directed the contractor to provide

structural steel fire resistance coatings in accordance with required codes and standards. Fire

proofing is now underway, significantly improving fire resistance.

Safety Basis and Hydrogen Gas Hazards. In March 2004, the Board completed a

review of the research and development to address mitigation of hydrogen hazards related to

mixing non-Newtonian waste. These reviews focused on the theoretical basis for testing,

experimental design, and analysis of results. Overall, the results of this research program

demonstrated that a safety basis exists for mixing individual non-Newtonian tanks. The Board

noted that the use of preliminary test data, which had not undergone a thorough quality review,

would not be completed until months after major design decisions were to be made. DOE

acknowledged the problem and directed its contractor, Bechtel National Incorporated, to take

actions as suggested by the Board. Bechtel completed a summary level report forming the basis

for some of the critical decisions necessary to support continued design. During the remainder

of 2004, Bechtel continued to develop the mixing design for non-Newtonian wastes and will

likely complete final testing and data analysis in 2005. This will form the basis for final design

decisions.

Electrical System Design. The Board discovered that several safety-significant loads

were connected to safety-class buses, contrary to established industry standards. Bechtel has

since removed these loads to a separate safety-significant bus. The Board also noted that the

fire-protection system designed to protect switchgear in the electrical substation had been

intentionally disabled because of concern that the sprinkler water might enter the equipment

(which is vented at the top). The system has been redesigned and returned to operation, but

switchgear has not yet been covered to prevent water intrusion and consequent equipment

damage following sprinkler activation. Efforts are underway to correct this remaining

deficiency. 

Earthquake Ground Motion

The Board has reviewed a number of specific technical issues that require resolution as

part of assessing and updating the earthquake ground motion at the Hanford site. These issues

involve developing an improved understanding of how the near-surface soils and bedrock affect

the assessment of ground motion given the potential occurrence of an earthquake. Currently,

DOE assumes that the assessment of earthquake ground motion can be based on California

earthquake ground motion models. The basis for this assumption has been questioned in part

because the properties of near-surface soils and bedrock at Hanford are not the same as 

California’s. This source of error is compounded by the paucity of direct data for the physical

properties of Hanford soils and bedrock, critical to completing ground motion estimates. Finally, 

the bedrock at Hanford is not a continuous unit, having alternating layers of harder basalt and

softer sedimentary interbeds. The overall purpose of the Board’s inquiry is to address these

uncertainties and assess the impact on estimating earthquake ground motions.
4-4

DOE has developed an overall program plan for reassessment of the Hanford earthquake

ground motion. As part of executing this plan, DOE has undertaken the collection of additional

subsurface geologic data. Efforts to acquire this data have been largely successful. 

Modeling of earthquake ground motion is also underway. Early results suggest that the

assessment of earthquake ground motion is sensitive to assumed properties for both soils and

bedrock (basalt and interbeds). Results from the modeling of earthquake ground motion will be

reviewed to ensure that any changes to the overall Hanford design are conservative. If it is

necessary to increase ground motion design parameters for the Hanford site, the impact on all

projects in the design stage will need to be assessed.

4.1.2 Savannah River

Plutonium Storage

DOE is planning to consolidate its excess plutonium at Savannah River pending final

disposition. Some of the material will be used as feed to manufacture mixed-oxide reactor fuel. 

DOE is in the preliminary stages of design for modifications to the K-Area facility that would

allow immobilizing excess plutonium in glass and shipping the glass logs to the planned Yucca

Mountain repository. Neither of these disposition paths will be completed in the next 10 years.

As requested by Congress, the Board evaluated the facilities planned to be used for this

storage. In the mid-1990s, DOE had planned to store the excess plutonium in a new facility

specifically designed for storage. This facility had been designed and excavation begun when

DOE canceled its construction in 2001. This decision was based primarily on budget constraints

and expectations that the plutonium would be disposed of in a short period of time. DOE’s plans

shifted to utilizing two 50-year-old facilities that do not meet modern safety standards, viz., the

old K-Reactor facility in which several areas have been modified for storage, and Building

235-F. The K-Reactor plutonium storage facility is now called the K-Area Material Storage

facility, commonly known as KAMS.

The Board’s study concluded that storage of plutonium in KAMS could be safely

accomplished for the next 4 or 5 years, but that for extended storage beyond this time,

improvements in fire protection should be undertaken. The Board’s study further concluded that

DOE should not plan on extended storage of plutonium in Building 235-F without substantial

modernization of the safety systems and confirmation of the building’s structural adequacy. 

The Board issued its report to Congress and DOE on December 1, 2003, and a follow-up

status report on May 28, 2004. In the latter report, the Board continued to encourage DOE to

take a more comprehensive view of the current situation with regard to disposition of its excess

plutonium. The Board noted that for extended storage, consolidation of excess plutonium into a

single, robust facility was logical from a safety, security, and economic perspective.

In the summer of 2004, DOE completed a study (proposed by the Board) of the various

plutonium storage options. DOE reached the conclusion that using KAMS and Building 235-F

was still the best option. However, the Board believes that the report is based on unfounded

assumptions that shortened the needed storage duration. (A short duration for storage biases the 
4-5

conclusions toward acceptance of incremental improvements to existing facilities.) Since

completing that study, DOE has determined that meeting new security requirements in two old

facilities will not be cost effective. Therefore, DOE has again changed its plans and is pursuing

modifications to KAMS that would allow storage of all excess plutonium.

While the Board agrees with abandoning the use of Building 235-F, further study of the

revised plan for storage of more plutonium in KAMS will be required. The Board still believes

that the potentially large cost to retrofit this old facility to meet current safety and security

requirements could be better spent on a new facility specifically designed for safe and secure

storage. 

Salt Waste Processing Facility

The Board reviewed the facility design and identified weaknesses in the performance

categorization and potential seismic interactions of various portions of the facility. In a letter to

DOE dated August 27, 2004, the Board questioned the adequacy of this facility’s confinement

function during a potential earthquake. DOE plans to upgrade certain structural components to

address the seismic interaction concerns and to perform further analysis of the facility

performance categorization.

Pit Disassembly and Conversion Facility

The Board has been reviewing the structural design for the Pit Disassembly and

Conversion Facility. The Board has ensured that the structural design criteria were adequate, the

geotechnical evaluations were appropriate, and the soil-structure interaction analysis was

thorough and complete. In response to a May 13, 2003 letter from the Board, the contractor

conducted a fire risk analysis to assess a seismically induced full-facility fire. The Board is

reviewing the final design to ensure that it is adequate and incorporates appropriate

defense-in-depth.

Tritium Extraction Facility

The Tritium Extraction Facility will be used to extract tritium from target rods irradiated

in commercial light water reactors. The extracted tritium is to be used to replenish tritium

reserves for the nation’s nuclear weapons stockpile. During the past 7 years, the Board

conducted extensive reviews and provided comments to DOE on the design and construction of

the facility. The Board has concluded that the design provides adequate controls to address the

hazards posed, and that the buildings were constructed (and the safety-related components were

fabricated) in accordance with design requirements. 

During 2004, the Board reviewed component testing activities and preparations for

startup of the facility planned for September 2006. In general, the test program appears to be

progressing acceptably with the exception of the process control system software, which

includes the safety-significant Worker Protection System. The accelerated construction schedule

has caused significant delays in the development of the process control system software. The

Board will continue to provide oversight of testing activities and startup preparations in 2005

and 2006.
4-6

4.1.3 Y-12 National Security Complex.

Highly Enriched Uranium Materials Facility

The Board has continued its design reviews of the High Enriched Uranium Materials

Facility at the Y-12 National Security Complex. The Board conducted detailed reviews of

important safety systems and identified deficiencies in the design of the electrical, ventilation,

fire protection, instrumentation and control systems, and in the structural design. In response, 

DOE has incorporated greater reliability into the electrical design, has added steel reinforcement

details to the concrete structure to better resist an earthquake, and is working to resolve the other

design problems.

Enriched Uranium Manufacturing Facility

The Enriched Uranium Manufacturing Facility is a new project at Y-12 in the conceptual

design phase. When complete, it will replace a number of aging facilities that process enriched

uranium. The Board plans to provide technical oversight of this project throughout design and

construction.

4.1.4 Los Alamos National Laboratory

In a letter dated July 19, 2003, the Board objected to the laboratory’s failure to follow

DOE requirements for the design and installation of new safety-class equipment in Technical

Area 18. In a follow-up review conducted in 2004, the Board learned that while equipment had

been installed in two critical assemblies and designed for the other three, the issues identified in

the July 2003 letter had not been addressed. Based on the Board’s repeated identification of the

inadequacy of the designs, confirmed in an independent quality assurance assessment by the

NNSA Service Center, the laboratory finally stopped work on the safety class control systems

and initiated planning for a thorough independent design review. NNSA directed that the control

system remain non-operational and that no further funds be expended until the design review is

complete.

4.1.5 Pantex

DOE is upgrading Building 12-64 so that it once again can house nuclear explosive

operations. The Board noted structural deficiencies in the existing roof design and emphasized

the need for the upgrade to provide a permanent solution. A fiber-reinforced polymer composite

system was utilized to strengthen the roof slabs for earthquake loads. The design was modified

to incorporate the Board’s comments on the preliminary analysis and design. The Board found

the final design to be technically sound.

The project established an administrative limit on the quantity of high explosives to

preclude failure of the roof slabs. The Board questioned, however, whether the initial analysis

work justified the new explosive limits. DOE thereafter modified the methodology to include a

quantification of the hazard so that a rational and justifiable limit could be selected. The final

explosive limits were reviewed by the Board and found to provide an adequate level of safety.
5-1

5. NUCLEAR SAFETY PROGRAMS AND ANALYSIS

5.1 FEDERAL OVERSIGHT

5.1.1 Overview

To meet its statutory health and safety mandate, the Board must continuously assess

DOE’s ability to conduct adequate oversight of contractors working on defense nuclear facilities. 

In this context, oversight includes Federal line-management assessment of contractors,

contractor self-assessment, and independent assessment. For much of the work conducted in the

defense nuclear complex, DOE relies upon contractors to perform inherently risky activities in

government-owned facilities. These activities are nevertheless governed by nuclear safety

requirements promulgated by the government. Thus, DOE fills three simultaneous roles: owner,

customer, and regulator. Preventing conflict among these roles requires a complex oversight

system strained by competing demands that must be reconciled to ensure that the overall mission

is achieved safely.

5.1.2 Recommendation 2004-1

Information developed by the Columbia Accident Investigation Board with respect to the

loss of the space shuttle and by the U. S. Nuclear Regulatory Commission in connection with the

“near miss” at the Davis-Besse nuclear power plant suggests that weakening federal oversight of

contractor operations can have dire consequences. In furtherance of its statutory duty to protect

the public health and safety from hazards at defense nuclear facilities and its charge to restore

confidence in DOE’s management capabilities, the Board conducted two public meetings in

February 2004. During these meetings, the Board heard testimony from Department of Energy’s

Principal Deputy Administrator for Military Applications and from the Assistant Secretary for

Environment, Safety and Health. 

Based on the record of the public hearings and its prior study of DOE’s oversight

program, the Board determined that action needed to be taken to reverse the course DOE had set

itself upon. In particular, the Board saw the need to counter: (1) an increased emphasis on

productivity at the possible expense of safety; (2) the loss of technical competence and

understanding at high levels of DOE’s and NNSA’s organizational structure; (3) an apparent

lack of interest in safety research; and (4) reduced central oversight of safety. On May 21, 2004,

the Board issued Recommendation 2004-1, Oversight of Complex, High-Hazard Nuclear

Operations, along with an in-depth technical report, Safety Management of Complex,

High-Hazard Organizations (DNFSB/TECH-35). (The recommendation is reprinted in its

entirety in Appendix A.) Two months later, the Secretary of Energy accepted the

recommendation and assigned a DOE team to develop an implementation plan. 

On December 23, 2004, DOE submitted an implementation plan for the Board’s review.

This plan divides the actions that DOE will take in response to the recommendation into three

broad areas:
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! Strengthening Federal Safety Assurance,

! Learning from Internal and External Operating Experience, and

! Revitalizing Integrated Safety Management.

DOE committed to the following specific actions: 

! Establish two Central Technical Authorities, one within NNSA, and the other reporting

to the Under Secretary for Energy, Science and Environment.

! Implement and strengthen the DOE Oversight Model.

! Establish a permanent nuclear safety research function. 

! Complete an analysis of the staffing requirements, and ensure the qualification of

federal safety assurance personnel.

! Establish and verify implementation of new processes and criteria for delegation of

safety-related authority.

! Establish and implement an Operating Experience Program, as a key element of

improving the Feedback and Improvement core function of ISM.

! Complete field element action plans to improve work planning and work control.

Although the Board generally agreed with the overall direction of the implementation plan,

a complete analysis of its adequacy has just begun. 

5.2 INTEGRATED SAFETY MANAGEMENT

5.2.1 Overview

ISM is a concept that evolved from Recommendation 95-2. The basic tenets of ISM

provide the framework for safely performing all of the diverse hazardous activities in the defense

nuclear complex. ISM provides for a single safety management program rather than multiple,

unintegrated programs (e.g., quality assurance and environmental management). Nuclear safety

is an important but not exclusive target of ISM. Nonradioactive hazardous materials and

operations require attention in proportion to the risks they pose to the public, workers, and the

environment. ISM builds upon standards of safe practice for nuclear, chemical, and other

hazardous operations to ensure protection of the public, workers, and the environment. 

Since the Board’s issuance of Recommendation 95-2, the implementation of ISM has

progressed through three phases: (1) developing necessary guidance documents; (2) establishing

the infrastructure for implementing ISM at individual sites and facilities; and (3) confirming that

ISM systems are effective and are being applied to design and construction, start-up, operation,

and decommissioning of DOE’s hazardous facilities. At the end of 1999, the implementation of

ISM was well into the second phase. With the successful completion of ISM System

Verification Reviews at all sites during 2000, the Board’s focus on implementation of ISM

shifted to the third phase. Throughout 2004, the Board stressed the need to look beyond initial

implementation to ensure continued improvement and revitalization. In addition to ensuring that

ISM was implemented at all DOE sites, the Board focused on three key initiatives that are

critical to the long-term effectiveness of ISM: the annual update process, completion of

Recommendation 2000-2 tasks, and activity-level implementation.
5-3

5.2.2 Ongoing Assessments

In 2004, the Board continued to oversee implementation and effectiveness of ISM at

defense nuclear facilities. The Board evaluated efforts of the Energy Facility Contractors Group

to improve ISM and assessed updated ISM descriptions for several sites. The Board has also

instituted a series of assessments of ISM implementation at each NNSA field site and at NNSA

headquarters. These assessments are aimed at revitalizing implementation of ISM principles and

core functions within NNSA.

5.2.3 Vital Safety Systems

Defense nuclear facilities typically incorporate safety systems designed to control the

hazards present. Conditions specifying operational limits for these systems are placed into

Authorization Agreements between DOE and its contractors. For the many facilities constructed

decades ago, maintenance to ensure continued reliability of vital safety systems is a critical task.

In response to Recommendation 2000-2, DOE has taken steps to ensure the operability of

vital safety systems. During 2004, DOE actions in this regard included in-depth reviews of

specific systems and programs (such as configuration management) known to have problems. 

These reviews uncovered weaknesses in the operability of several systems, leading to further

evaluation. As a result of the evaluations, DOE’s Office of Environmental Management has

formulated corrective actions and has demonstrated an intent to meet individual milestones in

Recommendation 2000-2. On the other hand, the Board has found that several NNSA sites have

failed in this regard. Los Alamos National Laboratory has been unable to provide adequate

evidence of commitments to the recommendation due to the extended laboratory-wide standdown. Recent reviews at Lawrence Livermore National Laboratory have identified significant

failures in configuration management, as highlighted to NNSA in a letter from the Board dated

November 3, 2004. 

In early 2003, the Board found that few DOE site offices had fully staffed and

implemented the federal oversight program for safety systems to which DOE committed in the

implementation plan. By late 2003, DOE had applied more senior management attention and

resources to staffing and qualifying technical personnel for these systems engineering

organizations. In 2004, subject to the Board’s oversight, DOE revised and strengthened Manual

426.1-1, Federal Technical Capability Manual, defining federal safety system oversight

responsibilities and technical competencies. Issuance of this manual provides a sound basis for

the more uniform implementation of safety system oversight throughout DOE. DOE also began

a systematic review of the implementation of the safety system oversight program at each of its

site offices. 

5.2.4 Activity Level Work Planning

The Board has continuously emphasized the importance of ensuring that hazards are

identified and controlled, that work is performed in a careful manner in accordance with the

safety controls, and that DOE uses appropriate feedback mechanisms to ensure continuous

improvement at the individual activity level. In 2004, the Board conducted site-specific ISM 
5-4

reviews that revealed significant deficiencies at the Nevada Test Site and at Savannah River. 

These deficiencies were made known to NNSA and the Office of Environmental Management in

separate letters dated May 21 and December 13, 2004. The Board will continue to monitor ISM

implementation in 2005.

5.3 HEALTH AND SAFETY DIRECTIVES

5.3.1 Improvement of Directives

During 2004, the Board received nearly 60 new or revised drafts of health and safety

directives and policy letters from DOE. Highlights of the Board’s reviews follow:

! Nuclear Explosive Safety Directives. The process by which NNSA ensures that

nuclear explosive operations are safe has been the subject of a significant amount of

correspondence, including several formal recommendations. From the time of the

creation of NNSA, this process had gradually changed, such that it became less

formal and repeatable. In a letter dated July 9, 2003, the Board pointed out to NNSA

that it was not acting on the corrective actions recommended by its own Senior

Technical Advisory Panel on Nuclear Explosive Safety Studies. By January 2004,

the Board’s concern with the lack of coordinated effort led to a letter requiring NNSA

to provide a plan and schedule to update the controlling directives for nuclear

explosive safety. By the end of 2004, NNSA had revised and published the

controlling DOE standard for nuclear explosive safety studies, as well as two

supporting documents. These documents represent a significant step toward

formalizing and standardizing the nuclear explosive safety processes. Revisions to

the related DOE Orders, as well as development of lower tier guidance, will continue

through 2005. 

! Electrical Safety Handbook. In June 2001, the Board urged DOE to take a

leadership role with respect to electrical safety. DOE agreed in August 2002 to

update its Electrical Safety Handbook. However, in July 2003 the Board learned to

its dismay that DOE had deleted much of the technical content in the proposed

revision. In an August 7, 2003 letter, the Board informed DOE that this was

unacceptable, especially in light of the high rate of electrical safety incidents

observed across the defense nuclear complex. In letters dated September 5 and

December 15, 2003, DOE agreed to revise the handbook to include technical details

on electrical safety and guidance for an effective electrical safety program. 

Following a resolution of the Board’s comments, DOE published an acceptable

version of the handbook in December 2004.

! Environment, Safety, and Health Reporting. During 2003, the Board provided

technical advice on DOE’s effort to consolidate and revise various reporting orders

into a single directive. The Board commented on draft DOE Order 231.1A,

Environment, Safety and Health Reporting and its many supporting documents. 

During 2004, the Board monitored closely the effectiveness of the implementation of

this order, which is key to maintaining a strong feedback and improvement program
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across the defense nuclear complex. While there have been minor problems noted

with the implementation, in general it has proceeded well.

! Hoisting and Rigging Safety. The Board continued to oversee DOE’s programs,

policies, and practices in hoisting and rigging work at defense nuclear facilities. By

integrating insights from a number of field reviews, the Board provided substantive

input to DOE as it revised Standard 1090-2004, Hoisting and Rigging. As a result,

significant revisions were made to this standard that will further enhance the safety of

hoisting and rigging activities at all DOE sites.

! Functional Area Qualification Standards. During the past three years, the Board

has driven DOE to upgrade and incorporate 30 functional area qualification standards

for federal employees into the DOE directives system. During the past year, the

Board reviewed and evaluated 14 functional area qualification standards such as

nuclear explosive safety, facility maintenance, and technical training. This effort

significantly improved the technical content and rigor of the entire set of DOE

functional area qualification standards. 

5.3.2 Development of New Directives

The Board conducted a comprehensive evaluation of DOE’s use of quantitative risk

assessment and related methodologies at defense nuclear facilities. The evaluation revealed that

DOE has used quantitative risk assessment in the development of documented safety analyses

and other facility-level decision-making activities. In some cases, the results of risk assessments

appear to have influenced the selection of safety controls. The Board also found that DOE does

not appear to have a central authority (or technical resource) that oversees the use of quantitative

risk assessment. The results of the Board’s review were documented in a letter to DOE dated

April 5, 2004. In response to the Board’s observations, DOE has committed to developing a

comprehensive policy governing the use of risk assessment methodologies at defense nuclear

facilities. DOE has developed a draft policy statement and is continuing to investigate the need

for additional guidance in this area.

5.3.3 Worker Safety Rulemaking

On December 8, 2003, DOE published in the Federal Register a proposed rule on worker

protection, 10 CFR Part 851, Worker Safety and Health. This action was required under the Bob

Stump National Defense Authorization Act, Public Law 107-314, which directed DOE to

promulgate regulations on worker safety and health, rather than rely exclusively on a contractual

approach. The Board conducted a detailed review of the proposed rule and found that as written,

it would have greatly lessened the safety requirements embedded in DOE Order 440.1A, Worker

Protection Management for DOE Federal and Contractor Employees. The Board so informed

the Secretary by letter dated January 29, 2004. The Secretary suspended the rulemaking in late

February 2004, and in the ensuing months, the Board devoted considerable resources to assisting

DOE in preparing an acceptable rule. DOE published a revised rule for public comment on

January 26, 2005.
5-6

5.3.4 Scope of the Directives System

A safety directive can only contribute to health and safety if it is imposed via contractual

terms and implemented competently. In 2004, the Board continued to oppose DOE’s illconsidered initiatives to reduce the applicability of safety orders to defense nuclear facilities. By

the end of 2004, DOE had withdrawn changes to Order 251.1A, Directives System, and formed a

working group to reexamine the applicability question. Continued intense oversight of this

matter will be continued throughout 2005.

5.4 SAFETY PROGRAMS

5.4.1 Development and Implementation of Safety Controls

The development of a comprehensive safety basis and the identification and selection of

an appropriate control set are essential cornerstones of safe operation at defense nuclear

facilities. For this reason, in 2004 the Board continued its aggressive program to review safety

bases throughout the DOE complex. These reviews revealed a number of specific instances

where improper and non-conservative assumptions and methodologies were used in the

development of safety bases. 

The Board conducted reviews of the documented safety analyses at Pantex, Los Alamos,

Hanford, Nevada Test Site, and Sandia, and evaluated the use of WIPP’s Mobile Waste

Characterization and Loading Units at other sites. Typical corrective actions include the

following:

! At the Hanford Tank Farms, DOE rewrote the Technical Safety Requirements to

reinstate key controls (such as Process Control Plans) that the Board discovered were

improperly eliminated; lack of these controls creates a risk of retaining and releasing

significant quantities of flammable gas.

! DOE revised the Basis for Interim Operation for the WIPP Mobile Waste

Characterization and Loading Units to address the significant technical deficiencies

identified by the Board, including incorrect modeling of accident scenarios, lack of

proper documentation of accident analyses, and potentially inadequate identification

and classification of controls for protection of the public and workers.

! At Sandia National Laboratories, independent review teams confirmed systematic

weaknesses identified by the Board in the safety analyses for its nuclear facilities. In

response, NNSA and the laboratory have postponed start-up activities and reallocated

resources to correct the deficiencies in the safety analyses of the dynamic nuclear

facilities.

5.4.2 Administrative Controls

Contractors at defense nuclear facilities were required by 10 CFR Part 830 to submit 

documented safety analyses and controls to DOE by April 2003. To meet this requirement, 
5-7

many contractors had to develop new analyses and, perhaps more importantly, new safety

controls. In many cases, the choice of these new safety controls was limited because the

equipment installed had been built years or even decades ago. This led some contractors to

reclassify existing equipment as safety-related and to rely on safety-related administrative

controls rather than engineered features. In Recommendation 2002-3, the Board advised DOE to

improve its guidance for the use of administrative controls at defense nuclear facilities. 

Responding to the recommendation, DOE developed and implemented a plan to improve the

reliability and effectiveness of administrative controls that serve safety functions. As a key step

in the implementation plan, DOE has developed and issued a new standard, Specific

Administrative Controls (DOE-STD-1186). DOE has also developed a set of training materials

used to introduce the new requirements to field personnel. 

5.4.3 Active Confinement Ventilation

During the past few years, the Board has reviewed numerous safety analysis reports and

documented safety analyses for defense nuclear facilities. In certain cases, the Board has noticed

that the functional classification of ventilation systems in existing defense nuclear facilities is 

being downgraded from safety-class or safety-significant, and the building structure is being

relied upon to confine the release of radioactive material should an accident occur. This

approach is unacceptable because: (1) it relies on calculations that do not account for large

uncertainties; (2) it is based on analytically-determined building leak path factors found by

combining several computer programs not specifically designed for this purpose; and (3) it is

generally impossible for these programs to model the true conditions of a real accident because

of the uncertain behavior of the workers and emergency crews responding to the event. On

December 7, 2004, the Board issued Recommendation 2004-2, Active Confinement Systems.

(The Recommendation is reprinted in its entirety in Appendix A.) This recommendation advises

DOE to disallow primary reliance on passive confinement systems and require the use of active

confinement ventilation systems in all Hazard Category 2 and 3 facilities and projects.

5.4.4 Quality Assurance

During 2004, the Board continued to demand that DOE improve the implementation of

quality assurance (QA) Programs. While DOE has completed most of the commitments in its

Quality Assurance Improvement Plan, there remain frequent QA-related breakdowns at both the

activity level and the institutional level. As part of this plan, NNSA has developed a set of

quality assurance verification questions on design, procurement, fabrication, construction, and

operation. The questions were used to complete QA assessments at each NNSA site as part of

verifying that QA programs have been effectively implemented. These assessments are being

reviewed by NNSA; initial results indicate that procurement of safety equipment should be

improved. During the past year, DOE contractors formed a quality assurance working group

under the auspices of the Energy Facility Contractors Group. This group has already provided a

notification of potential weld quality issues and a guide for developing a Quality Improvement

Program. The Board views the contractors’ effort as useful, in that broad expertise can be

assembled to quickly develop and disseminate information and guidance. 
5-8

5.4.5 Software Quality Assurance

The safe design and operation of many of DOE’s defense nuclear facilities rests upon the

analysis and operational support provided by computer codes. During the past few years, the

Board has identified safety deficiencies caused by inadequate software design, implementation,

testing, configuration management, and training of personnel. For this reason, in late 2002 the

Board issued Recommendation 2002-1 to force significant changes in DOE’s policies and

practices for software quality assurance. During the past year DOE, under close scrutiny by the

Board, completed assessments of safety software at almost all defense nuclear facilities. 

Problems identified at specific sites were studied by headquarters personnel for applicability

across the complex. DOE has developed corrective actions and will implement them in 2005. 

5.4.6 Hoisting and Rigging

Throughout 2004, the Board continued to review the development and implementation of

critical hoisting and rigging activities. In a letter dated July 10, 2003, the Board provided an

assessment to DOE of the hoisting and rigging program at Pantex as well as general observations

pertaining to all sites. This assessment identified a number of weaknesses in equipment design,

reliability, maintenance, and training. During 2004, DOE made substantial safety improvements

in this program at Pantex. 

At Nevada Test Site, the Board’s review led to a letter dated January 21, 2004, in which

the Board questioned the safety classification of hoisting and rigging equipment. As a result,

DOE has redesignated as safety-class the critical safety equipment used in G-tunnel for the

handling of damaged nuclear weapons and improvised nuclear devices. On a generic level, the

Board provided technical oversight of DOE’s Hoisting and Rigging Technical Advisory

Committee, which is working on a revised hoisting and rigging standard. 

5.4.7 Criticality Safety

When closing Recommendation 97-2 in August 2003, the Board stressed the need for

aggressive self-assessment programs and expanded use of operational facility reviews and

independent oversight. The Board also requested an annual report from DOE on the status of

this program. Unfortunately, DOE’s performance to date has been unsatisfactory. DOE has

failed to review effectively each site’s nuclear criticality safety programs using knowledgeable

professionals; has not provided adequate staff for criticality safety work; and has not conducted

trending and analysis of performance indicators with sufficient rigor. In a letter dated May 21,

2004, the Board again cautioned DOE to proceed with care in the plan to relocate the Critical

Experiment Facility from the Los Alamos National Laboratory to Nevada Test Site. This

relocation could damage criticality safety programs at Los Alamos and undermine coordination

of criticality work among the Test Site, Los Alamos, and Lawrence Livermore. To highlight the

Board’s emphasis on criticality safety, a member of the Board provided the keynote presentation

on this topic at both the 2004 summer and winter meetings of the American Nuclear Society.
5-9

5.4.8 Suspect and Counterfeit Parts

The Board continued to provide oversight and technical assistance to DOE in order to

identify and prevent the introduction of suspect and counterfeit parts into safety-related or

mission sensitive applications affecting defense nuclear facilities. During the past year, DOE

discovered that valves had been procured from a major valve vendor who provided invalid

certifications. In this instance, DOE’s improved process for handling notifications appeared to

operate in a much more satisfactory manner. The Board also provided technical oversight to

DOE as it revised Order 414.1A, Quality Assurance, and accompanying guidance to ensure

inclusion of requirements and guidance to detect suspect and counterfeit parts.

5.5 TECHNICAL COMPETENCE

5.5.1 Training and Qualification of DOE and Contractor Personnel

The Board has long recognized the value and necessity of intense training programs for 

operators and key health and safety personnel at defense nuclear facilities. Based on the results

of a number of reviews and inquiries, the Board determined in 2003 that many NNSA facilities

were not performing audits of facility training programs as required by DOE Order 5480.20A,

Personnel Selection, Qualification, and Training Requirements for DOE Nuclear Facilities. In

an April 2003 letter to NNSA, the Board pointed out that these training deficiencies may affect

the contractor’s ability to maintain and improve conduct of operations. 

By August 2004, the Board found that senior NNSA management had not taken any

action to upgrade the programs at these three sites. In a letter to NNSA dated August 6, the

Board requested a report defining the problem within 45 days and a corrective action plan within

30 additional days. In response, NNSA has assessed the status of most of its training programs

and has developed action plans to ensure that all of the required assessments are performed in

accordance with the DOE Order 5480.20A.

5.5.2 NNSA Facility Representatives

In March 2004, the Board conducted on-site reviews of the staffing levels and training of

DOE’s facility representatives at the Pantex, Sandia, and Los Alamos Site Offices. The Board

found that both staffing and training were inadequate in all three offices, and so informed NNSA 

in a letter dated May 14, 2004. Responding on July 13, 2004, the NNSA Administrator agreed

that action was needed at all NNSA sites to strengthen the facility representative program. Since

that time, NNSA has improved its activity-specific hazard training and has developed a more

rigorous means of establishing a minimum staffing level at each office.
6-1

6. PUBLIC OUTREACH

6.1 PUBLIC MEETINGS

During 2004, the Board conducted two public meetings in Washington, D.C., regarding

DOE oversight policy.

6.2 RESPONDING TO PUBLIC REQUESTS

The Board answered numerous public requests for documents and information and

responded to 30 requests filed under the Freedom of Information Act (FOIA). The average

response time for FOIA requests was 7.1 working days, as compared with the statutory

requirement of 20 working days. The Board’s website contains a complete list of FOIA requests

processed since 2001.

6.3 ELECTRONIC ACCESS

The Board posts all essential, publicly-releasable documents on its website

(www.dnfsb.gov) in a timely manner. All documents can be downloaded in Adobe PDF format.

The Board also mails paper copies of certain documents (annual reports, technical reports, public

hearing notices, and others) to a list of more than four hundred addressees. There were four such

mailings in 2004. An initiative was begun in 2004 to offer those on the Board’s mailing list

the option of receiving documents via e-mail in lieu of paper copies. This would serve to speed

distribution of these documents, provide significant savings in printing and postal costs, and

further the Board’s E-Government initiative.

The Board continues to evaluate the effectiveness of its information security program to

ensure that it is in compliance with the requirements of the Federal Information Security

Management Act and other related standards and guidance. During 2004, the Board’s

information technology security staff upgraded computer security by measures such as

strengthening the Board’s internet firewall to prevent intrusion. The Board commissioned the

National Institute of Standards and Technology to perform an independent evaluation of its

information security program during 2004 to ensure that past improvements have been

successfully implemented and to detect any additional weaknesses.

6.4 INQUIRIES INTO HEALTH AND SAFETY ISSUES

The Board often receives information regarding potential health and safety hazards from

private citizens or from employees at defense nuclear facilities. The Board treats these matters

with the utmost seriousness by assigning members of its legal and technical staffs to investigate

or inquire further. These inquiries, which may involve interviews, review of documents, and site

visits, are continued until the Board is able to reach a technical judgment on the issues raised. If

the Board finds that a health or safety hazard exists, it takes prompt action to inform DOE and

closely monitors DOE’s corrective actions. When the Board receives information on matters

outside its jurisdiction, such as alleged criminal activities or unlawful personnel practices, it

refers the information to the appropriate federal agency for action.
6-2

During 2004, the Board directed inquiries into health and safety issues at Hanford,

Fernald, Savannah River, Los Alamos, Sandia, Lawrence Livermore, and Pantex. The Fernald

review resulted in improved safety analyses and work controls for the Silos Project. Similarly,

the reviews at the other sites led to improved safety and hazards analyses. 

6.5 SITE REPRESENTATIVE ACTIVITIES

The Board enhances its on-site health and safety oversight of defense nuclear facilities by

assigning experienced technical staff members to full-time duty at priority DOE sites: Pantex,

Hanford, Savannah River, Y-12 (Oak Ridge), Los Alamos, and as of August 9, 2004, Lawrence

Livermore. Site representatives conduct first-hand assessments of nuclear safety management to

identify health and safety concerns promptly. They meet regularly with the public, union

members, Congressional staff members, and public officials from federal, state, and local

agencies. The Board receives regular briefings from its site representatives in person and

maintains continuous contact with them using all available communications media. 
APPENDIX A

RECOMMENDATION 2004-1

RECOMMENDATION 2004-2
and "non-ignition" high-energy-density

experimental programs at NIF. Review

the overall balance and priority of

activities within the proposed plan and

the degree to which the proposed

program of NIF experiments supports

the near and long term goals of stockpile

stewardship and the overall NIF

mission. Assess the potential for NIF to

support the design and development of

new weapons. Focus on the extent to

which major stakeholders in NIF are

effectively integrated into the plan .

The mission of the Defense Science

Board is to advise the Secretary of

Defense and the Under Secretary of

Defense for Acquisitions, Technology &

Logistics on scientific and technical

matters as they affect the perceived

needs of the Department of Defense. At

these meetings, the Defense Science

Board Task Force will assess the

proposed ignition and "non-ignition"

high-energy-density experimental

programs at NIF. Review the overall

balance and priority of activities within

the proposed plan and the degree to

which the proposed program of NIF

experiments supports the near and long

term goals of stockpile stewardship and

the overall NIF mission . Assess the

potential for NIF to support the design

and development of new weapons .

Focus on the extent to which major

stakeholders in NIF are effectively

integrated into the plan .

Office of the Secretary ; Defense

in accordance with Section 10(d) of

Science Board the Federal Advisory Committee Act,

AGENCY : Department of Defense .

Pub. L . No . 92-463, as amended (5

U.S.C. app. II), it has been determined

ACTION: Notice of Advisory Committee

that these Defense Science Board Task

Meeting .

Force meetings concern matters listed in

SUMMARY: The Defense Science Board 5 U .S .C . 552b(c)(1) and (4) and that,

Task Force on Employment of the

accordingly, these meetings will be

National Ignition Facility (NIF) will closed to the public .

meet in closed session on June 21-22, Dated: May 28, 2004.

2004, at Lawrence Livermore National LM. Bynum,

Laboratory. This Task Force will review Alternate OSD Federal Register Liaison

the experimental program under

Officer, Department ofDefense. development for the National Ignition

[FR Doc. 04-12726 Filed 6-4-04 ; 8 :45 am]

Facility, NIF is a key component of the

BILLING CODE 5001-46-M

National Nuclear Security

Administration's (NNSA's) Stockpile

Stewardship Program to maintain the

nuclear weapons stockpile without

nuclear testing. The NIF is a 192-beam

laser designed to achieve fusion ignition

and produce high-energy-density

condition approaching those of nuclear

weapons. NNSA and the high-energydensity physics community have

developed a plan for activation and

early use of NIF which includes a goal

to demonstrate ignition by 2010 and

also supports high priority, non-ignition

experiments required for stockpile

stewardship . In this assessment, the task

force will assess the proposed ignition

selected on a standardized basis for

their preeminence in the field of

amputee patient care . The Board will

include members familiar with aspects

of patient care, psychosocial issues, and

family issues . Members will also be

chosen who have broad experience in

areas which impact on quality

improvement in amputee patient care

such as education and training . The

Board shall meet at least twice each year

to monitor the amputee patient care

programs and services and insure

effective organizational planning . The

Board will also ensure that through the

collaboration of a multi-disciplinary

team, the U .S . Army Amputee Patient

Care Program is providing worldrenowned amputee care, assisting their

patients as they return to the highest

levels of physical, psychological, and

emotional well being.

FOR FURTHER INFORMATION CONTACT:

Contact Ms . Jennifer Spaeth, DoD

Committee Management Officer, 703-

588-8151 .

Dated: May 28, 2004 .

L.M. Bynum,

Alternate OSD Federal Register Liaison

Officer, Department of Defense . [FR Doc. 04-12725 Filed 6-4-04 ; 8 :45 am]

BILLING CODE 5001-08-M

DEPARTMENT OF DEFENSE

Federal Register/Vol. 69, No . 109 /Monday, June 7, 2004 /Notices

DEPARTMENT OF DEFENSE

Department of the Army

Army Science Board ; Notice of Open

Meeting

In accordance with section 10(a)(2) of

the Federal Advisory Committee Act

(Pub. L . 92-463), announcement is

made of the following Committee

Meeting :

Name of Committee: Army Science Board

(ASH) .

Date(s) ofMeeting: 10 & 11 June 2004 .

A- 1

DEFENSE NUCLEAR FACILITIES

SAFETY BOARD

[Recommendation 2004-1J

Oversight of Complex, High-Hazard

Nuclear Operations

AGENCY: Defense Nuclear Facilities

Safety Board.

ACTION : Notice, recommendation .

31815

Time(s) of Meeting: 0800-1700, 10 June

2004; and 0800-1700, 11 June 2004 .

Place : Hilton Hotel, Crystal City, VA .

1 . Agenda: The Army Science Board FY04

Summer Studies, Force Balance and FCS

Urban Operations are holding a plenary

meeting on the 10th & 11th of June 2004 . The

meeting will be held at the Hilton Hotel in

Crystal City, VA. The meeting will begin at

0800 hrs on the 10th and will end at

approximately 1700 hrs on the 11th. For

further information regarding Force Balance,

please contact LTC Al Alkee @ (703)-601-

0676 or e-mail

@Alvin.Klee@ocar.army.pentagon .mil . For

FCS Urban Operations, please contact MAJ

Al Visconti @ (865) 574-8798 or e-mail

wiscontiaj@ornl.go v.

Wayne Joyner,

Program Support Specialist, Army Science

Board.

[FR Doc . 04-12802 Filed 6-4-04 ; 8 :45 am]

BILLING CODE 3710-08-IA . SUMMARY: The Defense Nuclear

Facilities Safety Board has unanimously

approved Recommendation 2004-1, for

DOE to consider . Recommendation

2004-1 deals with Oversight of

Complex, High-Hazard Nuclear

Operations .

DATES : Comments, data, views, or

arguments concerning the

recommendation are due on or before

July 7, 2004 .

ADDRESSES : Send comments, data,

views, or arguments concerning this

recommendation to : Defense Nuclear

Facilities Safety Board, 625 Indiana

Avenue, NW., Suite 700, Washington,

DC 20004-2001 .

FOR FURTHER INFORMATION CONTACT:

Kenneth M . Pusateri or Andrew L.

Thibadeau at the address above or

telephone (202) 694-7000 .

Dated : June 1, 2004.

John T . Conway,

Chairman .

[Recommendation 2004-1]

Oversight of Complex, High-Hazard

Nuclear Operations

Dated : May 21, 2004.

Background

In furtherance of its statutory duty to

oversee the Department of Energy's
31816

(DOE) protection of workers and the

public from hazards at defense nuclear

facilities operated for DOE and the

National Nuclear Safety Administration

(NNSA), the Defense Nuclear Facilities

Safety Board (Board) conducted eight

public hearings to examine DOE's

current and proposed methods of

ensuring safety at its defense nuclear

facilities .

In these hearings, the Board also

sought to benefit from the lessons

learned as a result of investigations

conducted following the Columbia

Space Shuttle disaster and the discovery

of the deep corrosion in the reactor

vessel head at the Davis-Besse Nuclear

Power Plant. The Board received

testimony from representatives of the

Nuclear Regulatory Commission; the

Naval Reactors Program; the Columbia

Accident Investigation Board ; the

Deputy Secretary of Energy; the

Administrator of NNSA; DOE's Under

Secretary of Energy, Science and

Environment ; DOE's Assistant Secretary

for Environment, Safety, and Health;

and selected site managers of DOE's

facilities, senior contractor managers,

and members of the public.

The overall objective of the hearings

was to gather information that could be

helpful in assessing DOE's proposals for

changing the methods it uses for

contract management and nuclear safety

oversight, as they have been controlled

through the DOE Directives System .

NNSA has proposed shifting

responsibility for safety oversight from

DOE Headquarters to the DOE field

offices and site contractors . The key

question the Board sought to address

was: Will modifications proposed by

DOE/NNSA to organizational structure

and practices, as well as increased

emphasis on productivity, improve or

reduce safety, and increase or decrease

the possibility of a high-consequence,

low-probability nuclear accident?

DOE's programs for national security

and environmental protection are

complex, with potentially high

consequences if not safely performed .

Mishandling of nuclear materials and

radioactive wastes could result in

unintended nuclear criticality, dispersal

of radioactive materials, and even

nuclear detonation . DOE has a long and

successful history of nuclear operations,

during which it has established a

structure of requirements directed to

achieving nuclear safety . That structure

is based on such methods as defense in

depth, redundancy of protective

measures, robust technical competence

in operations and oversight, extensive

research and testing, a Directives

System embodying nuclear safety

requirements, Integrated Safety

Federal Register/Vol . 69, No. 109 /Monday, June 7, 2004/Notices

Management, and processes to ensure

safe performance .

The United States owns the defense

nuclear facilities at which its programs

are carried out by a government

agency-DOE . Each such facility is

operated by a contractor that was

selected by DOE on the basis of being

best suited to conduct the work for DOE

at that site. Under the original Atomic

Energy Act of 1946 and continuing to

date in the Atomic Energy Act of 1954,

as amended, the government officials in

charge (i.e ., the Secretary of Energy and

other line officers) have a statutory

responsibility to protect health and

minimize danger to life or property . In

any delegation of responsibility or

authority to lower echelons of DOE or

to contractors, the highest levels of DOE

continue to retain safety responsibility .

While this responsibility can be

delegated, it is never ceded by the

person or organization making the

delegation. Contractors are responsible

to DOE for safety of their operations,

while DOE is itself responsible to the

President, Congress, and the public.

This reality was highlighted during

the course of the Board's hearings . Many

important lessons were cited in the

testimony provided. These included the

importance of a centralized and

technically competent oversight

authority, central control of technical

safety requirements and waivers for

departure from those requirements, an

ability to operate in a decentralized

mode when appropriate, a willingness

to accept criticisms, the need for

retention of technical expertise and

capabilities at high levels of any

organization in which technical failure

could have high consequences, and an

awareness that complacency can arise

from a history of successes . DOE

representatives testified that DOE's

attention to safety has continued to

improve with better on-site oversight

and self-assessment programs, use of

Integrated Safety Management, careful

attention to safety statistics, and

stabilization and disposal of high risk

nuclear materials. However, cause for

concern with regard to the potential

increase in the possibility of nuclear

accidents was also evident in: (1) The

increased emphasis on productivity at

the possible expense of safety, (2) the

loss of technical competency and

understanding at high levels of DOE's

and NNSA's organizational structure, (3)

the apparent absence of a strong safety

research focus, and (4) the reduced

central oversight of safety .

Clearly, safety performance can

benefit from attention to detail and

lessons learned from small incidents

and minor accidents . However, failures

A-2

leading to high-consequence, lowprobability accidents would likely have

their roots in interactions between

engineering failures and improper

human actions . Because the

consequences of large nuclear accidents

would be unacceptable, the nuclear

weapons complex cannot permit them

to occur. While the potential for such

accidents cannot be completely

eliminated, their likelihood can be held

to an insignificant level by rigorous

attention to Integrated Safety

Management with technical and

operational excellence based on nuclear

safety standards subject to rigorous

oversight . In addition, nuclear safety

must be founded on solid research,

analysis, and testing to ensure an

adequate understanding of energetic

initiating mechanisms under off-normal

conditions .

DOE has taken some preliminary

steps toward its proposed changes in

safety practices . These actions may have

contributed to some unfortunate

consequences, such as the following:

•A glovebox fire occurred at the

Rocky Flats closure site, where, in the

interest of efficiency, a generic

procedure was used instead of one

designed to identify and control specific

hazards. Apparently, success of the

cleanup project resulted in management

complacency . DOE site management

had given the impression that safety was

less important than progress, and

contract management had not

emphasized oversight of work control

processes . •

Downsizing of safety expertise has

begun in NNSA's NA-53 organization,

while field organizations such as the

Albuquerque Service Center have not

developed an equivalent technical

capability in a timely manner . As a

result, NNSA field offices are left

without an adequate depth of

understanding of such important

matters as seismic analysis and design,

training of nuclear workers, and

protection against unintended

criticality . •

DOE's Office of Environmental

Safety and Health, with assistance from

some sites and contractors, has

reviewed DOE Directives to simplify

safety requirements, with the objective

of supporting accelerated operations

that are also more efficient. This shift

has led to proposals for downgrading

some-worker safety Directives to the

level of guidance and modifying some

radiation protection requirements . It has

also led to a proposed modification of

the Order on Worker Safety and Health

to reduce requirements for protecting

workers from the consequences of fires,
explosions, and discharges from highpressure systems .

Proposed modifications to DOE and

NNSA's organizational structure,

manpower, contract management,

oversight policies and practices, and

safety directives could have unintended

consequences . These include reduction

of defense in depth, potentially

inconsistent safety-related decisions

caused by decentralization of safety

authority, emphasis on performance as

opposed to safety, and reduction of

technical capability at key points in the

organizational structure . DOE and

NNSA line managers could be left with

inadequate awareness of safety issues .

As a result of testimony it has

received, the Board is not convinced of

the benefit of the changes to'DOE's and

NNSA's organizational structure and

practices as they have been described.

The Board cautions that if any such

changes are, made, they must be done

formally and deliberatively, with due

attention given to unintended safety

consequences that could reduce the

present high level of nuclear safety.

DOE should take full advantage of

lessons learned from safety problems

discovered by National Aeronautics and

Space Administration and Nuclear

Regulatory Commission, and it should

learn from the success of the good

organizational and safety practices

championed by the Naval Reactors

Program. The Board needs to be sure

that any fundamental reorganization

does not degrade nuclear safety, and

that the likelihood of a serious accident,

facility failure, construction problem, or

nuclear incident will not be increased as

a result of well-intentioned changes .

As a result of testimony received at

the public hearings and the potential

effects on safety at defense nuclear

facilities outlined above, the Board

recommends:

1 . That delegation of authority for

nuclear safety matters to field offices

and contractors be contingent upon the

development and application of criteria

and implementing mechanisms to

ensure that :

o

a. Oversight responsibility includes

the capability for examining, assessing,

and auditing by all levels of the DOE

rgan ization,

. The technical capability and

appropriate experience for effective

safety oversight is in place, and

c . Corrective action plans consistent

with recommendations resulting from

internal DOE and NNSA reviews of the

Columbia accident and the Davis-Besse

incident are issued .

2 . That to ensure that any features of

the proposed changes will not increase

the likelihood of a low-probability,

Federal Register / Vol . 69, No . 109 / Monday, June 7, 2004 / Notices

high-consequence nuclear accident,

DOE and NNSA take steps to :

a. Empower a central and technically

competent authority responsible for

operational and nuclear safety goals,

expectations, requirements, standards,

directives, and waivers ;

b . Ensure the continued integration

and support of research, `analysis, and

testing in nuclear safety technologies ;

and

c. Require that the principles of

Integrated Safety Management serve as

the foundation of the implementing

mechanisms at the sites .

3 . That direct and unbroken line of

roles and responsibilities for the safety

of nuclear operations-from the

Secretary of Energy and the NNSA

Administrator to field offices and sitesbe insured according to appropriate

Functions, Responsibilities, and

Authorities documents and Quality

Assurance Implementation Plans .

4 . That prior to final delegation of

authority and responsibility for defense

nuclear safety matters to the field offices

and contractors, DOE and NNSA

Program Secretarial Officers provide a

report to the Secretary of Energy

describing the results of actions taken in

conformance with the above

recommendations.

John T. Conway,

Chairman .

(FR Doc . 04-12741 Filed 6-4-04; 8:45 am)

BIwNG CODE 3670-01-P

DEPARTMENT OF EDUCATION

Submission for OMS Review ;

Comment Request

AGENCY: Department of Education .

SUMMARY: The Leader, Regulatory

Information Management Group, Office

of the Chief Information Officer invites

comments on the submission for OMB

review as required by the Paperwork

Reduction Act of 1995 .

DATES: Interested persons are invited to

submit comments on or before July 7,

2004.

ADDRESSES: Written comments should

be addressed to the Office of

Information and Regulatory Affairs,

Attention : Alice Thaler, Desk Officer,

Department of Education, Office of

Management and Budget, 725 17th

Street, NW., Room 10222, New

Executive Office Building, Washington,

DC 20503 or faxed to (202) 395-6974.

SUPPLEMENTARY INFORMATION: Section

3506 of the Paperwork Reduction Act of

1995 (44 U.S.C. chapter 35) requires that

the Office of Management and Budget

(OMB) provide interested Federal

A-3

31817

agencies and the public an early

opportunity to comment on information

collection requests. OMB may amend or

waive"the requirement for public

consultation to the extent that public

participation in the approval process

would defeat the purpose of the

information collection, violate State or

Federal law, or substantially interfere

withlany agency's ability to perform its

statutory obligations . The Leader,

Regulatory Information Management

Group, Office of the Chief Information

Officer, publishes that notice containing

proposed information collection

requests prior to submission of these

requests to OMB . Each proposed

information collection, grouped by

office, contains the following: (1) Type

of review requested, e.g., new, revision,

extension, existing or reinstatement ; (2)

Title ; (3) Summary of the collection ; (4)

Description of the need for, and

proposed use of, the information ; (5)

Respondents and frequency of

collection ; and (6) Reporting and/or

Recordkeeping burden . OMB invites

public comment.

Dated: June 1, 2004 .

Angela C. Arrington,

Leader, Regulatory Information Management

Group, Office of the ChiefInformation Officer.

Federal Student Aid

Type of Review: New.

Title: Final Performance Report for

Preparing Tomorrow's Program To Use

Technology (PT3) Grant Program.

Frequency: One time .

Affected Public : Not-for-profit

institutions ; Businesses or other forprofit; State, local, or tribal gov't, SEAs

or LEAs .

Reporting and Recordkeeping Hour

Burden:

Responses: 197 .

Burden Hours : 3,940 .

Abstract. This is the final

performance report for approximately

197 PT3 FY 2000, 2001, and 2003

grantees . It is required by statute, Title

II, Part B, by EDGAR 75 .590, and by the

Government Performance and Results

Act (GPRA) .

Requests for copies of the submission

for OMB review ; comment request may

be accessed from http ://

www.edicsweb .ed.gov, by selecting the

"Browse Pending Collections" link and

by clicking on link number 2486. When

you access the information collection,

click on "Download Attachments" to

view. Written requests for information

should be addressed to U.S. Department

of Education, 400 Maryland Avenue,

SW., Potomac Center, 9th Floor,

Washington, DC 20202-4700. Requests

may also be electronically mailed to the
DEPARTMENT OF COMMERCE

National Oceanic and Atmospheric

Administration

P .D.110404C]

Endangered Species ; File No. 1510

AGENCY: National Marine Fisheries

Service (NMFS), National Oceanic and

Atmospheric Administration (NOAA),

Commerce.

ACTION : Receipt of application.

SUMMARY: Notice is hereby given that

the Liberty Science Center (Richard

Weddle, Principal Investigator), 251

Phillip Street, Jersey City, New Jersey

07305, has applied in due form for a

permit to take shortnose sturgeon

(Acipenser brevirostrum) for purposes of

enhancement through educational

display.

DATES: Written, telefaxed, or e-mail

comments must be received on or before

January 14, 2005 .

ADDRESSES: The application and related

documents are available for review

upon written request or by appointment

in the following office(s) :

Permits, Conservation and Education

Division, Office of Protected Resources,

NMFS, 1315 East-West Highway, Room

13705, Silver Spring, MD 20910; phone

(301)713-2289; fax (301)713-0376 ; and

Northeast Region, NMFS, One

Blackburn Drive, Gloucester, MA

01930-2298; phone (978)281-9200 ; fax

(978)281-9371 .

Written comments or requests for a

public hearing on this application

should be mailed to the Chief, Permits,

Conservation and Education Division,

F/PR1, Office of Protected Resources,

NMFS, 1315 East-West Highway, Room

13705, Silver Spring, MD 20910 . Those

individuals requesting a hearing should

set forth the specific reasons why a

hearing on this particular request would

be appropriate .

Comments may also be submitted by

facsimile at (301)713-0376, provided

the facsimile is confirmed by hard copy

submitted by mail and postmarked no

later than the closing date of the

comment period.

Comments may also be submitted by

e-mail. The mailbox address for

providing email comments is

NMFS.PriComments@noaa .go v. Include

in the subject line of the e-mail

comment the following document

identifier: File No . 1510.

FOR FURTHER INFORMATION CONTACT:

Jennifer Jefferies or Amy Sloan,

(301)713-2289.

SUPPLEMENTARY INFORMATION: The

subject permit is requested under the

Federal Register/Vol . 69, No. 240/Wednesday, December 15, 2004/Notices

authority of the Endangered Species Act

of 1973, as amended (ESA; 16 U.S .C.

1531 et seq.) and the regulations

governing the taking, importing, and

exporting of endangered and threatened

species (50 CFR 222-226) . The Liberty Science Center proposes

to receive and use five captive-bred,

non-releaseable shortnose sturgeon for

the purpose of educational display. The

proposed project of displaying

endangered cultured shortnose sturgeon

responds directly to a recommendation

from the NMFS recovery outline for this

species. In addition, the facility would

create a public education program and

exhibit to increase awareness of the

shortnose sturgeon and its status . The

proposed project would educate the

public on shortnose sturgeon life history

and the reasons for its declining

numbers.

Dated : December 9, 2004 .

Jennifer Skidmore,

Acting Chief Permits, Conservation and

Education Division, Office of Protected

Resources, National Marine Fisheries Service.

[FR Doc . 04-27430 Filed 12-14-04 ; 8 :45 am]

BILLING CODE 3510-22-S

SUPPLEMENTARY INFORMATION : On July

15, 2004, notice was published in the

Federal Register (69 FR 42424) that a

request for a permit amendment to take

the species identified above had been

submitted by the above-named

individual . The requested amendment

has been issued under the authority of

the Marine Mammal Protection Act of

1972% as amended (16 U.S .C. 1361 et

seq.), and the Regulations Governing the

Taking and Importing of Marine

Mammals (50 CFR part 216) .

The permit holder is authorized to

capture, sedate, tag (flipper and

instrument), sample, and release up to

30 adult southern elephant seals ; tag

and weigh up to 50 immature elephant

seals ; conduct population censussing ;

and incidentally disturb up to 100

elephant seals during research . The

purpose of this project is to examine the

foraging behavior and habitat utilization

of the southern elephant seal in the

Western Antarctic Peninsula .

In compliance with the National

Environmental Policy Act of 1969 (42

U.S .C . 4321 et seq.), a final

determination has been made that the

activity proposed is categorically

excluded from the requirement to

DEPARTMENT OF COMMERCE

prepare an environmental assessment or

environmental impact statement .

Dated : December 8, 2004 .

Stephen L. Leathery,

Chief, Permits, Conservation and Education

Division, Office of Protected Resources,

National Marine Fisheries Service .

[FR Doc . 04-27431 Filed 12-14-04 ; 8:45 am]

BILLING CODE. 3510-22-S

National Oceanic and Atmospheric

Administration

[I.D .120604A]

Marine Mammals ; File No. 87-1593

AGENCY: National Marine Fisheries

Service (NMFS), National Oceanic and

Atmospheric Administration (NOAA),

Commerce.

ACTION: Issuance of permit amendment .

SUMMARY: Notice is hereby given that

Daniel Costa, Ph.D ., University of

California, Santa Cruz, Long Marine

Lab, 100 Shaffer Road, Santa Cruz, CA

95060, has been issued an amendment

to Permit No . 87-1593 conduct

scientific research on southern elephant

seals . (Mirounga leonina) .

ADDRESSES: The permit and related

documents are available for review

upon written request or by appointment

in the following office(s) :

Permits, Conservation and Education

Division, Office of Protected Resources,

NMFS, 1315 East-West Highway, Room

13705, Silver Spring, MD 20910 ; phone

(301)713-2289 ; fax (301)713-0376 ; and

Southwest Region, NMFS, 501 West

Ocean Blvd., Suite 4200, Long Beach,

CA 90802-4213 ; phone (562)980-4001 ; fax (562)980-4018. .

FOR FURTHER INFORMATION CONTACT:

Amy Sloan or Ruth Johnson, (301)713-

2289.

A-4

DEFENSE NUCLEAR FACILITIES

SAFETY BOARD

[Recommendation 2004-21

Active Confinement Systems

AGENCY: Defense Nuclear Facilities

Safety Board.

ACTION: Notice, recommendation .

75047

SUMMARY: The Defense Nuclear

Facilities Safety Board has unanimously

approved Recommendation 2004-2, for

DOE to consider . Recommendation

2004-2 deals with the confinement of

hazardous materials at defense nuclear

facilities in the Department of Energy

complex.

DATES: Comments, data, views, or

arguments concerning the

recommendation are due on or before

January 14, 2005 .

ADDRESSES: Send comments, data,

views, or arguments concerning this

recommendation to: Defense Nuclear
75048

Federal Register/Vol . 69, No. 240 /Wednesday, December 15, 2004 /Notices

Facilities Safety Board, 625 Indiana

Avenue, NW., Suite 700, Washington,

DC 20004-2001 .

FOR FURTHER INFORMATION CONTACT:

Kenneth M. Pusateri or Andrew L .

Thibadeau at the address above or

telephone (2021694-7000.

Dated : December 10, 2004.

A.J. Eggenberger,

Vice Chairman .

Recommendation 2004-2 to the Secretary of

Energy, Pursuant to 42 U .S .C. 2286a(a)(5),

Atomic Energy Act of 1954, As Amended

Dated . December 7, 2004 . There is a long-standing safety practice in

the design, construction, and operation of

nuclear facilities to build-in and maintain

structures, systems, and components that

contain or confine radioactive materials . The

Department of Energy (DOE) establishes

requirements to ensure such containment or

confinement. In the hierarchy of safety_

controls, passive design features are preferred

over active systems ; however, controls must

be capable of performing their intended

function. Passive confinement systems are

not necessarily capable of containing

hazardous materials with confidence because

they allow a quantity of un filtered air

contaminated with radioactive material to be

released from an operating nuclear facility

following certain accident scenarios . Safety

related active confinement ventilation

systems will continue to function during an

accident, thereby ensuring that radioactive

material is captured by filters before it can be

released into the environment.

The enclosed technical report, DNFSB/

TECH-34, Confinement ofRadioactive

Materials at Defense Nuclear Facilities,

compares the benefits of including a safetyrelated active confinement ventilation system

to those of relying only on a passive

confinement system. This technical report

illustrates that using only a passive

confinement system for an existing or new

defense nuclear processing facility would not

account for many safety considerations such

as post-accident monitoring and response,

and may result in the release of an

undeterminable amount of radioactive

materials, the consequences of which could

approach that of the unmitigated scenarios .

The Defense Nuclear Facilities Safety

Board (Board) has advised DOE in various

ways during the past decade regarding the

need to pay increased attention to the design

and operational reliability of the confinement

ventilation systems at defense nuclear

facilities . These Board efforts include

transmittal of a technical report on May 31,

1995, Overview of Ventilation Systems at

Selected DOE Plutonium Processing and

Handling Facilities, a letter to the Deputy

Secretary of Energy dated July 8, 1999, and

Recommendation 2000-2, Configuration

Management, Vital Safety Systems, on March

8, 2000. This advice has helped DOE improve

the reliability of its confinement ventilation

systems . However, DOE requirements have

become less prescriptive during the last

decade as DOE Order 6430.1A, General

Design Criteria Manual, was replaced with

DOE Order 420 .1, Facility Safety, and its

subsequent revisions . Furthermore, it has

become apparent that the Board's advice on

confinement systems is not being rigorously

pursued as evidenced by the following : •

On December 27, 2002, the Board sent a

letter to the National Nuclear Security

Administration (NNSA) regarding the

confinement concept used for the Highly

Enriched Uranium Materials Facility at the

Y-12 National Security Complex . The

proposed confinement concept was based on

isolating the radioactive material in the

building using a passive confinement system

under certain abnormal events . The Board

communicated safety concerns associated

with this concept in the letter; subsequently,

the confinement concept for HEUMF was

modified to adopt a safety-related active

ventilation system.

•On April 12, 2004, the Board sent a letter

to the Administrator of NNSA regarding

similar safety issues related to the

confinement systems for the plutonium

facility at the Lawrence Livermore National

Laboratory. The proposed approach utilized

passive confinement of radioactive material

from the facility during certain accident

scenarios . Further, because the offsite dose

consequences of such an unfiltered release

were calculated to be below DOE's evaluation

guideline (25 rem), the proposal included

downgrading the existing safety-class active

confinement ventilation system to a safetysignificant system. The Board believed that

the new approach was inconsistent with a

defense-in-depth philosophy . Subsequently,

the Livermore Site Office commissioned an

independent calculation of the amount of the

unfiltered release. These calculations yielded

results that were an order of magnitude

greater than the original building leakage

estimates-clearly indicating that significant

uncertainties existed in the analytical

techniques . As a result, NNSA decided to

maintain the existing safety-class active

confinement ventilation system. •

On August 27, 2004, the Board sent a

letter to the Under Secretary of Energy

regarding the confinement approach

proposed for the Salt Waste Processing

Facility at the Savannah River Site . The

confinement concept for this new facility is

based on isolation of the process building

using passive confinement during\accident

scenarios. The Board suggested that the salt

waste facility should be designed with a

safety-related active ventilation system .

A number of existing facilities (including

the TA-55 Plutonium Facility, the Device

Assembly Facility, and the Hanford

Evaporator) rely on passive or non-safety

related confinement systems. More

importantly, designs for proposed facilities

(including Chemistry and Metallurgy

Research Replacement Facility and the Salt

Waste Processing Facility) are based on the

same passive confinement concept and use

an assumed quantitative value for the

building leak path factor as a design

criterion.

These examples illustrate two primary

concerns. First, a reliance on calculations

that do not appropriately account for large

uncertainties is not defensible. These

analytically determined building leak path

A-5

factors are based on a combination of several

computer programs that were not specifically

designed for this purpose . Furthermore, it is

generally impossible for these programs to

model the true conditions of a real accident

because of the uncertain behavior of the

workers and emergency crews responding to

the event.

Second, these examples represent a

fundamental change in DOE's approach to

protection of the public near defense nuclear

facilities . DOE appears to be using the

evaluation guideline of 25 rem exposure at

the site boundary as a design criterion and

an allowable dose to the public . This is

contrary to the Board's July 8, 1999 letter to

the Deputy Secretary of Energy that states

"the 25 rem evaluation guideline is not to be

treated as a design acceptance criterion nor

as a justification for nullifying the general

design criteria relative to defense-in-depth

safety measures ." It is also contrary to DOESTD-3009 that states that the 25 rem

evaluation guideline "is not to be treated as

a design acceptance criterion." However, the

Board continues to see 25 rem at the site

boundary used as an acceptance criterion for

the performance of confinement systems. The

Board is concerned that in these examples

DOE and its contractors are underestimating

the significance of the performance

requirements for a confinement ventilation

system and are relying on questionable

calculations of offsite doses to evaluate

performance . The Board reiterates that the 25

rem evaluation guideline is solely to be used

for guidance for the classification of safety

controls, and not as an acceptable dose to the

public for the purpose of designing or

operating defense nuclear facilities .

Notwithstanding the concerns discussed

above, DOE continues to pursue a passive

confinement approach in the design of some

new nuclear facilities that have the potential

for a radiological release . The Board

recognizes that DOE's defense nuclear

complex is comprised of a wide variety of

nuclear facilities with an equally diverse

range of materials, forms, activities, and

proximities to the public . For this reason, it

is difficult to prescribe a single, broadlyapplicable design requirement . However, in

light of the examples discussed above, the

Board believes a more prescriptive design

requirement is needed .

The Board further recognizes that certain

Hazard Category 2 and 3 defense nuclear

facilities may not benefit significantly from

an active confinement ventilation system. An

example would be a facility that stores

radioactive material in protected, safety-class

containers . Other examples may be certain

tritium facilities, outside storage locations,

burial grounds, or facilities with planned

declining nuclear material inventories and

scheduled for decommissioning in the near

future. This recommendation is not meant to

require an active confinement ventilation

system in all such cases .

Therefore, the Board recommends that

DOE:

1 . Disallow reliance on passive

confinement systems and require an active

confinement ventilation system for all new

and existing Hazard Category 2 defense

nuclear facilities with the potential for a
radiological release. These systems are

expected to be classified as safety-class or

safety-significant as required by a

conservative application of DOE-approved

methodology, and should be designed and

maintained to function during abnormal and

accident conditions . Exceptions to such

classifications should be approved at a level

in DOE that ensures a consistent,

conservative approach throughout the

complex.

2. Disallow reliance on passive

confinement systems and require an active

confinement ventilation system for all new

and existing Flazard Category 3 defense

nuclear facilities with the potential for a

radiological release. These systems would

not ordinarily be classified as safety-class or

safety-significant unless such designation is

required by the DOE-approved methodology .

3 . Revise all applicableDOE directives

pertaining to operation of existing facilities,

design and construction of new facilities, and

major modifications to existing facilities, in

accordance with Items 1 and 2 above . These

revisions should include guidance for

determining when a facility would not

benefit from an active confinement

ventilation system.

4 . Assess existing facilities, ongoing major

modifications, and new design/construction

projects, to ensure that :

(a) The confinement strategy described

above is implemented, and

(b) The 25 rem evaluation guideline is used

solely for classification of safety controls .

Section 42 U.S .C. 2286d(e) provides

authority to the Secretary of Energy to

"implement any such Recommendation (or

part of any such Recommendation) before,

on, or after the date on which the Secretary

of Energy transmits the implementation plan

to the Board under this subsection ." The

Board suggests that the Secretary of Energy

consider taking action on Item 4 above in

parallel with the development of an

Implementation Plan for this

Recommendation.

In addition, the Board's Recommendation

2004-1, Oversight of Complex, High-Hazard

Nucleat Operations, addresses the need for

complex-wide consistency in the application

of DOE requirements and expectations. The

Board expects the mechanisms established in

response to Recommendation 2004-1 would

likewise ensure consistent, conservative

implementation of the confinement

requirement provided here .

John T. Conway,

Chairman .

[FR Doe. 04-27426 Filed 12-14-04 ; 8:45 am]

BILLING CODE 3670-01-P

DEPARTMENT OF ENERGY

[Docket No. EA-274-A]

Application To Export Electric Energy ;

Wisconsin Public Service Corporation

AGENCY: Office of Fossil Energy, DOE.

Federal Register/ Vol. 69, No. 240/Wednesday, December 15, 2004 /Notices

SUMMARY: Wisconsin Public Service

Corporation (WPSC) has applied to

renew its authority to transmit electric

energy from the United States to Canada

pursuant to section 202(e) of the Federal

Power Act.

DATES: Comments, protests or requests

to intervene must be submitted on or

before January 14, 2005 .

ADDRESSES: Comments, protests or

requests to intervene should be

addressed as follows : Office of Coal &

Power Import/Export (FE-27), Office of

Fossil Energy, U.S . Department of

Energy, 1000 Independence Avenue,

SW., Washington, DC 20585-0350 (FAX

202-287-5736) .

FOR FURTHER INFORMATION CONTACT:

Xavier Puslowski (Program Office) 202-

586-4708 ,or Michael Skinker (Program

Attorney) 202-586-2793 .

SUPPLEMENTARY INFORMATION : Exports of

electricity from the United States to a

foreign country are regulated and

require authorization under section

202(e) of the Federal Power Act (FPA)

(16 U.S.C. 824a(e)) .

On February 6, 2003, the Office of

Fossil Energy (FE) of the Department of

Energy (DOE) issued Order No . EA-274

authorizing WPSC to transmit electric

energy from the United States to Canada

as a power marketer. That two year

authorization will expire on February 6,

2005.

On November 30, 2004, FE received

an application from WPSC to renew its

authorization to transmit electric energy

from the United States to Canada for a

five-year term. WPSC proposes to

arrange for the delivery of those exports

over the international transmission

facilities owned by Basin Electric Power

Cooperative, Bonneville Power

Administration, Eastern Maine Electric

Cooperative, International Transmission

Company, Joint Owners of the Highgate

Project, Long Sault, Inc ., Maine Electric

Power Company, Maine Public Service

Company, Minnesota Power, Inc .,

Minnkota Power Cooperative, New York

Power Authority, Niagara Mohawk

Power Corporation, Northern States

Power, Vermont Electric Company and

Vermont Electric Transmission

Company.

The construction of each of the

international transmission facilities to

be utilized by WPSC, as more fully

described in the application, has

previously been authorized by a

Presidential permit issued pursuant to

Executive Order 10485, as amended .

Procedural Matters: Any person

desiring to become a party to these

proceedings or to be heard by filing

comments or protests to this application

should file a petition to intervene,

A-6

comment or protest at the address

provided above in accordance with

§§ 385 .211 or 385 .214 of the FERC's

Rules of Practice and Procedures (18

CFR 385.211, 385 .214) . Fifteen copies of

each petition and protest should be filed

with the DOE on or before the dates

listed above .

Comments on the WPSC application

to export electric energy to Canada

should be clearly marked with Docket

EA-274-A. Additional copies are to be

filed directly with Dennis M. Derricks,

Director, Regulatory Policy & Analysis,

Wisconsin Public Service Corporation,

700 North Adams Street, P .O . Box

19001, Green Bay, WI 54307-9001, and

David Martin Connelly, Esquire, Bruder,

Gentile & Marcoux, L .L .P, 1701

Pennsylvania Avenue, NW ., Suite 900,

Washington, DC 20006-15807 .

Copies of this application will be

made available, upon request, for public

inspection and copying at the address

provided above or by accessing the

Fossil Energy Home Page at http ://

www.fe.doe.gov. Upon reaching the

Fossil Energy Home page, select

"Electricity Regulation," and then

"Pending Proceedings" from the options

menus.

Issued in Washington, DC, on December 8,

2004 .

Anthony J. Como,

Deputy Director, Electric Power Regulation,

Office of Fossil Energy.

[FR Doc . 04-27416 Filed 12-14-04; 8 :45 am]

Bi.Ltua CODE 6450-01-P

DEPARTMENT OF ENERGY

Federal Energy Regulatory

Commission

Notice of Application for Amendment

of License and Soliciting Comments,

Motions To Intervene, and Protests

December 9, 2004.

Take notice that the following

application has been filed with the

Commission and is available for public

inspection :

a. Application Type : Amendment of

License to Reflect Terms and Conditions

of Settlement Agreement.

b. Project No: 2360-144 .

c. Date Filed: November 12, 2004 .

d. Applicant: ALLETE, Inc .

e . Name of Project : St . Louis Project .

f. Location : The project is located on

the St . Louis, Beaver, and Cloquet

Rivers in Carlton and St . Louis

Counties, Minnesota.

g . Filed Pursuant to: Federal Power

Act, 16 U .S.C . 791(a) 825(r) and sections

799 and 801 .

h. Applicant Contact: Ingrid K .

Johnson, Assistant General Council,

75049
B-1

APPENDIX B

Recommendations Cited

Number Date Title

93-6 December 10, 1993 Maintaining Access to Nuclear Weapons Expertise in the

Defense Nuclear Facilities Complex

94-1 May 26, 1994 Improved Schedule for Remediation in the Defense Nuclear

Facilities Complex

95-2 October 11, 1995 Safety Management

97-2 May 19, 1997 Continuation of Criticality Safety at Defense Nuclear Facilities

in the Department of Energy

98-2 September 30, 1998 Safety Management at the Pantex Plant

99-1 August 11, 1999 Safe Storage of Fissionable Material Called “Pits”

2000-1 January 14, 2000 Prioritization for Stabilizing Nuclear Materials

2000-2 March 8, 2000 Configuration Management, Vital Safety Systems 

2002-1 September 23, 2002 Quality Assurance for Safety-Related Software

2002-2 October 3, 2002 Weapons Laboratory Support of the Defense Nuclear Complex

2002-3 December 11, 2002 Requirements for the Design, Implementation, and

Maintenance of Administrative Controls

2004-1 May 21, 2004 Oversight of Complex, High-Hazard Nuclear Operations

2004-2 December 7, 2004 Active Confinement Systems
C-1

APPENDIX C

2004 Reporting Requirements

Date Subject Response Due

December 16 NNSA’s draft Request for Proposal for Los Alamos

management and operating contract. 

Report 20 days

December 15 Continuing tooling problem failures at the Pantex Plant. Report 30 days

December 14 Safety issues regarding unvented transuranic waste

drums at Savannah River Site.

Briefing 30 days

December 14 Long delayed commitments in implementation plan for

Recommendation 98-2, safety improvements to nuclear

explosive operations.

Briefing Monthly

November 3 Lack of adequate configuration management program for

the highest-hazard nuclear facilities at Lawrence

Livermore. 

Report 60 days

November 3 Correction of deficiencies prior to increasing the pace of

operations and adding new missions at the Device

Assembly Facility at the Nevada Test Site. 

Report 90 days

October 27 Contractor failure to capture and archive safety-related

information for several weapon systems.

Report 90 days

September 27 Safety deficiencies in implementation of nuclear safety

requirements at Sandia National Laboratories.

Report

Briefing

90 days

September 8 Deficiencies at the activity level of the Hanford tank

farm integrated safety management system.

Report 60 days

August 27 Designation of the Salt Waste Processing Facility at the

Savannah River Site to ensure confinement of material

during earthquakes.

Report 45 days

August 6 Leak areas in nuclear explosive cells at Pantex Plant. Report

Briefing

45 days

August 6 Evaluations of the training and qualification programs at

Los Alamos, Lawrence Livermore, and Nevada Test

Site.

Within 30 days of completion of these evaluations,

NNSA representatives brief on corrective action plans.

Evaluation

Results

Briefing

45 days

30 days

July 29 Uncertainties in design of the Waste Treatment Plant at

Hanford, including assessment of the ground motion

criteria.

Program

Plan

30 day
C-2

2004 Reporting Requirements (cont.)

Date Subject Response Due

July 21 Fire protection of structural steel at Waste Treatment Plant

at Hanford.

Briefing 30 days

June 18 Quality assurance in tooling program at Pantex Plant. Report 30 days

May 21 Nuclear safety issues in Technical Area 18 at Los Alamos. Briefing 45 days

May 14 Inadequate Facility Representative training and staffing. Report 60 days

May 3 Deficiencies in Basis for Interim Operation at WIPP. Report 45 days

April 12 Confinement ventilation systems at Lawrence Livermore. Report 30 days

April 5 Issues and improvements in next year’s annual report on

nuclear criticality safety.

Report 1 year

April 5 Use of assessment in DOE’s oversight and operations at

defense nuclear facilities.

Briefing 60 days

April 1 Clarification of the term “site/facility management

contractor.”

Briefing 15 days

March 24 High-level waste at Savannah River Site. Briefing 30 days

March 24 Hydrogen hazards of non-Newtonian high-level waste,

black cell design concept for the Waste Treatment Plant at

Hanford.

Report 60 days

March 23 Fire protection and structural engineering issues at the

Waste Treatment Plant at Hanford.

Report 60 days

March 3 Request for revised implementation plan for sludge

removal from the K-East and K-West Basins at Hanford.

Revised

IP 

58 days

February 12 Recommendation 2000-1 implementation plan on

accelerated stabilization, repackaging, or disposition of

nuclear materials at Los Alamos.

Revised

IP 

120 days

January 29 DOE response to the Board’s comments on the proposed

Worker Safety Rule.

Briefing 30 days

January 27 Facility design, good engineering practices at Los Alamos. Report 90 days

January 22 Request to NNSA to improve nuclear explosive operations

and processes.

Report 60 days

January 20 Root-cause analysis of failures at Pantex and commitment

for resolution.

Report 30 days
D-1

APPENDIX D

CORRESPONDENCE

Hanford Site

March 3 letter to the Secretary of Energy requesting a revised implementation plan and

addressing safety issues associated with deteriorating irradiated nuclear fuel in the Hanford

K-East Basin with a 58-day reporting requirement.

March 23 letter to the Assistant Secretary for Environmental Management with 60-day reporting

requirement regarding Bechtel Nuclear process for developing requirements for fire resistance

for structural steel used in the process building at the Waste Treatment Plant.

March 24 letter to the Assistant Secretary for Environmental Management regarding Bechtel

Nuclear research and development processes for addressing hydrogen hazards related to nonNewtonian high-level wastes with a 60-day reporting requirement. 

June 18 letter to the Secretary of Energy regarding revisions to the implementation plan for the

Board’s Recommendations 94-1, Improved Schedule for Remediation in the Defense Nuclear

Facilities Complex and 2000-1, Prioritization for Stabilizing Nuclear Materials. 

July 21 letter to the Acting Assistant Secretary for Environmental Management regarding

proposed reduction of structural steel fire resistance for the Waste Treatment Plant with a 30-day

reporting requirement.

July 21 letter to the Acting Assistant Secretary for Environmental Management concerning

ventilation system being designed for the Hanford Waste Treatment Plant.

July 29 letter to the Acting Assistant Secretary for Environmental Management regarding ground

motion criteria for the Waste Treatment Plant with a 30-day reporting requirement.

August 24 letter to the Acting Assistant Secretary for Environmental Management regarding

unresolved issues on the design adequacy of the High-Level Waste Facility structure. 

August 26 letter to the Acting Assistant Secretary for Environmental Management forwarding a

report on the Review of Electrical and Instrumentation and Control of the Waste Treatment

Plant.

September 8 letter to the Acting Assistant Secretary for Environmental Management regarding

operational events at Hanford Tank Farms and Waste Treatment Plant with a 60-day reporting

requirement.

September 29 letter to the Acting Assistant Secretary for Environmental Management

forwarding a staff issue report regarding the Waste Treatment Plant Process Engineering.
D-2

Los Alamos National Laboratory

January 27 letter to the Administrator, National Nuclear Security Administration, regarding

conduct of engineering practices with a 90-day reporting requirement. 

February 12 letter to the Secretary of Energy requesting a revised implementation plan for

Recommendation 2000-1 with a 120-day reporting requirement.

May 3 letter to the Secretary of Energy regarding the establishment of a “safety basis academy.” 

May 21 letter to the Administrator, National Nuclear Security Administration, regarding

continued safe operations in Technical Area-18 in advance of the relocation of the facility’s

mission with a 45-day reporting requirement.

May 27 letter to the Administrator, National Nuclear Security Administration, regarding the

status of safety bases. 

June 22 letter to the Secretary of Energy regarding Ms. Joanne Lorence of Los Alamos Site

Office, the Facility Representative of the Year for 2003.

September 13 letter to the Administrator, National Nuclear Security Administration, regarding

safety conditions during the shutdown of work activities.

December 16 letter to the Administrator, National Nuclear Security Administration, regarding

Request for Proposal for management and operating contract, with a 20-day reporting

requirement.

Lawrence Livermore National Laboratory

April 12 letter to the Administrator, National Nuclear Security Administration, with 30-day

reporting requirement regarding unfiltered radioactive material released during certain accidents.

November 3 letter to the Secretary of Energy requesting a report within a 60-day period that

outlines adequate configuration management.

Nevada Test Site

January 21 letter to the Administrator, National Nuclear Security Administration, regarding the

hoisting and rigging operations.

Y-12 National Security Site at Oak Ridge

March 1 letter to the Deputy Administrator for Defense Programs, National Nuclear Security

Administration, on electrical system design of the Highly Enriched Uranium Materials Facility.
D-3

Pantex Plant

January 20 letter to the Secretary of Energy requesting a comprehensive report with a 30-day

reporting requirement documenting a root-cause analysis of failures and commitments for

resolution regarding discovery of cracked high explosive during a weapon dismantlement.

June 18 letter to the Administrator, National Nuclear Security Administration, requesting a

comprehensive review of quality assurance regarding the tooling program at Pantex Plant with a

30-day reporting requirement.

August 6 letter to the Administrator, National Nuclear Security Administration, regarding

potential problems through leak areas in nuclear explosive cells at Pantex Plant with a 45-day

reporting requirement.

November 3 to the Administrator, National Nuclear Security Administration, regarding the

electrical and lightning protection systems.

December 14 letter to the Secretary of Energy requesting monthly briefings to focus on delays

regarding important commitments.

December 15 letter to the Deputy Administrator for Defense Programs, National Nuclear

Security Administration, providing a 30-day reporting requirement regarding the inadequacies in

the tooling program.

Sandia National Laboratories

October 8 letter to the Administrator, National Nuclear Security Administration, regarding

multiple failures of hazard analysis and work control processes.

September 27 letter to the Administrator, National Nuclear Security Administration, requesting a

report and briefing in 90 days on the status of safety basis for a nuclear facility. 

December 13 letter to the Administrator, National Nuclear Security Administration, regarding

the adequacy of safety bases.

Savannah River Site

February 13 letter to the Assistant Secretary for Environmental Management on lightning

protection systems for the K-Area Material Storage Facility, FB-Line, and Building 235-F.

March 24 letter to the Assistant Secretary for Environmental Management requesting a plan for

the management, processing, and stabilization of high-level waste as well as a contingent plan

for accomplishing the process within the 2005 budget with a 30-day response time.

May 14 letter to the Secretary of Energy regarding the nuclear safety consequences of proposed

Section 3116 of the National Defense Authorization Act for Fiscal year 2005.
D-4

June 18 letter to the Deputy Secretary of Energy regarding the delays and consequences with the

management and disposition of radioactive wastes.

August 23 letter to the Acting Assistant Secretary for Environmental Management regarding the

electrical and ventilation systems for the high-level waste Concentration, Storage, and Transfer

Facilities.

August 27 letter to the Under Secretary of Energy about changing the performance category

designation of PC-2 to PC-3 and the plan and schedule for revising the affected directives with a

45-day reporting requirement. 

December 13 letter to the Acting Assistant Secretary for Environmental Management regarding

the activity-level work planning and control of deactivation and decommissioning activities.

December 14 letter to the Acting Assistant Secretary for Environmental Management regarding

the safety hazards of unvented transuranic waste drums with 30-day reporting requirement.

Other Significant Correspondence With DOE

January 22 letter to the Assistant Deputy Administrator, Military Applications and Stockpile

Operations, National Nuclear Security Administration requesting a 60-day response time of

actions to be taken to address identified shortcomings and enhance the Nuclear Explosive Safety

Study.

January 29 letter to the Under Secretary of Energy, Science and Environment establishing a 30-

day reporting requirement for a briefing on the plans for addressing the Board’s comments on

proposed rule 10 CFR Part 851, Worker Safety and Health.

January 30 letter to the Assistant Secretary for Environmental Management concerning

deactivation and decommissioning activities at defense nuclear facilities.

February 24 letter to the Secretary of Energy regarding suspension of the proposed rulemaking

on 10 CFR Part 851 and cancellation of the previously announced public meeting scheduled for 

February 27, 2004.

February 24 letter to the Departmental Representative forwarding a copy of the Board’s

Fourteenth Annual Report to Congress.

March 24 letter to the Assistant Secretary for Environment, Safety and Health requesting waivers

that DOE had granted to its defense facility contractors to DOE Order 440.1A as mentioned in

the testimony at the February 9, 2004 hearing.

March 29 letter to the Departmental Representative forwarding an updated list of Department of

Energy Orders of Interest to the Board.
D-5

April 1 letter to the Under Secretary of Energy, Science and Environment, regarding issues on

the term “site/facility management contractor” with a 15-day response reporting requirement.

April 5 letter to the Secretary of Energy regarding the use of formal risk assessment in its

oversight and operations at defense nuclear facilities with a 60-day reporting requirement.

April 5 letter to the Assistant Deputy Administrator for Research, Development, and Simulation,

National Nuclear Security Administration, regarding reporting annually on specific issues on the

Nuclear Criticality Safety Program.

May 3 letter to the Assistant Secretary for Environmental Management regarding the

inadequacies in safety basis, Basis for Interim Operation for the Mobile Waste Characterization

and Loading Units for the Central Characterization Project with a 45-day reporting requirement.

May 14 letter to the Secretary of Energy regarding the staffing of Facility Representatives at

National Nuclear Security Administration sites with a 60-day reporting requirement.

May 21 letter to the Administrator, National Nuclear Security Administration, regarding

effective implementation of ISM into the work planning and control at its various sites.

May 21 letter to the Secretary of Energy forwarding Recommendation 2004-1, Oversight of

Complex, High-Hazard Nuclear Operations.

August 6 letter to the Administrator, National Nuclear Security Administration, regarding

training and qualification programs at NNSA sites, providing 45 days for evaluation results

followed by a briefing within 30 days of the results.

October 27 letter to the Administrator, National Nuclear Security Administration, regarding a

program for archiving safety-related activities at the Pantex Plant, the Y-12 National Nuclear

Complex, and the Nevada Test Site. 

November 3 letter with a 90-day reporting requirement to the Administrator, National Nuclear

Security Administration, requesting identification and correction of any deficiencies in the

Device Assembly Facility, its equipment, or safety management program.

December 7 letter to the Secretary of Energy forwarding Recommendation 2004-2, Active

Confinement Systems.

December 14 letter to the Secretary of Energy forwarding the technical report, DNFSB/TECH35, Safety Management of Complex, High Hazard Organizations.

December 22 letter to the Deputy Secretary of Energy regarding DOE Policy 226.1, Department

of Energy Oversight Policy.
E-1

APPENDIX E

ADMINISTRATIVE ACTIVITIES

Human Resources

As of December 31, 2004, the Board employed 90 full-time staff in addition to the five

full-time Board Members. The Board continued its aggressive recruitment program to attract the

brightest engineering students from colleges and universities across the country, as well as

experienced engineering professionals. This year, technical recruiters visited four campus career

fairs, and the Board continued its recruitment outreach program.

The Board’s ability to fulfill its safety mission rests heavily on attracting and retaining

top-caliber technical staff. The Board has succeeded in creating a work environment that

emphasizes excellence as the standard for staff performance and has rewarded its staff

accordingly. The pay banding and pay for performance programs developed and implemented

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

accountable for their performance, and rewarding outstanding performance on the job. The

Board’s enabling legislation grants authority for excepted service hiring and classification. 

Using this authority, along with recruitment and relocation bonuses, student loan repayments,

and retention allowances, the Board has been successful in competing for scientific and technical

staff in a competitive employment market.

Competition from the private sector and fiscal constraints make recruiting and retaining a

high-quality, diverse workforce a challenge. Competition for top engineering professionals is

intense. Even with the special hiring and pay authorities granted to the Board, private industry

can easily promise higher salaries and benefits. The Board has also found that the federal

downsizing campaigns of the 1990s, coupled with the perception that the federal bureaucracy

stifles creativity and fails to encourage and reward outstanding work, have damaged its

recruiting campaigns. Recruitment and retention of recent college engineering graduates,

especially women and minorities, is difficult in the current job market, and will become even

more challenging with the renewed activity in the commercial nuclear industry.

Despite these problems, the Board has assembled a professional staff of exceptional

technical capability. Staff members’ expertise covers all major aspects of nuclear safety: 

nuclear, mechanical, electrical, chemical, fire protection, and structural engineering, as well as

physics and metallurgy. Most mid- to senior-level technical staff members possess practical

nuclear experience gained from duty in the United States Navy nuclear propulsion program, the

nuclear weapons field, or the civilian nuclear reactor industry. Both the Board and its staff

include individuals experienced in environmental impact assessments and regulatory processes. 

Four of the Board’s attorneys have technical degrees, and one is also a licensed professional

engineer.

Ten technical staff members are located at priority DOE sites. There are two site

representatives at the Pantex Plant near Amarillo, Texas; two at Hanford near Richland,

Washington; one at Savannah River Site near Aiken, South Carolina; two at the Y-12 National 
E-2

Security Complex in Oak Ridge, Tennessee; two at Los Alamos National Laboratory in New

Mexico; and one at Lawrence Livermore National Laboratory in Livermore, California.

The Board expects its engineers and scientists to maintain the highest level of technical

knowledge, encouraging them to improve their skills continually through academic study. 

Ninety-three percent of the Board’s senior technical staff holds advanced science and

engineering degrees, with 23 percent at the Ph.D. level. Younger technical staff members have

been recruited through the Board’s professional development program. Entry-level employees

recruited into this 3-year program receive graduate-school education and intensive on-the-job

training guided by experienced technical mentors. Currently, there are eight entry-level

employees in this program. Three completed their master’s degrees in the summer of 2004 and

are in their third-year field assignment. By the summer of 2005, three more of these individuals

should be awarded a master’s degree in an engineering discipline. The Board’s professional

development program remains extremely useful in attracting and retaining high-quality, entrylevel engineers and preparing them for challenging assignments in their fields.

Information Technology and Security

The Board has continued to increase its use of advanced information technology. 

Desktop hardware, software, and network servers provided to the staff are continually upgraded

to ensure that the latest tools are available. In 2004, the Board completed a “technology refresh

program” and upgraded all of the Board’s desktop computers to a standard configuration. Use of

a standard configuration significantly improves computer security and streamlines operational

support requirements. The Board’s internet website (www.dnfsb.gov) is kept current to ensure

that public documents are available for viewing and downloading. A Google®-style search

engine for the website has been purchased and is currently being tested. When implemented, the

search engine will improve the public’s access to the Board’s documents.

Dispute Resolution Programs

The Board, like other federal agencies, is required by the Administrative Dispute

Resolution Act of 1996 to provide an alternative dispute resolution program for use in resolving

appropriate disputes. The Board maintains such a program, making use of cooperative

agreements with other agencies to resolve workplace and contracts disputes economically.
F-1

APPENDIX F

Acronyms and Abbreviations

Board Defense Nuclear Facilities Safety Board

CFR Code of Federal Regulations

CPP Chemical Processing Plant

D&D Deactivation and Decommissioning

DNFSB Defense Nuclear Facilities Safety Board

DOE Department of Energy

DST Double Shell Tank

FOIA Freedom of Information Act

FY Fiscal Year

ISM Integrated Safety Management

KAMS K-Area Material Storage

NNSA National Nuclear Security Administration

Ph.D. Philosophiae Doctor

PDF Portable Document Format

QA Quality Assurance

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