Department of Energy

Activities Relating to the 

Defense Nuclear 

Facilities Safety Board

Fiscal Year 2011

Report to Congress

May 2012

United States Department of Energy

Washington, DC 20585

U.S. Department of

ENERGY



Board-Related Activities, FY11 │ Page iii

Executive Summary 

The Department of Energy (DOE or the Department) welcomes the opportunity to provide this annual report to 

Congress in accordance with Section 316(b) of the Atomic Energy Act of 1954, as amended. This report describes 

the Department’s activities during fiscal year (FY) 2011 related to the Defense Nuclear Facilities Safety Board 

(Board), including the Department’s safety initiatives and activities, the status of Board recommendations, and 

interface activities between the Department and the Board.

To enhance its nuclear safety posture at DOE’s defense nuclear facilities, DOE supports a proactive, cooperative, 

and transparent relationship with the Board. Such a relationship enhances the Department’s nuclear safety 

programs by promoting their continuous improvement; fully supports the health and well-being of the public, 

the environment, and DOE’s workers; and advances the reliability of the DOE mission. The Department has a 

unique role as an owner, operator, and regulator. The Board’s expertise can positively guide the Department’s 

safety posture.

Department Safety Initiatives 

Section III of the report describes key recent safety initiatives the Department has implemented to reinforce and 

ensure its nuclear safety performance at defense nuclear facilities. These initiatives respond both to issues 

identified by the Board and to issues proactively identified by the Department through site and facility selfassessments and through the oversight activities of the DOE Office of Health, Safety and Security (HSS) at DOE 

defense nuclear facilities. The Department has undertaken numerous safety initiatives, each of which 

contributes to DOE-wide nuclear safety and risk reduction programs. Among these, three warrant particular 

mention for FY11: the DOE-wide safety and security reform initiative; efforts to enhance facility design and the 

adequacy of facility safety analysis; and Departmental efforts to ensure a robust safety culture throughout the 

Department.

Safety and Security Reform Initiative

The goal of the directives reform initiative is to ensure that the Department has a comprehensive set of 

requirements that consistently and effectively protects workers, the public, and the environment. This effort 

was undertaken with the objective of not only strengthening and improving the system, but also continuing to 

assure adequate protection and accident prevention at our defense nuclear facilities. This initiative is the most 

significant review of DOE’s governing safety requirements since 1995. It has improved the Department’s body of 

safety requirements and has put DOE in a better position to manage and maintain its set of safety requirements 

in the future. HSS is nearing completion of this reform project and expects all directive revisions to be approved 

in FY12. HSS has significantly streamlined the directives set. These revisions give added emphasis to the essential 

safety requirements and responsibilities, and improve the Department’s ability to accomplish its mission safely 

and efficiently. HSS has developed framework documents to describe how each set of topical area requirements 

documents provides for protection of public health and safety, worker safety, and the environment. HSS has also 

clearly established and documented the technical bases for each individual safety requirement. The Department 

met its major project milestone to have 100 percent of the HSS directives either complete or into concurrence 

review by September 30, 2011. 
Board-Related Activities, FY11 │ Page iv

Facility Design and the Adequacy of Facility Safety Analysis

In response to the March 2011 events at the Fukushima Daiichi nuclear power plant in Japan, DOE took a series 

of actions to review the safety of its nuclear facilities related to natural hazards and to identify opportunities for 

improvement. On March 23, 2011, the Secretary issued Safety Bulletin Number 2011-01, Events Beyond Design 

Safety Basis Analysis, which required DOE Program and Field Offices to review the safety of their nuclear 

facilities. In June 2011, the Deputy Secretary convened a nuclear safety workshop that was attended by senior 

nuclear safety managers and technical experts from the Department, the Board, the Nuclear Regulatory 

Commission, the Federal Emergency Management Agency, and representatives from the commercial nuclear 

power industry. In September 2011, the Deputy Secretary transmitted to the Board the report, Review of 

Requirements and Capabilities for Analyzing and Responding to Beyond Design Basis Events, which describes the 

opportunities for improvement identified by DOE's review and provides recommendations for short-term and 

long-term actions for improving nuclear safety at the DOE facilities.

Safety Culture

Promoting a rigorous safety culture throughout DOE remains a top priority. HSS and the DOE Integrated Safety 

Management (ISM) Champions Council identified “safety culture” as a top ISM-related priority in 2007. Extensive 

operating experience in various industries has shown that certain cultural elements significantly influence 

overall operational and safety performance. The DOE ISM Champions Workshop, held September 12-15, 2011,

in Kennewick, WA, featured a session dedicated to safety culture and how it relates to ISM. The joint 

DOE/Energy Facility Contractors Group task team produced guidance documents based on three key factors that 

will encourage a global view of safety, enhance employee engagement, and improve performance within DOE: 

organizational learning, high reliability organization, and human performance improvement.

Board Recommendations

The Board issued three new recommendations in FY11: Recommendation 2010-1, Safety Analysis Requirements 

for Defining Adequate Protection for the Public and the Workers; Recommendation 2010-2, Pulse Jet Mixing at 

the Waste Treatment and Immobilization Plant; and Recommendation 2011-1, Safety Culture at the Waste 

Treatment and Immobilization Plant. No recommendations were closed during FY11. Thirteen recommendations 

remained open at the end of FY11. (Recommendation 2001-1, High-Level Waste Management at the Savannah 

River Site, was closed in early FY12.) Progress toward addressing each of these is discussed in Section IV of the 

report. The number of open recommendations has remained fairly constant, ranging from 10 to 14 over the past 

decade as new recommendations are issued and older ones closed.
Board-Related Activities, FY11 │ Page v

REPORT TO CONGRESS

Table of Contents

I. Legislative Language ....................................................................................................................... 1

II. Introduction .................................................................................................................................... 1

III. Department Safety Initiatives, Activities, and Reforms................................................................ 2

A. Directives Reform and Regulatory Structure ....................................................................... 2

B. Facility Design and Adequacy of Safety Analysis.................................................................. 5

C. Oversight .............................................................................................................................. 5

D. Safety Culture....................................................................................................................... 7

E. Work Planning and Control .................................................................................................. 8

F. Office of Environmental Management Activities................................................................. 8

G. NNSA Defense Program Activities...................................................................................... 11

H. NNSA Chief of Defense Nuclear Safety Activities............................................................... 12

IV. Progress in Implementing Board Recommendations................................................................... 13

A. Overview of Board Recommendations .............................................................................. 14

B. Recommendations Issued in FY11...................................................................................... 15

C. Other Open Recommendations ......................................................................................... 17

V. Interface Activities........................................................................................................................ 22

A. Briefings, Site Visits, and Other Board Interactions........................................................... 22

B. Responses to Board Reporting Requirements................................................................... 22

C. Public Meetings.................................................................................................................. 22

Appendix A. Summary Status of Board Recommendations and Reporting Commitments..................... 23

Appendix B. Acronyms and Abbreviations............................................................................................... 28

Figures

Figure 1. Department of Energy Defense Nuclear Facility Sites................................................................ 2

Figure 2. Revisions to Safety Policies and Orders Completed in FY11 ....................................................... 4

Figure 3. Status of Board Recommendations in Calendar Years 1990-2011............................................ 15
Board-Related Activities, FY11 │ Page vi

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Board-Related Activities, FY11 │ Page 1

I. Legislative Language

This report responds to legislative language set 

forth in 42 U.S.C. § 2286e, wherein it is stated: 

SEC. 316. REPORTS. [42 U.S.C. § 2286e]

(b) DOE REPORT. The Secretary of Energy shall

submit to the Committees on Armed Services and

on Appropriations of the Senate and to the

Speaker of the House of Representatives each

year, at the same time that the President

submits the budget to Congress pursuant to 

Section 1105(a) of Title 31, United States Code, a

written report concerning the activities of the

Department of Energy under this chapter during

the year preceding the year in which the report 

is submitted.

II. Introduction 

The Department of Energy (DOE or the Department)

welcomes the opportunity to provide this annual 

report to Congress that describes the Department’s 

activities in fiscal year (FY) 2011 related to the 

Defense Nuclear Facilities Safety Board (DNFSB or 

Board). 

The Board is an independent executive-branch 

agency established by Congress in 1988 to provide 

recommendations to the Secretary of Energy 

regarding public health and safety issues at the 

Department’s defense nuclear facilities. The Board 

reviews and evaluates the content and 

implementation of standards relating to the design, 

construction, operation, and decommissioning of 

the Department’s defense nuclear facilities. Figure 1 

shows the locations of DOE’s defense nuclear 

facilities. 

The Board and the Department communicate and 

interact through a variety of mechanisms, including 

formal Board recommendations, formal reporting 

requirements, Board letters requesting action and 

information, letters providing suggestions, letters 

providing information (e.g., staff trip reports and 

reports on specific issues), Board-sponsored public 

meetings, Board briefings, discussions, and Board 

site visits.

The remainder of this report is organized as follows:

• Section III, “Department Safety Initiatives,

Activities, and Reforms,” describes broadbased Departmental activities affecting 

environment, safety, and health that are of 

interest to the Board.

• Section IV, “Progress in Implementing 

Board Recommendations,” describes 

Departmental activities completed or 

ongoing in FY11 to implement Board 

recommendations accepted by or under 

review by the Secretary of Energy.

• Section V, “Interface Activities,” describes 

Departmental activities to maintain 

communications and improve interaction 

between the Department and the Board.

• Appendix A contains several tables 

illustrating the status of specific Board 

recommendations and reporting 

requirements.

• Appendix B defines acronyms and 

abbreviations used in this report.

Site-specific activities and accomplishments for 

FY11 are provided in a supplement to this Annual 

Report to Congress. The supplement is available on 

the webpage of the Departmental Representative

to the DNFSB (DR), which the reader can access at 

www.hss.energy.gov/deprep.
Board-Related Activities, FY11 │ Page 2

Figure 1. Department of Energy Defense Nuclear Facility Sites

III. Department Safety 

Initiatives, Activities, 

and Reforms 

This section describes the FY11 initiatives, activities, 

and reforms the Department is implementing to 

improve and ensure its nuclear safety performance

throughout the complex. These activities address 

issues identified by the Board, as well as issues 

identified through self-assessments and 

independent oversight efforts undertaken by the 

Department at its defense nuclear facilities. 

A. Directives Reform and Regulatory 

Structure 

On March 16, 2010, the Deputy Secretary of Energy 

approved the Department's plan for safety and 

security reform, which includes end-state visions for

safety and security. The goal of the directives 

reform initiative, which is nearing completion, is to 

develop a set of Departmental safety and security 

requirements that is consistent with adequate 

consensus standards of safety and security and that 

provides for the effective and efficient protection of 

workers, the public, DOE’s national security assets, 

and the environment. In implementing the 

initiative, we have not only streamlined 

requirements and eliminated duplications wherever 

possible to improve clarity and usability, but have 

also identified and addressed various gaps in 

existing requirements to ensure that the final set of 

requirements is complete and adequate. The 
Board-Related Activities, FY11 │ Page 3

outcome of the initiative will be a system of 

directives that supports safe, secure, effective, and 

efficient performance in accomplishing DOE’s 

current and future missions.

DOE acknowledges and appreciates the assistance 

the Board has provided to our directives reform 

initiative. By actively participating in the directives 

review cycle and by offering valuable insights and 

suggestions, the Board has facilitated and expedited 

the process of bringing this important safety and 

security enhancement to a positive conclusion.

In June 2010, the DOE Office of Health, Safety and 

Security (HSS) finalized its project management plan 

(PMP), Revision 2, to provide direction for 

implementing the Department's 2010 safety and 

security reform plan in a disciplined manner. The 

PMP establishes effective project controls based on 

stakeholder feedback, including establishment of 

executive steering committees, a requirements 

framework for each topical area to ensure that a 

systems approach is applied when changing

requirements, multi-disciplinary expert and 

stakeholder reviews before submittal to DOE-wide 

reviews, and a checklist of review criteria that must 

be addressed for each directive. The project scope 

includes the following seven topical areas: worker 

safety and health; nuclear safety; environment and 

quality assurance; operational awareness;

independent oversight; safeguards and security;

and classification. This initiative is the most 

significant review of DOE’s governing safety 

requirements since 1995. It has improved the 

Department’s body of safety requirements and has 

put DOE in a better position to manage and 

maintain its set of safety requirements in the 

future. 

For directives reform, changes have been made 

within the established Departmental directives 

program. For each identified directive action, formal 

justification memos were developed and approved 

by the Department's directives review board. Once 

the scope and schedule of planned actions were

approved, revised, or consolidated, draft new 

directives were developed by teams of subject 

matter experts with input from the associated 

topical area executive steering committee. The 

proposed changes were then released for DOE-wide 

review. Review, comment resolution, concurrence, 

and approval also proceeded in accordance with the 

Department's established directives process and 

direction from the Department’s directives review 

board. The PMP provides effective controls by 

augmenting the established Departmental 

directives program with additional stakeholder 

reviews and inputs. 

HSS is nearing completion of this reform project and 

expects all directive revisions to be approved in 

early FY12. HSS has achieved significant 

streamlining by reducing the number of directives. 

By removing unnecessary process requirements, 

these revisions give added emphasis to the essential 

safety requirements and responsibilities, and 

improve the Department’s ability to accomplish its 

mission safely and efficiently. These revisions have 

improved clarity in applicability, requirements, and 

responsibilities, and have eliminated redundancies. 

In addition, HSS has developed framework 

documents to describe how each set of topical area 

requirements documents provides for the 

protection of public health and safety, worker 

safety, and the environment. HSS has also clearly 

established and documented the technical bases for 

each individual safety requirement. Taken together, 

these changes will help the Department maintain 

and improve its safety requirements set, both now 

and in the future. 

As part of the review and revision process, the 

Department addressed identified gaps in safety 

requirements to make the requirements more 

comprehensive. Examples of improvements that 

have been made include:

• Enhanced the independence of accident 

investigations by requiring an off-site 

investigation leader for all accident 

investigations (Order 225.1B, Accident 

Investigations);
Board-Related Activities, FY11 │ Page 4

DOE Policy 420.1 Department of Energy Nuclear Safety Policy (February 2011)

DOE Order 458.1 Radiation Protection of the Public and the Environment (February 2011)

DOE Order 252.1A Technical Standards Program (February 2011)

DOE Order 225.1B Accident Investigations (March 2011)

DOE Order 210.2A DOE Corporate Operating Experience Program (April 2011)

DOE Policy 226.1B Department of Energy Oversight Policy (April 2011)

DOE Order 226.1B Implementation of DOE Oversight Policy (April 2011)

DOE Order 414.1D Quality Assurance (April 2011)

DOE Order 450.2 Integrated Safety Management (April 2011)

DOE Order 232.1B Environment, Safety and Health Reporting (June 2011)

DOE Order 442.2 Differing Professional Opinions for Technical Issues Involving Environment, 

Safety and Health (July 2011)

DOE Order 232.2 Occurrence Reporting and Processing of Operations Information (August 2011)

DOE Order 227.1 Independent Oversight Program (August 2011)

DOE Order 426.1 Federal Technical Capability (September 2011)

• Clarified requirements for federal personnel 

re-qualification (Order 426.1, Federal 

Technical Capability); and

• Clarified requirements for use of design 

codes and standards, and for confinement 

ventilation design in the draft revision to 

Order 420.1C, Facility Safety.

The Department met its major project milestone to 

have 100 percent of the HSS directives either 

complete or into concurrence review by September 

30, 2011. As of the end of FY11, 98 of 107 HSS 

directives (92 percent) were complete (revised, recertified, or cancelled), and the remaining directives 

are projected to be complete by the end of the 

second quarter of FY12. Revisions to safety policies 

and orders completed in FY11 are shown in 

Figure 2.

Figure 2. Revisions to Safety Policies and Orders Completed in FY11
Board-Related Activities, FY11 │ Page 5

Beyond Design Basis Accidents

“Beyond design basis” accidents are accident 

scenarios and sequences that are possible but 

were not fully considered in the design of a 

facility because they were judged to be too 

unlikely. In that sense, they are considered 

beyond the scope of “design basis” accidents, 

to which a nuclear or other high-hazard facility 

must be designed and built to withstand. 

Consequently, beyond design basis accidents 

are analyzed to fully understand how well a 

facility can tolerate an accident, however 

unlikely the accident scenario might be. 

B. Facility Design and Adequacy of 

Safety Analysis

In response to the March 2011 events at the 

Fukushima Daiichi nuclear power plant in Japan, 

DOE took a series of actions to review the safety of 

its nuclear facilities related to natural hazards and 

to identify opportunities for improvement. On 

March 23, 2011, the Secretary issued Safety Bulletin 

Number 2011-01, Events Beyond Design Safety 

Basis Analysis, which required DOE Program and 

Field Offices to review their nuclear facilities and 

report on the: 

• Analyses that have been performed for 

beyond design basis events and controls in 

place to mitigate them;

• Ability to safely manage their nuclear 

facilities during a total loss of power;

• Operability of important safety systems; 

and

• Readiness of emergency management plans 

and procedures.

On June 6-7, 2011, the Deputy Secretary convened 

a nuclear safety workshop that was attended by 

senior nuclear safety managers and technical 

experts from the Department, the Nuclear 

Regulatory Commission (NRC), the Board, the 

Federal Emergency Management Agency; and 

representatives from the commercial nuclear 

power industry. Subsequently, the Department 

evaluated its existing requirements and guidance 

for safety analysis, facility design, and emergency 

response as they relate to beyond design basis 

events. At the same time, the Department reviewed

commercial nuclear power industry requirements 

and guidance related to beyond design basis events,

including recent efforts by the NRC and the 

European Union. 

DOE nuclear facilities differ from the commercial 

nuclear power industry, but can still apply the 

lessons learned from the accident at the Fukushima 

Daiichi nuclear plant to improve their own nuclear 

safety. Although the responses to the safety bulletin 

confirmed that DOE has sound provisions in place to 

address beyond design basis accidents, the 

Department is taking additional actions to improve 

the criteria and guidance for evaluating such 

accidents and to determine whether improvements 

in emergency response capabilities are necessary. In 

September 2011, the Deputy Secretary issued the 

report, Review of Requirements and Capabilities for 

Analyzing and Responding to Beyond Design Basis 

Events. This report describes the opportunities for 

improvement identified by the DOE review and 

provides recommendations for short-term and longterm actions to improve nuclear safety at DOE 

facilities. DOE has begun implementing the report 

recommendations and expects to complete the

actions in accordance with the completion dates 

identified in this report.

C. Oversight

United States national and economic security 

demands that the DOE science, energy, 

environmental, and National Nuclear Security 

Administration (NNSA) enterprise missions maintain 

technological superiority and nuclear capabilities 
Board-Related Activities, FY11 │ Page 6

second to none. To use its resources most 

efficiently while also ensuring the safe, secure, and 

reliable delivery of its mission, the Department is 

implementing oversight reform initiatives, often 

modeled on those undertaken by other highly 

reliable government and corporate organizations. 

Reform is being achieved: 1) through an improved 

understanding of how we govern and perform, and 

2) by leveraging strong federal and contractor 

assurance systems that improve performance and 

accountability, reduce costs, and use validated 

industry standards for both nuclear and non-nuclear 

activities wherever and whenever possible. 

On July 5, 2011, the Deputy Secretary issued the 

memorandum, “Roles and Responsibilities for the 

Central Technical Authority, Chief of Nuclear 

Safety/Chief of Defense Nuclear Safety, and Chief 

Operating Officer.” The memorandum affirmed the 

roles and responsibilities for each position and 

named the individuals assigned to each Under 

Secretary. 

Nuclear Safety and Security Council 

The Nuclear Safety and Security Council was 

chartered in June 2011 by the Deputy Secretary to 

support implementation of actions for transforming 

DOE's approach to safety and security as identified 

in the Department’s strategic plan. The actions and 

recommendations of this Council directly affect the

Department’s nuclear safety and security mission. 

The Council, chaired by the Associate Deputy 

Secretary and with membership drawn from the 

senior management of each of the Program Offices

and the Office of the General Counsel, addresses 

the nuclear safety and security management 

framework. The purpose is to improve 

communications across a wide variety of key 

leaders who are members of the Council and to

propose measures to resolve technical and 

programmatic issues that are brought to their 

attention through recommendations to the 

Department’s Chief Operating Officers. 

The Council collaboratively evaluates nuclear safety 

and security issues during regularly scheduled 

meetings and agrees on actions to be taken. The 

Council aims for continuous improvement of DOE 

safety and security performance in five broad areas: 

(1) strategy; (2) performance and accountability; (3) 

oversight; (4) training; and (5) infrastructure. Topics 

discussed by the Council to date include nuclear 

safety performance metrics, nuclear safety training, 

implementation plans for recommendations by the 

Board, the nuclear safety and security directives 

revision process, nuclear safety research and 

development, and other crosscutting topics to 

improve the nuclear safety and security mission.

HSS Oversight Initiatives 

Within HSS, ongoing oversight reform is evidenced 

by the establishment of a dedicated Office of 

Nuclear Safety (HS-30) in May 2011. This 

reorganization consolidated and realigned HSS 

resources to better focus on the Department’s 

nuclear safety requirements, expectations, and 

research. As part of this reorganization, HSS created 

the Nuclear Safety Research and Development 

(NSR&D) Program within HS-30 to provide 

corporate-level leadership to support nuclear safety 

research and development throughout the 

Department. The HSS NSR&D Program will work 

with NNSA and the DOE program offices to (1) 

develop mechanisms for effectively sharing 

information on nuclear safety research and 

development activities and results, and (2) seek cost 

effective means to perform nuclear safety research 

and development that may have benefit DOE-wide. 

The NSR&D Program will also solicit input from the 

Nuclear Safety and Security Council.

HSS is also continuing to implement and refine a 

significantly modified approach to conducting 

independent oversight of nuclear safety through its 

Nuclear Safety Site Lead and Targeted Review 

Programs. These changes were initiated in part to 

address concerns raised by the U.S. Government 

Accountability Office in its 2008 report, Nuclear 

Safety: Department of Energy Needs to Strengthen 

its Independent Oversight of Nuclear Facilities and 

Operations.

Under the Nuclear Safety Site Lead Program, a 

designated nuclear safety professional from the HSS 
Board-Related Activities, FY11 │ Page 7

Safety Culture

Safety culture is defined as, "An organization’s 

values and behaviors modeled by its leaders 

and internalized by its members, which serve 

to make safe performance of work the 

overriding priority to protect the workers, 

public, and the environment." 

(DOE G 450.4-1C, Integrated Safety 

Management Guide)

Office of Enforcement and Oversight is assigned to 

monitor the activities at each DOE site that has one 

or more nuclear facilities or activities requiring a 

Documented Safety Analysis. The site leads are 

responsible for maintaining operational awareness 

of nuclear facilities and operations and using this 

information to make informed decisions about 

independent oversight review priorities that are 

tailored to site-specific conditions and operations. 

This program has given HSS a significantly increased 

on-site presence at the Department’s highest 

priority nuclear sites. The independent oversight 

Targeted Review Program takes a Department-wide 

view of specific nuclear safety-related functional 

areas and topics. Topics are selected based on such 

factors as safety performance trends, new or 

changed nuclear safety requirements, and the need 

for additional information to assess the status and 

adequacy of site nuclear safety documentation and 

its implementation. The first targeted reviews, now

underway, are evaluating (1) the quality of 

implementation verification reviews conducted to 

validate safety basis changes, (2) processes for 

procuring safety systems and components for 

nuclear facilities undergoing design or construction, 

and (3) emergency preparedness for severe natural 

phenomena events. These program enhancements 

provide the means for increased HSS monitoring of 

the status and implementation of nuclear facility 

safety bases and timely follow-up on corrective 

actions to evaluate effectiveness.

D. Safety Culture

Safety culture at the Waste Treatment and 

Immobilization Plant (WTP) at the Hanford Site is a 

topic specifically addressed by the DNFSB in 

Recommendation 2011-1, issued on June 9, 2011. 

DOE’s progress in responding to this 

recommendation is discussed in Section IV. HSS has 

a longstanding focus on safety culture, having

conducted an independent review of nuclear safety 

culture at the WTP and reported its findings in 

October 2010, prior to Recommendation 2011-1.

HSS and the DOE Integrated Safety Management 

(ISM) Champions Council identified “safety culture” 

as a top ISM-related priority in 2007. DOE and the 

Energy Facility Contractors Group (EFCOG) jointly

sponsored the ISMS Safety Culture Task Team 

specifically to address safety culture within the 

Department. The goal of this effort was to achieve 

an improved safety culture by promoting

continuous improvement in ISM and building on 

operating experience from similar industries, such 

as the domestic and international commercial 

nuclear and chemical industries. 

Extensive operating experience in various industries 

has shown that certain cultural elements have a

significant influence on overall operational and 

safety performance. The ISMS Safety Culture Task 

Team has evaluated lessons learned from related 

industries and organizations, such as the Institute of 

Nuclear Power Operations (INPO), the NRC, the 

National Aeronautics and Space Administration 

(NASA), the Occupational Safety and Health 

Administration, and the International Atomic 

Energy Agency, and relevant information on safety 

culture issues from DOE oversight and enforcement

programs. 

The DOE ISM Champions Workshop, held 

September 12-15, 2011, in Kennewick WA, featured 

a session dedicated to safety culture and how it 

relates to ISM. The joint DOE/EFCOG task team 

produced guidance documents based on three key 

factors that will encourage a global view of safety, 
Board-Related Activities, FY11 │ Page 8

Work Planning and Control 

Work planning and control is the use of 

formalized, standardized, and documented 

methods and processes for considering and 

mitigating risks when planning, authorizing, 

releasing, and performing work.

enhance employee engagement, and improve 

performance within DOE: organizational learning;

high reliability organization; and human 

performance improvement. 

E. Work Planning and Control

The purpose of work planning and control (WPC) is 

to ensure the protection of workers, the public, and 

the environment. Without such controls, all three

would be placed at avoidable and unacceptable risk. 

Using ISM principles, WPC emphasizes using a 

graded approach in specifying the level of 

coordination required to identify and mitigate 

hazards to workers, the public, and the 

environment. 

The DOE acquisition regulations (DEAR) require that 

work be performed in a manner that protects 

workers, the public, and the environment. They 

further require that the management of 

environment, safety, and health functions and 

activities be an integral and visible part of the work 

planning and execution process (48 CFR 970.5223-1, 

Integration of Environment, Safety, and Health into 

Work Planning and Execution). The DEAR further 

require that work be managed and performed in 

accordance with a documented safety management 

system that describes how the contractor will 

ensure that the ISM five core functions and seven 

guiding principles are implemented. The ISM core 

functions require that work be defined, that the 

associated hazards be identified and analyzed, and 

that work be performed within controls 

implemented to protect workers, the public, and 

the environment from the hazards. 

In early FY11, The Office of Environmental 

Management (EM), HSS, NNSA, and EFCOG initiated 

a program and project plan expressly designed to 

improve contractor assurance and federal oversight 

of WPC across NNSA and EM sites. This initiative 

establishes a commitment by contractors to 

improve WPC throughout their operations. 

HSS will engage with this initiative on matters of 

WPC policy and implementation. The initiative will 

also interface with EFCOG groups that focus on 

human performance improvement; safety culture; 

quality assurance; environment, safety, and health; 

contractor assurance; and work management to

pursue WPC improvement and integrated solutions. 

The project plan documents an initial approach for 

managing the EM/NNSA/EFCOG WPC improvement 

project. The plan will be finalized in FY12 to build on

the existing WPC programs at EM and NNSA sites by 

sharing best practices and incorporating practices 

from INPO, NASA, and other external sources.

F. Office of Environmental 

Management Activities

In FY11, EM continued its aggressive campaign to 

improve safety performance throughout the 

organization, including procurement; engineering; 

construction and commissioning; operations; and 

deactivation/decommissioning and environmental 

restoration. These efforts reduced EM’s total annual 

recordable case rate and its cases of days away 

from work and on-job restriction or transfer, which

remain significantly below the average DOE rates 

and comparable private construction and waste 

remediation industry rates. 
Board-Related Activities, FY11 │ Page 9

ISM Five Core Functions

and Seven Guiding Principles 

Core Functions

1. Define the scope of work

2. Analyze the hazards

3. Develop and implement hazard 

controls

4. Perform work within controls

5. Provide feedback and continuous 

improvement

Guiding Principles

1. Line management responsibility for 

safety

2. Clear roles and responsibilities

3. Competence commensurate with 

responsibilities

4. Balanced priorities

5. Identification of safety standards and 

requirements

6. Hazard controls tailored to work being 

performed

7. Operations authorization

EM remained vigilant in identifying emerging safety 

issues through ongoing awareness and analysis of 

operational experience and data on injuries and 

illnesses. EM has also addressed several overarching 

issues in performance, including safety 

performance, at the Separations Process Research 

Unit, the Idaho and Paducah cleanup projects, the 

WTP, and the Savannah River Site (SRS). 

Organization-wide issues were addressed through:

• Partnering with EFCOG and major corporations 

that support EM work in order to develop and 

enhance work planning expectations and best 

practices in the field;

• Developing criteria for Integrated Safety 

Management System (ISMS) effectiveness 

reviews for nuclear safety culture and 

maintenance of a safety conscious work 

environment; and

• Implementing specific administrative controls,

including comprehensive field reviews 

conducted by EM Headquarters.

EM is developing a suite of performance indicators 

that can be used to identify trends, positive and 

negative, so action can be taken before an event 

occurs. These indicators will be piloted at a site in 

FY12 to determine how well they work and 

implement identified improvements. EM will then

expand their use throughout the organization.

EM provided direction to field managers that 

formalizes guidance and metrics for ensuring that at 

least 95 percent of the installed safety class and 

safety significant equipment/software contains no 

defects, and is not a “suspect or counterfeit” item. 

EM achieved a 99 percent success rate against this 

safety goal.

Other major EM safety-related initiatives in FY11 

included:

• Co-sponsoring with CNS-Energy, and 

participating in, a workshop on safety 

decisions under uncertainty; 

• Addressing the findings from the site 

evaluations of “beyond design basis 

events;”

• Improving the WPC process, including 

participating in the URS Corporation

initiative to improve WPC;

• Serving on the EFCOG Executive Committee 

and providing program managers for EFCOG 

initiatives; and 

• Establishing the EM acquisition center to 

standardize the acquisition planning 

process to achieve more efficient and 

timely acquisitions.
Board-Related Activities, FY11 │ Page 10

CNS-Energy Oversight

During FY11, CNS-Energy continued to support line 

oversight activities through nuclear criticality safety 

program evaluations, operational awareness 

reviews, programmatic assessments of ISMSs, and 

construction project reviews (CPRs), which are 

further discussed below. The office also conducted

20 field activity reviews involving ten functional 

areas: facility safety/authorization basis, nuclear 

criticality safety, oversight program, seismic safety,

project management/CPR, contract review, ISM,

quality assurance and software quality assurance, 

operational readiness, and risk management.

CNS-Energy remained closely engaged in supporting 

and monitoring key technical issues involving the 

WTP, including pulse jet mixing (PJM) and solids 

accumulation, nuclear safety requirements, the 

evaluation of dry deposition velocity (DV), and the 

System for Analysis of Soil-Structure Interaction. 

Construction Project Reviews. The CNS-Energy 

staff has continued to provide leadership and 

technical expertise to EM in establishing corporate 

CPRs, which were instituted to assess the progress 

of each EM capital project and provide proactive 

recommendations for achieving its next critical 

decision stage within the approved cost and 

schedule. The first round of CPRs was completed in 

2009. CPR Committees evaluate project progress in 

such areas as technical execution; cost, schedule, 

risk, and contracts; management and prior reviews; 

environment, safety, and health; quality assurance; 

and commissioning. 

PJM and Solids Accumulation. CNS-Energy has 

closely monitored the handling of a differing 

professional opinion (DPO), submitted by an Office 

of River Protection staff member, that raised a 

number of technical issues regarding WTP 

equipment design and operability. The DPO states

that fabrication and construction of some 

equipment is premature because technical design 

issues have not been resolved. Through the Hanford 

Site DPO process, it was determined that the 

project adequately tracks all issues and that the 

timing of equipment fabrication ahead of final 

design approval is a risk-management decision. 

After exhausting the site DPO process, an appeal of 

the DPO decision was submitted to CNS-Energy. 

Specifically, the DPO appeal requested that two

issues be reviewed: whether proceeding with the 

fabrication violates the requirements of 10 CFR Part 

830, Nuclear Safety Management, and whether the 

potential for excessive erosion could cause 

premature equipment failures. CNS-Energy has 

been delegated as the DPO manager for the appeal.

WTP Nuclear Safety Requirements. The CNSEnergy staff reviewed the draft requests for 

proposals that were prepared for the WTP and Tank 

Farms “one system” strategy for nuclear safety 

requirements. This strategy would align the two 

projects for early startup of the Low-Activity Waste 

Facility. 

Evaluation of DV at the WTP Project. The CNSEnergy staff continued to work toward resolving the 

DNFSB’s concerns regarding DV, which is a factor 

that is used in calculating potential accident 

impacts. The WTP project, informed by CNSEnergy/DNFSB communications and consistent with 

ongoing efforts within HSS, has selected an 

appropriately conservative DV value that will result 

in a technically defensible accident analysis.

System for Analysis of Soil-Structure Interaction.

The System for Analysis of Soil-Structure Interaction 

(SASSI) is a computer code used to evaluate and 

predict the effects of seismic ground motion on 

structures. SASSI is widely used by the nuclear 

industry and by DOE. The most recent SASSI user’s 

manual states that one of the methods used in the 

code, the subtraction method, “is the preferred 

method of analysis.” However, in August 2010, CNSEnergy learned of analyses showing that the 

subtraction method, under some conditions, yields 

results that deviate significantly from those 

obtained from the more computationally-intensive 

“direct method.” The subtraction method was 

found to both overestimate and underestimate a 

structure’s response to a seismic event, depending 

on the seismic conditions being examined. CNSEnergy, in consultation with subject matter experts, 

assessed the implications of SASSI errors for DOE
Board-Related Activities, FY11 │ Page 11

facilities and recommended actions the Department 

should take. 

On April 8, 2011, the Board sent a letter to DOE 

expressing its concerns about the SASSI technical 

and software quality assurance issues. On July 29, 

2011, DOE responded with a technical report and 

schedule of commitments to address the Board’s 

concerns. The DOE response also noted that since 

many variations (i.e., modified versions) of the 

original SASSI code are currently in use, DOE would 

send a software quality assurance questionnaire to 

managers of construction projects that are using, or 

have used, SASSI. A summary report of responses 

was transmitted to the Board.

EM has the lead responsibility for coordinating the 

SASSI issue resolution with the Board, but does not 

currently use SASSI on any EM program. The SASSI 

code is used by NNSA on the Uranium Processing 

Facility at Y-12 and the Chemistry and Metallurgy 

Research Replacement Facility at Los Alamos 

National Laboratory (LANL) – two projects that 

would benefit most from resolution of SASSI issues. 

NNSA is developing and executing an integrated 

action plan to address the root cause of the SASSI 

errors, and to develop verification and validation 

problem sets to help ensure the accuracy of SASSI 

outputs. DOE will continue to work closely with the 

Board to resolve all outstanding SASSI issues.

CNS-Energy Continuous Learning

CNS-Energy continues to sponsor a series of training 

courses using recognized experts from established 

training programs, such as the Safety Basis 

Academy and the American Society of Mechanical 

Engineers (ASME), to strengthen fundamental 

knowledge in critical technical areas. These 

offerings include: (1) ASME Code for the Design and 

Fabrication of Tanks, Vessels and Piping Systems 

with Applications at DOE Facilities; and (2) Seismic 

Design and Retrofit of Structures, Systems, and 

Components. 

G. NNSA Defense Program Activities 

The NNSA Headquarters Office of Defense Programs 

(NA-10) provides direction and oversight of NNSA 

defense programs activities, including nuclear 

safety and operations, transportation, research, 

engineering, and production at the NNSA field 

offices. Significant activities during FY11 included 

taking action on the results of the Seismic Analysis 

of Facilities and Evaluation of Risk (SAFER) project 

for the LANL Plutonium Facility (PF-4) and making 

progress on improving NNSA WPC.

SAFER Project

The SAFER project was initiated to analyze the 

seismic performance of selected structures, 

systems, and components (SSC) using recent

information about an increase in the seismic ground 

motion estimate at LANL. The SAFER project 

analysis for PF-4 identified an increased potential 

for failure of certain SSCs in a maximum postulated 

earthquake event. In a justification for continued 

operations (JCO) document, LANL identified interim 

compensatory measures and longer-term structural 

corrective maintenance actions that are intended to 

result in the facility structure meeting the updated 

performance category 3 probability performance 

goal. Most of the corrective maintenance activities

in the JCO were completed in 2011. The remaining 

significant structural corrective maintenance 

actions in the JCO are scheduled to be completed by 

mid FY12. A detailed structural analysis to 

determine if any additional structural corrective 

actions are required is expected to be complete by 

the 3rd quarter of FY12.
Board-Related Activities, FY11 │ Page 12

Work Planning and Control

As discussed above, NNSA, in collaboration with 

EFCOG, EM, and HSS, implemented a project 

initiative to improve WPC during FY11. 

Accomplishments during the year include:

• Collecting WPC performance measures 

across DOE sites and with industry for 

evaluation and improvement;

• Establishing and collecting WPC tools for 

improvement across the DOE enterprise 

and applying these tools within a draft 

EFCOG WPC guideline document;

• Establishing a single set of criteria, review,

and approach documents (CRADs) for WPC 

that combine the best practices from 

several prior CRAD sets. The CRADs are 

contained in the EFCOG WPC guideline 

document and are proposed for the draft 

DOE oversight guide;

• Supporting the EFCOG work management 

subgroup during WPC assist visits at the 

Nevada National Security Site and the 

Waste Isolation Pilot Plant.

H. NNSA Chief of Defense Nuclear 

Safety Activities 

DOE established Central Technical Authority (CTA)

positions within the Department in response to

DNFSB Recommendation 2004-1, Oversight of 

Complex, High-Hazard Nuclear Operations. The CTA 

for NNSA is the NNSA Administrator, while the Chief 

of Defense Nuclear Safety (CDNS) provides technical 

support to the CTA in several areas, such as:

• Conducting biennial reviews of NNSA site 

offices;

• Granting exemptions from nuclear safety 

requirements;

• Performing liaison functions with the 

DNFSB;

• Approving delegations of nuclear safety 

authorities, and interpreting and developing

nuclear safety policies, requirements, and 

guidance;

• Serving as DPO manager; and

• Conducting independent analyses and 

investigations. 

Biennial reviews of NNSA site offices, initiated in 

2005, continued in FY11. Since the first round of 

full-scope/baseline reviews, the tailored follow-up 

reviews have indicated overall continued good 

performance or improved performance. CDNS will 

continue the follow-up reviews in FY12. 
Board-Related Activities, FY11 │ Page 13

Chief of Defense Nuclear Safety Accomplishments during FY11

 Initiated a project to derive a first-of-a-kind set of site-specific correlations 

between calculated accident dose consequences at selected DOE site 

boundaries and the Department’s quantitative safety objectives for nuclear 

facilities. This information can inform a variety of nuclear safety decisions. 

 Created a new professional development course for the review and approval of safety 

basis documents and provided training to safety professionals through the National 

Training Center. 

 Developed and completed a robust implementation program for the new 

readiness order that included briefings to senior managers at all NNSA sites to 

ensure a smooth transition to the revised requirements. The program resulted 

in full implementation of the order in an efficient manner.

 Supported the CTA responsibilities for ensuring adequate treatment of nuclear safety 

in the related DOE directives by completing the revision of 25 DOE directives, initiating

the revision of 9 directives, and canceling 17 directives.

 Actively supported promotion and improvement of safety culture through the 

revision of Departmental directives that govern the process for disposition of 

DPOs on technical issues related to both nuclear and non-nuclear safety. 

 Completed four baseline/full-scope biennial reviews that indicated continued improved 

performance at the Savannah River, Pantex, Nevada, and Livermore sites.

 Updating the final hazard categorization methodology for use in NNSA nuclear facilities

to allow a significant additional margin for work with important isotopes. The 

approach, its basis, and lessons learned in implementation will provide useful data for 

updating the Department-wide standard (expected in 2012). 
Board-Related Activities, FY11 │ Page 14

Open Board Recommendations 

2000-1 Prioritization for Stabilizing Nuclear 

Materials

2002-3 Requirements for the Design, 

Implementation, and Maintenance 

of Administrative Controls

2004-1 Oversight of Complex, High-Hazard 

Nuclear Operations

2004-2 Active Confinement Systems

2005-1 Nuclear Material Packaging

2007-1 Safety-Related In Situ 

Nondestructive Assay of Radioactive 

Materials

2008-1 Safety Classification of Fire 

Protection Systems

2009-1 Risk Assessment Methodologies at 

Defense Nuclear Facilities

2009-2 Los Alamos National Laboratory 

Plutonium Facility Seismic Safety

2010-1 Safety Analysis Requirements for 

Defining Adequate Protection for 

the Public and the Workers

2010-2 Pulse Jet Mixing at the Waste 

Treatment and Immobilization Plant

2011-1 Safety Culture at the Waste 

Treatment and Immobilization Plant

IV. Progress in Implementing

Board Recommendations 

A. Overview of Board 

Recommendations

The Board issues recommendations regarding the 

content and implementation of safety standards at 

defense nuclear facilities to the Secretary on issues 

or circumstances it believes must be resolved to 

assure adequate protection of public health and 

safety. The Secretary is required to respond to each 

Board recommendation within 45 days of its 

publication in the Federal Register (or longer, if 

granted additional time). In addition, the Secretary 

must provide an Implementation Plan (IP) to the 

Board within 90 days of publication in the Federal 

Register of the Secretary’s acceptance of the 

recommendation (or longer, upon appropriate 

notice). The Department’s policy is to begin IP

development in parallel with the development of 

the Department’s response if it is expected that the 

Secretary will accept the recommendation in whole 

or in part. 

The Department is expected to complete all IP 

commitments within one year of issuance of the IP. 

However, most IP commitment schedules extend 

beyond one year due to the scope and technical 

complexity of the safety issues being addressed, the 

lengthy concurrence processes for revising DOE 

directives, and the challenges inherent in 

implementing and verifying changes throughout 

DOE’s defense nuclear complex. 

Thirteen recommendations remained open at the 

end of FY11.1 The number of open 

recommendations has remained fairly constant, 

ranging from 10 to 14 over the past decade as new 

recommendations are issued and older 

recommendations are closed (Figure 3). A status

 1 The IP for Board Recommendation 2001-1, High Level 

Waste Management at the Savannah River Site, was 

closed in December 2011.

update for each of the open recommendations is 

provided below. 

Appendix A, Table A.1, Open Commitments, lists 

DOE projects’ timeframes for completing the IPs for 

each open recommendation. 
Board-Related Activities, FY11 │ Page 15

Figure 3. Status of Board Recommendations in Calendar Years 1990-2011

The Board issued three new recommendations in 

FY11: Recommendation 2010-1, Safety Analysis 

Requirements for Defining Adequate Protection for 

the Public and the Workers; Recommendation 

2010-2, Pulse Jet Mixing at the Waste Treatment 

and Immobilization Plant; and Recommendation 

2011-1, Safety Culture at the Waste Treatment and 

Immobilization Plant. These recommendations are 

discussed below. The other ten open 

recommendations are discussed in Section IV.C. 

B. Recommendations Issued 

in FY11

2011-1: Safety Culture at the Waste Treatment 

and Immobilization Plant

The Board issued Recommendation 2011-1 on June 

9, 2011, addressing the safety culture at the

Hanford Site WTP. The Secretary designated the

Deputy Secretary as the Department’s responsible 

manager to oversee the IP development and 

execution. The Board designated its Vice Chairman 

to work directly with the Deputy Secretary.
Board-Related Activities, FY11 │ Page 16

On June 30, 2011, the Secretary accepted the

recommendation. On August 12, 2011, the Board 

requested certain clarifications to the Secretary’s 

response, which the Secretary provided in a letter 

dated September 19, 2011. The Recommendation 

2011-1 IP was transmitted to the Board in early 

FY12. The Department committed to take broad 

and comprehensive actions focused on resolving

safety culture deficiencies at the WTP and to

examine and improve the safety culture throughout 

the DOE complex.

2010-2: Pulse Jet Mixing at the Waste Treatment 

and Immobilization Plant

The Board issued Recommendation 2010-2 on 

December 17, 2010. The Recommendation 

addresses the Board’s concern that equipment

testing and analysis should be enhanced to 

establish with confidence that the PJM and transfer 

systems will perform adequately at full scale. 

On February 10, 2011, the Secretary accepted the 

recommendation and committed to more testing to 

provide additional confidence that PJM and transfer

systems for the WTP will meet their design and 

operating requirements. The acceptance letter 

included clarifications regarding four of the Board’s 

specific technical recommendations. On June 20, 

2011, the Secretary assured the Board that the 

acceptance letter was intended to clarify the 

actions being taken to validate the design, 

operation, and safety of the WTP PJM and transfer 

systems. The Secretary reaffirmed the acceptance 

of the recommendation, and the IP was delivered in 

early FY12. 

2010-1: Safety Analysis Requirements for Defining 

Adequate Protection for the Public and the 

Workers

The Board issued Recommendation 2010-1 on 

October 29, 2010. This recommendation calls for 

the amendment of 10 CFR 830, Nuclear Safety 

Management, by incorporating a revised DOE 

Standard 3009-94, Preparation Guide for U.S. 

Department of Energy Nonreactor Nuclear Facility

Documented Safety Analyses, into the text as a 

requirement. The recommendation also requests 

that the revisions to DOE Standard 3009-94 reflect 

clearly delineated criteria for methodologies, 

accident scenarios, and mitigation options, as well 

as a clearly defined approval authority for safety 

analyses at defense nuclear facilities.

The Secretary partially accepted the 

recommendation on February 28, 2011, noting that 

the Department shared the Board’s conviction that

a clear set of requirements and standards is vital for 

safe operations. The Secretary noted that in 2008 

the Department began a comprehensive 

reexamination of its nuclear safety requirements 

— the directives reform initiative — to ensure that 

all requirements and standards were clear, concise, 

complete, and up to date. The Secretary further 

noted that in March 2010, the Department had 

enhanced the directives reform initiative to better 

define and expedite it. The Secretary also clarified

several of the responses to the associated subrecommendations. On April 27, 2011, the Board 

advised the Secretary that the response constituted 

a partial rejection of the recommendation and 

reaffirmed the recommendation as originally issued. 

On May 27, 2011, the Secretary reaffirmed the 

analyses and conclusions in the original acceptance 

response and noted that the IP would achieve the 

underlying safety improvements identified in the 

recommendation. 

DOE transmitted the Recommendation 2010-1 IP to 

the Board on September 26, 2011. The IP provides 

the approach for updating the Department’s 

Documented Safety Analysis standards and 

requirements, which will improve the performance 

of hazard and accident analysis and the 

identification of safety controls. The IP reinforces 

and expands the improvements in the directives 

reform initiative, discussed in Section III.A. 
Board-Related Activities, FY11 │ Page 17

DOE Standard 3009-94

DOE’s existing nuclear safety regulatory 

framework, which applies DOE Standard 3009, 

Preparation Guide for U.S. Department of 

Energy Nonreactor Nuclear Facility 

Documented Safety Analyses, as a safe harbor 

methodology for non-reactor hazard category 

1, 2 and 3 facilities, can be used to effectively 

implement the 10 CFR Part 830 safety basis 

requirements.

C. Other Open Recommendations

2009-2: Los Alamos National Laboratory Plutonium 

Facility Seismic Safety 

The Board issued Recommendation 2009-2 on 

October 26, 2009. The recommendation calls for 

the Department to implement near-term actions 

and compensatory measures to reduce the 

consequences of potential seismic events at PF-4 

and to develop and implement a longer-term 

strategy to reduce seismic event consequences. The 

Secretary accepted the recommendation on 

February 2, 2010, and transmitted the associated IP 

to the Board on July 13, 2010. The Board visited 

LANL November 29 through December 3, 2010, and 

noted progress on this recommendation. 

The IP identifies near-term actions and a long-term 

strategy to mitigate the consequences of postseismic events so that the DOE evaluation guideline 

of 25 rem is not exceeded. The plan includes 11 

primary deliverables. Eight deliverables were 

completed in FY11, and completion of the 

remaining deliverables is anticipated in FY12. In the 

most recent update of the PF-4 Documented Safety 

Analysis the calculated mitigated radiological 

consequences to the maximally exposed off-site 

individual from a post-seismic fire event is

significantly reduced as compared to the 2008 

Documented Safety Analysis, which was the basis 

for the recommendation. High-priority efforts in 

FY11 included implementation of the SAFER project 

for PF-4 and completion of a refined accident 

analysis and control selection for seismically

induced events in the safety basis update. The 

SAFER project was an essential prerequisite for 

identifying the most appropriate seismic upgrades. 

It systematically identified the credited safety 

function; related this to a structural limit or 

mechanical function; calculated the performance 

achieved using the current seismic hazard analysis 

comparing it to performance goals; and 

recommended appropriate replacement or 

upgrades if the performance goals were not met.

2009-1: Risk Assessment Methodologies at 

Defense Nuclear Facilities

The Board issued Recommendation 2009-1 on July 

30, 2009. The Secretary accepted the 

recommendation on November 3, 2009, and

subsequently transmitted the IP to the Board. The 

recommendation calls for adequate policies and 

associated standards and guidance on the use of 

quantitative risk assessment methodologies 

(referred to as probabilistic risk assessment) at 

defense nuclear facilities. On April 27, 2010, the 

Secretary transmitted revision 1 to the IP to the 

Board. The revision included a commitment to 

periodically brief the Board or staff on progress and 

four other deliverables:

• Establish the Risk Assessment Technical 

Experts Working Group (RWG);

• Issue a nuclear safety risk assessment 

information notice;

• Revise and issue the DOE Nuclear Safety 

Policy to address the use of quantitative risk 

assessment in nuclear safety; and

• Transmit a letter to the Board on the 

Department’s plans for the appropriate 

changes to directives or standards on the 

use of quantitative risk assessment at 

defense nuclear facilities based on the 

results of risk assessment studies. 
Board-Related Activities, FY11 │ Page 18

The establishment of the RWG and issuance of the 

Information Notice were completed in 2010. DOE 

issued the revised Nuclear Safety Policy (DOE Policy

420.1) on February 8, 2011, which included DOE 

expectations regarding the use of quantitative or 

probabilistic risk assessment in nuclear safety 

decisions. The response to the Board addressing 

quantitative risk assessments remains to be 

completed.

To address the last deliverable in the 

recommendation, DOE conducted studies of the use 

of quantitative and probabilistic risk assessment 

within the DOE complex and in other agencies and 

industries that need to prevent and mitigate highconsequence/low-frequency events. The studies 

were supported by a DOE-sponsored interagency 

workshop on risk assessment and safety decisionmaking under uncertainty, data collection efforts, 

and interviews at DOE facilities and with 

representatives of other agencies and industry,

including the NRC, the Nuclear Energy Institute, 

NASA, the Food and Drug Administration, the 

American Institute of Chemical Engineers Center for 

Chemical Process Safety, and the Federal Aviation 

Administration. The studies were completed in 

FY11, and the reports will be issued in FY12. 

From these efforts, and based on feedback 

obtained during the development of the Nuclear 

Safety Policy, DOE developed a draft technical 

standard, Development and Use of Probabilistic Risk 

Assessments in Department of Energy Nuclear 

Safety Applications, and distributed it for interim 

use. The Department expects to publish the 

standard in FY12. 

2008-1: Safety Classification of Fire Protection 

Systems 

The Board issued Recommendation 2008-1 on 

January 29, 2008. The recommendation calls for 

development and revision of standards applicable 

to the design and operation of the fire protection 

systems that are relied on as a primary means of 

protecting the public and workers from radiological 

hazards at DOE defense nuclear facilities. The 

Secretary accepted the recommendation on March 

19, 2008, and transmitted the associated IP to the 

Board on July 23, 2008. 

The Department established a working group that 

includes EM, HSS, SC, NNSA Headquarters Program 

Offices, CNS-Energy, CDNS, and representatives of

multiple sites and field offices. The Department 

drafted specific design and operational criteria for 

fire barriers other than sprinkler systems for nuclear 

facilities. The group continues its work on the 

actions in the IP.

During FY11, DOE made significant progress in 

revising DOE Standard 1066, Fire Protection Design 

Criteria, to incorporate the new sprinkler and fire 

barrier guidance while ensuring the consistent 

application of the standard within the planned 

revision of DOE Order 420.1B, Facility Safety. On 

September 30, 2011, the revised standard entered 

the RevCom2 concurrence process, and DOE expects 

to complete the revision early in FY12. The 

Department is also addressing some additional

comments from the Board. 

2007-1: Safety-Related In Situ Nondestructive 

Assay of Radioactive Materials

The Board issued Recommendation 2007-1 on April 

25, 2007. The recommendation addresses issues 

related to measuring radioactive material holdup at 

defense nuclear facilities and cites a need for three 

specific improvements: standardized requirements 

for performing measurements, design requirements 

to facilitate accurate holdup measurement in new 

facilities, and research and development on new 

instruments and/or measurement techniques. 

The Secretary accepted the recommendation on 

June 28, 2007, and transmitted the associated IP to 

the Board on October 24, 2007. With the exception 

 

2 RevCom is an online, real-time web application for

managing and supporting the collaborative 

development, review, approval, and dissemination of 

new and revised Departmental directives.
Board-Related Activities, FY11 │ Page 19

of periodic reviews and briefings, the Department 

completed the remaining specific IP commitments 

during FY11. These included defining and 

prioritizing requirements, programs, and guidance 

to address gaps in training and qualification,

equipment capabilities, directives, research and 

development, quality assurance, and oversight. The 

Department also provided the Board with a 

prioritized action plan, with a schedule and 

milestones, for addressing the gap analysis results. 

In May 2011, the Deputy Secretary committed to 

work closely with Board staff to address the gaps 

the Department has identified in the areas listed 

above.

Also in May 2011, DOE advised the Board that NNSA 

rather than EM would thereafter serve as the 

Department’s designated lead organization 

responsible for the remaining open commitments in 

the IP. EM and NNSA will continue to interface on 

the completion of programmatic actions. Only one 

EM facility, the Plutonium Finishing Plant at 

Hanford, relies on in situ measurements for 

criticality safety. This facility is undergoing 

accelerated decommissioning and will likely be 

razed before the site-specific actions associated 

with Recommendation 2007-1 have been 

completed. Y-12 is the only NNSA site with a 

credible criticality risk that relies on nondestructive 

assay for prevention.

2005-1: Nuclear Material Packaging 

The Board issued Recommendation 2005-1 on 

March 10, 2005. The recommendation 

acknowledges that DOE has made progress in 

stabilizing and storing its excess nuclear materials, 

but calls for DOE to further enhance nuclear safety 

by developing technically justified criteria for 

packaging systems for nuclear materials on a DOEwide level.

The Secretary accepted the recommendation on 

May 6, 2005, and transmitted the associated IP to 

the Board on August 17, 2005. The IP identified

several interim milestones and deliverables, 

including issuance of a new requirements document 

for packaging and storage of nuclear materials: DOE 

Manual 441.1-1, Nuclear Material Packaging 

Manual, which was issued in March 2008. The 

Department completed the final IP deliverable in 

September 2009. Repackaging activities continued 

in FY11 and completion is expected in FY14, with an 

emphasis on repackaging higher-risk materials 

earlier in the schedule. 

The first prototype of the next-generation special 

nuclear material container is undergoing design and 

test evaluation under the management of the LASO

package certification group. DOE sites are 

developing detailed plans for repackaging 

campaigns, with the goal of repackaging all nuclear 

material into containers meeting the 2008 guidance 

within the next four years.

The Department expects to close this 

recommendation in FY12, after the new storage 

containers have been produced and repackaging of 

very high- and high-risk material is complete. 

2004-2: Active Confinement Systems 

The Board issued Recommendation 2004-2 on 

December 7, 2004. The recommendation cites the 

benefits that would accrue if the Department 

changed its safety policy to require active 

confinement ventilation systems for all new and 

existing hazard category 2 and 3 defense nuclear 

facilities where there is the potential for a 

radiological release. The Board also recommended 

that the Department evaluate all new and existing 

defense nuclear facilities and enhance and update 

associated DOE directives and standards.

The Secretary accepted the recommendation on 

March 18, 2005. Revision 1 to the IP, which was 

transmitted to the Board on July 12, 2006, commits 

the Department to reviewing all hazard category 2 

and 3 defense nuclear facilities to assure that the 

selected confinement strategy is properly justified 

and documented. In accordance with the IP, priority 

was given to design and construction projects, 

including ongoing major modifications to existing 

facilities.
Board-Related Activities, FY11 │ Page 20

In a letter to the Board dated February 10, 2011, 

the NNSA announced the completion of deliverable 

8.6.5, Program Secretarial Office concurrence and 

approval on disposition of gaps and upgrades 

identified in evaluations after coordination with the 

CTA, if necessary. This deliverable required nonexcluded facilities to be evaluated for compliance 

with performance criteria identified in DOE’s 

Ventilation System Evaluation Guidance for SafetyRelated and Non-Safety Related Systems and the 

site-specific Documented Safety Analysis. Of the 

evaluated facilities, only the LANL PF-4 facility was 

identified as having performance gaps that required

upgrades. However, NNSA has postponed the 

implementation of all PF-4 upgrades related to 

Recommendation 2004-2 until after the PF-4 

seismic analysis in response to Recommendation 

2009-2, Los Alamos National Laboratory Plutonium 

Facility Seismic Safety, has been completed.

With the completion of deliverable 8.6.5, DOE has 

met all IP commitments except for updating its 

nuclear safety directives to incorporate guidance on

active confinement ventilation systems. HSS has 

developed draft revisions to the relevant directives 

(DOE Guide 420.1-1, Nonreactor Nuclear Safety 

Design Criteria and Explosive Safety Criteria Guide 

for Use with DOE Order 420.1, Facility Safety, and

DOE Order 420.1B Chg 1, Facility Safety). Both draft 

revisions have been submitted to RevCom, and DOE 

expects to complete this commitment in early FY12. 

2004-1: Oversight of Complex, High-Hazard 

Nuclear Operations 

The Board issued Recommendation 2004-1 on May 

21, 2004, citing concerns about a number of safety 

issues related to creating the CTA, delegations of 

safety responsibilities, technical capability, NSR&D, 

lessons learned from significant external events, 

and ISM.

The Secretary accepted the recommendation on 

July 21, 2004. Revision 2 to the IP was transmitted 

to the Board on October 12, 2006 and updated on 

August 30, 2011. The IP identifies several broad 

areas for improvement, including strengthening 

federal safety assurance, learning from internal and

external operating experience, revitalizing ISM

implementation, and improving NSR&D. 

On May 25, 2011, the Board held the third in a 

series of public meetings in Washington, D.C. to 

examine the Department’s implementation of this 

recommendation. Departmental progress on 

Recommendation 2004-1 during FY11 focused on IP 

commitments 7 and 8, which address the 

Department’s corporate approach to NSR&D. In an 

August 30, 2011, letter to the Board, the 

Department updated the IP to reflect a change in 

the responsible organization for commitments 7 

and 8. HSS (and the newly created HS-30) will now 

function as the integrating organization responsible 

for implementing these two commitments. HS-30 

has appointed a lead for the Department-wide 

effort to address crosscutting NSR&D issues. A 

project plan has been developed specifically to reinvigorate current NSR&D throughout the DOE 

complex, and HSS will develop and maintain a

Department-wide database of all NSR&D activities. 

Additional progress in FY11 included completing an 

HSS effectiveness assessment of the Department’s 

ability and processes to learn from both internal 

and external operating experiences.. Procedures 

and guidance have been adequately implemented 

and identified safety issues have been resolved. 

2002-3: Requirements for the Design,

Implementation, and Maintenance of 

Administrative Controls

The Board issued Recommendation 2002-3 on 

December 11, 2002. The recommendation cites 

technical inadequacies in a number of safetyrelated administrative controls (now called specific 

administrative controls) proposed for, or in use at,

various defense nuclear facilities. The Board noted 

that in many cases DOE and/or its contractors have 

asserted that the methods used to establish specific 

administrative controls comply with existing DOE 

directives. However, the Board concluded that the 

DOE directives system did not contain adequate 

requirements for the design, implementation, and 

maintenance of specific administrative controls.
Board-Related Activities, FY11 │ Page 21

The Secretary accepted the recommendation on 

January 31, 2003, and transmitted the associated IP

to the Board on June 26, 2003. HSS has undertaken 

efforts to bolster the Department’s actions to 

support closure of this recommendation that

involve site, Program Office, and HSS evaluations of 

specific administrative control implementation at 

targeted sites. These sites include LANL, Y-12, 

Lawrence Livermore National Laboratory, Pantex, 

SRS, Sandia National Laboratories, and the East 

Tennessee Technology Park. Program offices are 

working with these sites to ensure that the formal 

corrective actions are closed on a reasonable 

schedule. Additionally, the program offices must

verify more broadly that specific administrative 

controls are being evaluated across all of the 

program sites. In FY11, DOE conducted reviews at 

multiple DOE sites and provided updates to the 

DNFSB. DOE expects that this recommendation will 

be closed in FY12.

2001-1: High-Level Waste Management at the 

Savannah River Site 

Recommendation 2001-1 IP was closed in early 

FY12. It is discussed here for purposes of 

documenting progress made during FY11. 

The Board issued Recommendation 2001-1 on 

March 23, 2001, addressing the margin of safety 

and the amount of available tank space in the SRS

high-level waste system. 

The Secretary accepted the recommendation on 

May 18, 2001, and transmitted IP Revision 6 to the 

Board on November 24, 2010. The Board expressed 

its continued concern over changes in strategy and 

several delays that could adversely affect the SRS 

high-level waste system on January 28, 2011. The 

Board urged DOE to pursue additional measures to 

mitigate the impacts of these delays and associated 

risks at the tank farms.

Progress during FY11 included the completion of 

key technical review and procurement 

commitments. Savannah River Remediation, LLC, 

issued contracts to purchase additional tanks 

needed to allow the use of Tank 590 for tank farm 

service. DOE reviewed and certified completion of 

35 percent design of the Tank 48 Treatment Project 

by a design review of the completed set of technical 

documents. However, DOE suspended the Tank 48 

Treatment Project in July 2011 because of

identification of a promising new technology for 

treating the waste, and an improved outlook on 

high-level waste tank space resulting from 

enhancements at the Defense Waste Processing 

Facility.

2000-1: Prioritization for Stabilizing Nuclear 

Materials 

The Board issued Recommendation 2000-1 on 

January 14, 2000. The recommendation calls for an 

accelerated schedule for stabilizing and repackaging 

high-risk, unstable special nuclear materials, spent 

fuel, unstable solid plutonium residues, and highly 

radioactive liquids that pose potential safety 

concerns for the public, workers, and the 

environment. The Secretary accepted the 

recommendation on March 13, 2000. Revision 2 to 

the IP was transmitted to the Board on July 22, 

2002. On July 23, 2004, DOE transmitted an IP

update specific to LANL, and on November 28, 

2005, DOE transmitted an IP update specific to 

Hanford. 

This recommendation applies to both NNSA and EM 

sites. All NNSA commitments are complete with the 

exception of various stabilization activities at LANL, 

which are currently projected for completion by 

2013. All EM commitments are complete with the 

exception of the stabilization of sludge materials at 

the Hanford K-Basin Sludge Treatment Project (STP).

On December 1, 2009, EM informed the Board of its 

plans regarding the STP, and on June 30, 2010, DOE 

provided the Board with the project execution plan 

for the project. In a follow-up communication dated 

June 23, 2011, EM informed the Board that the STP 

alternatives analysis had identified several 

contracting and technology issues. These issues 

have forced an extension of the alternatives 

evaluation, and a plan is now in place to complete 

the STP packaging technology evaluation in 2012.
Board-Related Activities, FY11 │ Page 22

V. Interface Activities

A. Briefings, Site Visits, and Other 

Board Interactions 

The Board and its staff regularly visit the 

Department’s defense nuclear facilities to review

the implementation of safety initiatives, examine 

safety facilities and operations, and attend 

briefings. Information about DNFSB interactions

with DOE is available on the DR website at

www.hss.doe.gov/deprep. 

B. Responses to Board Reporting 

Requirements 

During FY11, the Board issued 18 formal reporting 

requirements, as shown in Appendix A, Table A.2.

Table A.3 lists the three active reporting 

requirements from prior years, and Table A.4 lists 

the 20 letter commitments DOE completed during 

FY11.

C. Public Meetings 

Three public meetings were held during FY11. The

first took place October 7-8, 2010, in Pasco, WA and 

focused on concerns associated with safety-related 

aspects of the design and construction of the 

Hanford Site WTP. Technical issues reviewed 

included: (1) changes in safety-related design 

criteria resulting from modification of the materialat-risk characterization in tanks; (2) changes in

design strategy to address hydrogen in pipes and 

ancillary vessels; (3) criticality safety concerns and 

other safety-related risks for the PJM system; (4) 

reclassification of safety-related SSCs; and (5) 

safety-related design aspects of new facilities or 

modifications of existing facilities needed to deliver 

high-level waste feed.

The second meeting was held May 2-5, 2011, at 

the Board’s public hearing room in Washington D.C. 

The Board discussed DOE's implementation of 

Recommendation 2004-1, Oversight of Complex, 

High-Hazard Nuclear Operations. 

The third meeting was held June 16, 2011, in 

Augusta, GA and addressed three topics concerning 

operations at the SRS: (1) liquid waste processing; 

(2) emergency preparedness; and (3) nuclear 

materials storage and disposition (the future of the 

H-Canyon facility). 

Early in FY12, the DNFSB held a public hearing in 

Santa Fe, NM on the seismic safety of the LANL PF-4

facility. The hearing focused on DOE’s definition of 

adequate public safety and highlighted the 

continuing points of discussion between DOE and 

the DNFSB on issues that are intrinsic to 

Recommendations 2009-2 and 2010-1. DOE will 

consider the concerns presented at the hearing and 

the ongoing discussions with the DNFSB, including 

their concerns regarding the schedule for planned 

installation of active confinement ventilation, as the 

final commitments are completed.
Board-Related Activities, FY11 │ Page 23

Appendix A. Summary Status of Board Recommendations 

and Reporting Commitments 

Table A.1: Open Recommendations

Recommendation

Number Title Date Opened

Timeframe for 

Completing 

Implementation Plan

2000-1 Prioritization for Stabilizing Nuclear 

Materials 01/14/2000 Late 2015

2001-1 High-Level Waste Management at the 

Savannah River Site 03/23/2001 Closed 12/7/2011

2002-3

Requirements for the Design, 

Implementation, and Maintenance of 

Administrative Controls

12/11/2002 2012

2004-1 Oversight of Complex, High-Hazard 

Nuclear Operations 05/21/2004 2013

2004-2 Active Confinement Systems 12/07/2004 2012

2005-1 Nuclear Material Packaging 03/10/2005 All Plan Commitments 

Complete

2007-1 Safety-Related In Situ Nondestructive 

Assay of Radioactive Materials 04/25/2007 2012

2008-1 Safety Classification of Fire Protection 

Systems 01/29/2008 2012

2009-1 Risk Assessment Methodologies at 

Defense Nuclear Facilities 07/30/2009 2012

2009-2 Los Alamos National Laboratory 

Plutonium Facility Seismic Safety 10/26/2009 2012

2010-1

Safety Analysis Requirements for Defining 

Adequate Protection for the Public and the 

Workers

10/29/2010 2013

2010-2 Pulse Jet Mixing at the Waste Treatment 

and Immobilization Plant 12/17/2010 2016

2011-1 Safety Culture at the Waste Treatment 

and Immobilization Plant 06/20/2011 2013
Board-Related Activities, FY11 │ Page 24

Table A.2: Formal Reporting Requirements Issued by the Board in FY11

Date Reporting Requirements Days to 

Report

10/22/2010 A report on actions to correct work planning and control deficiencies at 

the Waste Isolation Pilot Plant 90

01/25/2011

A report and briefing on anticipated improvements to public and worker 

safety resulting from the expedited directives review process and 

resolution of staff comments on two DOE orders

30

02/04/2011 A report and briefing on Non-MAA [Material Access Area] Material 

Storage at Y-12 in Building 9720-5

90

02/08/2011

Briefing to discuss NNSA's decision process, timing, and bases for 

changes related to Board concerns resolved under the Chemistry and 

Metallurgy Research Replacement certification process at Los Alamos

National Laboratory

30

03/28/2011 A report on work planning and control process improvements by the 

Nevada Site Office and National Security Technologies, LLC 90

04/05/2011 A report on the Department's spray leak analysis and methodology for 

the Waste Treatment and Immobilization Plant 60

04/05/2011

A report on actions taken to completely implement Standard 

DOE-NA-STD-3016-2006, Hazard Analysis Reports for Nuclear 

Explosive Operations at weapons design agencies

90

04/08/2011 A report and briefing on issues related to the SASSI computer software 

code 45

04/20/2011 A report and briefing on Safety Posture of Y-12 National Security 

Complex 30

04/26/2011 A report and briefing on actions to address the deficiencies associated 

with the waste transfer system at Hanford 90

05/05/2011

A report and briefing to address the deficiencies in the instrumentation 

and control system design for the Waste Treatment and Immobilization 

Plant

30

05/16/2011

A report and briefing to provide the rationale for the current proposed 

safety basis and control strategy for the Tritium Facility at Lawrence 

Livermore National Laboratory

30

06/07/2011

A report on the continued use of the Low Order Accumulation Model for 

accumulation of solids in Waste Treatment and Immobilization Plant 

vessel calculations

60
Board-Related Activities, FY11 │ Page 25

Table A.2: Formal Reporting Requirements Issued by the Board in FY11 (cont’d)

Table A.3: Active Reporting Requirements Issued by the Board in Prior Years

Date Reporting Requirements Days to 

Report

06/24/2011 A report Outlining actions taken or planned by DOE to address 

weaknesses in the fire protection program at Waste Isolation Pilot Plant 180

08/03/2011

A report on the validity of the heat transfer analyses from process 

vessels in the Pretreatment Facility at the Waste Treatment and 

Immobilization Plant 

60

08/19/2011 A report and briefing on the revised safety basis at the Savannah River 

Site tritium facilities. 90

08/25/2011 A report and briefing on weaknesses in conduct of operations and 

technical procedures at the Y-12 National Security Complex 180

09/13/2011 A report on the hazards and controls associated with the anhydrous 

ammonia system at the Waste Treatment and Immobilization Plant 60

Date Reporting Requirements Frequency

8/7/2003

(Modified 

1/28/2008)

Annual report on the Department’s Nuclear Criticality Safety Program 1 year

9/9/2005 Annual briefing on the contents of the annual revision to the Pantex 

Nuclear Material Management Program 1 year

3/13/2007 Annual report on the annual assessment of the 9212 Complex, and the 

progress on the Uranium Processing Facility 1 year
Board-Related Activities, FY11 │ Page 26

Table A.4: Letter Commitments Completed in FY11

Letter 

Number Commitment Title Date Completed

SL10-009 Monthly briefings on DOE safety and security reform and DOE directives 

consolidation 10/25/2010

SL10-018 A report and briefing on analytical and implementation deficiencies in the 

Hanford Tank Farms Documented Safety Analysis 10/29/2010

SL10-016 A report and briefing on actions to bring the Savannah River Site 

Documented Safety Analysis procedures into compliance with 10 CFR 830 11/23/2010

SL10-021 A report on actions to correct work planning and control deficiencies by the 

Richland Operations Office and CH2M Hill Plateau Remediation Company 12/20/2010

SL10-020

A report on deficiencies in the electrical safety program and the 480V Motor 

Control Center in the Fire Water Pump Building at the Waste Isolation Pilot 

Plant

12/21/2010

SL09-014 Quarterly report on the status of the Structural Peer Review Team efforts 

regarding Waste Treatment and Immobilization Plant facilities 12/29/2010

SL05-026 Annual briefing on the contents of the annual revision to the Pantex 

Nuclear Material Management Program 01/20/2011

SL10-022 A report on actions to correct work planning and control deficiencies at 

Waste Isolation Pilot Plant 01/20/2011

SL10-019

A report and briefing on deficiencies in the accident analysis, control set, 

and safety system design for the Critical Experiments Facility at Nevada 

Test Site

02/10/2011

SL11-002

A report and briefing on anticipated improvements to public and worker 

safety resulting from the expedited directives review process and resolution 

of staff comments on two DOE orders

02/25/2011

SL03-031 Annual report on the Department’s Nuclear Criticality Safety Program 03/15/2011

SL07-004 Annual report on the annual assessment of the 9212 Complex, and the 

progress on the Uranium Processing Facility 05/17/2011

SL11-003 A report and briefing on Non-MAA [Material Access Area] Material Storage 

at Y-12 in Building 9720-5 05/18/2011

SL11-008 A report on the Department's spray leak analysis and methodology for the 

Waste Treatment and Immobilization Plant 06/03/2011

SL11-013

A report and briefing to provide the rationale for the current proposed safety 

basis and control strategy for the Tritium Facility at Lawrence Livermore

National Laboratory

06/15/2011

SL11-009 A report and briefing on Safety Posture of Y-12 National Security Complex 06/16/2011
Board-Related Activities, FY11 │ Page 27

Table A.4: Letter Commitments Completed in FY11 (cont’d)

Letter

Number Commitment Title Date Completed

SL11-005 A report on work planning and control process improvements by the 

Nevada Site Office and National Security Technologies, LLC 06/22/2011

SL11-010 A report and briefing on actions to address the deficiencies associated with 

the waste transfer system at Hanford 08/02/2011

SL11-007

A report on actions taken to completely implement Standard 

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

Operations at weapons design agencies

08/03/2011

SL11-016

A report on the continued use of the Low Order Accumulation Model for 

accumulation of solids in Waste Treatment and Immobilization Plant vessel 

calculations

08/05/2011
Board-Related Activities, FY11 │ Page 28

Appendix B. Acronyms and Abbreviations 

ASME American Society of Mechanical Engineers 

Board Defense Nuclear Facilities Safety Board 

CDNS Chief of Defense Nuclear Safety 

CFR Code of Federal Regulations

CNS Chief of Nuclear Safety

CTA Central Technical Authority

CPR Construction Project Review

CRAD Criteria, Review, and Approach Document

DEAR DOE Acquisition Regulations

Department Department of Energy

DNFSB Defense Nuclear Facilities Safety Board

DOE Department of Energy 

DPO Differing Professional Opinion

DR Departmental Representative to the DNFSB 

DV Deposition Velocity

EFCOG Energy Facility Contractors Group 

EM Office of Environmental Management 

FY Fiscal Year 

HSS Office of Health, Safety and Security

HS-30 Office of Nuclear Safety

INPO Institute of Nuclear Power Operations

IP Implementation Plan

ISM Integrated Safety Management 

ISMS Integrated Safety Management System

JCO Justification for Continued Operations 

LANL Los Alamos National Laboratory 

LASO Los Alamos Site Office 

NASA National Aeronautics and Space Administration

NNSA National Nuclear Security Administration 

NRC Nuclear Regulatory Commission 

NSR&D Nuclear Safety Research and Development 

PF-4 Plutonium Facility

PJM Pulse Jet Mixing 

PMP Project Management Plan

RWG Risk Assessment Technical Experts Working Group

SAFER Seismic Analysis of Facilities and Evaluation of Risk

SASSI System for Analysis of Soil-Structure Interaction

SRS Savannah River Site 

SSC Structures, Systems, and Components

STP Sludge Treatment Project

WPC Work Planning and Control 

WTP Waste Treatment and Immobilization Plant