Department of Energy 

Activities Relating to the 

Defense Nuclear 

Facilities Safety Board 

Fiscal Year 2012 

Report to Congress 

August 2013 

United States Department of Energy 

Washington, DC 20585 
Department of Energy I August 2013 

Message from the Secretary 

Section 316(b) of the Atomic Energy Act of 1954, as amended, requires the Department of Energy to 

submit a written report to Congress addressing the Department' s activities related to the Defense 

Nuclear Facilities Safety Board (Board). Enclosed is the Fiscal Year 2012 (FY12) report on Department 

of Energy Activities Relating to the Board. 

The Board has a critical advisory role within the Department' s safety framework for defense nuclear 

facilities. Its expertise in reviewing the Department's safety directives and nuclear facility designs 

helps strengthen the safety protocols at the Department' s facilities nationwide, and we welcome the 

Board's advice and recommendations. Through healthy exchanges with the Board and its staff, we can 

together fulfill our shared goal of protecting workers and the public at the Department's defense 

nuclear facilities. We look forward to continuing to work closely with the Board in the coming year and 

welcome Congress' review of the attached FY12 Annual Report. 

Highlights of the Department' s accomplishments are included in the report's Executive Summary. 

Additional details, as well as the status of the Department' s actions in response to Board 

recommendations and other Board input, are included in the body of the report. 

This report is being provided to the following members of Congress: 

• The Honorable Joseph R. Biden, Jr. 

President of the Senate 

• The Honorable Ron Wyden 

Chair, Senate Committee on Energy and Natural Resources 

• The Honorable Lisa Murkowski 

Ranking Member, Senate Committee on Energy and Natural Resources 

• The Honorable Barbara A. Mikulski 

Chair, Senate Committee on Appropriations 

• The Honorable Richard C. Shelby 

Ranking Member, Senate Committee on Appropriations 

• The Honorable Dianne Feinstein 

Chair, Senate Subcommittee on Energy and Water Development 

• The Honorable Lamar Alexander 

Ranking Member, Senate Subcommittee on Energy and Water Development 

• The Honorable Carl Levin 

Chair, Senate Committee on Armed Services 

• The Honorable James M. lnhofe 

Ranking Member, Senate Committee on Armed Services 

Board-Related Activities, FY12 I Page i 
Department of Energy I August 2013 

• The Honorable Mark Udall 

Chair, Senate Subcommittee on Strategic Forces 

• The Honorable Jeff Sessions 

Ranking Member, Senate Subcommittee on Strategic Forces 

• The Honorable John Boehner 

Speaker of the House of Representatives 

• The Honorable Harold Rogers 

Chair, House Committee on Appropriations 

• The Honorable Nita M. Lowey 

Ranking Member, House Committee on Appropriations 

• The Honorable Rodney Frelinghuysen 

Chair, House Subcommittee on Energy and Water Development 

• The Honorable Marcy Kaptur 

Ranking Member, House Subcommittee on Energy and Water Development 

• The Honorable Howard P. "Buck" McKeon 

Chair, House Committee on Armed Services 

• The Honorable Adam Smith 

Ranking Member, House Committee on Armed Services 

• The Honorable Mike Rogers 

Chair, House Subcommittee on Strategic Forces 

• The Honorable Jim Cooper 

Ranking Member, House Subcommittee on Strategic Forces 

• The Honorable Fred Upton 

Chair, House Committee on Energy and Commerce 

• The Honorable Henry A. Waxman 

Ranking Member, House Committee on Energy and Commerce 

If you have any questions or need additional information, please contact me or Mr. Brad Crowell, 

Assistant Secretary for Congressional and Intergovernmental Affairs, at (202) 586-5450. 

Sincerely, 

Ernest J. Moniz 

Board-Related Activities, FY12 I Page ii 
Department of Energy I August 2013 

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 2012 (FY12) 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. 

The Department has a unique role as owner, operator, and regulator of the nation's defense nuclear 

facilities, and the Board's expertise has enhanced the Department's nuclear safety posture at these 

facilities. Despite progress made during FY12, some very difficult issues relating to safety culture, 

safety assurance, and the design of both aging and new facilities came into focus during FY12 at several 

facilities. 

Department Safety Initiatives, Activities, and Reforms 

The Department has undertaken safety initiatives, activities, and reforms, including safety initiatives to 

reinforce and ensure nuclear safety performance. 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 independent oversight activities of the DOE Office of Health, Safety and 

Security (HSS). 

Safety Culture. The critical importance of safety culture was reiterated by the Secretary and Deputy 

Secretary in a memorandum to DOE managers on December 5, 2011, which emphasized the 

Secretary's expectations f~r a healthy safety culture. The memorandum provided the vision for how 

DOE's safety culture should support and be an integral part of completing its mission. Throughout 

FY12, DOE focused on safety culture assessments and improvements to resolve identified safety 

culture deficiencies at the Hanford Site Waste Treatment and Immobilization Plant (WTP) and the 

Pantex Plant, and to assess and improve safety culture throughout the DOE complex. Independent 

safety culture assessments were conducted for selected major nuclear design, construction and 

operational projects to identify safety culture concerns. These assessments provided insight to safety 

culture challenges across the Department. Significant efforts are needed to upgrade the safety culture 

of some organizations to meet DOE standards and expectations for a healthy organizational culture 

and working environment. Many corrective action plans have been initiated, and DOE is continuing to 

implement a sustained, long-term effort to complete these actions, to effectively change 

organizational cultures, and to support a thriving, safety-conscious work environment. 

Safety Assurance. In July 2012, the Deputy Secretary informed the Board of the Department's 

processes for ensuring public safety from the operation of its nuclear facilities (including new designs 

and existing facilities), and a path forward to improve these processes. The path forward describes 

how the Department intends to respond to new information (e.g., new seismic hazards) and provides 

additional criteria by which DOE will evaluate the adequacy of a facility's safety basis for rare situations 

(exigent circumstances) where, for existing facilities, the hazard control set does not provide the level 

of accident mitigation called for in DOE standards. Further, the path forward describes the 

Board-Related Activities, FY12 I Page iii 
Department of Energy I August 2013 

documentation required in such situations and the process for obtaining approval of the facility safety 

basis. 

Aging Facilities and Adequacy of Design. During FY12, the Department initiated or accelerated 

activities specifically to address age-related issues at its most susceptible facilities, notably the 

Plutonium Facility (PF-4) at Los Alamos National Laboratory and Building 9212 at the Y-12 National 

Security Complex (Y-12). PF-4 is critical to the Department's mission and to national security. Several 

years ago, design safety analysis reevaluations indicated that the PF-4 structure could be more 

vulnerable to seismic activity than previously believed. Improvements to PF-4's structural integrity and 

close attention to material at risk have continued throughout the year. The updated structural analysis 

which provides a full understanding of the building vulnerabilities and which supports the development 

of the long-term path forward for reinforcing PF-4 is nearing completion. The Building 9212 Complex 

cannot meet the existing requirements for Hazard Category 2 nuclear facilities and is over 60 years old. 

Action to reduce the amount of radioactive material in the facilities and increased management 

attention to the physical condition of the facility has been effective in supporting safe and reliable 

operations. 

Integration of Safety into New Facility Design. During FY12, the Secretary and a group of 

independent, highly capable subject matter experts reviewed technical challenges associated with the 

design ofthe WTP. In an effort to accelerate the resolution of the remaining technical issues, a design 

completion core team and a number of technical sub-teams were established and staffed with 

experienced employees from DOE, the national laboratories, and DOE's contractor. The technical subteams are focused on: (1) vessel testing; (2) in-service inspection and redundancy; (3) vessel analysis 

including analysis of "black cells" (enclosed concrete rooms containing tanks and piping in the WTP 

Pretreatment Facility that are designed to be sealed due to high levels of radioactivity, with no access 

by personnel over the anticipated 40-year operating life cycle of the plant); (4) erosion/corrosion; and 

(5) the identification of tank farm waste pre-treatment requirements. 

Timely and comprehensive integration of safety into the design of the Uranium Processing Facility at Y12 is also a concern, but FY12 has seen significant improvement resulting from narrowing the gap 

between the maturity of the engineering design and the safety case, resolving several Board technical 

issues (e.g., seismic design criteria, criticality safety criteria, and post seismic event ventilation 

capability), and improving the quality of the safety document. 

Work Planning and Control. Although the Department has required application of integrated safety 

management concepts in performing hazardous work for about 15 years, the Department continues to 

struggle to effectively implement consistent work planning and control processes across the complex. 

Many operating experience reports in the Department's safety databases identify poor work planning 

and control processes as the root cause. The Deputy Secretary committed to improving 

implementation through better implementation guidance, analysis of lessons learned, and clearly 

defined Federal oversight. Actions continue at several levels to continuously improve work planning 

and control processes through responses to specific Board concerns and proactive Departmental 

initiatives. 

Board-Related Activities, FY12 I Page iv 
Department of Energy I August 2013 

Lessons from Fukushima. In the six months following the March 2011 Fukushima Daiichi Nuclear 

Power Plant disaster in Japan, the Department took several actions to review the safety of its nuclear 

facilities and identify near-term improvements. These actions and recommendations were addressed 

in an August 2011 report to the Secretary of Energy, Review of Requirements and Capabilities for 

Analyzing and Responding to Beyond Design Basis Events. Based on recommendations in this report, 

DOE embarked on activities in FY12 to develop and refine guidance that supports improvements in 

DOE processes for analyzing and mitigating beyond design basis events at its nuclear facilities. 

Completion of Directives Reform Initiative. During FY12, HSS completed the directives reform effort 

started in FY10. This accomplishment improved the Department's ability to execute its mission safely 

and efficiently. By removing unnecessary process requirements and eliminating directives that were 

either redundant or unnecessary for safety and health these revisions give added clarity and emphasis 

to essential safety requirements and to line management responsibility and accountability. 

Board Recommendations 

The Board stated that it closed one recommendation in FY12, Recommendation 2001-1, High-level 

Waste Management at the Savannah River Site. The Board issued two new recommendations in FY12: 

Recommendation 2012-1, Savannah River Site Building 235-F Safety; and Recommendation 2012-2, 

Hanford Tank Farms Flammable Gas Safety Strategy. Fourteen recommendations remained open at 

the end of FY12. 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, FY12 I Page v 
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Department of Energy I August 2013 

REPORT TO CONGRESS 

Table of Contents 

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

II. Background and Organization ............................................................................ 1 

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

A. Safety Culture .................................................................................................................................... 3 

B. Safety Assurance .. ............................................................................................................................. 4 

C. Aging Facilities and Adequacy of Design ........................................................................................... 4 

D. Integration of Safety into New Facility Design .................................................................................. 5 

E. Work Planning and Control ............................................................................................................... 6 

F. Lessons from Fukushima ................................................................................................................... 6 

G. Completion of Directives Reform Initiative ....................................................................................... 7 

H. Office of Environmental Management Activities .............................................................................. 7 

I. NNSA Defense Program Activities ..................................................................................................... 8 

IV. FY12 Progress on Board Recommendations ........................................................ 9 

Overview ....................................................................................................................................................... 9 

Recommendations Closed in FY12 .............................................................................................................. 10 

Recommendations Opened in FY12 ........................................................................................................... 10 

Other Open Recommendations .................................................................................................................. 11 

V. Interface Activities ................................................................................................. 16 

Appendix A. FY12 Summary: Open Recommendations, Reporting Requirement 

Commitments Met, and Public Meetings and Hearings .................................... 18 

Appendix B. Acronyms and Abbreviations ................................................................. 21 

Figures 

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

Board-Related Activities, FY12 I Page vii 
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Department of Energy I August 2013 

I. Legislative Language 

This report is provided in accordance with 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, 

Appropriations, and Energy and Commerce of the House of Representatives and the Committees on 

Armed Services, Appropriations, and Energy and Natural Resources of the Senate each year, at the 

same time that the ·President submits the budget to Congress pursuant to section llOS(a) of Title 31 

[United States Code], a written report concerning the activities of the Department of Energy under this 

subchapter during the year preceding the year in which the report is submitted. 

II. Background and Organization 

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

report to Congress describing the Department's activities in fiscal year 2012 (FY12) that are 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 major 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 and hearings, Board briefings, discussions, 

and Board site visits. The Board's four public hearings in FY12 are listed in Appendix A, Table A.3. 

The remainder of this report is organized as follows: 

• Section Ill, Department Safety Initiatives, Activities, and Reforms, describes broad-based 

Departmental activities affecting environment, safety, and health that are of interest to the 

Board. 

• Section IV, FY12 Progress on Board Recommendations, describes Departmental activities 

completed or ongoing in FY12 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. 

Board-Related Activities, FY12 I Page 1 
Department of Energy I August 2013 

• Appendix A contains tables illustrating the status of the open Board recommendations, 

reporting requirement commitments completed, and Board public meetings and hearings in 

FY12. 

• Appendix B lists acronyms and abbreviations. 

H1nford Sitt: 

Office of River Protection (ORP) 

Rlchlend Operotlons Office (Rl) 

Poclflc Northwest Sitt Ollice (PNSO) 

Ltwrtnt t Llvtrmore National 

L•borotoiv: 

Livermore Sitt Office (LSO) 

~ • 

\ • 

• 

Idaho Sitelldaho National Laboratory: 

Idaho Operations Olfice (DOE.JD) 

/ 

• 

• 

Oak Ridge 

Y-12 National Security Complex. 

NNSA Production Office (NPO) 

Oak Ridge Ollice ol Environmental Management 

• ,OQ Nevodo .. ""'M" Site Olflce '"""" (NSO) "'" / ~ ~ /'• 

Los Alamos Notional Laboratory: I • Los Alamos Sitt Office (LASO) 

Sandia National Laboratories: 

Sandia Sitt Olllce (SSO) \ • 

Waste Isolation Pilot Plant: 

Carlsbad Field Olflce (CBFO) 

Pontex Plant: 

NNSA Production Olflce (NPO) 

Savannah River Site: 

Sovonnoh River Operations Olflce (SRO) 

Savannah River Site Ofllce (SRSO) 

Figure 1. Department of Energy Defense Nuclear Facility Sites 

III. Department Safety Initiatives, Activities, 

and Reforms 

This section describes the FY12 initiatives and activities the Department took to improve and ensure its 

nuclear safety performance throughout the complex. These activities address issues identified by the 

Board and issues identified through self-assessments and independent oversight efforts undertaken by 

the Department at its defense nuclear facilities. 

Board-Related Activities, FY12 I Page 2 
Department of Energy I August 2013 

A. Safety Culture 

Safety culture assessments and improvements were a focus for DOE throughout FY12 to resolve 

identified safety culture deficiencies at the Waste Treatment and Immobilization Plant (WTP) at the 

Hanford Site and to assess and improve safety culture throughout the DOE complex. Safety culture is 

also a Board priority. On June 9, 2011, the Board transmitted Recommendation 2011-1, Safety Culture 

at the Waste Treatment and Immobilization Plant, to the Secretary. This recommendation prompted 

DOE to redouble its efforts to foster a rigorous safety culture. During FY12, the Secretary confirmed 

the importance he places on a robust safety culture throughout the Department. The Office of River 

Protection (ORP) at Hanford moved to implement corrective actions at the WTP, and the DOE Office of 

Health, Safety and Security (HSS) initiated a broad assessment of the state of safety culture at WTP and 

other DOE sites. DOE developed safety culture-relevant guidance and training designed to elevate the 

importance of safety culture at nuclear facilities. 

Secretarial Reiteration of Safety Culture Expectations. The Secretary and Deputy Secretary reiterated 

the critical importance of safety culture in a memorandum to DOE managers on December 5, 2011, 

which emphasized the Secretary's expectations for a healthy safety culture. The memorandum 

provided a vision of how DOE's safety culture should support and be an integral part of completing its 

mission. The Secretary also led a town hall meeting near the WTP in June 2012, which he used as a 

venue to emphasize his high expectations with regard to safety culture. 

Assessment of Safety Culture throughout DOE. As part of the Implementation Plan (IP) to address 

DNFSB Recommendation 2011-1, the Secretary directed the performance of safety culture 

assessments at selected major nuclear design, construction, and operational projects to determine 

safety culture concerns (extent-of-condition assessments). Before beginning the assessments, DOE 

enhanced its capability to assess safety culture processes and capability through consultation with the 

Nuclear Regulatory Commission, several nuclear power generating utilities, and associated 

organizations to benchmark their processes. HSS contracted with nationally recognized experts in 

human performance analysis to support the data collection and analysis efforts. The assessments 

included a review that followed up on DOE's October 2010 review of WTP nuclear safety culture. 

The projects and organizations reviewed for safety culture in FY12 were: the Office of Environmental 

Management (EM) Headquarters, Los Alamos National Laboratory (LANL) Chemistry and Metallurgy 

Research Replacement Project (CMRR), WTP and ORP, the Pantex Plant (Pantex), the Uranium 

Processing Facility (UPF) Project, and the Idaho Cleanup Project Sodium Bearing Waste Treatment 

Plant. Workforce commitment to execute the mission and site mechanisms to identify problems are 

positive observations of the reviews. Insufficient oversight, weak safety conscious work environment 

(SCWE) behaviors, and inadequate communication are areas in need of attention. Many sites have 

already started corrective action plans. 

Safety Conscious Work Environment Self-Assessment Guidance and Training. A SCWE is a subset of 

safety culture related to a work environment in which employees feel free to raise safety concerns to 

management (and/or a regulator) without fear of retaliation. Drawing on the lessons learned from the 

safety culture extent-of-condition reviews at selected sites and related self-assessments at other sites 

Board-Related Activities, FY12 I Page 3 
Department of Energy I August 2013 

during FY12, DOE issued SCWE self-assessment guidance and developed a SCWE training course for 

DOE and contractor leaders. SCWE training was delivered to Headquarters and field staff beginning in 

August 2012. Development of two new courses tailored for workers and front line supervisors to 

complement the first course began in FY12. 

B. Safety Assurance 

Safety is of vital importance in the execution of the Department's missions. DOE implements measures 

that permit a facility to operate in a manner that provides adequate protection of public health and 

safety. In July 2012, the Deputy Secretary forwarded to the Board a "path forward" that presented the 

Department's commitments to ensure adequate protection. 

The path forward describes how to implement the Secretary's commitments for new and existing 

facilities, and how the Department intends to respond to new information {e.g., new seismic hazards). 

The path forward also provides additional criteria by which DOE will evaluate the adequacy of a 

facility's safety basis and its implementation, and describes the documentation required for areas that 

must be revisited or receive further management oversight and approval. 

The provisions of the path forward comprise a Departmental commitment under the IP for Board 

Recommendation 2010-1, Safety Analysis Requirements for Defining Adequate Protection for the Public 

and the Workers, and the Department intends to include them in the final revisions to DOE Standard 

3009, Preparation Guide for U.S Department of Energy Nonreactor Nuclear Facility Documented Safety 

Analyses, and DOE Standard 1104, Review and Approval of Nuclear Facility Safety Basis and Safety 

Design Basis Documents. 

C. Aging Facilities and Adequacy of Design 

Many of the Department's defense nuclear facilities are rapidly approaching or have already exceeded 

their expected life spans. Some of these facilities no longer meet modern safety standards, and the 

original design of some of the older facilities is acknowledged to be unable to meet current and 

credible design basis seismic or weather-related accidents or a rare "beyond design basis event" 

(BOBE). Recognizing this challenge, the Department is analyzing the most pressing age-related hazards 

confronting its older facilities and implementing measures to eliminate or mitigate them. During FY12, 

the Department initiated or continued with activities specifically to address age-related issues at its 

most susceptible facilities. Examples of current activities the Department is taking to address agerelated concerns at two unique mission-critical facilities are provided below. 

Los Alamos National Laboratory Plutonium Facility (PF-4). Board Recommendation 2009-2, Los 

Alamos National Laboratory Plutonium Facility (PF-4} Seismic Safety, was motivated by concerns about 

a postulated seismically-induced fire. The National Nuclear Security Administration (NNSA) has 

completed extensive structural modifications, and additional actions are being pursued to ensure that 

seismic concerns are thoroughly addressed. The facility upgrades initially drove the estimated dose to 

the hypothetical maximally-exposed offsite individual (MEOI) well below the 2008 documented safety 

analysis (DSA) but above the Department's evaluation guideline. However, the seismic analysis of 

Board-Related Activities, FY12 I Page 4 
Department of Energy I August 2013 

facilities and evaluation of risk updated the estimated dose to the hypothetical MEOI in April 2011 

based on new information but it remained above the Department's guideline. Dose consequence 

calculations have been continuously debated since this update as a result of differing technical 

opinions on calculation parameters. Actions taken in the last three years - such as structural 

reinforcement, combustible and ignition source reduction, improved material packaging, and improved 

fire barriers - reduce the potential consequences from the postulated accident. However, additional 

actions are being pursued to ensure that seismic concerns are thoroughly addressed, especially efforts 

to better understand and model responses of the PF-4 structure to seismic events that could be linked 

to building collapse. Late in 2012, the site identified potential collapse mechanisms from a large, rare 

earthquake (i.e., a period of greater then 8,300 years) and initiated a PF-4 Safety Basis addendum. 

NNSA is moving forward with the Deputy Secretary's directed guidelines, including steps to be followed 

when an exigent condition causes design safety analysis calculations to exceed guidelines. 

V-12 National Security Complex, Building 9212. Until the UPF can be constructed and become 

operational, enriched uranium (EU) operations will depend on continued operations within Building 

9212, portions of which are over 60 years old. DOE has initiated a regimen of increased vigilance and 

.close observation by the 9212 Continued Safe Operability Oversight Team (CSOOT), which regularly 

conducts facility risk reviews to assess the physical condition of Building 9212 to support safe 

operations. The CSOOT makes quarterly updates to senior management on their evaluations and 

recommendations regarding the continued safe operation of Building 9212. 

In addition, the CSOOT provides an annual written report and briefing to NNSA and the Board. The 

CSOOT's FY12 annual evaluation of Building 9212 performance indicators, facility system and process 

condition assessments, and operations and safety data identified no safety issue that would currently 

provide reason for limiting operations in Building 9212. Line management responded promptly with 

increased attention to aging issues with respect to important safety-related fire suppression systems -

end-of-life sprinkler heads - and identified corrosion issues in dry pipe systems. Replacement efforts 

were promptly implemented in both cases to facilitate continued safe operation. These events 

validated the ability of current oversight and infrastructure to respond to aging issues and to ensure 

that risk remains acceptable for continued safe operations in Building 9212. The Board has especially 

been concerned as the schedule for the UPF slipped, requiring Building 9212 to operate until at least 

2022. Taking these concerns into consideration, a February 14, 2012, memorandum from the NNSA 

Deputy Administrator for Defense Programs outlined an accelerated UPF project strategy to begin 

transitioning EU processes out of Building 9212 in 2019. 

D. Integration of Safety into New Facility Design 

Resolution of Technical Issues. During FY12, the Secretary and a group of independent, highly capable 

subject matter experts reviewed technical challenges associated with the design of the WTP. These 

experts also provided independent analysis of some of the challenges associated with the construction 

and operation of the WTP. 

To accelerate the resolution of the remaining technical issues, a design completion core team and a 

number of technical sub-teams were established and staffed with experienced employees from DOE, 

Board-Related Activities, FY12 I Page 5 
Department of Energy I August 2013 

the national laboratories and DOE's contractor. The technical sub-teams are focused on: (1) vessel 

testing; (2) in-service inspection and redundancy; (3) vessel analysis including analysis of "black cells" 

(enclosed concrete rooms containing tanks and piping in the WTP Pretreatment Facility that are 

designed to be sealed due to high levels of radioactivity, with no access by personnel over the 

anticipated 40-year operating life cycle of the plant); (4) erosion/corrosion; and (5) identification of 

tank farm waste pre-treatment requirements. 

Further examples of initiatives and activities to integrate safety into new facility design are presented 

below in Section Ill.I, NNSA Defense Program Activities. 

E. Work Planning and Control 

At the core of the implementation of integrated safety management {ISM) are effective work planning 

and control (WP&C) processes that ensure the safety of workers, the public, and the environment. The 

Department's missions rely on well-developed and consistently implemented WP&C programs. The 

Deputy Secretary committed to striving for continuous improvement by strengthening guidance 

through the Department directives system and ensuring adequate Federal and contractor oversight 

methods. The objective is to attain a lasting and consistent methodology for safe and successful 

WP&C. 

Activities to strengthen WP&C implementation and oversight included the development and issuance 

of a revised DOE Guide 226.1-2, Federal Line Management Oversight of Department of Energy Nuclear 

Facilities, that includes criteria, review, and approach documents (CRADs) to assist in program 

implementation and oversight. 

DOE and the Energy Facility Contractors Group {EFCOG) completed efforts that began in FYll to 

improve contractor implementation, assurance, and Federal oversight of WP&C across DOE, allowing 

opportunities for improvement in the integration of WP&C programs. This effort resulted in the 

issuance of the detailed EFCOG WP&C Program Guideline document, which provides examples for 

developing an effective program. 

F. Lessons from Fukushima 

In the six months following the March 2011 Fukushima Daiichi Nuclear Power Plant disaster in Japan, 

the Department took several actions to review the safety of its nuclear facilities and identify 

opportunities for near-term improvements. These actions were addressed in an August 2011 HSS 

report to the Secretary of Energy, Review of Requirements and Capabilities for Analyzing and 

Responding to Beyond Design Basis Events. Based on the recommendations in this report, DOE 

embarked on activities in FY12 to develop and refine guidance that supports improvements in DOE 

processes for analyzing and mitigating BDBEs at its nuclear facilities. 

The main activity was a set of pilot reviews of BOBE analysis and mitigation features at four DOE 

nuclear facilities representing a range of DOE sites, nuclear facility types/activities, and responsible 

program offices. The pilot reviews focused on: {1) how BDBEs were evaluated and documented in the 

Board-Related Activities, FY12 I Page 6 
Department of Energy I August 2013 

facility DSAs; (2) potential BOBE vulnerabilities in the facilities; and (3) facility and site emergency 

management programs' preparations for responding to severe accidents and BDBEs. 

The BOBE project also evaluated whether draft BOBE guidance on safety analysis and emergency 

management could be used to improve the analysis of, and preparations for mitigating, severe 

accidents and BDBEs. The pilot reviews confirmed that the primary BOBE threats had been identified 

and analyzed at the facilities reviewed, and that the related DOE requirements would be adequate if 

appropriately implemented. The pilot reviews validated the process and provided the practical 

experience and insights needed to refine the draft guidance related to evaluating BDBEs. 

In addition, DOE sponsored a Nuclear Safety Workshop in September 2012 with the theme Post 

Fukushima Initiatives and Results. The workshop shared practices and initiatives related to nuclear 

safety culture, the regulatory framework related to BDBEs, and the use of risk assessments to support 

nuclear safety decision-making. The workshop drew over 200 attendees and provided national, 

international, government, academic, and industry perspectives. 

G. Completion of Directives Reform Initiative 

During FY12, HSS completed the directives reform effort that started in FYlO. These reforms give 

added clarity and emphasis to the essential safety requirements and responsibilities by removing 

redundancies in the existing directives, allowing tailoring of requirements to appropriately address the 

hazards, and more clearly defining roles and responsibilities. The Department's ability to accomplish 

its mission safely and efficiently has been greatly improved by instituting these revisions to the 

directives system. 

H. Office of Environmental Management Activities 

In FY12, EM rolled out program-wide changes intended to improve safety culture across the DOE 

complex. Although some of these changes were related to execution of the IP for DNFSB 

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

efforts extended well beyond WTP. 

EM remained vigilant in identifying emerging safety issues through ongoing awareness and analysis of 

operational experience and efforts to improve WP&C. This effort culminated in the issuance of 

combined EM/NNSA guidance - developed through a partnership with EFCOG and major corporations 

that support EM work - to develop and enhance work planning expectations and best practices in the 

field. Examples of efforts supporting improvements in this area include: 

• Participating in the development of the EFCOG WP&C Program Guideline document and CRAD 

supporting DOE Guide 226.l, Federal Line Management Oversight of Department of Energy 

Nuclear Facilities 

• Performing WP&C and/or Conduct of Operations assessments at multiple sites 

Board-Related Activities, FY12 I Page 7 
Department of Energy I August 2013 

• Evaluating the URS Corporation's programmatic review of the Washington TRU Solutions WP&C 

program at the Waste Isolation Pilot Plant and the Washington Closure Hanford WP&C program 

at the River Corridor Closure Project. 

EM continues to work with the sites to promote the widespread use of performance indicators 

targeted at identifying trends, positive and negative, so action can be taken before an event occurs. 

Initial pilot efforts in FY12 showed promise and their continued use and refinement remain a priority as 

EM works to expand their implementation throughout the organization. 

EM completed verification of the Corporate Quality Assurance Plan (OAP) across the DOE complex in 

FY12. 

I. NNSA Defense Program Activities 

NNSA activities involving interactions with the DNFSB during FY12 included: maturing safety basis 

documents, advancing the readiness of technologies, continuing design of the UPF, progress in 

improving the nuclear explosive safety (NES) closure process, and other Board-related activities. 

UPF Design. The UPF at Y-12 is NNSA's effort to acquire a facility to sustain the nation's long-term 

highly enriched uranium processing capabilities. The Board had observed that the engineering efforts 

significantly outpaced the safety case development, imparting a risk of engineering design 

modifications if additional nuclear safety requirements emerge late in the design. This risk was 

exacerbated by the contractor's preliminary safety design report (PSDR), a top-level safety document 

that did not meet quality expectations when originally delivered. Achievements since the beginning of 

FY12 include narrowing the gap between maturity of engineering design and the PSDR, resolving 

several Board technical issues (seismic design criteria, criticality safety criteria, and post seismic 

confinement capability). 

NES Closure Process. On November 7, 2011, the DNFSB issued a letter to NNSA stating that the Board 

believed the tracking and closure process for NES findings and senior technical advisor {STA) comments 

at the Pantex Plant did not adequately meet the intent of DOE Manual 452.2-2, Nuclear Explosive 

Safety Evaluation Processes. To address these matters, NNSA identified and committed to make 

changes to DOE Manual 452.2-2 that will improve the process for handling NES findings and STA 

comments. 

Other Board-Related NNSA Activities. NNSA received a letter from the DNFSB on March 3, 2012, 

concerning an event at the Pantex Plant in the fall of 2011 involving operations conducted outside the 

NES-approved process. In addition to an investigation by B&W Pantex, NNSA performed an 

independent review of the overall NES change evaluation process at the Pantex Plant. The review 

identified weaknesses and recommendations for B&W Pantex, the NNSA Production Office (NPO), and 

the Office of Stockpile Management within Defense Programs (NA-12). Actions to evaluate and 

disposition the weaknesses and recommendations were initiated in FY12. 

Board-Related Activities, FY12 I Page 8 
Department of Energy I August 2013 

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. The Chief of Defense Nuclear Safety (CONS) provides technical 

support to the CTA in several areas, including: providing biennial reviews of NNSA offices; nuclear 

safety requirem.ent exemptions; NNSA liaison with DNFSB; interpreting and developing nuclear safety 

policies, requirements, and guidance; serving as differing professional opinion manager; and 

conducting independent analyses and investigations. 

CONS biennial reviews of NNSA site offices, initiated in 2005, continued in FY12. Three rounds of 

biennial reviews have been conducted at all site offices except the Y-12 Site Office (YSO}, which will be 

reviewed once the consolidation of YSO and the Pantex Site Office into the NNSA Production Office 

(NPO) is complete. Significant technical and security matters at Y-12 merited immediate, high level 

attention and will require future oversight and reviews. Each round of reviews indicated steady 

improvement in site office performance. In the first round, only 67 percent of the functional areas met 

their objective. This number increased to 90 percent after the second round of reviews and 95 percent 

after the third. 

IV. FY12 Progress on Board Recommendations 

Overview 

The Board issues recommendations to the Secretary on issues or circumstances it believes must be 

resolved to ensure 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 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 strives 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 DOE concurrence processes for revising its 

directives, and the challenges inherent in implementing and verifying complex-wide changes. 

Appendix A, Table A.1, Open Board Recommendations, lists the 14 recommendations that remained 

open at the end of FY12, the date they were issued, and the timeframe that DOE currently projects for 

completing the associated IP commitments. The number of open recommendations has remained 

fairly constant from 10 to 14 over the past decade as new recommendations were issued and older 

ones closed. 

Board-Related Activities, FY12 I Page 9 
Department of Energy I August 2013 

All recommendations (both open and closed), the associated IPs, and a chronological record of related 

correspondence between DOE and the Board can be accessed on the websites of the Departmental 

Representative to the DNFSB (DR) or the Board. 

The Board stated that it closed one recommendation in FY12: Recommendation 2001-1, High-level 

Waste Management at the Savannah River Site. The Board issued two new recommendations in FY12: 

Recommendation 2012-1, Savannah River Site Building 235-F Safety, and Recommendation 

2012-2, Hanford Tank Farms Flammable Gas Safety Strategy. 

Recommendations Closed in FY12 

2001-1: High-Level Waste Management at the Savannah River Site 

By letter dated December 7, 2011, the Board stated that it closes Recommendation 2001-1. The 

recommendation was issued in 2001 to address the critical shortage of tank space in the SRS HLW 

system, which threatened to delay stabilization of nuclear materials at SRS and could impact 

vitrification activities at the SRS Defense Waste Processing Facility. In its letter, the Board noted that 

DOE had not only addressed the immediate issue of leaks in an old-style tank but also had successfully 

completed corrective actions focused on selecting and developing salt processing capabilities and 

improving HLW management at SRS. 

Recommendations Opened in FY12 

2012-2: Hanford Tank Farms Flammable Gas Safety Strategy 

The Board issued Recommendation 2012-2 on September 28, 2012. The recommendation reflects the 

Board's assessment that current operations at the Hanford tank farms require safety-significant active 

ventilation of double-shell tanks to ensure the removal of flammable gas from the tanks' headspace. A 

significant flammable gas accident could have considerable radiological consequences, endanger 

personnel, contaminate portions of the tank farms, and seriously disrupt the Hanford waste cleanup 

mission. The Board also recommends that DOE install real-time monitoring to measure tank 

ventilation flow rates and perform other upgrades to indication systems used to perform safety related 

functions. 

2012-1: Savannah River Site Building 235-F Safety 

The Board issued Recommendation 2012-1 on May 9, 2012. The recommendation reflects the Board's 

assessment that the Department should take action to remove and/or immobilize the residual 

contamination within Building 235-F because of the potential dose consequences associated with a 

radiological release to collocated workers and the public. The Board also believes that DOE must take 

near-term action to more effectively prevent a major fire in Building 235-F. The Secretary accepted the 

recommendation, agreeing that action must be taken to reduce the hazards associated with the 

material at risk that remains as residual contamination within Building 235-F. The Secretary's 

acceptance letter noted that DOE has taken action to remove special nuclear material from Building 

235-F, remove transient combustible material, and limit access to the building. 

Board-Related Activities, FY12 I Page 10 
Department of Energy I August 2013 

Other Open Recommendations 

2011-1: Safety Culture at the Waste Treatment and Immobilization Plant 

The Board issued Recommendation 2011-1 on June 9, 2011. The recommendation reflects the Board's 

assessment that, taken as a whole, the Board's investigative record indicates that the safety culture at 

WTP is in need of prompt, major improvement and that corrective actions will only be successful and 

enduring if championed by the Secretary of Energy. The Secretary accepted the recommendation, and 

the IP was delivered to the Board on December 27, 2011. On September 14, 2012, an IP addendum 

was delivered to supplement the original IP based on information and experience to date during 

execution ofthe IP. 

During FY12, the Department completed ten non-recurring1 IP commitments, including two for which 

the Secretary was the responsible manager and two for which the Deputy Secretary was the 

responsible manager, consistent with the recommendation language that the Department assert 

Federal control "at the highest level" and direct, track, and validate the specific corrective actions to be 

taken to establish a strong safety culture within the WTP Project. The Secretary formally 

communicated his expectations to the Undersecretary for Nuclear Security regarding safety culture at 

the WTP and reiterated his expectations as the keynote speaker at a WTP town hall meeting and in 

other meetings with WTP employees. 

In January 2012, HSS issued the results of its independent oversight assessment of nuclear safety 

culture and management of nuclear safety concerns at the WTP, following up on the October 2010 HSS 

review of the WTP nuclear safety culture. In April 2012, ORP issued a Safety Culture Improvement Plan 

to initiate needed improvements in the ORP safety culture. Also in April 2012, Bechtel National, Inc., 

the WTP prime contractor, issued a comprehensive corrective action plan for strengthening the nuclear 

safety quality and culture at the WTP. This plan addresses the findings of the January 2012 HSS 

independent assessment. 

In Recommendation 2011-1, the Board also recommended that DOE conduct extent-of-condition 

reviews to determine the state of safety culture at sites/facilities other than the WTP. During FY12, 

HSS collaborated with independent safety culture experts to conduct such evaluations at selected DOE 

organizations, as discussed in Section Ill.A. During FY12, HSS issued individual reports for four 

facilities: WTP (January 2012), CMRR (April 2012), UPF (June 2012), and Pantex (November 2012). 

Preliminary analyses of these reviews indicate both strong points and areas requiring attention. 

Strengths include workforce commitment to the mission, strong efforts to improve personnel safety, 

multiple mechanisms to identify problems, and initiatives to formalize work procedures. Areas 

requiring attention include pressures created by internal and external stakeholders, high-stress 

standards of performance, insufficient oversight by site offices and Headquarters organizations, an 

overly narrow perspective on safety in general, double standards with respect to accountability, and 

methods of communication. These reports are available on the DR website. A consolidated summary 

1 Recurring IP commitments include regularly or periodically scheduled reports, briefings, or updates that DOE provides the Board. 

Board-Related Activities, FY12 I Page 11 
Department of Energy I August 2013 

report for the HSS reviews, as well as the self-assessments described in the next paragraph, is expected 

in November 2013 and is an action called for in the IP. 

During FY12, extent-of-condition self-assessment reviews were also conducted at contractor sites with 

defense nuclear facilities and/or construction projects and at the Federal offices with associated 

oversight responsibilities. These include site and field offices, project offices, Headquarters program 

offices, and the Office of Acquisition and Project Management. When complete, these selfassessments of site safety culture will provide further insights into the overall safety culture 

throughout the Department. Results of these extent-of-condition self-assessments will inform HSS's 

consolidated report, as described previously. 

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 at the WTP should be enhanced to establish 

with confidence that the pulse jet mixing (PJM) and waste transfer systems will perform adequately at 

full scale. The Secretary accepted the recommendation and committed to more testing to provide 

additional confidence that PJM and waste transfer systems for the WTP will achieve their design and 

operating requirements. The IP was delivered to the Board on November 10, 2011. 

During FY12, DOE completed 15 non-recurring IP commitments. However, in May 2012 DOE informed 

the Board that, based on scoping test data, revisions to the IP would be required. In August 2012, the 

Secretary and a group of independent technical experts began assessing WTP technical issues. The 

assessment included the plant's capability to detect equipment failure and to repair failed equipment 

inside the WTP Pretreatment Facility. Based on the scoping data findings and ongoing technical 

analyses, the Secretary informed the Board that as the Department gains a better understanding of the 

plant design verification strategy, DOE will be in a position to develop a revised IP for this 

recommendation. Technical sub-teams have been formed to analyze the remaining technical issues. 

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. The recommendation advised DOE to 

amend 10 CFR Part 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 the Board's desire to see 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, and DOE transmitted the IP to the Board on 

September 26, 2011. The IP provides an approach for updating the Department's DSA standards and 

requirements to improve performance of hazard and accident analysis and the identification of safety 

Board-Related Activities, FY12 I Page 12 
Department of Energy I August 2013 

controls. The actions taken pursuant to the IP also reinforce and expand on the improvements made 

during DOE's recently completed directives reform initiative. 

DOE completed one non-recurring milestone in FY12, an evaluation of improvements to DOE Standard 

3009. The product from this completed milestone was delivered to the Board on January 6, 2012. 

In July 2012, the Deputy Secretary developed and delivered to the Board a detailed "path forward" 

that presented the Department's commitments to assure adequate protection and to support DOE 

Policy 420.1, Department of Energy Nuclear Safety Policy, including its Technical Basis Document, 

DOE/HS-0006. The path forward describes how the Department will implement the Secretary's 

commitments for new and existing facilities and how it intends to respond to new information (e.g., 

new seismic hazards). The path forward also provides additional criteria by which the Department can 

evaluate the adequacy of the safety basis and its implementation, and describes the documentation 

required for areas that must be revisited or that must receive further management oversight and 

approval. The provisions of the path forward fulfill a Departmental commitment under 

Recommendation 2010-1. The Department intends to include these provisions in the revised DOE 

Standard 3009, Preparation Guide for U.S. Department of Energy Nonreactor Nuclear Facility 

Documented Safety Analyses, and DOE Standard 1104, Review and Approval of Nuclear Facility Safety 

Basis and Safety Design Basis Documents. As part of the Department's IP efforts, the revision of DOE 

Standard 3009 was actively pursued during FY12, including significant efforts to incorporate the 

perspectives of key stakeholders, such as site offices, contractors, and the DNFSB. 

2009-2: Los Alamos National Laboratory Plutonium Facility Seismic Safety 

The Board issued Recommendation 2009-2 on October 26, 2009. The recommendation advises 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 

consequences from seismic events. The Secretary accepted the recommendation on February 2, 2010, 

and transmitted the IP to the Board on July 13, 2010. 

DOE completed the last two non-recurring IP milestones in FY12: approval of the refined accident 

analysis, and glovebox stand seismic upgrades. The recommendation remains open because of the 

extended timeframe for the installation of active confinement ventilation and pending further 

structural analysis and development of modifications; NNSA continues to update the project execution 

plan for safety significant components for upgrades to mitigate consequences to seismic activity. 

Quarterly briefings to the Board continue. 

2009-1: Risk Assessment Methodologies at Defense Nuclear Facilities 

The Board issued Recommendation 2009-1 on July 30, 2009. The recommendation advises DOE to 

establish policies and associated standards and guidance on the use of quantitative risk assessment 

methodologies (referred to as probabilistic risk assessment) at the defense nuclear facilities. The 

Secretary accepted the recommendation on November 3, 2009 and subsequently transmitted the IP to 

the Board. On April 27, 2010, the Secretary transmitted Revision 1 of the IP to the Board. 

Board-Related Activities, FY12 I Page 13 
Department of Energy I August 2013 

Two non-recurring IP actions remain open, both related to the appropriate Department-specific 

guidance, standards, or policy expectations that are necessary to ensure the appropriate and 

consistent use of quantitative risk assessment in nuclear safety analysis and to related decision making 

to support the design and operation of defense nuclear facilities. Risk assessment and management 

was the topic of one breakout session during the September 19-20, 2012, Nuclear Safety Workshop 

hosted by DOE. Discussions during this session included DOE examples of quantitative risk assessment 

and the DOE draft standard on the subject. 

2008-1: Safety Classification of Fire Protection Systems 

The Board issued Recommendation 2008-1 on January 29, 2008. The recommendation advises DOE to 

develop new and revise existing standards applicable to the design and operation of fire protection 

systems to be relied upon 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 IP to the Board on July 23, 2008. 

DOE completed one IP milestone in FY12: Draft Revision of DOE Standard 1066, Fire Protection Design 

Criteria. This draft standard, which incorporates specific design and operational criteria for sprinkler 

and other selected fire protection systems, has been submitted for DOE-wide review. Three nonrecurring IP milestones remain open. 

2007-1: Safety-related In Situ Nondestructive Assay (NDA) of Radioactive Materials 

The Board issued Recommendation 2007-1 on April 25, 2007. The recommendation addresses the 

measurement of radioactive material holdup at defense nuclear facilities and cites a need for three 

specific improvements: standardized requirements for performing measurements, design 

requirements for new facilities that would facilitate accurate holdup measurement, and research and 

development activities for new instrumentation and/or measurement techniques. The Secretary 

accepted the recommendation on June 28, 2007, and transmitted the IP to the Board on October 24, 

2007. No non-recurring IP commitments remain open. 

2005-1: Nuclear Material Packaging 

The Board issued Recommendation 2005-1 on March 10, 2005. The recommendation acknowledges 

that DOE has made progress in the stabilization and storage of 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 DOE-wide level. The Secretary accepted the recommendation on May 6, 

2005, and transmitted the IP to the Board on August 17, 2005. 

The Department completed the final non-recurring IP milestone in FYll; only recurring milestones 

remain. Onsite repackaging activities will continue on a priority basis until all material is properly 

packaged. The Department expects to propose closing this recommendation in FY14 after three 

associated activities are complete: production of new storage containers, development of a path for 

new container certification, and repackaging of very-high-risk and high-risk material is in progress. 

Board-Related Activities, FY12 I Page 14 
Department of Energy I August 2013 

2004-2: Active Confinement Systems 

The Board issued Recommendation 2004-2 on December 7, 2004. The recommendation cites the 

Board's assessment that 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 with 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 of the IP was transmitted 

to the Board on July 12, 2006. The revised IP commits to review all hazard category 2 and 3 defense 

nuclear facilities to ensure 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. 

DOE has met all non-recurring commitments in the IP except for updating its nuclear safety directives 

to incorporate guidance for the use of active confinement ventilation systems. 

2004-1: Oversight of Complex, High-Hazard Nuclear Operations 

The Board issued Recommendation 2004-1 on May 21, 2004. The recommendation cites Board 

concerns regarding a number of safety issues related to the central technical authority, delegations of 

safety responsibilities, technical capability, nuclear safety research and development, lessons learned 

from significant external events, and ISM. On August 30, 2011, DOE transmitted to the Board an 

updated IP which identifies three broad areas for improvement: strengthening Federal safety 

assurance, learning from internal and external operating experience, and revitalizing ISM 

implementation. 

Five non-recurring IP commitments remain open. In FY12, DOE issued Guide 226.1-2, Federal Line 

Management Oversight of DOE Nuclear Facilities. DOE continues to work with the Board to fully satisfy 

the remaining commitments of the IP. Significant progress has been made on the nuclear safety 

research and development commitments. A charter for a committee has been written, a team 

assembled, and research and development database opportunities explored. 

2002-3: Requirements for the Design, Implementation, and Maintenance of Administrative Controls 

The Board issued Recommendation 2002-3 on December 30, 2002. The recommendation cites 

technical inadequacies in a number of safety-related 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, 

Board-Related Activities, FY12 ( Page 15 
Department of Energy I August 2013 

and maintenance of specific administrative controls. The Secretary accepted the recommendation on 

January 31, 2003 and transmitted the IP to the Board on June 26, 2003. 

DOE proposed closing this recommendation in 2007. The Board was last briefed on November 30, 

2011. HSS has undertaken efforts to ensure that specific administrative controls are being applied 

effectively across the DOE complex. These efforts involved site, program office, and NNSA evaluations 

of specific administrative control implementation at targeted sites, including 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 are in the process of 

verifying more broadly that specific administrative controls are being evaluated across all program 

sites. 

2000-1: Prioritization for Stabilizing Nuclear Materials 

The Board issued Recommendation 2000-1 on January 14, 2000. The recommendation advises DOE to 

accelerate the 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 majority of the 

recommendation on March 13, 2000, and Revision 2 of the IP was transmitted to the Board on July 22, 

2002. On July 23, 2004, DOE submitted an update of the IP that is specific to LANL; on November 28, 

2005, DOE submitted 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; all EM commitments are complete, with the exception of the stabilization of Hanford 

K-Basin sludge materials, i.e., the Sludge Treatment Project (STP). 

One IP commitment was completed in FY12: the Hanford STP Phase-II alternatives analysis to develop 

treatment and packaging technologies. 

V. Interface Activities 

In addition to formal recommendations, the Board and its staff regularly communicate with DOE by 

letter, and they visit the Department's defense nuclear facilities to review the implementation of safety 

initiatives, examine defense nuclear facilities and operations, and attend briefings. Information about 

DNFSB interactions with DOE, including all correspondence, is available by site and by fiscal year on the 

DR website at http://www.hss.doe.gov/deprep/ 

In addition to meeting IP commitments, DOE responds to commitments requested by the Board 

through the issuance of formal letters establishing reporting requirements pursuant to 42 U.S.C. 

Section 2286b(d). During FY12, DOE completed 19 actions related to such reporting requirements. 

These are shown in Appendix A, Table A.2. 

Four public hearings were held during FY12. These are listed and summarized in Appendix A, Table A.3. 

Board-Related Activities, FY12 I Page 16 
Department of Energy I August 2013 

Board-Related Activities, FY12 · I Page 17 
Rec # 

2012-2 

2012-1 

2011-1 

2010-2 

2010-1 

2009-2 

2009-1 

2008-1 

2007-1 

2005-1 

2004-2 

2004-1 

2002-3 

Department of Energy I August 2013 

Appendix A. FY12 Summary: Open Recommendations, 

Reporting Requirement Commitments Met, and Public 

Meetings and Hearings 

Table A.1 Open Board Recommendations 

Title 

Date I Timeframe for Completing 

Opened Implementation Plan 

Hanford Tank Farms Flammable Gas Safety Strategy 09/28/2012 

Plan Under Development 

Savannah River Site Building 235-F Safety 05/09/2012 IP Issued December 2012 

Safety Culture at the Waste Treatment and Immobilization Plant 06/09/2011 2014 

Pulse Jet Mixing at the Waste Treatment and Immobilization 12/17/2010 2016 Plant 

Safety Analysis Requirements for Defining Adequate Protection 10/29/2010 2014 for the Public and the Workers 

Los Alamos National Laboratory Plutonium Facility Seismic 10/26/2009 All Plan Milestones are Complete Safety 

Risk Assessment Methodologies at Defense Nuclear Facilities 07/30/2009 2014 

Safety Classification of Fire Protection Systems 01/29/2008 2013 

Safety-Related In Situ Nondestructive Assay of Radioactive 04/25/2007 Closed Materials 

Nuclear Material Packaging 03/10/2005 2014 

Active Confinement Systems 12/07/2004 2014 

Oversight of Complex, High-Hazard Nuclear Operations 05/21/2004 2014 

Requirements for the Design, Implementation, and Maintenance 12/11/2002 All Plan Milestones are Complete of Administrative Controls 

Board-Related Activities, FY12 I Page 18 
Department of Energy I August 2013 

2000-1 Prioritization for Stabilizing Nuclear Materials 01/14/2000 2015 

Table A.2 Formal Reporting Requirement Commitments Completed in FY12 

Letter# Commitment Title Date Completed 

SL 11-023 A report on the hazards and controls associated with the anhydrous ammonia 11/16/2011 system at the Waste Treatment and Immobilization Plant 

SL 11-019 A report on the validity of the heat transfer analyses from process vessels in the 11/16/2011 Pretreatment Facility at the Waste Treatment and Immobilization Plant 

I 

SL 11-021 A report and briefing on the revised safety basis at the Savannah River Site 12/07/2011 tritium facilities 

SL 11-017 A report outlining actions taken or planned by DOE to address weaknesses in 12/21/2011 the fire protection program at the Waste Isolation Pilot Plant 

SL05-026 Annual briefing on the contents of the annual revision to the Pantex Nuclear 01/27/2012 

I Material Management Program 

SL 11-024 A report and briefing on the Maintenance Program at the Hanford Waste 02/02/2012 Encapsulation and Storage Facility 

SL03-031 Annual report on the Department's Nuclear Criticality Safety Program 02/28/2012 

i 

! SL 11-022 A report and briefing on the weaknesses in conduct of operations and technical I 02/29/2012 procedures at the Y-12 National Security Complex I 

I 

I 

A report and briefing on actions NNSA has taken or plans to take to ensure the 

SL 11-026 Plutonium Facility's glovebox system and fire detection and alarm system can 03/08/2012 

I 

perform their safety functions at Lawrence Livermore National Laboratory 

Board-Related Activities, FY12 I Page 19 
Department of Energy I August 2013 

Table A.3 Board Public Meetings and Hearings in FY12 

Date Topic Location 

Seismic safety of the Santa Fe Community Explored safety matters and gathered other 

11/17/2011 Plutonium Facility, Los Alamos Convention Center, information related to public and worker health 

National Laboratory 

1

201 West Marcy Street, and safety for defense nuclear facilities at the 

Santa Fe, NM 87501 Los Alamos National Laboratory ..,....-- -- Session I - Status of actions related to 

Status of actions related to unresolved technical safety issues in the 

unresolved technical Three Rivers Convention design of the Waste Treatment and 

03/22/2012 safety issues and DOE's 'Center Immobilization Plant 

7016 West Grandridge Implementation Plan for Boulevard Session II - Status of actions related to DOE's Recommendation 2011-1 Kennewick, WA 99352 implementation plan for Recommendation 

2011-1 , Safety Culture at the Waste Treatment 

and Immobilization Plant 

Status of actions related to A continuation of hearing Session II of March 

unresolved technical Defense Nuclear Facilities 22, 2012, on DOE's implementation plan for 

safety issues and DOE's Safety Board Headquarters Recommendation 2011-1, Safety Culture at the 

05/22/2012 Implementation Plan for Waste Treatment and Immobilization Plant 

Recommendation 2011-1 -

1

625 Indiana Avenue NW 

Supplemental Panel Washington, DC 20004 

Session 

Factors that Could Affect I Knoxville Convention Explored NNSA's Oversight roles and 

Center responsibilities, federal staffing, Board's the Timely Execution and concerns from April 2, 2012 letter, gap 10/02/2012 Safety of the Uranium 1701 Henley Street between safety basis and design, risk of Processing Facility (UPF) deferred scope and safety implications of the Project J Knoxville, TN 37902 space/fit issue. 

Board-Related Activities, FY12 I Page 20 
Department of Energy I August 2013 

Appendix B. Acronyms and Abbreviations 

BOBE 

Board 

CONS 

CFR 

CMRR 

CNS 

CTA 

CRAD 

CSOOT 

DCT 

Department 

DNFSB 

DOE 

DR 

DSA 

EFCOG 

EM 

EU 

FY 

HLW 

HSS 

IP 

ISM 

LANL 

MEOI 

MOX 

NES 

NNSA 

NPO 

ORP 

Pantex 

PF-4 

PJM 

QAP 

SCWE 

SRS 

STA 

STP 

SWPF 

TRU 

UPF 

WP&C 

WTP 

Beyond Design Basis Event 

Defense Nuclear Facilities Safety Board 

Chief of Defense Nuclear Safety 

Code of Federal Regulations 

LANL Chemistry and Metallurgy Research Replacement Project 

Chief of Nuclear Safety 

Central Technical Authority 

Criteria, Review, and Approach Document 

Continued Safe Operability Oversight Team 

WTP Design Completion Team 

Department of Energy 

Defense Nuclear Facilities Safety Board 

Department of Energy 

Departmental Representative to the DNFSB 

Documented Safety Analysis 

Energy Facility Contractors Group 

Office of Environmental Management 

Enriched Uranium 

Fiscal Year 

High Level Waste 

Office of Health, Safety and Security 

Implementation Plan 

Integrated Safety Management 

Los Alamos National Laboratory 

Maximally-Exposed Offsite Individual 

Mixed Oxide 

Nuclear Explosive Safety 

National Nuclear Security Administration 

NNSA Production Office 

Office of River Protection 

Pantex Plant 

LANL Plutonium Facility 

Pulse Jet Mixing 

Quality Assurance Plan 

Safety Conscious Work Environment 

Savannah River Site 

Senior Technical Advisor 

Sludge Treatment Project 

SRS Salt Waste Processing Facility 

Transuranic 

Y-12 Uranium Processing Facility 

Work Planning and Control 

Waste Treatment and Immobilization Plant 

Board-Related Activities, FY12 I Page 21 
Y-12 

YSO 

Y-12 National Security Complex 

Y-12 Site Office 

Department of Energy I August 2013 

Board-Related Activities, FY12 I Page 22