Department of Energy 

Activities Relating to the 

Defense Nuclear 

Facilities Safety Board 

Fiscal Year 2013 

Report to Congress 

May 2014 

United States Department of Energy 

Washington, DC 20585 
Department of Energy I May 2014 
Department of Energy I May 2014 

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 annual report to Congress addressing the Department's activities related to the 

Defense Nuclear Facilities Safety Board (Board). Enclosed is the report on the Department's activities 

for fiscal year 2013 (FY13). 

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

facilities. Its expertise in reviewing the content and implementation of standards and directives 

relating to the design, construction, operation, and decommissioning of the Department's defense 

nuclear facilities helps strengthen the safety protocols at the Department's facilities nationwide. 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's review of the attached FY13 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 Mary L. Landrieu 

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 

Board-Related Activities, FY13 I Page i 
Department of Energy I May 2014 

• The Honorable James M. lnhofe 

Ranking Member, Senate Committee on Armed Services 

• 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 Mike Simpson 

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" McKean 

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, FY13 I Page ii 
Department of Energy I May 2014 

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 2013 {FY13) related to the Defense 

Nuclear Facilities Safety Board (DNFSB or the 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. The Department's nuclear safety assurance program includes continuously 

improved policies, procedures, activities, and initiatives, which collectively support safety 

implementation and a thorough response to emergent nuclear safety issues. As nuclear safety 

vulnerabilities are discovered, DOE determines their causes in order to address them both locally and 

across the complex if applicable. 

The Department has undertaken safety initiatives and activities to reinforce and ensure nuclear safety 

performance. These initiatives respond to issues identified by the Board, as well as issues proactively 

identified by the Department through site, facility, and program office self-assessments; through the 

independent oversight activities of the DOE Office of Health, Safety and Security; and through other 

Departmental safety improvement initiatives and activities. This report describes the Department's 

FY13 initiatives and activities related to the Board. 

Progress on Initiatives and Activities 

Los Alamos National Laboratory Seismic Initiative at the Plutonium Facility. DOE has undertaken 

physical upgrades to reduce seismic risk at the Los Alamos National Laboratory (LANL) Plutonium 

Facility (PF-4) concurrently with a new seismic risk analysis. FY13 improvements have included a new 

safety-class nuclear material storage system using fire-rated safes and containers, repairs to the 

facility's main fire wall, a strengthened roof, braced ventilation room columns and fan pads, and 

repairs above the facility floor. 

Los Alamos National Laboratory Criticality Safety Program. In June 2013, the LANL director suspended 

programmatic activities in PF-4 because of criticality safety program non-compliance with DOE 

requirements, and to resolve a backlog of criticality safety issues. In light of Board observations and 

Federal and contractor assessments, the National Nuclear Security Administration {NNSA) has 

established a corrective action plan for a deliberate and formal resumption of operations, and the 

laboratory has implemented improvements to ensure that criticality safety procedures are in place and 

in use. The corrective action plan involves further program reviews to determine the root causes of 

the criticality safety program deficiencies. 

Aging Facilities. Recognizing the challenges posed by aging but essential defense nuclear facilities and 

budget challenges, the Department is analyzing the most pressing age-related hazards confronting its 

older facilities and is implementing measures to eliminate or mitigate those hazards on a priority basis. 

During FY13, the Department continued with activities to address age-related issues at its higher risk 

Board-Related Activities, FY13 I Page iii 
Department of Energy I May 2014 

facilities. The report discusses three of many examples: the Aging Management Program at the Y-12 

National Security Complex, upgrades to aging fire suppression systems at the Pantex Plant and the 

Savannah River Site, and improvements at the Waste Encapsulation and Storage Facility at the Hanford 

Site. 

Safety Culture. Throughout FY13, safety culture assessments and improvements were a priority focus 

for DOE. In a memorandum to DOE managers on September 20, 2013, the Secretary and Deputy 

Secretary reiterated the critical importance of safety culture and a safety conscious work environment. 

The Secretary emphasized his expectations for a safety culture built on an environment of trust and 

mutual respect, worker engagement and open communication, an atmosphere that promotes a 

questioning attitude with effective resolution of reported problems, and continuous learning. As part 

of the Department's effort to improve safety culture, during FY13 a team of DOE, NNSA, national 

laboratory, and site contractor subject matter experts were assembled. In collaboration with the DOE 

National Training Center, this team designed, developed, and implemented a unique course, sponsored 

by the Secretary and Deputy Secretary, titled SAF-200, Safety Conscious Work Environment. 

Additionally, safety culture assessments were conducted at sites throughout the nuclear weapons 

complex, at both the Federal and contractor level, to support an understanding of safety culture health 

and identify areas to improve. 

Work Planning and Control. During FY13, the Department made significant progress toward 

completing its work planning and control (WP&C) commitments to the Board. These commitments 

target two specific outcomes: enhancing complex-wide awareness and reinforcing the need for 

rigorous activity-level planning, and strengthening the guidance and formality associated with 

contractor implementation and Federal monitoring of these activities. Actions to create new directives 

are laying a firm foundation to ensure effective WP&C program implementation and oversight for the 

future. 

Lessons from Fukushima. In April 2013, the Department issued an Operating Experience Level 1 

Document (OE-1: 2013-01}, Improving Department of Energy Capabilities for Mitigating Beyond Design 

Basis Events. This document requires all higher hazard DOE nuclear facilities to evaluate their 

vulnerability to severe accidents beyond the facility's design basis in order to identify opportunities for 

improving their capabilities to mitigate such events, and then provide a formal response to their 

respective under secretaries. 

Progress on Board Recommendations 

This report documents the Board closure of three recommendations. The Board issued no new 

recommendations in FY13. Eleven recommendations remained open at the end of FY13. 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, FY13 I Page iv 
Department of Energy I May 2014 

• 

REPORT TO CONGRESS 

Table of Contents 

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

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

III. Departmental Nuclear Safety Initiatives and Activities .................................. 2 

A. Nuclear Safety at the Los Alamos National Laboratory PF-4 Facility .......... 3 

B. Nuclear Safety Oversight ................................................................................................ 4 

C. Nuclear Safety at Aging Facilities ................................................................................ 4 

D. Nuclear Safety in New Facility Design ...................................................................... 6 

E. Nuclear Safety Policy ........................................................................................................ 6 

F. Nuclear Explosives Safety .............................................................................................. 7 

G. Nuclear Criticality Safety ................................................................................................ 7 

H. Nuclear Safety Culture ..................................................................................................... 7 

I. Nuclear Safety at the Work Planning and Control Level.. ................................. 8 

J. Nuclear Safety Emergency Preparedness: Lessons from Fukushima ......... 9 

K. Other Office of Environmental Management Nuclear Safety Activities ...... 9 

L. Other National Nuclear Security Administration Nuclear Safety ActivitieslO 

IV. FY13 Progress on Board Recommendations ..................................................... 10 

A. Overview .............................................................................................................................. 10 

B. Recommendations Closed in FY13 ........................................................................... 11 

C. Open Recommendations ............................................................................................... 12 

V. Interface Activities ..................................................................................................... 18 

Appendix A. FY13 Summary: Open Recommendations; Statutory Letter 

Reports; and Public Meetings/Hearings ............................................................. 19 

Appendix B. Acronyms and Abbreviations .................................................................. 22 

Board-Related Activities, FY13 I Page v 
Department of Energy I May 2014 

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

Board-Related Activities, FY13 I Page vi 
Department of Energy I May 2014 

I. Legislative Language 

This report is provided in accordance with 42 U.S.C. § 2286e: 

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 2013 (FY13) 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 

independent analysis, advice and 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 and directives relating to the design, construction, 

operation, and decommissioning of the Department's defense nuclear facilities. Figure 1 shows the 

locations of DOE's active defense nuclear facility sites. 

The Board and the Department communicate and interact through a variety of mechanisms, including 

formal Board recommendations, formal reporting requirements, Board letters requesting 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 remainder of this report is organized as follows: 

• Section Ill, Departmental Nuclear Safety Initiatives and Activities describes broad-based 

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

Board. 

• Section IV, FY13 Progress on Board Recommendations, describes Departmental activities 

completed or ongoing in FY13 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, FY13 I Page 1 
Department of Energy I May 2014 

• Appendix A contains tables summarizing the status of the 11 open Board recommendations, 

the 15 letter reports completed in FY13, and two Board public meetings/hearings held in FY13. 

• Appendix B lists acronyms and abbreviations. 

HANFORD SITE 

Office of River Protection (ORP) 

Richland Operations Office (RL) 

Pacific Northwest Site Office (PNSO) 

Pacific Northwest National Laboratory (PNNL) 

LAWRENCE LIVERMORE 

NATIONAL LABORATORY 

Livennore Field Office (LFO) 

~ 

~ • 

• 

• 

NEVADA NATIONAL SECURITY SITE___-* 

• 

IDAHOSITE 

Idaho Operations Office (DOE~D) 

Idaho National Laboratory (INL) 

I 

" '"'' FloldOffi"(NFO) ~ 

LOSALAMOSNATIONALLABORATORY ; · • 

Los Alamos Field Office(LAFO) 

OAK RIDGE RESERVATION 

Y-12 Nation al Security Complex (Y-12) 

NNSA Production Office (NPO) 

Oak Ridge Office of Environmental Management 

Oak Ridge National Laboratory (ORNL) 

SANDIA NATIONAL LABORATORIES 

Sandia Field Office (SFO) PANT EX PLANT 

WASTE ISOLATION PILOT PLANT 

Carlsbad Field Office (CBFO) 

NNSA Production Office (NPO) 

SAVANNAH RIVER SITE 

Savannah River Operations Office (SRO) 

Savannah River Field Office (SRFO) 

Savannah River National Laboratory (SRNL) 

Figure 1. Department of Energy Active Defense Nuclear Facility Sites 

III. Departmental Nuclear Safety Initiatives and Activities 

This section describes the major FY13 initiatives and activities the Department undertook to improve 

and ensure its nuclear safety performance. These initiatives respond both to issues identified by the 

Board and to issues proactively identified by the Department through site, facility, and program office 

self-assessments; through the independent oversight activities of the DOE Office of Health, Safety and 

Security (HSS); and through other Departmental safety improvement initiatives and activities. The 

Department ensures protection of its workers, the public, and the environment from nuclear hazards 

Board-Related Activities, FY13 I Page 2 
Department of Energy I May 2014 

through a rigorous, proactive nuclear safety program and a robust regulatory framework. DOE 

operates defense nuclear facilities under specific nuclear safety enabling legislation and wellestablished rules in the Code of Federal Regulations (CFR). DOE establishes and implements nuclear 

safety policies, requirements, and guidance within a system of directives and technical standards that 

are cited in contract terms and conditions. Several layers of oversight, as well as enforcement 

activities, are used to assure compliance with DOE's safety requirements. This report describes the 

Department's FY13 Board-related nuclear safety initiatives and activities, operating within this 

framework. 

A. Nuclear Safety at the Los Alamos National Laboratory PF-4 Facility 

The Plutonium Facility (PF-4) at Los Alamos National Laboratory (LANL) is the nation's only fully 

operational, full capability plutonium science and manufacturing facility; its national security mission is 

unique. In 1996, DOE funded a seminal study by LANL scientists and contractors that concluded, in 

part, that "The ground shaking hazard at LANL is higher than might be indicated by the historical record 

and therefore higher than is commonly believed possible." Subsequent studies have confirmed and 

further illuminated PF-4's seismic vulnerabilities. PF-4 is 36 years old and has approximately 30 years 

of projected remaining service. However, having been designed and built in the 1970s, it lacks the 

structural ductility and redundancy required by today's building codes and standards, particularly in 

regard to seismic rigidity and post seismic event fire protection. Collectively, the unique mission, the 

material at risk, the known seismic hazard, the infrastructure age, and the potential for public and 

worker exposure following an earthquake and/or fire pose a unique combination of nuclear safety 

challenges. 

Seismic and Fire Safety Enhancements. In late FY12, the DNFSB communicated to DOE its concerns 

about prior seismic analyses of the PF-4 facility and suggested a need to perform a more 

representative alternate analysis. In his response to the DNFSB, the Deputy Secretary committed the 

National Nuclear Security Administration (NNSA) to conduct a modal loading analysis of PF-4 to 

augment the previous analyses. The NNSA believes that this alternate analysis, which is currently 

under way, will further its understanding of PF-4's seismic integrity and will provide additional 

information for evaluating the facility's structural elements. NNSA has consulted with the DNFSB 

throughout this process to ensure that the assumptions and methodologies underpinning the modal 

loading analysis are appropriate and well documented. Concurrently with this analysis, DOE has 

undertaken physical upgrades to reduce seismic risk for PF-4. For example, during FY13, LANL: (1) 

installed a new safety-class nuclear material storage system using fire rated safes and containers; (2) 

assessed and repaired the facility's main fire wall; (3) strengthened the roof and braced the ventilation 

room columns and fan pads; and (4) repaired the mezzanines located above the laboratory floor. 

These upgrades were completed as required by Department standards, based on revised site-specific 

seismic hazards. 

Criticality Safety Measures. The Board staff reviewed PF-4 operations in May 2013 and identified 

several issues relating to criticality safety, leading to the LANL director suspending fissionable material 

operations at PF-4. LANL then commissioned an external review team of subject matter experts from 

around the complex to provide criticality safety advice and recommendations. This team identified 

Board-Related Activities, FY13 I Page 3 
Department of Energy I May 2014 

longstanding weaknesses in the criticality safety program, and, in response, LANL developed both 

immediate corrective actions and longer-term improvements. Key improvements being made include 

ensuring rigorous compliance with all applicable criticality safety standards and conduct-of-operations 

requirements, ensuring that criticality safety documentation is both current and readily available to 

staff, and providing regular criticality safety refresher training to fissile material handlers. 

During FY13, LANL received Federal concurrence for the criticality safety limits established for most 

fissile material operations on site. The exceptions involve solutions and high-fissile-mass operations, 

which will receive higher scrutiny as part of the resumption of PF-4 operations. During FY13, LANL also 

began a campaign to increase the number of qualified criticality safety staff members. 

8. Nuclear Safety Oversight 

The Department has Congressionally mandated nuclear safety oversight responsibilities at DOE's 

defense nuclear facilities and the Board is responsible for advising and making recommendations to 

the Secretary of Energy on safety issues at DOE defense nuclear facilities. These two responsibilities 

are complementary, and the Board and the Department strive to ensure that the nation's defense 

nuclear facilities are designed, operated, and ultimately decommissioned in a safe manner. 

Over the past three years, DOE's oversight approach shifted from large headquarters and independent 

oversight teams to a more reliance on DOE field and site office line management oversight. This shift 

has resulted in greater reliance on contractor assurance systems and line management assessment of 

these systems. Although there are benefits to increased use of contractor assurance systems, the 

ultimate ownership of, and responsibility for, nuclear safety oversight remains with the Department. 

Consequently, the Department has made considerable effort to assess and enhance its oversight 

model, and senior leadership has testified that DOE does not, and will not, have an "eyes on, hands 

off' approach to oversight of nuclear and high hazard operations. The Department is aware of the 

need to establish a clear understanding of the roles and responsibilities between Federal line 

management oversight and contractors executing their contractor assurance systems. 

C. Nuclear Safety at Aging Facilities 

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

their expected life spans, and some facilities do not meet modern safety standards. The DNFSB's 

Fourth Annual Report to Congress, Summary of Significant Safety-Related Aging Infrastructure Issues at 

Operating Defense Nuclear Facilities, issued in early FY14, noted that DOE made progress during FY13 

in resolving issues at some of its aging facilities. One example is NNSA's completion of structural 

upgrades at PF-4. However, the report also identified the aging tanks at Hanford's Tank Farms and a 

degraded fire protection water supply system at the Savannah River Site (SRS) as emerging concerns. 

The Board cites LANL's Chemistry and Metallurgy Research facility, constructed in 1952, and the 9212 

Complex at the Y-12 National Security Complex (Y-12), which began service in 1951, as facilities of 

particular concern from an age perspective. 

Recognizing the challenges posed by aging but essential defense nuclear facilities and budget needs, 

the Department is analyzing the most pressing age-related hazards confronting its older facilities and 

Board-Related Activities, FY13 I Page4 
Department of Energy I May 2014 

implementing measures to eliminate or mitigate those hazards on a risk priority basis. During FY13, 

the Department continued with activities specifically to address age-related issues at its higher risk 

facilities such as PF-4, discussed above. Examples of other activities that were initiated or continued in 

FY13 to address age-related concerns at unique or mission-critical facilities are described below. 

Y-12 Aging Management Program. During FY13, the Y-12 production organization promulga~ed a 

Facilities and Infrastructure Aging Management Strategy and a Y-12 Aging Management Program 

(AMP) procedure. The AMP will be applied to production facilities and infrastructure in a graded 

approach for all Y-12 missions, with a focus on the enriched uranium (EU) nuclear facilities. The 

objectives of the AMP are to integrate the various aging management processes already under way, 

including the system health program, and to ensure that risks for continued safe operations are 

identified, gaps in gathering data to evaluate risk for continued safe operations are found, and 

management is informed when the risk for continued safe operations is not acceptable. During FY13 

the site contractor, B&W Y-12, implemented a system health reporting program as an enhancement to 

existing Y-12 AMP management tools, which include the Continued Safe Operability Oversight Team 

and facility-specific operations plans. The purpose of the system health reporting program is to 

improve the information used to reflect the overall health of key production and safety-related 

systems by not only tracking system availability, but also defining a common set of metrics to better 

characterize system sustainability. To date, B&W Y-12 has developed system health reports for 22 

systems. 

Aging Fire Suppression Systems. Throughout FY13, the Department assessed vulnerabilities posed by 

aging fire suppression systems at several sites and implemented upgrades on a priority basis. In 

January 2013, HSS issued the results of an Independent Oversight review of SRS that included selected 

aspects of fire protection system design. Identified deficiencies at the SRS A Area have since been 

addressed through upgrades that allow the A Area water supply to provide adequate water flow and 

pressure to the meet the safety significant fire suppression demands of the Savannah River National 

Laboratory. Although the B&W Pantex fire protection program for the Pantex Plant is excellent in 

many respects, recent HSS and Board reviews have documented some areas, often age-related, in 

need of upgrading. During FY13, B&W Pantex continued with a multi-year, prioritized program of 

upgrades that include replacement of the plant's high pressure fire loop, fire protection lead-ins, and 

most of the plant's fire penetration seals, as well as replacement or refurbishing of fire alarm panels. 

Collectively, these upgrades have significantly enhanced this critical safety system. 

Waste Encapsulation Storage Facility. The integrity of the concrete walls at the aging Waste 

Encapsulation Storage Facility (WESF) at Hanford illustrates the Department's approach to analyzing 

and mitigating age-related hazards. A November 2012 safety evaluation report for the WESF concrete 

pool cells led to a determination that the pool cell concrete has sufficient strength to withstand a 

design basis earthquake. In addition, WESF completed the redistribution of the capsules in the pool in 

FY13, which placed higher-emitting capsules in positions farther from the pool cell walls. Thermal 

analysis showed that this configuration has mitigated the exposure of pool concrete to degrading 

gamma radiation. 

Board-Related Activities, FY13 I Pages 
Department of Energy I May 2014 

D. Nuclear Safety in New Facility Design 

Hanford Site Waste Treatment and Immobilization Plant. During FV13, significant work continued on 

resolving a range of technical issues that have stalled progress in designing both the High Level Waste 

Vitrification Facility and the Pretreatment Facility at the Waste Treatment and Immobilization Plant 

{WTP}. Actions have also been taken to better integrate engineering, safety, and operations into the 

overall design process. The WTP Design Completion Team, chartered in October 2012, is now the focal 

point for addressing all design-related issues at WTP. The project's integrated project team, composed 

of DOE and contractor staff, is developing a safety design strategy {SOS} in accordance with DOE 

Standard 1189-2008, Integration of Safety into the Design Process, to incorporate safety requirements 

and considerations into the engineering design process. The SOS describes the major hazards 

anticipated at WTP and how those hazards will be comprehensively addressed using safety structures, 

systems, and components. The technical issues that have impeded completion of the final design have 

been organized into nine topical groups: (1) hydrogen gas release from vessel solids, (2) criticality in 

WTP vessels, (3) hydrogen in pipe and ancillary vessels, (4) pulse jet mixing (PJM) vessel performance, 

(5) erosion and localized corrosion, (6) design redundancy and in-service inspection, (7) black cell 

vessel structural integrity, (8) facility ventilation, and (9) waste preconditioning requirements. 

Dedicated technical issue resolution teams have been established to resolve each of these issues. 

Although resources are being applied to these areas, continued focus is needed. 

Y-12 National Security Complex Uranium Processing Facility. The NNSA's strategy to meet the nation's 

EU processing requirements is to replace Y-12's aging EU processing facilities with a new Uranium 

Processing Facility (UPF). The UPF is in design and will undergo a phased construction and startup, 

with planned initial operations to support the 9212 Complex processes in the mid-2020s and full 

operations in the 2030s. Since 2010, the Board has raised a series of safety concerns regarding the 

design of the UPF. On October 25, 2013, the Government Accountability Office {GAO) released its 

second report on the UPF, Information on Safety Concerns with the Uranium Processing Facility, GA0-

14-79R. The report is based on an extensive GAO audit conducted April-October 2013, which 

examined the Board's UPF concerns and NNSA's actions to address them. The report states that "As of 

June 2013, the Safety Board also identified 15 specific safety concerns with the UPF's design, and NNSA 

has taken actions-or has agreed to take actions-to address 14 of these concerns." The GAO report 

notes that Board staff and NNSA officials agreed that none of the 15 concerns should prevent the UPF 

from achieving approval of targets for the project's cost, schedule, and scope in 2015 as scheduled. 

The GAO audit report did not include any recommendations for congressional consideration or agency 

action. 

E. Nuclear Safety Policy 

The Department protects its workers, the public, and the environment from nuclear hazards through a 

rigorous, proactive nuclear safety program and through equally rigorous responses to incidents or 

safety vulnerabilities identified through internal or external oversight. The Department's nuclear 

safety program includes continuously improved policies and procedures to support safety 

implementation and a thorough response to emergent nuclear safety issues within the complex. DOE's 

Board-Related Activities, FY13 I Page 6 
Department of Energy I May 2014 

nuclear safety policies, standards, and requirements comprise the foundation of its proactive nuclear 

safety assurance stance. 

As further discussed in Section IV, revision of DOE Standard 3009, Preparation Guide for U.S. 

Department of Energy Nonreactor Nuclear Facility Documented Safety Analyses, was actively pursued 

during FY13, including significant efforts to incorporate the perspectives of key stakeholders, such as 

site offices, contractors, and the DNFSB. Also, updates to DOE Standard 1104, Review and Approval of 

Nuclear Facility Safety Basis and Safety Design Basis Documents, and DOE Order 420.lC, Facility Safety, 

have been initiated. 

F. Nuclear Explosives Safety 

In 2012, the DNFSB expressed concerns about a nuclear explosives safety (NES) issue at the Pantex 

Plant and about the independence and authority of the plant's NES organization. Organizational and 

operational corrective actions and improvements began immediately and continued into FY13. In April 

2013, B&W Pantex completed a full causal factors analysis of the specific event that led to the initial 

DNFSB concerns and initiated a corrective action plan. The Board has considered some of NNSA's 

decisions about NES matters to be non-conservative, counter to promoting a healthy safety culture, 

and not fully transparent to the Board. Although discussions are ongoing, the technical issues have not 

yet been resolved. The NNSA Associate Administrator for Safety and Health, in his new NES oversight 

role, has taken the initiative to conduct a bottom-up review of NES directives and ensure clarity of 

requirements. In addition, NNSA has committed to reviewing the implementation of DOE Standard 

3016, Hazard Analysis Reports/or Nuclear Explosive Operations (a companion to 10 CFR 830, Nuclear 

Safety Management) to ensure that Federal expectations are met. 

G. Nuclear Criticality Safety 

As discussed above in Section Ill.A, nuclear criticality safety (NCS) issues at the PF-4 facility resulted in 

the suspension of programmatic activities in June 2013. The corrective plan includes extensive 

procedure and documentation reviews, posting validation of criticality safety limits, proper labeling 

and handling of fissile materials, additional personnel training and certifications, and management 

engagement. At Y-12, a March 2013 review of the NCS program by B&W Y-12 indicated a need to 

enhance the program in the areas of criticality safety evaluation implementation procedures, the roles 

and responsibilities of the criticality safety officer and NCS engineers, and the scope and requirements 

of periodic reviews. In July 2013, in coordination with the DOE Criticality Safety Support Group and the 

NNSA Production Office, the NNSA Office of Infrastructure and Operations examined the Y-12 criticality 

safety operational review process, noting that senior Y-12 management had initiated and fully 

supported the NCS Implementation Review Plan and that significant progress had been made. 

H. Nuclear Safety Culture 

Secretarial Reiteration of Safety Culture Expectations. Shortly after his confirmation, the Secretary 

traveled to Hanford to gain a firsthand understanding of the technical and safety culture issues at the 

WTP. In a memorandum to DOE managers on September 20, 2013, the Secretary and Deputy Secretary 

reiterated the critical importance of safety culture and a safety conscious work environment (SCWE). 

Board-Related Activities, FY13 I Page7 
Department of Energy I May 2014 

The Secretary emphasized his expectations for a safety culture built on an environment of trust and 

mutual respect; worker engagement and open communication; and an atmosphere that promotes a 

questioning attitude, with effective resolution of reported problems and continuous learning. The 

memorandum also committed to fostering a SCWE across all Departmental operations and stated that 

DOE's ultimate safety objective is to have zero accidents, work-related injuries and illnesses, regulatory 

violations, and reportable environmental releases. Throughout FY13, safety culture assessments and 

improvements were a priority for DOE 

Safety Conscious Work Environment. SCWE is an essential aspect of safety culture related to a work 

environment in which employees feel free to raise safety concerns to management or regulators 

without fear of retaliation. As part of the Department's effort to improve safety culture, during FY13 a 

team of DOE, NNSA, national laboratory, and site contractor subject matter experts assembled, in 

collaboration with the DOE National Training Center, to develop a senior leadership course, SAF-200, 

Safety Conscious Work Environment. The resulting course is based on best practices in the commercial 

nuclear industry, the oil and gas industry, and other high hazard industries; is aligned with the DOE 

integrated safety management system (ISMS); and focuses on the newly developed DOE ISMS guide. 

The course was delivered 70 times to approximately 1, 700 DOE and contractor managers and leaders 

at both DOE Headquarters and sites across the DOE complex. In addition, DOE program and site offices 

and contractors conducted SCWE self-assessments using guidance provided by the Recommendation 

2011-1 (Safety Culture at the Waste Treatment and Immobilization Plant) implementation team. An 

independent evaluation of line self-assessments of SCWE at sites across the DOE complex was initiated 

in May 2013 and will be completed in 2014. 

I. Nuclear Safety at the Work Planning and Control Level 

On August 28, 2012, the Board issued a letter to DOE expressing concerns associated with deficiencies 

and weaknesses in the implementation of work planning and control (WP&C) at the activity level. The 

Board asked to be apprised of DOE's actions, both taken and planned, to address WP&C deficiencies 

and weaknesses, and to be informed of DOE's assessment of the effectiveness of these actions. During 

FY13, working across DOE program and staff offices, the Department has made significant progress 

toward completing each of the WP&C commitments stated to the Board. These commitments target 

two specific outcomes: (1) enhance complex-wide awareness and reinforce the need for rigorous 

activity-level planning, and (2) strengthen the guidance and formality associated with contractor 

implementation and Federal monitoring of these activities. The effort has enhanced complex-wide 

awareness through an integrated safety management {ISM) workshop and through analysis of WP&C 

weaknesses in HSS safety databases. Steps have been taken to develop a process handbook and 

guidance for Federal oversight in order to institutionalize guidance and oversight. This documentation 

will be promulgated within the DOE directives system. In addition, individual sites and program offices 

have undertaken an extensive list of specific activities. Sustained Federal and contractor oversight of 

the effectiveness of activity level WP&C is supported by the array of Departmental actions and strong 

Secretary and Deputy Secretary leadership and support. 

Board-Related Activities, FY13 I Pages 
Department of Energy I May 2014 

J. Nuclear Safety Emergency Preparedness: Lessons from Fukushima 

After the March 2011 Fukushima Daiichi nuclear plant accident in Japan, DOE embarked on several 

initiatives to investigate the safety posture of its nuclear facilities relative to beyond design basis 

events (BDBEs). These initiatives have included issuing Safety Bulletin 2011-01, Events Beyond Design 

Safety Basis Analysis; conducting pilots to refine possible process improvements; and conducting three 

nuclear safety workshops. DOE has issued two reports documenting the results of these initiatives: 

Review of Requirements and Capabilities for Analyzing and Responding to Beyond Design Basis Events, 

August 2011; and Beyond Design Basis Event Pilot Evaluations: Results and Recommendations for 

Improvements to Enhance Nuclear Safety at DOE Nuclear Facilities, January 2013. 

In April 2013, the Department issued an Operating Experience Level 1 Document (OE-1: 2013-01}, 

Improving Department of Energy Capabilities for Mitigating Beyond Design Basis Events. This 

document requires all higher hazard DOE nuclear facilities to evaluate their vulnerability to severe 

accidents beyond the facility's design basis and to identify opportunities for improving their capabilities 

to mitigate such events. In addition, the Department's Independent Oversight organization issued an 

April 2013 lessons-learned report on emergency management reviews conducted in 2011 and 2012 

regarding preparedness for severe natural phenomenon events at sites wi.th hazard category 1 and 2 

nuclear facilities, some of which also have significant quantities of hazardous chemicals. Several 

additional Independent Oversight reviews of preparedness for severe natural phenomenon events 

were conducted at other sites. Early results show that many site plans do not fully consider the 

ramifications of severe natural phenomenon event consequences by considering hazardous material 

(HAZMAT) releases from multiple facilities, the degradation of command centers and employee 

shelters, the proximity of command centers to HAZMAT, and complications in acquiring offsite assets. 

Also, Independent Oversight identified practices at some sites that were not consistent with DOE 

policy. 

K. Other Office of Environmental Management Nuclear Safety Activities 

In FY13, the DOE Office of Environmental Management (EM} continued program-wide changes and 

initiatives intended to improve safety culture across the DOE complex. These changes were related to 

execution of the implementation plan (IP) for DNFSB Recommendation 2011-1, Safety Culture at the 

Waste Treatment and Immobilization Plant. However, these efforts extended well beyond the WTP. 

EM identified emerging safety issues through ongoing awareness and analysis of operational 

experience and efforts to improve the quality assurance (QA) program across EM sites. Examples of 

EM efforts supporting operational experience improvements include: 

• Implementation of the revised Corporate Quality Assurance Plan document including 

status/verification reviews by EM Headquarters; 

• Assessments of WP&C and conduct of operations at multiple sites; 

• Participation in the DOE Nuclear Criticality Safety Support Group; 

• Support of the DOE differing professional opinion process; and 

• Support and review of EM sites' annual ISMS and QA report declarations. 

Board-Related Activities, FY13 I Page9 
Department of Energy I May 2014 

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

identifying trends, positive and negative, so that action can be taken before an event occurs. EM also 

instituted the Integrated Site Team (IST) matrix concept. The responsibilities of the IST span the 

functional areas of safety, project management, program planning, and budget execution. 

L. Other National Nuclear Security Administration Nuclear Safety Activities 

The Chief of Defense Nuclear Safety's biennial reviews of NNSA offices with nuclear safety 

responsibilities, initiated in 2005, continued in FY13. The fourth round of reviews commenced in FY13 

with reviews at the Nevada Field Office and at the Savannah River Field Office, the latter including a 

review of the Federal oversight of the Mixed Oxides (MOX) project under the Office of Defense Nuclear 

Nonproliferation. These reviews noted continuing steady improvement in field office performance. 

IV. FY13 Progress on Board Recommendations 

A. Overview 

The Board issues recommendations to the Secretary for specific measures that should be adopted to 

ensure adequate protection of public health and safety. The Secretary is required to respond to each 

Board recommendation within 45 days after 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 after 

publication in the Federal Register of the Secretary's acceptance of all or part of a 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 satisfy all IP actions within one year of 

issuance. However, most IP schedules extend beyond one year due to the scope and technical 

complexity of the safety issues being addressed, the lengthy processes for revising DOE directives, and 

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

Appendix A, Table A.1, Open Board Recommendations, lists the 11 recommendations that remained 

open at the end of FY13, the date they were issued, and the timeframe that DOE currently projects for 

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

constant (between 10 and 14) over the past decade as new recommendations were issued and older 

ones closed. 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 

DOE Office of the Departmental Representative to the DNFSB (DR) 

(https://hsspublic.energy.gov/deprep//) or the Board (http://www.dnfsb.gov/). 

This report documents the closure of three recommendations which include: Recommendation 2008-1: 

Safety Classification of Fire Protection Systems, Recommendation 2007-1: Safety-Related In Situ 

Nondestructive Assay of Radioactive Materials and Recommendation 2002-3: Requirements for the 

Board-Related Activities, FY13 I Page 10 
Department of Energy I May 2014 

Design, Implementation, and Maintenance of Administrative Controls. The Board issued no new 

recommendations in FY13. 

B. Recommendations Closed in FY13 

2008-1: Safety Classification of Fire Protection Systems 

Recommendation 2008-1 was opened in January 2008. It identified the need for standards applicable 

to the design and operation of 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. 

In a letter dated March 21, 2013, DOE advised the Board that the Department had developed these 

standards; included them in DOE Standard 1066-2012, Fire Protection; and incorporated appropriate 

changes into DOE Order 420. lC, Facility Safety. Both the standard and the order were issued in 

December 2012. By letter dated April 22, 2013, the Board agreed that DOE's actions were sufficient to 

close this recommendation. 

2007-1: Safety-Related In Situ Nondestructive Assay of Radioactive Materials 

Recommendation 2007-1 was opened in April 2007. It identified the need for improved assay 

programs for radioactive material holdup at DOE defense nuclear facilities. By letter dated October 22, 

2012, DOE advised the Board that it had completed all actions necessary to satisfy the IP. By letter 

dated March 19, 2013, the Board agreed that DOE's actions were sufficient to close this 

recommendation. 

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

The Board issued Recommendation 2002-3 on December 11, 2002. The recommendation cited 

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 Secretary 

accepted the recommendation on January 31, 2003. 

In 2007, the Department completed the actions to establish specific administrative control guidance 

and proposed closing this recommendation. The Board countered by citing a need for additional 

actions to ensure appropriate implementation of specific administrative controls in the field. In 

response, the Department performed a series of line management and independent oversight reviews 

to verify that specific administrative controls had been implemented properly. These reviews 

confirmed that specific administrative controls were appropriately implemented in the field and that 

processes are in place to continue oversight of their proper implementation. 

In a letter dated August 21, 2013, the Secretary notified the Board that all actions contained in the IP 

for Recommendation 2002-3 had been completed. In early FY14, the Board agreed and confirmed 

closure of this recommendation. 

Board-Related Activities, FY13 I Page 11 
Department of Energy I May 2014 

C. Open Recommendations 

2012-2: Hanford Tank Farms Flammable Gas Safety Strategy 

The Board issued Recommendation 2012-2 on September 28, 2012. It reflected the Board's belief that 

current operations at the Hanford Tank Farms require safety-significant active ventilation of doubleshell tanks to ensure the removal of flammable gas from the tanks' headspace. A significant flammable 

gas accident would have considerable radiological consequences, endanger personnel, contaminate 

. portions of the Tank Farms, and seriously disrupt the Hanford waste cleanup mission. The Board also 

recommended that DOE install real-time monitoring to measure tank ventilation flow rates and 

perform other upgrades on indication systems used to perform safety-related functions. DOE 

delivered the IP for this recommendation to the Board on June 6, 2013. 

Two IP actions were completed during FY13; 11 remain open. During FY13, the DOE Tank Farm 

operations contractor completed implementation of a revision to the Tank Farms documented safety 

analysis (DSA), which added a new control that measures ventilation flow through each tank on a 

periodic basis, supplementing the existing flammable gas monitoring control. This revision also placed 

requirements on operability of the in-service and standby primary ventilation trains. 

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

The Board issued Recommendation 2012-1 on May 9, 2012. The recommendation reflected the 

Board's stance 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 believed that DOE must take 

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

recommendation, agreeing with the need to take action 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 DOE's actions to remove special nuclear material from Building 235-F, remove 

transient combustible material, and limit access to the building. The IP for Recommendation 2012-1 

was issued on December 5, 2012. 

Ten IP actions were completed in FY13, all on schedule. Nineteen IP actions remain open; completion 

of all IP actions is currently scheduled for 2018. DOE Savannah River made a strong start on the 235-F 

risk reduction project, including the development of a Deactivation Project Plan. A core project 

management team with experience in deactivation and decommissioning projects was assembled. 

Other accomplishments include the fabrication and installation of a plutonium fuel form cell mockup 

facility for procedure development, training, operator qualification, and work planning. A transient 

combustible control program was implemented, and a plan for fixed combustible removal, 

encapsulation, or isolation was developed. A key requirement of the IP is the execution of at least one 

formally-assessed drill each year based on a postulated radiological release from Building 235-F. Three 

such drills were conducted in FY13. The overall performance of the facility's emergency response 

organization, as demonstrated in these drills, indicates that the facility is capable of responding 

effectively to a radiological release from 235-F and implementing protective actions to protect 

personnel in facilities and construction sites surrounding 235-F. 

Board-Related Activities, FY13 Page 12 
Department of Energy I May 2014 

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

The Board issued Recommendation 2011-1 on June 9, 2011. The recommendation reflected the 

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

at WTP was in need of prompt, major improvement and that corrective actions would be successful 

and enduring only 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 accumulated to date during execution of the IP. A revised schedule for completing some IP 

milestones related to complex-wide actions was sent to the Board on September 27, 2013. 

During FY13, the Department completed three non-recurring1 IP activities, and 10 activities remain 

open. The activities completed in FY 13 represent substantial progress toward completing the IP. One 

part of this recommendation was that DOE should conduct extent-of-condition reviews to determine 

the state of safety culture at sites/facilities other than the WTP. By letter dated February 11, 2013, 

DOE transmitted the final safety culture assessment report to the Board, marking the completion of 

the independent reviews of selected major DOE projects called for in the recommendation. 

In a letter dated April 30, 2013, the EM informed the Board that the Office of River Protection (ORP) 

had completed its Safety Culture Improvement Plan addressing ORP actions for safety culture 

improvements, including responses to HSS's recommendations for ORP and changes to management 

and employee performance plans that include specific measures for meeting safety culture 

expectations. ORP has now completed the nine near-term actions described in this plan. By letter 

· dated May 30, 2013, DOE transmitted to the Board a report on the validation and effectiveness 

reviews of ORP contractor safety culture improvement actions. The report concluded that ORP has 

made a substantial start toward improving its safety culture, while acknowledging that much remains 

to be done to demonstrate effective change. 

As outlined in Section 111.H of this report, other 2011-1 Recommendation activities supporting the 

overall enhancement of an effective safety culture throughout the DOE complex included training for 

supervisors and the conduct of safety culture self-assessments at all sites by Federal and contractor 

organizations. 

2010-2: Pulse Jet Mixing at the Waste Treatment and Immobilization Plant 

The Board issued Recommendation 2010-2 on December 17, 2010. The recommendation addressed 

the Board's concern that equipment testing and analysis at the WTP should be enhanced to establish 

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

Board-Related Activities, FY13 I Page 13 
Department of Energy I May 2014 

with confidence that the 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 late FY12 and FY13, DOE identified and confirmed the need to revise the original IP based on a 

different technical approach to resolving the Board's concerns about inadequate mixing, which could 

lead to a criticality event, flammable gas releases, or an inability to fully control P JM vessels. The 

revised approach addresses concerns associated with the potential accumulation of solids due to 

inadequate mixing. On January 28, 2014, the Board closed Recommendation 2010-2. 

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 requested 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. A revised IP schedule was transmitted to the 

Board on September 20, 2013. 

The IP provides an approach for updating the Department's DSA standards and requirements to 

improve the performance of hazard and accident analysis and the identification of safety controls. The 

actions taken pursuant to the IP also reinforce and expand on the improvements made during DOE's 

recently completed directives reform initiative. As part of the Department's IP efforts, the revision of 

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

Documented Safety Analyses, was actively pursued during FY13, including significant efforts to 

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

guide is scheduled to be issued in FY14. Also, updates to DOE Standard 1104, Review and Approval of 

Nuclear Facility Safety Basis and Safety Design Basis Documents, and DOE Order 420. lC, Facility Safety, 

have been initiated to incorporate commitments from the IP into the DSA approval process. 

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

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

All non-recurring IP actions for this recommendation have been completed. The recommendation 

remains open pending completion of the installation of certain active confinement ventilation 

Board-Related Activities, FV13 I Page 14 
Department of Energy I May 2014 

elements, the completion of further structural analysis, and, if necessary and appropriate, the 

development of modifications. 

In a letter dated March 27, 2013, Secretary Chu advised the Board that since PF-4 can provide its 

confinement safety function based on DOE's current seismic analysis and the identified near-term risk 

reduction measures, he had concluded that PF-4 can continue to operate safely while longer-term 

structural modifications are completed. However, Secretary Chu also noted that an evaluation of DOE 

safety analyses indicated that although Departmental analytical methods were appropriate for 

determining safety control classification within DOE's safety basis construct, the Department might 

benefit from the nuclear industry's best practices in risk assessment. To this end, he directed HSS to 

investigate national and international standards, and best regulatory practices, to determine how the 

Department might take advantage of them to improve safety. 

NNSA continues to update its project execution plan for upgrading safety significant components to 

mitigate consequences from seismic activity. By letter dated September 3, 2013, NNSA advised the 

Board that two major analysis efforts, a dynamic linear analysis and a static non-linear analysis, had 

been completed and that a third alternative analysis, modal loading, was completed in December 

2013. Modal loading analysis provides better understanding of the seismic integrity of the PF-4 facility 

and enhanced confidence that all structural elements requiring reinforcement have been identified. 

2009-1: Risk Assessment Methodologies at Defense Nuclear Facilities 

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

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

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

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

and, on April 27, 2010, transmitted Revision 1 of the IP to the Board. 

Two IP actions remained open at the end of FY 2013. They are related to Department-specific 

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

consistent use of probabilistic risk assessment (PRA) in nuclear safety analysis and to the related 

decision making processes supported by PRA in the design and operation of defense nuclear facilities. 

In early FY14, DOE communicated to the Board that all remaining IP actions for this recommendation 

had been completed. The Board closed this recommendation on January 28, 2014. 

2005-1: Nuclear Material Packaging 

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

DOE's progress in the stabilization and storage of its excess nuclear materials, but called for further 

enhancement of nuclear safety by developing technically justified criteria for nuclear material 

packaging systems 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 action in FYll. Onsite repackaging activities will 

continue on a priority basis until all material is properly packaged. Significant progress has been made 

Board-Related Activities, FY13 I Page 15 
Department of Energy I May 2014 

in ensuring worker safety during the packaging of nuclear material. The Department approached this 

issue with worker risk in mind. Repackaging or disposal of the highest risk material as soon as 

practicable is, and will remain, the first priority. An orderly, risk-driven schedule will be followed in 

repackaging lower risk material. This repackaging strategy reduces risks to worker safety from the 

storage of nuclear material in older, less robust, containers while minimizing the radiation exposure 

and cost associated with the repackaging effort. NNSA has led the way with LANL to develop material 

containers and a process for certifying these containers at individual sites. This action will benefit the 

entire complex and is an ongoing effort to fully implement DOE Manual 441.1-1, Nuclear Material 

Packaging Manual. The Department is evaluating the completed IP commitments and ongoing actions. 

2004-2: Active Confinement Systems 

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

Board's belief 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 that present 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 

the associated DOE directives and standards. 

The Secretary accepted the recommendation on March 18, 2005, and transmitted Revision 1 of the IP 

to the Board on July 12, 2006. The revised IP commits to a review of 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. 

In a letter dated November 30, 2012, DOE advised the Board that a review had been performed to 

evaluate the recommended modifications for EM facilities, and also to provide DOE decision makers a 

way to focus on and prioritize the modifications of active confinement ventilation systems that are 

most likely to significantly improve safety performance across the relevant EM facilities. In December 

2012, DOE satisfied the last non-recurring action in the IP for this recommendation: revisions to DOE 

Order 420.lC, Facility Safety, and DOE Guide 420.1-lA, Nonreactor Nuclear Safety Design Guide for Use 

with DOE 0 420.lC, Facility Safety. DOE Order 420.lC establishes facility and programmatic safety 

requirements for DOE and NNSA for nuclear safety design criteria, fire protection, criticality safety, 

natural phenomena hazards mitigation, and the system engineer program. DOE Guide 420.1-lA 

provides an acceptable approach for safety design of DOE hazard category 1, 2, and 3 nuclear facilities 

to satisfy the requirements of DOE Order 420.lC. 

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

The Board issued Recommendation 2004-1 on May 21, 2004. The recommendation cited 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 {NSR&D), lessons 

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

an updated IP that identified three broad areas for improvement: strengthening Federal safety 

Board-Related Activities, FY13 I Page 16 
Department of Energy I May 2014 

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

implementation. 

Five non-recurring IP actions remain open, addressing three general topics: issuing a DOE Safety 

Oversight Guide, implementing an NSR&D function, and establishing and verifying a robust Federal 

safety assurance capability. 

Safety Oversight Guide. DOE issued Guide 226.1-2, Federal line Management Oversight of DOE 

Nuclear Facilities, in FY12. However, the Board expressed concerns about DOE's expectations for the 

criteria, review and approach documents cited in Appendix C of the Guide and requested more 

information on DOE's implementation of its independent oversight function. Discussions with the 

Board are ongoing to better understand and complete this commitment. 

Nuclear Safety Research and Development. The NSR&D program DOE established in response to this 

recommendation now provides a corporate-wide structure and process to improve coordination, 

integration, and support of the Department's research, analysis, and testing of nuclear safety 

technologies, consistent with its Implementation Plan to Improve Oversight of Nuclear Operations. 

Significant progress has been made on the NSR&D commitments. The NSR&D Committee is now in full 

operation, and an NSR&D Program Manager has been brought on board. The corporate NSR&D 

program funded its first three projects during FY13 and will solicit proposals for additional projects in 

FY14. Funding for NSR&D has been adequate to appropriately address current NSR&D needs. 

Federal Safety Assurance Capability. This is a multi-faceted and overarching "desired end state" 

requirement that includes instituting central technical authorities; providing effective Federal 

oversight; instituting a nuclear safety research program; establishing clear roles, responsibilities, and 

authorities; and ensuring technical capability and capacity to fulfill safety responsibilities for proper 

oversight and execution of complex, high-hazard nuclear operations. Because some Departmental 

organizations and operations have changed since this IP was developed, the method for verifying 

compliance with the specific details of the commitment for effective Federal oversight may differ from 

what is specified in the plan. The Department is working with the Board to develop a satisfactory 

method to ensure that validation actions reflect current expectations. 

2000-1.: Prioritization for Stabilizing Nuclear Materials 

The Board issued Recommendation 2000-1 on January 14, 2000. The recommendation encouraged 

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 most 

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

July 22, 2002. All NNSA IP actions are complete, except for various material stabilization activities at 

LANL. All EM IP actions are complete, except for the stabilization of Hanford K-Basin sludge. 

In a letter dated April 11, 2013, NNSA updated the Board on progress toward stabilizing the remaining 

materials at LANL. Approximately 20 kilograms of depleted uranium and 5 kilograms of actinides other 

Board-Related Activities, FY13 I Page 17 
Department of Energy I May 2014 

than plutonium that do not require immediate stabilization are now included in a larger, accelerated 

NNSA effort to disposition all excess materials held at LANL. Under this effort, these items will be 

prioritized by risk and dispositioned over the next five years. The confinement vessel disposition 

project is now managing the stabilization of full vessels and disposition of materials. The Board closed 

this recommendation December 19, 2013. 

V. Interface Activities 

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

letter, 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 https://hsspublic.energy.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 FY13, DOE completed 15 actions related to such reporting requirements. 

These are shown in Appendix A, Table A.2. One public hearing was held during FY13. It is summarized 

in Appendix A, Table A.3. 

Board-Related Activities, FY13 I Page 18 
Department of Energy I May 2014 

Appendix A. FY13 Summary: Open Recommendations; 

Statutory Letter Reports; and Public Meetings/ Hearings 

Table A.1 Open Recommendations 

Rec# Title Date Opened Projected Timeframe for Completing 

Implementation Plan Actions 

201 2-2 Hanford Tank Farms Flammable Gas 09/28/2012 2015 (Before vitrification operations 

Safety Strategy begin at WTP) 

2012-1 Savannah River Site Building 235-F 05/09/201 2 2018 Safety 

2011-1 Safety Culture at the Waste 06/09/2011 2014 Treatment and Immobilization Plant 

2010-2 Pulse Jet Mixing at the Waste 12/17/2010 Closed by Board letter of 

Treatment and Immobilization Plant January 28, 2014 

Safety Analysis Requirements for 

2010-1 Defining Adequate Protection for the 10/29/2010 2016 (Assuming issuance of 

Public and the Workers Standard 3009 in March 2014) 

2009-2 Los Alamos National Laboratory 10/26/2009 2014 Plutonium Facility Seismic Safety 

2009-1 Risk Assessment Methodologies at 07/30/2009 Closed by Board letter of 

Defense Nuclear Facilities January 28, 2014 

2005-1 Nuclear Material Packaging 03/10/2005 2014 

2004-2 Active Confinement Systems 12/07/2004 2014 

2004-1 Oversight of Complex, High-Hazard 05/21/2004 2014 Nuclear Operations 

2000-1 Prioritization for Stabilizing Nuclear 01 /14/2000 Closed by Board letter of 

Materials December 19, 2013 

Board-Related Activities, FY13 I Page 19 
Department of Energy I May 2014 

Table A.2 DOE Reports Requested by DNFSB Letters Completed In FY13 

• . 

SL 12-014 

SL12-015 

I SL12-021 

Commitment Title 

A report identifying actions taken or planned by the National Nuclear Security 

Administration to resolve safety issues relating to the Transuranic Waste Facility 

project at Los Alamos National Laboratory 

A report and briefing regarding the approved safety basis for the Plutonium Facility at 

Los Alamos National Laboratory 

A report on NNSA's approach to validate the modeling assumptions in the analysis 

and design of the Uranium Processing Facility main building at Y-12 

• • 

.. 10/09/2012 

11/05/2012 

11/05/2012 

A report and briefing on the actions taken and planned by DOE to address the lack of ::J 

SL 12-019 comprehensive requirements and guidance for Integrated Safety Management at the 11/30/2012 

activity level: work planning and control 

~ 12_

0231 ; report on DOE's plans to address issues regarding approved safety basis ~ 11612013 1 ' I Area G at Los Alamos National Laboratory I v ' ' 

I 

SL 12-020 

A report and briefing regarding the adequacy of the development, review, and 

approval of safety control strategies for nuclear operations at Lawrence Livermore 

National Laboratory 

1 

-0 A report and bri fin~ on -;ctions the NNSA has taken or-;ians to take to ensure the 

SL 11-026 Lawrence Livermore National Laboratory Plutonium Facility's glovebox system and 

Fire Detection and Alarm System can perform their safety functions 

1 

SL03-031 I Annual report on th-;-Department's Nuclear Criticality Safety Program 

A report and briefing regarding plans to address the issues/weaknesses in the 

tracking and closure process for Nuclear Explosive Safety findings at the Pantex 

Plant 

01/31/2013 

02/20/2013 

03/25/2013 

03/25/2013 

I - - -- -- - ---------T-------1 I 

SL 12-006 

I 

SL 13-001 

I 

SL 13-002 

I SL 13-003 

I 

A report on the NNSA's actions to address the issues on the effectiveness of the 

nuclear explosive safety program at the Pantex Plant 

A report and briefing on DOE senior leadership's assessment of the current state of 

public and worker protection for seismic accident scenarios, and the risk reduction 

measures to be applied to mitigate near term seismic risks of the Plutonium Facility 

at Los Alamos National Laboratory 

A report and briefing regarding plans and schedules for actions to ensure the proper 

operability and reliability of fire protection systems at the Pantex Plant 

A schedule outlining the path to complete the alternate analysis for a seismic 

collapse scenario at the Los Alamos National Laboratory Plutonium Facility 

Board-Related Activities, FV13 I 

03/30/2013 

03/27/2013 

05/30/2013 

09/03/2013 

Page 20 
Department of Energy I May 2014 

r-- report providing the schedule for completing a revised implementation plan for 

SL 13-005 Recommendation 2010-2, Pulse Jet Mixing at the Waste Treatment and 

Immobilization Plant 

09/11/2013 

SL 13-006 

Date 

03/14/2013 

10/02/2012 

~~ ~~ 

A report and briefing on the actions DOE is taking to meet the commitments of its 

Implementation Plan for Recommendation 2010-1 , Safety Analysis Requirements for 

Defining Adequate Protection for the Public and the Workers, with an updated 

Implementation Plan schedule 

09/20/2013 

Table A.3 DNFSB Public Meetings/Hearings Conducted in FY13 

Safety Culture, 

Emergency 

Preparedness, 

and Nuclear 

Explosive 

Operations at 

Pantex 

Factors That 

Could Affect the 

Timely Execution 

and Safety of the 

Uranium 

Processing 

Facility (UPF) 

Project 

Amarillo Civic 

Center 

Amarillo, Texas 

Knoxville 

Convention Center, 

Knoxville, 

Tennessee 

• 

• 

• 

• 

• 

• 

• 

• 

Discussion Areas 

Identification of shortfalls in the Pantex safety 

culture 

Potential impacts that a flawed safety culture 

may have on nuclear explosives operations 

Management approaches to improving safety 

culture 

Status of emergency preparedness at the 

Pantex Plant. 

Actions taken to address issues with the 

conduct of operations, maintenance and work 

planning at Y-12 National Security Complex 

The contractor's process for identifying and 

resolving safety issues 

Effectiveness of NNSA oversight of nuclear 

operations 

Status of emergency preparedness and 

contractor's method to ensure effective 

response to severe site emergencies. 

Board-Related Activities, FY13 I Page 21 
Department of Energy I May 2014 

Appendix B. Acronyms and Abbreviations 

AMP 

BOBE 

Board 

CFR 

Department 

DNFSB 

DOE 

DR 

DSA 

EM 

EU 

FY 

GAO 

Hanford 

HAZMAT 

HSS 

IP 

ISM 

ISMS 

IST 

LANL 

NCS 

NES 

NNSA 

NSR&D 

ORP 

Pantex 

PF-4 

PJM 

PRA 

QA 

SCWE 

sos 

SRS 

UPF 

u.s.c. 

WESF 

WP&C 

WTP 

Y-12 

Y-12 Aging Management Program 

Beyond Design Basis Event 

Defense Nuclear Facilities Safety Board 

Code of Federal Regulations 

Department of Energy 

Defense Nuclear Facilities Safety Board 

Department of Energy 

Office of the Departmental Representative to the DNFSB 

Documented Safety Analysis 

Office of Environmental Management 

Enriched Uranium 

Fiscal Year 

Government Accountability Office 

Hanford Site 

Hazardous Material 

Office of Health, Safety and Security 

Implementation Plan 

Integrated Safety Management 

Integrated Safety Management System 

EM Integrated Site Team 

Los Alamos National Laboratory 

Nuclear Criticality Safety 

Nuclear Explosives Safety 

National Nuclear Security Administration 

Nuclear Safety Research and Development 

Office of River Protection 

Pantex Plant 

LAN L Plutonium Facility 

Pulse Jet Mixing 

Probabilistic Risk Assessment 

Quality Assurance 

Safety Conscious Work Environment 

WTP Safety Design Strategy 

Savannah River Site 

Y-12 Uranium Processing Facility 

United States Code 

Hanford Waste Encapsulation Storage Facility 

Work Planning and Control 

Hanford Waste Treatment and Immobilization Plant 

Y-12 National Security Complex 

Board-Related Activities, FY13 I Page 22