John T. Conway, Chairman

AJ. Eggenberger, Vice Chairman

Joseph J. OiNunno

Herbert John Cecil Kouts

John E. Mansfield

DEFENSE NUCLEAR FACILITIES

SAFETY BOARD

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

(202) 208-6400

June 26, 1998

The Honorable Ernest J. Moniz

Under Secretary ofEnergy

Department ofEnergy

1000 Independence Avenue, SW

Washington, DC 20585-1000

Dear Dr. Moniz:

The Defense Nuclear Facilities Safety Board (Board) has reviewed the Operational

Readiness Review (ORR) conducted for the Department ofEnergy's Richland Operations Office

(DOE-RL) in support ofdecommissioning activities at the 233-S Concentration Facility at the

Hanford Site. The enclosed issue report prepared by the Board's staff describes what appears to

be additional evidence that a systematic problem exists in the way DOE-RL implements its

process for verifying readiness for start-up and restart ofoperations. The report provides further

background that DOE may wish to use in preparing a response to the Board's April 15, 1998,

letter to DOE. That letter detailed deficiencies in the readiness verification process at Hanford

and requested that DOE report on efforts to improve this process.

The Board's staff review ofthe ORR for the 233-S facility noted issues related to

mangement and the readiness process at DOE-RL. Issues related to qualification ofteam

members and verification offuture readiness are of particular concern. For example:

• Only two of nine personnel assigned to the ORR Team were qualified to enter the area

with airborne radioactivity, where much ofthe decommissioning work will be -'

conducted. Therefore, the ORR Team was prevented from witnessing conditions

which playa significant role in determining worker hazards. Most significantly, the

individual tasked with reviewing compliance with radiological safety was unable to

witness compliance ofworkers with radiological controls. Moreover, ORR Team

membership did not contain individuals with extensive experience at plutonium

facilities, and no attempt appeared to have been made to acquire this expertise from

other DOE sites.

• Future readiness activities outlined in the plan of action which was prepared by DOERL's line management was not fully consistent with the requirements and/or guidance

outlined in DOE Order 425.1, Startup and Restart ofNuclear Facilities, and DOESTD-3006-95, Planning and Conduct ofOperational Readiness Reviews (ORR).

This situation is particularly distressing since the current ORR was only able to review

work packages related to 2 of 9 decommissioning activities, none of'Yhich represent

the most hazardous work to be conducted. DOE plans no explicit verification of

deadlines for the 7 activities of highest hazard but rather plans to rely solely on

certification by DOE-RL that all relevant work packages have been completed.
The Honorable Ernest J. Moniz Page 2

DOE-RL's ORR Team recognized these issues and made appropriate recommendations

for corrective action in their exit briefing, conducted at the end oftheir on-site review. The Board

concurs with the approaches recommended by the ORR Team. However, this alone is not

sufficient to prevent similar issues from occurring in other readiness verifications.

Should you have any questions on this matter, please do not hesitate to call me.

Sincerely,

f/~~~~an fffe?

c: Mark B. Whitaker, Jr.

Mr. John D. Wagoner

Enclosure
88/2633·

DEFENSE NUCLEAR FACILITIES SAFETY BOARD

DNFSB StaffIssue Report

June 18, 1998

MEMORANDUM FOR: G. W. Cunningham, Technical Director

COPIES: Board Members

FROM: S. A. Stokes

SUBJECT: 233-S Operational Readiness Review

This report documents an issue reviewed by the staffofthe Defense Nuclear Facilities

Safety Board (Board) related to the Operational Readiness Review (ORR) for decommissioning

the 233-S Concentration Facility at the Hanford Site. This review was conducted by S. Stokes

and outside expert R. Lewis during May 12-18, 1998.

Background. The 233-S facility comprises the original process building with

modifications; the 233-SA exhaust filter building; and interconnecting piping, trenches, and

ducting. The 233-S process building is a reinforced concrete structure that contains the main

contaminated areas, primarily where process-related activities took place. Approximately 1.5 kg

of plutonium-bearing materials remain within 233-S. This estimate is based upon preliminary

characterization efforts; however, the decommissioning contractor, Bechtel Hanford Incorporated

(BHI), recognizes that there are unknowns that could affect this estimate. Bill's existing work

approach relies heavily on analytical studies to provide timely information about unknown or

unexpected hazard conditions.

Based on the remaining radiological hazards, 233-S is a hazard category 2 nuclear facility,

which, based on requirements contained in Department of Energy (DOE) Order 425.1, Startup

andRestart ofNuclear Facilities, requires an ORR prior to initiating decommissioning activities.

The attachment to this report contains a list ofthe activities to be completed as part ofthe

decommissioning.

233-S ORR Plan of Action (POA). The 233-S ORR POA outlined a phased approach to

verifying readiness based on three completed work packages and a review ofthe programs

.required to develop work packages and train personnel. Completion offuture work packages,

which involved the highest-hazard activities, was to be considered pre-start items f~)[ the

associated tasks, and reviewed for closure by the Bill ORR team, and certified closed by

Department ofEnery-Richland (DOE-RL) line management. There would be no explicit

verification of readiness for these high-hazard activities.
The Board's staff believes that this approach is not fully consistent with DOE Order 425.1

and DOE-STD-3006-95, Planning andConduct ofOperational Readiness Reviews (ORR), given

the findings ofthe current DOE-RL ORR Team DOE-RL line management involvement in the

project was found to be less than adequate. For example, these directives require an ORR for the

initial startup, and they require the examination offacilities, equipment, personnel, procedures,

and management control systems to ensure that a facility will be operating safely within its

approved safety envelope prior to the initiation of new or unreviewed program work. (Note that

program work is defined in DOE-STD-3006-95 as work in a reactor or nonreactor nuclear facility

that is accomplished to further the goals ofthe facility mission and/or the program for which the

facility is operated.) Because ofthe hazards remaining in 233-S, a readiness assessment that has

been graded to reflect the appropriate level ofrisk involved in the new/unreviewed program work,

would normally be completed. The Board's staffbelieves that by not requiring future readiness

assessments, DOE-RL line management is allowing the most hazardous work to proceed using a

process less rigorous than that used to verify their readiness to proceed.

In its exit briefing, the DOE-RL ORR Team recognized this issue and recommended that a

contractor independent review, followed by a DOE-RL line assessment and separate DOE-RL

independent Readiness Assessment, be completed before new program work is initiated. The

Board's staff concurs with this approach, and believes it to be in line with DOE Order 425.1

requirements and appropriate given the risks associated with this and other future activities.

DOE-RL Management of the ORR Process. The ORR effort was completed consistent

with requirements contained in the DOE Order and Richland Implementation Document.

However, the Board's staff noted the following:

--'

• Team members were not qualified to make entries into facility airborne areas. This

situation prevented team members from understanding the risks inherent in conducting

decommissioning operations within the facility. This issue was recognized in the ORR

Team's exit report, which recommended that future DOE readiness team members be

fully qualified to make entries in the areas where work is planned..

• Assistance from outside DOE-RL was not solicited. This assistance would have

benefited the team, particularly with regard to its breadth of experience. For example,

decommissioning of plutonium facilities is currently being conducted at the Rocky

Flats Environmental Technology Site. This issue was similarly recognized in the ORR

Team's exit report, which recommended that individuals from offsite, with experience

in plutonium facility operations, be included on future teams.

ORR Team Findings. The following are significant findings and observations from the

ORR Team's exit report that remain open (all are post-start findings [F] or obserVations [0]):

2
• DOE-RL line management involvement is less than adequate (F). This issue is

particularly important given the approach outlined in the plan of action for future

readiness activities, since a lack ofinvolvement severely limits line management's

ability to certify pre-start items for future work packages as closed. Additionally, the

director ofthe projcct division is also director ofthe project support division that

supports the 233-5 project manager. This dual responsibility is believed not to allow

the director ofthe project division to fully utilize his capabilities at 233-5 (0).

• The 233-5 program did not have a test program instruction defining guidelines for

performing equipment testing to confirm operability of equipment, viability of

procedures, and training of personnel (F). Additionally, lessons learned were not

formally incorporated into training (0). These are both critical components ofthe

project's approach to work planning and Integrated Safety Management.

• The Emergency Preparedness Program in support of233-S needs improvement (F).

Weaknesses related to the training and qualification ofthe building emergency

directors (BEDs) surfaced in a drill held during the ORR. The weaknesses include the

BEDs' ability to properly classify an event involving a fire at the 233-S and

weaknesses in the overall drill program.

Overall, the ORR was conducted in accordance with DOE Order 425.1, and the ORR

Team's findings represented an adequate assessment ofthe project's readiness to proceed for the

current scope of planned work (three work packages). The Board's staff believes that ifthe

recommendations made in the ORR Team's exit briefing are not fully implemented prior to the

initiation of new/unreviewed program work, a significant degradation ofsafety is likely to re~~1t

...

-'
Attachment

The following are the major decommissioning activities anticipated for the process area

decommissioning (activities that were reviewed as part of this ORR):

• Process pipe removal in the pipe trench

• Loadout hood decontamination and removal

• Viewing room equipment removal and decontamination

• Process hood decontamination and plastic polymethyl methacrylate panel removal

• Process hood equipment removal and decontamination

• Equipment draining

• Process system removal

• Process hood structural member removal

• Old filter house removal