1

Remarks of the Honorable Mr. Thomas A. Summers, 

Vice Chair of the Defense Nuclear Facilities Safety Board

At the Session on US DOE EM Nuclear Safety Oversight

Of the Waste Management Symposia, 2023

Good afternoon, it is great to be here today! I am Thomas 

Summers, and I am the Vice Chair of the Defense Nuclear Facilities 

Safety Board. I would like to thank Ms. Anderson, Mr. Benda, 

Ms. Hawks, and Mr. Sosson for this invitation to speak with you. 

I’d like to touch on three safety concerns that are very high on the 

Defense Nuclear Facilities Safety Board’s list—aging infrastructure, risk 

management, and DOE safety oversight. 

Let’s start with aging infrastructure. The phrase “aging 

infrastructure” has a lot of meanings, but today we are talking about agerelated degradation of real property assets and their installed equipment. 

Regardless of whether the asset is an office building, fire station, parking 

lot, or plutonium processing building, that asset contributes to, and 

sometimes is essential to, the safety and success of the mission it 

supports.
2

As assets and installed equipment age, their reliability, resiliency, 

and operability degrade. Surveillance and maintenance sustain them for 

a while, but ultimately age takes its toll. According to DOE, the average 

age of an asset in DOE’s general-purpose infrastructure is about 

40 years. You might think that EM has an extra challenge here since the

infrastructure at its sites was already old and degraded before EM 

assumed responsibility for it. However, EM was created specifically to 

manage old and degraded infrastructure.

Certainly, the contributions from all assets are not equally 

important, but do not assume that an asset’s importance aligns with its

monetary value. We often get surprised when a failure in a low-value

asset interferes with important work in our high-value main building. 

This is particularly troublesome when the failure affects the safety of the 

work. We need to understand the safety contribution from all parts of 

the site’s infrastructure.

That brings us to my second topic, risk management. DOE

performs a documented safety analysis for its major defense nuclear 

facilities. However, DOE does NOT require comprehensive site-wide or 
3

enterprise-level risk assessments to understand the full suite of risks

associated with its defense nuclear facilities and their supporting 

infrastructure. 

Why should an infrastructure risk assessment be important to EM? 

EM is a collection of closure projects, not a long-term enterprise, right? 

Well, according to its budget guidance and strategic plans, EM

intends to operate some sites and facilities for another 50 or more years. 

For examples, EM anticipates storing immobilized high-level waste and

spent fuel at multiple sites for at least another 25 years before a 

disposition path becomes available. The Waste Treatment and 

Immobilization Plant at Hanford will be operating for at least 40 years—

after it starts up—and the 46-year-old 242-A Evaporator is needed to 

support that operation. Nineteen facilities on EM’s list of “higher risk 

facilities” have estimated disposal dates between the years 2050 and 

2075, and disposal dates haven’t even been estimated for 30 other

facilities on that list. The Waste Isolation Pilot Plant is already beyond 

its original design life, but it is EM’s only disposal pathway for 
4

transuranic waste from some of those buildings that haven’t even been 

scheduled for disposal yet.

Clearly, a full refurbishment and replacement program for the 

infrastructure supporting these long-term EM missions is unrealistic, but 

so is allowing that infrastructure to run to failure without considering the 

possible impacts to worker, public, and environmental safety.

The bottom line is that EM will have to manage and sustain some 

of its aged infrastructure for another 50 or more years. So, the simple 

question becomes, how can EM improve its management of this aged 

infrastructure so that EM can continue its important cleanup operations 

safely and efficiently? The answer is complicated, but there are simple

things that EM can do to get started.

First, EM headquarters needs a formal and consistent approach to 

assessing the condition of the infrastructure at its sites. I understand that 

EM has taken steps to develop an enterprise-level view of its 

infrastructure, and I encourage them to continue that effort as that is the 

first important step in understanding the condition of their infrastructure. 

Also, EM headquarters needs a method to rate and prioritize the safety 
5

and mission significance of all its assets. These three steps will provide

EM headquarters the high quality and consistent information it needs for 

a complex-wide view of its infrastructure. These steps will enable EM’s 

senior leaders to improve the balancing of their resources between safety 

and mission to ultimately accomplish their missions safely. 

Accomplishing missions safely, I think, is the goal that we’d all like to 

achieve.

Second, EM headquarters needs a strategic approach for guiding 

decisions on predictive, preventative, and reactive maintenance at its 

sites, and to determine when deferring maintenance or running-to-failure 

is acceptable. Applying a strategic and consistent approach to all its

sites will help EM assure that its resources are used to best effect.

Third, EM needs a champion for infrastructure management within 

the senior level of EM headquarters. That champion needs the authority

to influence EM-wide decisions on infrastructure-related asset 

procurement, refurbishment, recapitalization, and sustainment actions.

Finally, this brings us to my third topic, DOE safety oversight. I’m 

sure you’ve already noticed that I am explicitly calling out EM 
6 

headquarters in the solutions to these problems. Any effort to make 

long-term improvements, or even to maintain status quo, within a large 

organization requires constant leadership and vigilance at the highest

levels and throughout the organization. To that end, EM’s senior leaders 

need to have strong and effective safety oversight, performance 

monitoring, and corrective action programs, with sufficient dedicated 

resources, to support their efforts to improve and sustain EM’s 

infrastructure.

In closing, we all know that there are no easy solutions to the 

challenges EM faces. However, we also know there are ample 

opportunities to combine good strategies, sufficient guidance, 

comprehensive plans, adequate implementation of those plans, and 

effective leadership and oversight to succeed in major efforts.

Thank you for listening, I will be happy to entertain questions 

during the open panel discussion.

[End of remarks]
7

Possible topics for Q&A (not in any order)

1. What are examples of consequences of run-to-failure approach?

In general, a run-to-failure approach may result in important safety 

systems not being able to perform their safety function when 

needed. The Board recently communicated concerns with the runto-failure approach NNSA was using for their oxygen monitors at 

the Savannah River Tritium Enterprise. 

Our staff is currently performing a complex-wide review on aging 

management, part of which will be looking at DOE’s use of run-tofailure approaches at both EM and NNSA sites.

Note that the Board recognizes that there are situations where a 

run-to-failure approach may be acceptable. However, the Board 

believes that situations where such an approach is applied should 

be considered as part of a risk-based aging infrastructure 

management program.

2. Why worry about infrastructure failures, aren’t the safety systems 

of the defense nuclear facilities designed to protect against them?

a. First, you never want to unnecessarily challenge your safety 

systems.

b. Second, if you haven’t assessed the risk from failures in your 

infrastructure, you do not know how a failure can impact 

your facility.

3. What’s the difference between management of aging infrastructure 

and aging management?

a. Aging management is a framework for assessing and 

managing the aging of individual components in a system. 

Management of aging infrastructure is the broader concept of 
8

understanding the current state of an infrastructure and 

maintaining it as it ages to ensure that the infrastructure can 

continue to support the activities that depend on it. Aging 

management is one of the tools in the management of aging 

infrastructure toolbox.