Management of Aging 

Infrastructure at Sites with

DOE Defense Nuclear Facilities

Thomas A. Summers, Vice Chair

Defense Nuclear Facilities Safety Board

EFCOG Cybersecurity Working Group 2023 Workshop

October 25, 2023
Infrastructure and Cybersecurity

There are overlapping concerns between cybersecurity and infrastructure

• The Board’s focus is on DOE’s aging real property assets and their installed 

equipment that support DOE’s defense nuclear facilities

• The Board is also concerned with DOE’s current approach to managing risks 

associated with that aging infrastructure

October 2023 EFCOG Cybersecurity Working Group 2023 Workshop 2

• The EFCOG cybersecurity work group’s 

work plan for 2023 states that the working 

group’s focus includes:

• Industrial control systems and 

distributed control systems

• Internet of Things (IoT)

• Smart technologies, and

• Risk management and governance

[Source of picture: Freepic.com]
Why Worry about Aged Infrastructure?

October 2023 EFCOG Cybersecurity Working Group 2023 Workshop 3

Aged infrastructure reduces personnel safety and performance

• Reduces worker morale and encourages acceptance of lower standards

• Increases housekeeping needs and the potential for errors and accidents

• Places heightened pressure on maintenance personnel

• Interferes with safe conduct of work and leads to declining productivity

Age-related degradation increases risk to facility safety

• Increases component failure rates and reduces system reliability 

• Introduces common-cause failure modes that challenge safety analyses

• Reduces system resilience by limiting ability to respond to off-normal needs

• Creates failure modes that challenge SSCs or trigger unanticipated accident 

sequences

Technical obsolescence increases the number of vulnerabilities 

and exposures that may provide unauthorized access to smart 

systems, resulting in an unanalyzed risk to facility safety
What is “Infrastructure?”

• In this discussion, the word infrastructure refers to all real property assets 

and their installed equipment that enables or supports activities or 

DOE’s mission at a site 

• Basically, infrastructure is a system of systems; the functionality of an 

infrastructure is created by the combined functionality of the individual real 

property assets that support it

October 2023 EFCOG Cybersecurity Working Group 2023 Workshop 4

• Infrastructure management is about making 

informed decisions based on a systematic 

approach to evaluating component and 

system adequacy and vulnerability, 

understanding intersystem dependencies, and 

determining the potential consequences of 

system failure

• Aging management programs are some of 

the tools of infrastructure management, but 

the two are not synonymous

Aerial view of Pantex Plant
Board Perspective on Infrastructure

DOE’s challenges extend to managing its aging infrastructure, ...particularly in 

systematically evaluating the infrastructure that supports the safe 

operation of its defense nuclear facilities.

DOE appears to struggle with implementing and maintaining necessary 

infrastructure and safety controls, even after recognizing the importance of 

those systems and controls to DOE’s ability to ensure adequate protection of 

its workers, the public, and the environment.

Defense Nuclear Facilities Safety Board

33rd Annual Report to Congress, March 2023

October 2023 EFCOG Cybersecurity Working Group 2023 Workshop 5
Aging Infrastructure Impact on NNSA

A well-organized, well-maintained, and modern infrastructure system is the 

bedrock of a flexible and resilient nuclear security enterprise. More than 60 

percent [of NNSA’s assets and facilities] are beyond their life expectancy, 

with some of the most important dating back to the Manhattan Project. 

NNSA Administrator Jill Hruby

House Armed Services Committee 

Subcommittee on Strategic Forces

March 28, 2023

October 2023 EFCOG Cybersecurity Working Group 2023 Workshop 6

Building 9212, Y-12 National Security Complex. Built in 1945.
Aging Infrastructure Impact on EM

Hanford’s 56 million gallons of radioactive and 

chemical waste stored in 177 aging storage tanks 

represent EM’s greatest environmental risk and 

financial liability. Recognizing that additional 

delays bring greater environmental risks, 

exacerbate the impacts of already aging 

infrastructure, and increase costs, we are 

focused on moving the entire Hanford tank 

waste mission forward.

William “Ike” White

Senior Advisor for DOE-EM

Senate Armed Services Committee 

Subcommittee on Armed Forces

April 18, 2023

October 2023 EFCOG Cybersecurity Working Group 2023 Workshop 7

241-C Tank Farms, Hanford

Waste Treatment Plant, Hanford
DOE’s Continuity Challenge

41 years ago: Some multiprogram laboratory facilities are in obvious need of repair. 

DOE management is aware of this, [but] it does not know the true condition of all 

facilities. (GAO, February 1982)

33 years ago: DOE faces major challenges including modernizing facilities that have 

deteriorated over the 30 to 40 years since their construction. DOE must also...ensure that 

it operates in compliance with current environmental, safety, and health standards. (GAO, 

September 1990)

20 years ago: The seriousness of infrastructure deficiencies, combined with competing 

needs...and historical weaknesses in project management, make implementing plans for 

infrastructure revitalization a management challenge for [DOE]. (GAO, January 2003)

11 years ago: Of the few major [NNSA] projects that were successfully completed...we 

could find no successful historical major project that both cost more than $700 million 

and achieved CD-4 in less than 16 years. (IDA, November 2012) 

5 years ago: NNSA may have to defer certain modernization work planned for fiscal years 

2018 through 2021. ...this deferral could exacerbate a significant bow wave of 

modernization funding needs that NNSA projects for the out-years. (GAO, February 2018)

October 2023 EFCOG Cybersecurity Working Group 2023 Workshop 8
DOE’s Cybersecurity Challenge

• The National Nuclear Security Administration (NNSA) and its contractors 

have not fully implemented six foundational cybersecurity risk practices in its 

traditional IT environment. NNSA also has not fully implemented these 

practices in its operational technology and nuclear weapons IT environments.

(GAO, GAO-22-104195, 2022)

• We recommended that the Departments of Energy, Health and Human 

Services, Homeland Security, and Transportation...establish and use metrics 

to assess the effectiveness of sector IoT and OT [Operating Technologies] 

cybersecurity efforts and evaluate sector IoT and OT cybersecurity risks. As 

of December 2022, none of these recommendations had been implemented.

(GAO, GAO-23-106415, 2023)

• NNSA’s efforts to address cybersecurity at the system level in the OT 

environment remain in the early stages of development and implementation. 

In our September 2022 report, we noted that NNSA has made limited 

progress—after several years of effort—to implement risk management practices that would help it inventory OT systems and assess and mitigate the 

risks to such systems. (GAO, GAO-23-106309, 2023)

October 2023 EFCOG Cybersecurity Working Group 2023 Workshop 9
Why No Continuity?

As a government agency, DOE faces inherent challenges that complicate its 

ability to maintain continuity on long-term programs like infrastructure renewal

October 2023 EFCOG Cybersecurity Working Group 2023 Workshop 10

• Frequently changing missions, priorities, 

budgets, leadership, and world events

• Extremely complex missions with rapidly 

evolving technology

• Urgent need for continued and expanded 

operations in aging facilities

• Aged assets may degrade faster than they 

can be refurbished or replaced

• High costs associated with nuclear and 

specialized products and construction

• Changing workforce and loss of corporate 

knowledge and experience

Tritium Facility, Savannah River Site
Sub-recommendation 1 of R2020-1

October 2023 EFCOG Cybersecurity Working Group 2023 Workshop 11

From reaffirmed Recommendation 2020-1: 

Develop and implement an integrated approach—including 

requirements—for the management of aging infrastructure 

that includes formal processes to identify and perform 

infrastructure upgrades necessary to ensure facilities and 

structures, systems, and components can perform their 

safety functions.

The approach needs to be 

integrated into DOE’s current 

real property and nuclear 

facility management processes.

The concern is about DOE’s 

management of aging infrastructure and 

the need to ensure that it can continue 

to perform its safety functions.

The approach needs formal 

processes for identifying 

and performing necessary 

infrastructure upgrades

Requirements need to be 

established at Secretarial 

level (i.e., directives)
Recipe for Success

Consider some of the most successful safety improvements in DOE:

• Integrated Safety Management Systems have been key to personnel and 

facility safety for almost 30 years

• DOE Facility Representatives have provided vital day-to-day oversight of 

facility operations for over 30 years

• Operational Readiness Reviews have helped ensure the safe startup of 

facilities for over 30 years

• DOE System Safety Engineers have ensured the quality and availability of 

the safety systems that the nuclear facilities rely on for over 20 years

What do these programs have in common?

• The requirements are integrated into DOE’s system of directives

• The essential elements are established at the secretarial level

• The approach includes formal processes and appropriate guidance

• The scope and intent of the programs are well defined and understood

October 2023 EFCOG Cybersecurity Working Group 2023 Workshop 12
Scope of Sub-recommendation 1

The Board perceives that there has been some confusion about the scope of 

the aging infrastructure sub-recommendation 

• The Board’s concern extends to all real property assets and installed 

equipment that provide or support a safety function at a DOE defense 

nuclear facility, regardless of whether those assets are inside or outside 

the facility’s DSA-designated boundary

• Examples include

• Electrical substations and distribution systems

• Centralized process steam and heat plants

• Fire stations, firewater tanks, pumphouses, and firewater pipes

• Emergency Operations Centers and facility assembly areas

• Access roads and bridges

October 2023 EFCOG Cybersecurity Working Group 2023 Workshop 13
EM Example

SRS H-Canyon 

Exhaust Tunnel Structural Integrity

• Constructed in 1953, the tunnel is a critical part of 

H-Canyon’s safety class ventilation system

• SRS has monitored and documented age-related 

degradation since 1990

• Evaluations since 2011 noted that degradation is 

severe and may impact post-seismic functionality

• Since 2011, Board and DOE have evaluated this 

issue with multiple analyses, letters, and briefings

• DOE is now pursuing a new safety strategy that 

does not rely on the tunnel for post-seismic safety

October 2023 EFCOG Cybersecurity Working Group 2023 Workshop 14
NNSA Example

NNSS Device Assembly Facility

Firewater Supply Tank

• Constructed in 1985, the tank is a safety class 

SSC in the current DSA

• Seismic vulnerabilities recognized around 2006

• Tank replacement was a planned improvement 

in the 2008 DSA

• An inspection in 2010 reported significant rust 

and blisters in coatings but no deep pitting

• By 2022, inspections reported widespread rust 

and blisters with significant deep pitting

• Facility is now operating under a JCO, and 

replacement project is scheduled for 2025

October 2023 EFCOG Cybersecurity Working Group 2023 Workshop 15

NNSS Device Assembly Facility

Ceiling Section 2010 Ceiling Section 2022
What Needs to be Done?

• DOE needs a set of requirements that create an integrated, systematic 

framework for managing its infrastructure

• Infrastructure is a system of systems; DOE needs a framework that 

considers individual assets as components of the bigger system

• DOE’s infrastructure is already significantly aged, DOE should consider 

adequacy as a strategic goal and facility safety as a priority

• Understanding risks is key to decision-making; DOE should implement an 

enterprise risk management system as the foundation for managing its 

infrastructure

• There are agencies and consensus standards bodies that address aging 

management, such as NRC, IAEA, and IEEE; DOE should look to those 

groups for demonstrated processes and strategies for its infrastructure

October 2023 EFCOG Cybersecurity Working Group 2023 Workshop 16
Moving Forward

• The Board is encouraged to see the increased focus on DOE’s aging 

infrastructure

• Both EM and NNSA are building enterprise-level views of their 

infrastructure and identifying performance metrics

• That effort will aid senior managers in understanding the infrastructure risks 

DOE faces and support their decisions on infrastructure strategies

• DOE needs to build on this increased focus by institutionalizing it into 

clear and adequate directives before momentum is lost to another priority

• Short term investments in infrastructure improvement will have a big 

payback

Most importantly, DOE’s missions will also benefit 

from improved infrastructure

October 2023 EFCOG Cybersecurity Working Group 2023 Workshop 17
Your Role is Important

• There are direct links between cybersecurity and age-related 

degradation

• As DOE addresses its real property infrastructure challenges, you 

have a great opportunity to apply your expertise to their efforts

• The cybersecurity working group’s work plan aligns with DOE’s 

needs in addressing its infrastructure

• If you are already engaged in improving DOE’s infrastructure, 

EXCELLENT!

• If not, find a way to engage, your talents are needed!

October 2023 EFCOG Cybersecurity Working Group 2023 Workshop 18