[DNFSB LETTERHEAD]

February 21, 2003

Mr. Mark B. Whitaker Jr.
Departmental Representative to the DNFSB, S-3.1
U. S. Department of Energy
1000 Independence Avenue, SW
Forrestal Building, Room 6H-025
Washington, DC 20585-1000

Dear Mr. Whitaker:

The Defense Nuclear Facilities Safety Board (Board) is pleased to enclose a printed copy of its Thirteenth Annual Report to Congress which describes the Board's health and safety activities relating to the Department of Energy's defense nuclear facilities during the calendar year 2002.

Sincerely,

John T. Conway
Chairman

Enclosure: As stated





 

THIRTEENTH ANNUAL REPORT

TO CONGRESS

DEFENSE NUCLEAR FACILITIES
SAFETY BOARD

 


FEBRUARY 2003



PREFACE

Congress created the Defense Nuclear Facilities Safety Board (Board) as an independent agency within the Executive Branch (42 U.S.C. § 2286, et seq.) to identify the nature and consequences of potential threats to public health and safety at the Department of Energy's (DOE) defense nuclear facilities, to elevate such issues to the highest levels of authority, and to inform the public.

The Board is required to review and evaluate the content and implementation of health and safety standards, including DOE's orders, rules, and other safety requirements, practices, and events relating to system design, construction, operation, and decommissioning of DOE's defense nuclear facilities. The Board makes recommendations to the Secretary of Energy that the Board believes are necessary to ensure adequate protection of public health and safety. The Board must consider the technical and economic feasibility of implementing the recommended measures. The Secretary may accept in whole or in part or reject the recommendations. If the Secretary rejects a recommendation in whole or in part for any reason, the Board does not withdraw or modify the recommendation, and the Secretary maintains the rejection, the Secretary must publish his or her decision and reasoning in the Federal Register and must formally notify both Houses of Congress. The Secretary must report to the President and Congress if implementation of a recommendation is impracticable because of budgetary considerations. Should the Board determine that an imminent or severe threat to public health or safety exists, the Board must transmit its recommendation to the President, and the Secretaries of Energy and Defense.

The Board may conduct investigations, issue subpoenas, hold public hearings, gather information, conduct studies, establish reporting requirements for DOE, and take other actions in furtherance of its oversight of health and safety at defense nuclear facilities.

The Board is required by law to submit an annual report to the Committees on Armed Services and Appropriations of the Senate and to the Speaker of the House of Representatives. This report is to include all recommendations made by the Board during the preceding year, and an assessment of (1) the improvements in the safety of DOE defense nuclear facilities during the period covered by the report; (2) the improvements in the safety of DOE defense nuclear facilities resulting from actions taken by the Board or taken on the basis of the activities of the Board; and (3) the outstanding safety problems, if any, of DOE defense nuclear facilities.


EXECUTIVE SUMMARY

The nuclear weapons program of the Department of Energy (DOE), including the National Nuclear Security Administration (NNSA), is a complex and hazardous operation. Missions include maintenance of the national nuclear arsenal; dismantlement of surplus weapons; stabilization, storage, disposition, and disposal of surplus nuclear materials and toxic and contaminated waste; and cleanup of surplus facilities and sites. Some of these missions are carried out with aging facilities; others demand the construction of new facilities. The constant vigilance of the Defense Nuclear Facilities Safety Board (Board) is required to ensure that all of these activities are carried out by DOE in a manner that protects the public, workers, and the environment.

During this past year, actions by the Board resulted in numerous health and safety improvements. These improvements are described in this Annual Report along the lines of the Board's three strategic areas of concentration:

The most significant health and safety improvements during 2002 are summarized below.


SAFE MANAGEMENT AND STEWARDSHIP OF THE NATION'S NUCLEAR WEAPONS STOCKPILE AND NUCLEAR WEAPONS COMPONENTS


SAFE DISPOSITION OF THE HAZARDOUS REMNANTS OF NUCLEAR WEAPONS PRODUCTION

- At the Rocky Flats Environmental Technology Site (RFETS), all plutonium- bearing residues (more than 100 metric tons) were packaged into stable configurations; all plutonium-bearing solutions were eliminated; and more than 60 percent of the plutonium metal and oxide material was stabilized and packaged into robust sealed containers.

- At the Hanford Spent Nuclear Fuel Project, a major milestone was reached with the removal, stabilization, and packaging of the first containers of deteriorating spent nuclear fuel from the K-East Basin.

- At the Hanford Plutonium Finishing Plant, stabilization of plutonium-impregnated polystyrene cubes was begun; all plutonium solutions were disposed or converted to stable solids; thermal stabilization of plutonium alloys was completed; and all plutonium-bearing ash and sand, slag, and crucible residues were packaged for disposal at the Waste Isolation Pilot Plant (WIPP).

- At the Savannah River Site (SRS), disposition of plutonium-bearing residues and dissolution of damaged and deteriorating targets and spent nuclear fuel continued; stabilization and disposition of plutonium solutions began.

- At LANL, processing of plutonium residues and oxide items continued; higher- risk materials and organic solutions were eliminated.


COMPLEX-WIDE HEALTH AND SAFETY ISSUES

Accomplishments affecting multiple sites:

Accomplishments at Specific Sites:


OUTSTANDING SAFETY PROBLEMS OF DEFENSE NUCLEAR FACILITIES


HUMAN CAPITAL MANAGEMENT

The ability of the Board to fulfill its mission to ensure the health and safety of workers and the public depends heavily on attracting and retaining top-caliber technical staff. The Board has been successful in creating a work environment that emphasizes excellence as the standard for staff performance, and rewards staff members accordingly. The pay banding and pay for performance programs developed and implemented by the Board have proven to be effective in hiring technical talent, holding employees accountable for their performance, and rewarding outstanding performance on the job.

The Board's enabling legislation grants authority for excepted service hiring and classification. During fiscal year (FY) 2002, the Board operated at 63 percent of its statutory employment ceiling of 150 Full Time Equivalents due to fiscal constraints. Within these constraints, however, the Board used excepted service authority, along with recruitment and relocation bonuses, student loan repayments, and retention allowances. In consequence, the Board has been successful in competing for scientific and technical staff in a competitive employment market. The recruitment and retention of scientific and technical staff with outstanding qualifications continues to be critical to the successful accomplishment of the Board's mission.

The Board expects its engineers and scientist to maintain the highest level of technical knowledge to meet the wide range of health and safety challenges it faces. As of the end of FY 2002, 87 percent of the staff held advanced degrees, 29 percent of which were at the Ph.D. level. To meet expected staffing needs, the Board continued its recruitment of senior, experienced technical staff by traditional methods. To attract younger staff members, the Board relies on its Professional Development Program (PDP), a 3-year program that brings entry-level technical talent into professional positions within the Board. Through a technical mentor, individuals are provided a series of individually tailored developmental assignments, formal academic schooling, and a 1-year hands-on field assignment. This is a highly competitive program to attract the next generation of scientific and technical talent to federal service.

In summary, the Board's ability to accomplish its health and safety mission successfully begins with a determined, focused, and well-executed human capital program. This program uses all available tools to attract and retain the people necessary to accomplish the job that Congress has asked the Board to do.


TABLE OF CONTENTS

Section

Page
 

1. INTRODUCTION 1-1
  1.1 Background 1-1
  1.2 Health and Safety Oversight Strategy 1-2
  1.3 Goals and Objectives of the
Board's Strategic Plan		 1-3
2. SAFE MANAGEMENT AND STEWARDSHIP OF
NUCLEAR WEAPONS STOCKPILE AND COMPONENTS		 2-1
  2.1 Safe Conduct of Stockpile Management 2-1
    2.1.1 Pantex Plant 2-1
    2.1.2 Y-12 National Security Complex 2-3
    2.1.3 Tritium Production 2-4
  2.2 Safe Conduct of Stockpile Stewardship 2-4
    2.2.1 Recommendation 2002-2, Weapons
Laboratory Support of the Defense Nuclear Complex		 2-4
    2.2.2 Los Alamos National Laboratory 2-5
    2.2.3 Lawrence Livermore National Laboratory 2-7
    2.2.4 Nevada Test Site 2-8
    2.2.5 Sandia National Laboratories 2-9
3. SAFE DISPOSITION OF HAZARDOUS REMNANTS OF
WEAPONS PRODUCTION		 3-1
  3.1 Stabilization and Storage of Remnant Materials 3-1
    3.1.1 Complex-Wide Program 3-1
    3.1.2 Plutonium 3-2
    3.1.3 Uranium 3-4
    3.1.4 Special Isotopes 3-5
    3.1.5 Inactive NNSA Nuclear Materials 3-5
  3.2 Stabilization of Spent Nuclear Fuel 3-6
    3.2.1 Hanford Spent Nuclear Fuel Project 3-6
    3.2.2 Savannah River Site 3-7
  3.3 Waste Management 3-7
    3.3.1 High-Level Waste 3-7
    3.3.2 Low-Level and Transuranic Waste 3-9
  3.4 Facility Deactivation and Decommissioning 3-10
    3.4.1 Safe Practices for Deactivation and Decommissioning 3-10
    3.4.2 Y-12 National Security Complex 3-10
    3.4.3 Rocky Flats Environmental Technology Site 3-11
    3.4.4 Fernald Closure Project 3-11
    3.4.5 Mound Closure Project 3-12
4. COMPLEX-WIDE HEALTH AND SAFETY ISSUES 4-1
  4.1 Implementation of Integrated Safety Management 4-1
    4.1.1 Overview 4-1
    4.1.2 ISM Annual Update Process 4-1
    4.1.3 Reliability and Configuration Management of Vital Safety Systems 4-2
    4.1.4 Site-Specific ISM Reviews and Improvements 4-2
  4.2 Health and Safety Directives 4-3
    4.2.1 Improvement of Directives 4-3
    4.2.2 Implementation of Directives 4-4
    4.2.3 Recommendation 2002-3, Requirements for the Design, Implementation, and Maintenance of Administrative Controls 4-7
  4.3 Technical Competence 4-7
    4.3.1 Competence of DOE and Contractor Personnel 4-7
    4.3.2 System Engineers and Federal Subject Matter Experts 4-8
  4.4 Nuclear Facility Design Reviews 4-9
5. INFORMING THE PUBLIC 5-1
  5.1 Public Meetings 5-1
  5.2 Responding to Public Requests 5-1
  5.3 Electronic Access 5-1
  5.4 Inquiries into Health and Safety Issues 5-1
  5.5 Site Representative Activities 5-2
Appendices  
A. RECOMMENDATIONS A-1
B. REPORTING REQUIREMENTS B-1
C. CORRESPONDENCE C-1
D. ADMINISTRATIVE ACTIVITIES D-1
E. HUMAN RESOURCES E-1
F. LIST OF ABBREVIATIONS AND ACRONYMS F-1

 

1. INTRODUCTION

1.1 BACKGROUND

The Defense Nuclear Facilities Safety Board (Board) is an independent federal agency established by Congress in1989. Simply stated, the Board's mandate under the Atomic Energy Act is safety oversight of the civilian nuclear weapons facilities managed by the Department of Energy (DOE). The nuclear weapons program remains a complex and hazardous operation. DOE must maintain in readiness a nuclear arsenal, maintain aging facilities, dismantle surplus weapons, dispose of excess radioactive materials, clean up surplus facilities, and construct new facilities for many purposes. All of these functions must be carried out in a manner that protects the public, workers, and the environment.

Congress expects the Board to be an independent, expert agency capable of understanding the complexity of nuclear weapons facilities and operations. For that reason, Members of the Board are required by statute to be experts in the field of nuclear safety. The Board has, in turn, assembled a permanent staff with broad nuclear industry experience and competence in all major aspects of nuclear safety: nuclear, mechanical, electrical, chemical, and structural engineering, as well as physics and metallurgy. Currently, 87 percent of the Board's technical staff hold advanced degrees, of which 29 percent are at the Ph.D. level.

The Board has established site offices at six high-priority defense nuclear sites: Pantex Plant in Texas, Los Alamos National Laboratory (LANL) in New Mexico, the Y-12 National Security Complex (Y-12) in Tennessee, Savannah River Site (SRS) in South Carolina, the Hanford Reservation in Washington State, and the Rocky Flats Environmental Restoration Site (RFETS) in Colorado. These site offices provide the Board with capability for continuous on-site oversight.

During the Board's 13 years of operation, its priorities have evolved with changes in the nuclear weapons program. The Board uses its Strategic Plan under the Government Performance and Results Act (GPRA) to ensure that its limited resources remain focused on the most significant health and safety challenges, and to keep pace with shifts in those challenges from year to year. The Board's health and safety activities are closely tied to goals and objectives embodied in this plan.

This Annual Report summarizes the Board's work during calendar year 2002. Sections 2, 3, and 4 describe progress in the three major areas of the Board's operations: safe management and stewardship of nuclear weapons, safe disposition of hazardous nuclear materials and facilities, and complex-wide health and safety issues. Section 5 addresses the Board's interactions with the public. Appendices A through F provide additional material: the text of the Board's recommendations (Appendix A), a list of reports requested from DOE (Appendix B), a list of the Board's letters (Appendix C), a summary of administrative activities (Appendix D), a description of the Board's human resources activities (Appendix E), and a list of abbreviations and acronyms used in this report (Appendix F).

1.2 HEALTH AND SAFETY OVERSIGHT STRATEGY

Maintaining an effective safety oversight program that fulfills the broad mandates of the Board's enabling legislation requires a constant reassessment of health and safety conditions throughout DOE's defense nuclear complex. The Board continues to focus its attention on the most hazardous DOE operations and complex-wide health and safety issues, consistent with its strategic plan and the health and safety oversight philosophy described below.

On the basis of 13 years of operating experience, the Board has established the following guiding principles for maximizing the effective use of its resources:

The Board is provided by statute with a number of action-forcing mechanisms to elicit a DOE response to safety problems. Among these mechanisms are recommendations, typically broad and comprehensive in nature; reporting requirements, most often sharply focused on specific safety issues; and public hearings, used to obtain information from DOE, other expert sources, and the public at large on important health and safety issues.

Since 1989 when the Board began operations, 45 formal recommendations, comprising 210 individual sub-recommendations, have been transmitted to the Secretary of Energy. Eighty-nine reporting requirement letters have been sent to DOE requesting specific information on actions that DOE agrees to take to resolve the identified health and safety deficiencies. It is informative, in retrospect, to look at the topics the Board has asked DOE to target for safety improvements. The 45 recommendations and 89 reporting requirement letters fall into the broad categories of human resources (11), safety standards (10), design and construction (13), decommissioning (12), safety management (35), and operational safety (55). A review of these actions shows that in the early years, the Board focused on ensuring that safety standards and DOE's technical competence were adequate, while at the same time trying to ensure that operational safety issues were dealt with expeditiously. Once adequate safety standards were in place, the Board focused more explicitly on DOE's safety management activities, on continuing improvement in conduct of operations, and on ensuring the integration of safety principles into design, construction, and decommissioning activities.

The Board's recommendation authority has been used most fruitfully for gaining DOE response to broad, cross-cutting matters that affect much of the defense nuclear complex. Examples of complex-wide issues include stabilization and remediation of hazardous materials, technical qualifications, criticality safety, and configuration management of vital safety systems. In view of the typical breadth and complexity of the issues addressed by a recommendation, the time required for DOE to develop an implementation plan and carry it to completion is measured in years.

In contrast, a mandatory reporting requirement has been an effective tool in compelling DOE to respond in a more expeditious manner to important safety issues. Comparison of the Board's use of these two methods shows a marked shift beginning in 1994 toward much greater reliance on reporting requirements. Prior to 1995, the Board had issued 31 recommendations and 17 reporting requirement letters. For the 7-year period from 1995 through 2002, the Board issued 14 recommendations and 72 reporting requirement letters. In 2002 alone, the Board sent 22 reporting requirement letters to DOE.

Using both recommendations and reporting requirements, the Board has been able to enhance markedly DOE's integrated safety management program. The health and safety of the public and workers, and protection of the environment, have been improved as a result of the actions taken by DOE in response to the combined 299 sub-recommendations and reporting requirement letters.


1.3 GOALS AND OBJECTIVES OF THE BOARD'S STRATEGIC PLAN

The Board organizes its safety work by merging the broad health and safety mandate of its statute with the requirements of GPRA. The Board's Strategic Plan identifies the serious hazards associated with the handling of nuclear weapons, weapon materials, and cleanup of aging and surplus facilities. These hazards include the following:

The Board's Strategic Plan sets forth its statutory mission, divided logically along the lines established by three general goals:


2. SAFE MANAGEMENT AND STEWARDSHIP OF NUCLEAR WEAPONS
STOCKPILE AND COMPONENTS


2.1 SAFE CONDUCT OF STOCKPILE MANAGEMENT

Stockpile management is the term used to describe the industrial aspects of maintaining the National Nuclear Security Administration's nuclear weapons stockpile and complex. Examples of the Board's activities to improve health and safety in stockpile management are discussed in the following subsections.

2.1.1 Pantex Plant

The Pantex Plant, located near Amarillo, Texas, serves a central role in stockpile management. Operations at the site include the assembly, disassembly, dismantlement, and surveillance of nuclear weapons, (7) as well as interim storage of plutonium removed from retired weapons. In 2002, the Board sought health and safety improvements in weapons operations, fire protection, lightning protection, laboratory support, and storage of special nuclear materials. The Board's pursuit of operational safety improvements at Pantex involved three related areas: development of adequate safety bases, re-engineering of nuclear explosive processes consistent with the Board's Recommendation 98-2, and operators' procedural compliance.

NNSA and its contractors have been working to develop site safety bases compliant with 10 CFR Part 830 by the April 2003 deadline. A key element of the system to protect and maintain these safety bases is the site's Unreviewed Safety Question (USQ) program. Responding to deficiencies pointed out by the Board, NNSA directed the Pantex Plant contractor to revise the USQ process to ensure compliance with the requirements of 10 CFR Part 830.

The Board has closely monitored safety basis development at the Pantex Plant to ensure that hazards are being accurately identified and controls properly classified. In November 2002, the Board noted deficiencies in the classification and reliability of worker safety controls identified in the hazard analysis. To correct these deficiencies, NNSA has agreed to impose alternative controls to protect workers from potential exposures to tritium. Likewise, in a staff report enclosed with an August 2002 letter, the Board challenged the reliability of existing systems reclassified as safety-class or safety-significant. The Board observed that insufficient effort had been made to verify or validate the design adequacy of reclassified systems. In response, the Pantex Plant contractor and the Office of Amarillo Site Operations are developing a policy to evaluate reclassified systems against current design criteria. Where appropriate from a cost-benefit perspective, these backfit evaluations will lead to improvements in the reliability of existing safety systems.

In a letter dated March 25, 2002, the Board emphasized the importance of aggressively addressing inadequate procedural compliance at the Pantex Plant. In response, the Pantex contractor executed an action plan designed to decrease the frequency and significance of events attributed to lack of compliance with procedures. Key corrective actions remain to be completed in 2003, including a procedure upgrade project and implementation of a fully automated material movement system. Observations by the Board's staff and NNSA personnel indicate significant improvement in safety for handling of several weapons programs.

The Board continued to emphasize the need for improved tooling and procedures for work on nuclear explosives by urging DOE to complete the engineering process called Seamless Safety for the 21st Century (SS-21). In December 2002, the Board accepted NNSA's proposed revision to the Implementation Plan for Recommendation 98-2. NNSA has started the SS-21 process for four additional enduring stockpile programs. The wisdom of moving rapidly ahead with SS-21 was illustrated when, in an attempt to perform disassembly and inspection of several W62 warheads, an unexpected bond separation occurred. This event could have been averted had the SS-21 process been fully implemented for this operation. The Board's oversight of NNSA resulted in a more careful and thorough accident analysis by the contractor to ensure safe disassembly of these units. All future units will be disassembled using new SS-21 tooling.

During the last several years, the Board, NNSA, and the Pantex contractor have noted deficiencies at Pantex in the implementation of fire protection controls in the authorization basis, existing fire detection and suppression systems, and the response capability of the Pantex Fire Department. In 2002, NNSA and its contractor undertook to correct many of these deficiencies. The Board also provided additional guidance and insights to further improve fire protection at Pantex in a report forwarded to NNSA in September 2002.

The Board's efforts to improve lightning protection at the Pantex Plant reached a milestone in 2002 when Sandia National Laboratories (SNL) completed low-voltage testing of all selected nuclear facilities as part of the Pantex Plant's Project Plan for Lightning Protection Authorization Basis Post-Start Implementation. Information from this testing is critical for validating the conservatism of voltage estimates that are used to derive safety controls. The evaluation of these critical data will continue into 2003. An August 2002 letter from the Board urged the timely completion of these evaluations to verify the efficacy of lightning protection controls.

The Board continued to press NNSA to make safety improvements in the packaging and storage of special nuclear materials at Pantex. During 2002, NNSA sustained its goal of repackaging an average of 200 pits per month into robust containers with inert internal environments. The Pantex Plant contractor reduced by half the existing surveillance backlog. In a May 2002 letter, the Board outlined the remaining health and safety issues associated with the packaging of pits. (See Recommendation 99-1, Safe Storage of Fissionable Material called "Pits".)


2.1.2 Y-12 National Security Complex

Y-12 is a manufacturing facility located in Oak Ridge, Tennessee. Stockpile management activities at Y-12 include the production, maintenance, refurbishment, dismantlement, evaluation, and storage of certain components of nuclear weapons. Production activities include the manufacture or re-manufacture of unique nuclear weapon components required by the nation's long-term defense capabilities. The Board's most recent efforts to improve safety at Y-12 were concentrated in the areas of preparations for processing of highly enriched uranium, criticality safety, maintenance, nuclear material storage, and fire protection/combustible loading.

In several letters to DOE, the Board highlighted health and safety deficiencies in the management of readiness preparations at Y-12. Based on observations of a contractor operational readiness review (ORR) for the wet chemistry process in Building 9212, the Board found that preparations in the areas of operating procedures, conduct of operations, and training were inadequate. The ORR was suspended. The inability to complete this contractor ORR indicated that the corrective actions taken by the contractor in response to previous letters from the Board on this topic had not been effective. The Board continues to impress upon NNSA that satisfactory preparations prior to the restart of hazardous activities are imperative to ensure the health and safety of workers and the public.

The Board has continued intense oversight of criticality safety practices at Y-12. During 2002, criticality safety violations in Building 9212 gave the Board cause for concern, pointing to a general neglect of some criticality controls in the storage and handling of fissile material. In November, the Board emphasized the need to correct deficiencies in the criticality safety program at Y-12, as well as the associated formality of operations program. The Board urged NNSA to standardize storage conditions, requirements, postings, and containers to further operators' understanding of and compliance with the essentials of criticality safety. In previous correspondence, the Board had urged Y-12 to reduce maintenance backload, establish reliable maintenance schedules, track and reduce equipment unavailability, track maintenance history, and identify maintenance for vital safety equipment. In 2002, Y-12 made some progress in most of these areas, but further efforts are required to demonstrate that the maintenance program has reached nuclear quality and effectiveness.

The Board has expressed significant concern with regard to deteriorating nuclear storage facilities and material disposition activities at Y-12. In 2002, NNSA reduced specific risks in these areas. Particularly noteworthy were actions taken to move non-nuclear material out of inadequate facilities, raze one of these inadequate facilities, and prepare another facility for imminent transfer to the Infrastructure Reduction organization. The Y-12 contractor made substantial progress in reducing the inventory of highly enriched uranium in Building 9206, as well as in developing disposition pathways for unique items currently stored in the warehouse. The Y-12 contractor also began to integrate long-range facility planning with overall storage planning, which will result in a significant upgrade in the future safety posture of the site.

This year, the Board also reviewed NNSA's plans to build a new long-term storage facility at Y-12 for highly enriched uranium, a material critical to the nation's security posture. Many issues were identified in the areas of siting, safety analysis, and disposition and containerization of legacy material. Some issues have been resolved, and others require more action by NNSA and its contractor. (For more details, see Section 4.4.)

Based on the high risk of fire and the grave potential consequences of fire in the wet chemistry area of Building 9212 (B-l Wing), the Board suggested that NNSA consider installation of a fixed fire suppression system to protect the structure and its workers. NNSA has decided to reexamine the process to be used for fire prevention and remediation and to seek alternatives that would reduce fire hazards. In the interim, the contractor has proposed upgrades to the fire protection program to support resumption of operations in this area. These upgrades will include installation of full sprinkler coverage for the long term if the activities in the B-1 Wing are to continue. The Board also found that combustible loading control and general housekeeping in Building 9204-4 were deficient. In response, facility management removed hundreds of cubic meters of combustible waste. Recent walkdowns of the facility revealed measurable improvement, significantly lowering the likelihood of a building-wide fire.


2.1.3 Tritium Production

Tritium, a radioactive isotope of hydrogen, has a relatively short half-life (12.3 years) and must be replaced periodically. The tritium facilities at SRS, located near Aiken, South Carolina, play a vital role in stockpile management: ensuring the nation's capability to replenish certain weapon components with tritium gas and to process and store the gas. In 2002, the Board devoted time and resources to reviewing the design and construction of the Tritium Extraction Facility (TEF) at SRS, currently under construction. This facility will be used to extract tritium from target rods irradiated in commercial light water reactors. The Board reviewed the application of integrated safety management (ISM) to the TEF design to ensure that hazards had been identified and appropriate controls developed. Based on the Board's latest review, TEF operations can be conducted while providing adequate protection of workers, the public, and the environment. (For more information, see Section 4.4.)


2.2 SAFE CONDUCT OF STOCKPILE STEWARDSHIP

Stockpile stewardship is the term used by NNSA to refer to activities, in the absence of underground nuclear weapons testing, carried out to ensure confidence in the safety, security, and reliability of nuclear weapons in the stockpile. Stockpile stewardship includes using past nuclear test data in combination with future non-weapon test data and aggressive application of computer modeling, experimental facilities, and simulations. Safety aspects of activities at the major sites engaged in stockpile stewardship are discussed in the following subsections.


2.2.1 Recommendation 2002-2, Weapons Laboratory Support of the Defense Nuclear Complex

Safe operations in the nuclear weapons complex depend directly upon the technical abilities of the highly skilled scientists and engineers at the nuclear weapons laboratories. These personnel apply their unique expertise to address the health and safety of operations throughout the complex. The information generated at the laboratories is of little use, however, unless it is disseminated effectively to the relevant operations in the complex. Thus, clear lines of communication are vital to ensure that issues raised anywhere in the complex are properly routed to the laboratories for resolution, that timely answers are developed, and that information generated at the laboratories is transmitted successfully for use throughout the complex.

While NNSA has taken some actions to ensure that there is a steady supply of qualified scientists and engineers and that clear lines of communication are maintained, the Board believes additional attention is needed to assure health and safety. In Recommendation 2002-2, the Board recommended that the Secretary of Energy reemphasize the priority of the nuclear weapons program at the nuclear weapons laboratories. The Board recommended that each nuclear weapon system in the stockpile have a senior, technically competent expert serving as the single point of contact responsible for that system at the cognizant laboratory.

This single point of contact should have the ability to ensure that emergent health and safety issues are tracked, prioritized, and resolved in a timely manner. Technical qualifications should be of the highest caliber, and a commensurate qualification and development program should be established to ensure the availability of personnel to fill these positions. The Board recommended that NNSA, as the integrator of the activities in the defense nuclear complex, also establish a point of contact within its laboratory site offices to ensure that requests for laboratory support are being met in a timely fashion and to resolve resource conflicts. (8)


2.2.2 Los Alamos National Laboratory

Los Alamos National Laboratory, located in New Mexico, is the NNSA weapons laboratory with the largest number of defense nuclear facilities and weapon-related activities. Site personnel are heavily involved in ongoing research and development on means for certifying the safety and reliability of nuclear weapons in the absence of nuclear testing. At present, LANL is the planned location of NNSA's limited-scale manufacturing capability for replacement pits for existing nuclear weapons. In 2002, the Board focused its attention on the effort to start up the Plutonium-238 (238Pu) Scrap Recovery Line, development of adequate documented safety analyses for selected facilities, quality assurance, lightning protection, construction of the new emergency operations center, fire protection, and formality of operations.

LANL is completing construction of a new aqueous processing line for recovery of scrap 238Pu. This new recovery line will be the only source of purified 238Pu for at least the next decade. The Board found significant deficiencies in the safety basis and the proposed implementation of safety controls associated with the line. LANL personnel have been working with the Board to develop a more rigorous safety basis. A new process hazards analysis has been performed, and new, more robust controls have been proposed to NNSA. The revised safety basis documentation is currently under review by contractor management prior to submission to NNSA for approval.

LANL's development of documented safety analyses complying with the requirements of 10 CFR Part 830 has led to the identification of new safety-class and safety-significant structures, systems, and components (SSCs), as well as the reclassification of some existing SSCs. However, LANL has not demonstrated that systems reclassified as safety-class or safety-significant equipment are designed adequately. The Board was briefed by NNSA personnel on this issue in November 2002, and expects that in 2003 LANL will remedy the situation with the Board's oversight.

For new projects at LANL, the Board has observed a need for early identification of candidate safety-related SSCs to preserve design flexibility as the coupled design and safety processes mature. This need is especially great with respect to the 238Pu Scrap Recovery Line and the DynEx Project. The Board also found deficiencies in the Safety Analysis Report developed by LANL for the Weapons Engineering Tritium Facility, and suggested ways to improve tritium containment. In response, NNSA has limited the amount of material approved for use in facility operations, and has demanded improvements in the tritium containment strategy.

In 2002, the Board continued to urge NNSA and the LANL contractor to improve the quality assurance program across the site. Institutional plans were still in development, and the Board found that several LANL divisions and projects for which quality programs needed to be in place sooner were proceeding with their own programs independent of the institutional effort. These disparate efforts were at cross-purposes in several cases. As a result of the Board's intervention, NNSA is now coordinating the improvement of quality assurance programs at LANL.

In August, the Board noted that, although the lightning protection system at the Weapons Engineering Tritium Facility had been designated as safety-class (important for the protection of the public), a rooftop review had identified numerous physical deficiencies in system components. The LANL contractor took immediate action to correct these deficiencies, and changed its safety controls to minimize the possibility of recurrence. The Board also found deficiencies in LANL's lightning warning and detection systems, and is closely monitoring improvements being made in these systems.

LANL is constructing a new Emergency Operations Center (EOC), located such that the prevailing winds would carry plumes from most postulated accidents away from the EOC. The location, however, is in the deformation zone associated with a seismically active fault. The initial design considered the new EOC in isolation, rather than as part of a system of EOCs that would include an older EOC and a mobile command center under consideration. The Board suggested that LANL adopt a systems approach to address the possible lack of functionality of the new EOC under severe seismic conditions. Moreover, the Board suggested that LANL consider the new EOC to be part of a system of EOCs that includes an older EOC and a mobile command center. NNSA and LANL have taken this approach and expect procurement of a mobile command center to be completed by September 2003. The new EOC is expected to be completed by then.

In January 2002, LANL experienced an uncontrolled energetic reaction in a non-nuclear laboratory, due in part to a lack of disciplined operations. An investigation by LANL personnel identified weaknesses in safe work practices as a cause. At LANL, documented safe work practices are the mechanism for incorporating ISM into program work for both nuclear and non-nuclear facilities. The Board has concluded that the lessons learned from this event may have laboratory-wide implications on work control, formality of operations, and safe work practices; LANL is currently evaluating these implications, and has committed to improving formality of operations in facility and program work.

As a result of the Board's Recommendation 2000-2, NNSA and LANL assessed fire protection and alarm systems in several nuclear facilities at LANL. In May 2002, these assessments led LANL to determine that institutional and facility-level issues exist with regard to inspection, testing, and maintenance of fire protection systems. LANL has developed and is executing a corrective action plan. The Board has also questioned the hydraulic adequacy of the fire suppression system at the Plutonium Facility known as Technical Area-55 (TA-55). NNSA and LANL plan to address this potential safety issue as part of the improved TA-55 Documented Safety Analysis, to be completed in 2003.

2.2.3 Lawrence Livermore National Laboratory

Lawrence Livermore National Laboratory (LLNL), located 45 miles southeast of San Francisco, California, is a nuclear weapons research and development laboratory. It provides technical expertise to support stockpile stewardship and management, including consultation on the surveillance and dismantlement of LLNL-developed nuclear weapons. Most defense nuclear activities are conducted in the Superblock complex, which includes the Building 332 Plutonium Facility and the Tritium Facility.

During 2002, the Board increased the scope and frequency of its health and safety reviews at LLNL. On September 26, 2002, the Board held a public hearing in Livermore, California. The Board focused its efforts on LLNL's support for Pantex Operations (see Section 2.2.1 above), the safety-class emergency power system (EPS) in the Plutonium Facility (Building 332), the deactivation of the Heavy Element Facility (Building 251), and the Decontamination and Waste Treatment Facility (DWTF) complex.

The Board found deficiencies in the EPS of Building 332 that threatened the reliability and efficacy of power-dependent hazard controls. In response, the LLNL contractor developed a set of compensatory measures and design modifications to address the identified deficiencies and foster an enhanced understanding of EPS vulnerabilities. EPS reliability has been enhanced, and should meet commercial standards upon completion of the corrective actions currently in progress.

The Board reviewed LLNL's plans for the deactivation of the Heavy Element Facility (Building 251). In addition to the decontamination and removal of 48 gloveboxes and contaminated systems, this effort involves the removal of nearly 300 items of radioactive material, some posing a significant risk of external radiation exposure to workers and the release of contamination in the building. The project is being pursued on an accelerated schedule to achieve near-term risk reduction and avoid costly safety basis upgrades. The Board found that planning for the project was being approached piecemeal, rather than in a systematic and integrated manner. In a March 2002 letter, the Board stated that the use of comprehensive planning methods, such as those contained in DOE Order 430.1A, Life Cycle Asset Management, was warranted. The use of an integrated and systematic planning approach results in safety and efficiency improvements by better identifying hazards and necessary controls, improving the sequencing of tasks, and identifying repetitive tasks that could be standardized. The LLNL contractor has now adopted this approach.

LLNL intends to centralize transuranic (TRU) waste processing and storage operations within the DWTF area. Building 696R is a new facility within the DWTF complex that will be used to store much of the TRU waste presently stored in a tent and in Building 332. Operations in Building 696R began in October 2002. Moving TRU waste from less desirable storage locations to Building 696R will reduce the health and safety risks. Ultimately, however, the Board believes that the only way to truly reduce the risk associated with storing TRU waste at LLNL is to ship the waste to an approved disposal site. The Board is currently evaluating health and safety issues affecting the transfer of TRU waste from LLNL.


2.2.4 Nevada Test Site

The Nevada Test Site (NTS) is located in southern Nevada, about 75 miles northwest of Las Vegas. Stockpile activities at NTS include test readiness preparations, disposition of damaged nuclear weapons, and subcritical experiments. Underground testing of nuclear weapons is no longer being conducted at NTS. However, NTS is maintained in a state of readiness should national security requirements demand the resumption of underground testing. The Board seeks to ensure that if testing is resumed, it would be done safely. During 2002, the Board focused its attention on NTS's test readiness posture, capability to dispose of a damaged nuclear weapon, subcritical experiments, and TRU waste operations.

During its 2002 review of NTS's current test readiness posture, the Board found weaknesses that could affect NNSA's ability to conduct safely an underground nuclear weapons test. The number of personnel uniquely qualified to plan and conduct underground nuclear weapons tests was shrinking. There was no formal safety basis for an underground nuclear weapons test, nor was there a rigorous process to assess the safety of such a test. Subsequently, NNSA developed a plan to prepare a safety basis, address the loss of uniquely qualified personnel, improve the state of readiness of facilities and equipment, and develop a readiness review process compliant with NNSA requirements for nuclear and nuclear explosive operations.

The Board continued to highlight the need to develop the programs and infrastructure necessary at NTS to safely dispose of a damaged nuclear weapon or improvised nuclear device. During 2002, the Board reviewed infrastructure improvements, procedures, and exercises designed to train personnel and develop standards of practice. NNSA continued to make physical improvements to G-Tunnel, and conducted an extensive exercise to practice the full scope of disposition activities at NTS and identify further issues to be addressed. The Board pointed out that there was still no safety basis for these nuclear explosive and nuclear operations, and that the work planning, review and approval processes and the conduct of operations were not sufficiently rigorous for nuclear explosive and nuclear operations. To improve this disposition capability in 2003, NNSA plans to develop a safety basis, address organizational issues, improve the condition of G-Tunnel, and conduct several training activities.

After reviewing the Joint Actinide Shock Physics Experimental Research subcritical experiments at NTS, the Board concluded that the quantity of nuclear material in the targets would exceed the threshold values for a Hazard Category 3 nuclear facility. (9) However, NTS personnel had not developed safety controls appropriate for this level of hazard. As a result of a July 2001 letter from the Board, a visit by the Board to NTS in April 2002, and numerous other communications, the contractor designed controls adequate for the safety of this operation. NNSA is now assessing and improving the adequacy of the controls and configuration management prior to the start of the next series of experiments. The Board has found that NNSA's assessment process is adequately rigorous.

NNSA conducts Hazard Category 2 storage and Hazard Category 3 examination and repackaging of TRU waste at NTS. In a March 2002 letter, the Board informed NNSA that controls from the Safety Analysis Report and Technical Safety Requirements had not been incorporated adequately into facility operating and surveillance procedures. Further, the Board has found that NTS's support programs (such as maintenance, training, and qualification) are not adequate to support Hazard Category 3 nuclear facility operations. As a result, NNSA has added nuclear facility requirements to the contract with its primary contractor, improved the capability of the Nevada Operations Office to manage and assess nuclear facility operations at NTS, initiated a complete revision of the documented safety analysis of all waste activities at NTS, and encouraged the primary contractor to improve its capability to manage and operate nuclear facilities.


2.2.5 Sandia National Laboratories

SNL, which manages research and development installations at several DOE sites, including Albuquerque, New Mexico, and Livermore, California, has significant responsibility for the conduct of engineering research on nuclear weapon systems and components. SNL's major defense nuclear facilities, most of which are located in TA-V at the New Mexico site, include the Annular Core Research Reactor, the Hot Cell Facility, the Gamma Irradiation Facility, and the Sandia Pulse Reactor Facility.

In 2001, the Board had reviewed preliminary plans for the Sandia Underground Reactor Facility project and found health and safety deficiencies in the protection of workers exposed to radiological and industrial hazards. Some of these problems stemmed from the below-ground location of the facility. NNSA committed to correct the deficiencies before approving the preliminary safety analysis. On November 12, 2002, however, NNSA canceled the project.


3. SAFE DISPOSITION OF HAZARDOUS REMNANTS OF WEAPONS PRODUCTION


3.1 STABILIZATION AND STORAGE OF REMNANT MATERIALS

3.1.1 Complex-Wide Program

In Recommendations 94-1, 96-1, 97-1, 2000-1, and 2001-1, the Board urged DOE to assess and take action on legacy nuclear materials remaining in defense nuclear facilities. Implementation of these recommendations has resulted in significant risk reduction. A large portion of the plutonium solutions and residues, special isotopes, and irradiated fuel and targets has been stabilized and placed into safe storage. In a major step forward, DOE began removing deteriorating spent nuclear fuel from the K-East Basin at Hanford after many years of preparation. However, significant hazards remain, some key stabilization activities have been delayed, and technical and programmatic difficulties threaten to cause further delays in risk reduction. The Board has continued to encourage DOE to promptly stabilize the materials and place them in a safe configuration for storage pending programmatic use or disposition.

The Board believes that DOE has established reasonable disposition paths and plans for most of the materials addressed by the Board's recommendations. However, the disposition of some materials remains problematic. For example, the schedule for addressing legacy plutonium materials at LANL continues to be delayed beyond the time the Board considers acceptable. Many of these items have not been opened for inspection for an extended period--more than 20 years in some cases. Likewise, the plan for stabilizing neptunium solutions at SRS is still uncertain.

The Board has begun to evaluate other materials in addition to those addressed by its existing recommendations that may require timely stabilization and disposition to prevent new hazards from developing. The Board has determined that NNSA is managing a substantial inventory of nuclear materials without identified programmatic uses. To avoid problems such as those prompting the issuance of the Board's previous recommendations, DOE must undertake a comprehensive evaluation of this inventory; stabilize materials and improve storage conditions; and improve life-cycle planning.

In addition to pressing for progress in reducing the risk posed by legacy nuclear materials, the Board has continued to assess the safety and adequacy of stabilization activities. In 2002, the Board conducted assessments of stabilization and disposition at LANL, Hanford, SRS, and RFETS. The Board evaluated the implementation of health and safety requirements in accordance with applicable standards (e.g., DOE-STD-3013, Stabilization, Packaging, and Storage of Plutonium-Bearing Materials), as well as safe startup of certain stabilization activities. The Board has paid particular attention to DOE's progress in providing a reliable methodology to verify that plutonium oxides are adequately stabilized prior to packaging for long-term storage. During the past year, the Board found inadequacies with stabilization activities and plans at Hanford, RFETS, and LANL.

The Board has closely evaluated DOE's management of SRS's nuclear chemical separation facilities, F-Canyon and H-Canyon. These facilities provide unique processing capabilities and have played a central role in DOE's nuclear materials stabilization program. In March 2002, the Board issued DNFSB/TECH-32, Savannah River Site Canyon Utilization, emphasizing the role of the F-Canyon facility in safely stabilizing nuclear materials, and suggesting the continued operation of both canyon facilities to ensure the timely completion of this mission. However, DOE has decided to halt chemical separation operations in F-Canyon, citing the need for cost savings, and has begun to deactivate the facility.

As a result of the suspension of F-Canyon operations, all materials that might have been processed in F-Canyon must now be processed in H-Canyon or disposed of by some other means. In a letter to DOE dated November 8, 2002, the Board asserted that DOE had not met the statutory requirements of Section 3137 of the National Defense Authorization Act for Fiscal Year 2001 (Public Law 106-398). The Board suggested that DOE identify clear and achievable disposition paths for materials present in F-Canyon and define how future requirements for disposition of fissile materials could be met without F-Canyon. The Board will continue its efforts to ensure that DOE's facility utilization decisions are based upon a sound evaluation of its processing needs.

3.1.2 Plutonium

In response to the Board's Recommendations 94-1 and 2000-1, DOE committed to stabilize and package its legacy plutonium materials. During the past year, DOE made significant progress:

Establishing the capability to stabilize and package plutonium-bearing materials to meet the requirements of DOE-STD-3013 is a key element of the implementation of these recommendations. RFETS, Hanford, and LLNL have established this capability, and SRS has made significant progress. The Board has evaluated initial steps to establish the necessary capabilities at SRS, and questioned DOE's plan to allow the contractor to commence stabilization operations next year with no independent readiness assessment by DOE. The Board raised this issue with DOE, which now plans to perform an independent readiness assessment of the activity.

As the sites continue to stabilize and package plutonium-bearing materials, the Board evaluates these activities to ensure that they are safe and effective. The Board identified deficiencies in the processing at RFETS and Hanford that had complex-wide implications regarding approved methods for measuring moisture and other volatile substances in stabilized plutonium oxides. Such measurements are essential to ensure that the stabilization process results in a product that can be kept safely in a sealed container during long-term storage. The Board pointed out deficiencies in DOE's technical basis for authorizing the measurement methods now being used. As a result, DOE has revised the technical basis and in doing so has greatly enhanced its understanding of moisture measurement methods.

The Board questioned Hanford's plans for meeting a requirement of DOE-STD-3013 by setting aside representative samples of packaged materials as part of a long-term surveillance program for long-term storage. As a result of actions by the Board, DOE is independently evaluating the materials at Hanford and has initiated actions to provide guidance for the complex on how to satisfy this important requirement. Also at Hanford, the Board called into question the safety of the polycube stabilization process, which was experiencing regular shutdowns because of clogged off-gas filters. DOE responded by installing new equipment and modifying the stabilization process until the plugging can be eliminated.

At SRS, DOE and its contractor resumed the plutonium solution stabilization process in the HB-Line facility. The Board performed an extensive review of the HB-Line restart in late 2001, making several suggestions for improving the safety of that operation, and performed follow-up reviews during 2002. The contractor made improvements in the areas of fire protection and chemical processes, and strengthened administrative controls for hazards in the facility.

The Board reviewed the SRS H-Canyon ventilation system--a safety system important to the protection of workers and the public. This system has experienced degradation in the past and has not been repaired. In a letter to DOE dated June 26, 2002, the Board stressed the need for DOE to take more aggressive action to correct deficiencies in the ventilation system. DOE is now planning to make the needed repairs.

The Board reviewed the technical basis for stabilizing impure plutonium oxide materials at RFETS. The Board concluded that DOE's technical evaluation was flawed, and that DOE had not identified adequate controls to prevent a deflagration or explosion in the stabilization furnace. Following briefings provided to the Board, DOE implemented modifications to the stabilization furnaces and associated process parameters to ensure that these materials could be safely stabilized.

The Board has continued to review and evaluate changes to DOE's long-term plutonium storage standard, DOE-STD-3013, to ensure that material is safely stabilized and packaged. This past year, DOE proposed reducing the stabilization temperature for chloride-bearing plutonium oxides at RFETS. This change was requested by RFETS to reduce the likelihood of corrosion in the process equipment. The Board noted deficiencies in the technical basis for this change. As a result, DOE agreed to approve this change only for a subset of purer, better-characterized materials, and to continue to verify adequate stabilization using the existing requirements of the standard.


3.1.3 Uranium

Highly Enriched Uranium. DOE has entered an agreement with the Tennessee Valley Authority to supply low-enriched uranium from the DOE complex to make commercial nuclear fuel. DOE is readying facilities in the H-Area of SRS to purify highly enriched uranium solution, blend it down to low enrichment, and ship it to a vendor for fabrication into fuel. The Board conducted several on-site reviews of this activity and found inadequacies in work processes and criticality safety. DOE is working to correct these inadequacies. The Board continues to monitor DOE's efforts to commence blending and shipping operations in 2003.

Uranium-233. Uranium-233 (233U) is a man-made radioisotope that contains uranium-232 (232U) as an unavoidable contaminant; products of the decay of 232U are highly radioactive. Most of the 233U not in the form of fabricated fuel materials is stored at Oak Ridge National Laboratory (ORNL). In Recommendation 97-1, the Board urged DOE to characterize, stabilize, and ensure safe storage of its 233U materials expeditiously, because there was significant uncertainty about the safety of storage conditions. During 2002, DOE made considerable progress in the 233U inspection program at ORNL. Forty containers representing about 75 percent of the types of containers stored at ORNL were successfully inspected. The containers were in good condition, except for one package containing an unexpected corrosive material. ORNL transferred that container to a hot cell and stabilized and repackaged its contents.

DOE is also storing sodium fluoride (NaF) traps that contain 233U in the form of uranium hexafluoride in Building 3019A at ORNL. These containers require remediation because they are becoming pressurized with fluorine gas produced by radiolysis of the uranium hexafluoride. On September 23, 2002, the Board issued a letter questioning DOE's program for dealing with these traps. In response to the Board's letter, DOE agreed to measure the pressure in several NaF traps and to depressurize them. DOE will use the results of this activity to develop plans for depressurizing the remaining NaF traps and disposing of the 233U.

Depleted Uranium. More than 22,000 metric tons of depleted uranium is stored at SRS. The Board reviewed storage conditions for the material, as well as DOE and contractor guidance for its packaging, storage, and inspection. The Board also reviewed DOE's disposition plans for these materials. In a letter dated March 7, 2002, the Board criticized improper storage conditions, weaknesses in hazard analyses, inadequate inspection of containers, and an overall lack of a disposition plan for depleted uranium. The Board noted that most of the depleted uranium had been in storage for an extended period and that the storage conditions were worsening with time. In response to the Board's letter, DOE and its contractor took short-term corrective actions and committed to the development of a long-term disposition strategy. DOE intends to dispose immediately of the material housed in the worst storage conditions, and to conduct a feasibility study to evaluate disposal of the remaining materials by fiscal year 2006.


3.1.4 Special Isotopes

Several thousand gallons of solution containing americium and curium (Am/Cm) stored in the SRS F-Canyon is being prepared for disposal in the SRS high-level waste tanks. The Board's review of the disposition plan uncovered several weaknesses that DOE is attempting to correct. Improvements DOE has agreed to implement include verifying the functionality of safety equipment prior to the transfer, modifying response times to radiation alarms to minimize potential worker exposure, implementing additional controls to preclude plugging the F-Canyon waste header through which the transfer will be made, and performing additional cold runs to demonstrate the viability of the transfer path.

As part of the Am/Cm disposal discussions, the Board expressed concern over the fate of Mark 18A targets stored in a spent fuel basin at SRS. These targets contain significant quantities of irreplaceable isotopes, and the Board has requested that DOE develop a firm path forward for the storage, processing, and recovery of these materials.


3.1.5 Inactive NNSA Nuclear Materials

The Board reviewed the packaging, storage, and disposition plans for inactive nuclear materials at LANL and LLNL. The Board found that NNSA has not been managing effectively its growing backlog of nuclear materials that have no identified programmatic application. Many of these materials lack adequate physical, chemical, or radiological characterization, and packaging of some items is inappropriate for extended storage.

The Board believes action is needed to improve the management of NNSA's inventory of inactive nuclear materials. In a letter dated May 20, 2002, the Board requested that NNSA examine the issues and outline measures to be taken to improve the safe management of these materials. NNSA's response of September 24, 2002, was not entirely satisfactory, but did acknowledge that improvement in the management of nuclear materials is needed and that the issues identified in the Board's letter will be addressed. The response identified the strategy by which NNSA will deal further with these issues, including the recent establishment of an Inactive Actinides Working Group to address inactive actinide issues. The Board will continue to press for improvements in this area.


3.2 STABILIZATION OF SPENT NUCLEAR FUEL


3.2.1 Hanford Spent Nuclear Fuel Project

The Board continued to perform comprehensive reviews of the Hanford Spent Nuclear Fuel Project (SNFP), which is presently retrieving deteriorating spent nuclear fuel from the K-East and K-West Basins, cleaning and drying the fuel, and packaging it for eventual repository disposal. The Board reviewed ongoing operations, as well as the design and installation of the remaining equipment needed to accomplish the project.

This year, DOE completed installation of the Fuel Transfer System (FTS) that transfers fuel from the K-East to the K-West Basin for cleaning and packaging. The Board's review of this system called into question the hoisting and rigging methods to be used for the fuel transfer cask. As a result, DOE modified the design of the equipment to limit the distance a dropped container could fall, and thus reduce the potential for a release of sludge and water from the cask in the event of a drop. The Board also found weaknesses in the contamination control strategy for the fuel casks, leading DOE to implement improved controls.

The Board expended considerable effort in ensuring that DOE will adequately achieve and confirm the readiness of SNFP processes to operate safely. In 2001, operations at T-Plant--from which spent fuel was to be removed to make room for interim storage of sludge from the K-Basins--failed the DOE ORR, despite having passed the contractor ORR. The contractor resisted performing another ORR, but the Board persuaded DOE to require one. The facility failed this ORR as well. After corrective actions were taken to shore up both the contractor's readiness determination process and DOE line management's verification process, the facility passed both ORRs.

The Board evaluated the implementation of these corrective actions during the contractor's and DOE's ORRs for the K-Basin FTS. Again, the contractor failed to achieve an adequate level of readiness prior to beginning its ORR; however, DOE's line management review team appropriately assessed the level of readiness and ensured that corrective actions were complete prior to initiating the DOE ORR. These activities culminated in the start of fuel removal from the K-East Basin on November, 26, 2002, a major accomplishment that has been many years in the making. However, DOE failed to meet the commitments made in its Implementation Plan for Recommendation 94-1 to begin containerization of sludge in the K-East Basin in November 2002 and to initiate sludge removal from the basin in December 2002, primarily as a result of continued deficiencies in project management.

The Board also continued to study the poor equipment performance hindering the removal of fuel from K-West Basin. The Board found that the major causes of low reliability were inadequate conduct of operations, maintenance, and engineering evaluation of equipment failures. Efforts by the contractor to deal with these weaknesses led to substantially improved production rates, recovering several months of production schedule.

The fuel from the K-Basins is packaged into mechanically sealed multi-canister overpacks (MCOs). The MCOs were to be welded shut, but DOE allowed the contractor to delay this operation to apply more resources to preparations for fuel retrieval and processing. The primary mechanical seals on several MCOs failed leak checks immediately following closure, leading the Board to challenge the adequacy of the MCO sealing process. In a letter dated February 15, 2002, the Board urged DOE to expedite preparations to weld closure caps on the MCOs as originally planned. As a result, the contractor improved the mechanical sealing process and is now completing preparations for welding operations.


3.2.2 Savannah River Site

In December 2001, DOE decided to suspend preparations to start up the L-Area Experimental Facility and cease pursuit of the planned full-scale facility to treat aluminum spent nuclear fuel for disposal. Since suspension of this activity, the Board has monitored DOE's efforts to consolidate spent nuclear fuel at SRS by transferring all fuel from the Receiving Basin for Offsite Fuel and the K-Reactor Basin to the L-Basin. The Board has expressed concern regarding the lack of a clear disposition path for the spent nuclear fuel at SRS, most recently in a letter to DOE on November 8, 2002, and will continue to press DOE on this matter.


3.3 WASTE MANAGEMENT

3.3.1 High-Level Waste

Tank Integrity. The Board has continued to press DOE to improve programs that protect and verify the integrity of the high-level waste (HLW) storage tanks at Hanford and SRS, particularly the double-shell tanks that must continue to provide reliable service for many years to come. Significant improvements in tank integrity programs have resulted, particularly at Hanford, including improved waste chemistry controls, addition of corrosion inhibitors to several tanks, development of improved capabilities for tank wall inspections, and progress toward implementation of more rigorous requirements to ventilate the tank annulus so as to help prevent corrosion of the primary tank wall. The Board has continued to urge DOE to address leak-tightness as well as gross structural integrity in its tank integrity program, and to thoroughly evaluate evidence that tank walls above the waste may be susceptible to corrosion despite the presence of corrosion inhibitors in the waste.

As part of its implementation of the Board's Recommendation 2001-1, DOE revised its in-service inspection program for the SRS HLW tanks. Based on guidance provided by the Board in a letter dated June 11, 2002, DOE modified the program to require ultrasonic inspection of all the double-shell tanks at SRS, instead of just a subset, and to inspect tanks early in the program if they are potentially at greater risk of corrosion. The Board continues to pursue acceleration of DOE's proposed 9-year schedule for inspecting all the double-shell tanks.

Accelerated HLW Cleanup at SRS. The Board reviewed the accelerated HLW cleanup initiative at SRS. As part of this initiative, DOE is exploring approaches to accelerate disposal of saltcake from the HLW tanks. DOE is pursuing disposal of dissolved saltcake on site as saltstone, with limited or no processing to remove radionuclides. This approach may increase the radioactivity in the saltstone beyond current permit limits, but is not expected to present a hazard to the public. However, the existing Saltstone Production Facility at SRS is not designed for the radiation levels expected from processing untreated saltcake, and the Board is closely evaluating the associated hazards for workers. DOE is presently analyzing the modifications necessary to protect workers from the increased radiological hazard.

The SRS contractor performed a "waste incidental to reprocessing" determination in accordance with DOE Order 435.1, Radioactive Waste Management, to demonstrate that the dissolved saltcake represents no greater risk than that posed by traditionally defined low-level waste. In a letter to DOE dated June 27, 2002, the Board suggested improvements in the methodology and assumptions used in this analysis. The choice of method is complicated by a pending court case challenging DOE's determination. Recognizing these uncertainties, the Board has encouraged DOE to pursue development and demonstration of alternative methods of waste treatment, especially for cesium removal.

As a result of the selection of caustic-side solvent extraction (CSSX) as the baseline technology for salt solution processing and the extensive research performed on benzene generation in the In-Tank Precipitation (ITP) process, the Board closed Recommendation 96-1, In-Tank Precipitation System at the Savannah River Site, this year. However, the former ITP precipitation tank still contains significant quantities of tetraphenylborate from early tests of the ITP process, and CSSX will not be capable of treating this waste. The Board has stressed the need for DOE to remediate this tank, preferably using a technology that could also treat wastes from other HLW tanks.

Safety Analysis of SRS Tank Farms. To comply with 10 CFR Part 830, the SRS contractor prepared a Documented Safety Analysis (DSA) for the HLW tank farms and associated facilities. Although the hazard and accident analyses reported in the DSA are the most comprehensive performed to date for the tank farms, the Board detected several deficiencies and informed DOE of its findings in a letter dated November 4, 2002. The Board found that, contrary to applicable DOE directives, analyses of unmitigated consequences had not been performed for several accidents, and certain key input values and assumptions had not been shown to be conservative. Analyses of unmitigated consequences are needed to allow the proper selection of safety-class and safety-significant controls to adequately protect members of the public and site workers. In response, the SRS contractor performed additional sensitivity calculations and added specific administrative controls in the Technical Safety Requirements to ensure the continued validity of key input values and assumptions used in the accident analyses.

Hanford Tank Farms. The Board continued to perform extensive reviews of the health and safety of ongoing and planned operations at the Hanford HLW tank farms. The Board has also tracked the development of an upgraded safety basis and preparations to provide feed for the planned Waste Treatment Plant (WTP).

Saltwell Pumping--The readiness assessment (RA) for starting saltwell pumping at Tank U-111 at Hanford was suspended after the Board questioned the preparedness of the RA team members and the depth and breadth of the review. The RA resumed after these issues had been addressed.

Common Cause Analysis for Electrical Safety--The Board highlighted several cases in which work had been performed on energized systems without proper authorization and appropriate controls. Subsequently, DOE's tank farms contractor performed a common cause analysis for 27 events involving electrical hazards. As a result of this analysis, the contractor initiated a number of corrective actions and communicated lessons learned to its workforce.

Transfer Line Failure--In January 2002, HLW being transferred through a temporary hose-in-hose transfer line leaked from the primary hose into the secondary hose. The Board suggested that the leak might have been caused by water flushes using operating parameters more severe than those used during qualification testing. As a result, the contractor changed the test specifications for this type of hose and performed field proof tests before resuming operations of another existing hose. DOE plans to inspect the failed hose, as suggested by the Board, to determine its failure mechanism.

Waste Feed Delivery--The Hanford Waste Feed Delivery transfer system will deliver the first phase of HLW slurries from the tank farms to WTP. The Board reviewed the design of this safety-class system, and issued letters to DOE in May 2001 and September 2002, identifying flaws in the characterization of the physical properties of the waste and functional design requirements for the system, particularly the minimum design pressure rating. DOE performed additional waste characterization and system modeling, and convened an expert panel in October 2002. The panel assessed the adequacy of physical property data and the waste transfer analytical model, and provided recommendations for a path forward.

Tank Farms Safety Basis--The Board assessed modifications to the existing safety basis for the HLW tank farms and reviewed a new DSA written to comply with 10 CFR Part 830. The Board concluded that DOE's guidance to the contractor imposed an excessively high consequence threshold for implementing safety-significant controls for worker protection. Following a briefing provided to the Board, DOE sent a letter to the contractor altering the risk classification criteria in the safety basis document and the guidelines for selecting controls for the tank farms.

3.3.2 Low-Level and Transuranic Waste

Waste Isolation Pilot Plant. During 2002, the pace of operations at WIPP increased significantly. More than 900 shipments totaling more than 29,000 drum equivalents of TRU waste were received and disposed of underground. The Board continued its oversight of these operations to ensure that they proceeded safely at the dramatically increased rate. To that end, the Board evaluated an August 2002 dry run of newly installed systems and equipment to be used for future disposal of remote-handled TRU waste at WIPP. The Board found the equipment, systems, and procedures to be satisfactory overall; however, several areas for improvement were identified.

Idaho National Engineering and Environmental Laboratory. The Board reviewed waste disposal activities at the Idaho National Engineering and Environmental Laboratory (INEEL) including both TRU waste characterization and loading of drums in shipping containers for shipment to WIPP. These reviews focused on the implementation of ISM to improve worker health and safety for these activities, and contributed to the successful completion of the project to ship the first 3,100 cubic meters of TRU from INEEL to WIPP.

The Board reviewed the design and construction of the Advanced Mixed Waste Treatment Project at INEEL, which will retrieve and process 65,000 cubic meters of TRU waste for shipment to WIPP. Since the 1970s, the drums stacked five-high have been stored in the TRU Waste Storage Area Retrieval Facility, on an asphalt pad, beneath an earthen berm, under a recently-erected weather enclosure. The contractor has been slow to address the potential plutonium inhalation hazard to workers handling aging and corroded drums that may fail or be damaged during retrieval. Based upon briefings provided to the Board in December 2002, it appears that the contractor has acknowledged this hazard and is working to identify appropriate controls.

Melton Valley Transuranic Waste Treatment Project. The Melton Valley Transuranic Waste Treatment Project at ORNL will process liquid and solid TRU waste and low-level radioactive waste for off-site disposal. Due to the high activity of substantial portions of the TRU and low-level wastes to be processed by this facility and the potential hazards for workers, the Board scrutinized the facility design process and the preparation of the facility's DSA. In 2002, an acceptable final design for the project was completed and the facility constructed. The Board will provide health and safety oversight of the startup of liquid processing in early 2003.

Hanford Central Waste Complex. Assessments conducted at Hanford in response to Recommendation 2000-2 resulted in the finding that dry pipe fire protection systems had not been inspected in accordance with National Fire Protection Association standards. These inspections were subsequently performed and revealed significant quantities of debris obstructing fire protection systems in the Central Waste Complex. These systems have been cleaned and restored to operability.


3.4 FACILITY DEACTIVATION AND DECOMMISSIONING

3.4.1 Safe Practices for Deactivation and Decommissioning

On March 19, 2002, the Board sent DOE a letter noting recent occurrences during deactivation and decommissioning that illustrated the health and safety hazards associated with cutting radioactively contaminated equipment using saws, cutting torches, and other tools. The Board pointed out that preventable mishaps, such as fires and lacerations, continue to occur despite DOE guidance on how such work can be performed safely. The Board suggested that a compendium of good practices would assist in the safe performance of such activities. More specific and detailed information would help support work planning, preclude duplication of effort, and minimize the repetition of errors.


3.4.2 Y-12 National Security Complex

The Board has persisted in urging DOE to reduce the hazardous materials inventory in Building 9206 at Y-12. These materials represent one of the most serious legacy health and safety issues at this site. In 2002, stabilization of pyrophoric materials was successfully completed, and the pyrophoric uranium compounds were processed and shipped out of the facility. Progress also continues to be made in reducing the inventory of containerized highly enriched uranium solids. The Board will continue to press DOE to expeditiously pursue risk reduction and deactivation in Building 9206.


3.4.3 Rocky Flats Environmental Technology Site

Facility decommissioning constitutes most of the high-hazard nuclear operations at RFETS. (10) Sound activity-level work planning and effective DOE oversight of contractor work planning have particular importance for the safety of decommissioning at the site. However, the Board's review of several occurrences at RFETS revealed deficiencies in activity-level hazard analyses, as well as failures to identify controls for work being performed. The Board's review also revealed that DOE had not been systematically reviewing activity-level work planning by the RFETS contractor. In March 2002, the Board issued a letter to DOE requesting that corrective actions be taken. In response, DOE committed to improving activity-level work planning and oversight, including mentoring of work planning teams and regular assessments of work planning. RFETS has implemented the actions, and the Board is examining their effectiveness.

In February 2002, the Board reviewed radiological work practices for decommissioning at RFETS. In response to the observations provided during this review, RFETS has increased monitoring of airborne radioactivity, improved requirements and guidance for air flow testing following reconfiguration of room areas, and improved requirements and guidance for hand protection against cuts and punctures that could cause injection of radiological material.

Lack of proper safety management and conduct of operations had been evident in occurrences involving subcontractors' work at RFETS in 2001. During 2002, the Board evaluated plans for increased use of subcontractors in decommissioning activities in major defense nuclear facilities at the site. The Board found that actions being pursued by RFETS did not address the flowdown of health and safety requirements and work planning/control processes or strengthening of floor-level oversight of subcontractor work by the principal contractor, Kaiser-Hill. In August 2002, DOE informed the Board of several actions to be taken to address these issues.


3.4.4 Fernald Closure Project

The Fernald Closure Project has made significant progress in the deactivation and decommissioning of former uranium processing buildings, and in removal of radioactive waste materials from the site. In 2002, the Board conducted reviews of the work authorization programs for each of the seven major closure projects and reviewed the health and safety oversight programs of DOE and its primary contractor. The Board found that both DOE and its contractor need to pay closer attention to worker health and safety and to proper conduct of operations on most site projects, especially those involving subcontractors.

The Board also reviewed the design and safety analysis work on the Silos project, which involves removing and treating radioactive waste (stored in three concrete silos for approximately 50 years) and shipping the material off site. The Board has provided technical comments to DOE on the structure and content of the safety basis for these activities. The Board also evaluated readiness reviews by DOE and the contractor for the startup of a new Radon Control System that will remove radon gas from the silos during waste removal and treatment. These readiness reviews were well-performed and revealed software problems in the distributed control system.

The Board evaluated additional health and safety problems at this site, including an April 2002 accident in which a worker was pinned between a railcar and a metal platform, and five separate accidents between February and August 2002 in which workers were exposed to nitrogen dioxide fumes. In light of this record, the Board continues to press DOE to supervise its contractors more closely at this site.


3.4.5 Mound Closure Project

The Board reviewed the work control program for decontamination and decommissioning at the Mound Closure Project, which has been revised to reduce its complexity. The Board found that the resulting work packages were simple to prepare and execute, but were less detailed and relied heavily on workers' familiarity with the facility. The work control procedure applied to all site work except maintenance, which was performed using a separate maintenance procedure. The Board noted discrepancies between the work control and maintenance procedures, which the contractor corrected. Many of the radiological control procedures have also been revised and streamlined to allow easier application and reduce the likelihood of errors.


4. COMPLEX-WIDE HEALTH AND SAFETY ISSUES


4.1 IMPLEMENTATION OF INTEGRATED SAFETY MANAGEMENT

4.1.1 Overview

ISM is a concept that evolved from the Board's Recommendation 95-2, Safety Management. The basic tenets of ISM provide the framework for safely performing all of the diverse hazardous activities in the defense nuclear complex.

ISM provides for a single safety management program rather than multiple, unintegrated programs. Nuclear safety is an important but not exclusive target of ISM. Nonradioactive hazardous materials and operations require attention in proportion to the risks they pose to the public, workers, and the environment. ISM builds upon standards of safe practice for nuclear, chemical, and other hazardous operations to ensure protection of the public, workers, and the environment.

Since the Board's initial recommendation, the implementation of ISM has progressed through three phases: (1) developing necessary guidance documents; (2) establishing the infrastructure for implementing ISM at individual sites and facilities, including instructing leaders and workers in the application of ISM; and (3) confirming that ISM Systems are effective and being applied to design and construction, startup, operation, and decommissioning of DOE's hazardous facilities. At the end of 1999, the implementation of ISM was well into the second phase. With the successful completion of ISM System Verification Reviews at all sites during 2000, the Board's focus on implementation of ISM shifted to the third phase. Throughout 2002, the Board stressed the need to look beyond initial implementation to ensure continued improvement. In addition to ensuring that ISM was implemented at all DOE sites, the Board focused on two key initiatives that are critical to the long-term effectiveness of ISM--the ISM annual update process and the implementation of the Board's Recommendation 2000-2, Configuration Management, Vital Safety Systems.


4.1.2ISM Annual Update Process

The Board continued to oversee the implementation and effectiveness of ISM at defense nuclear facilities. Noting indications that efforts to continually improve ISM were faltering, the Board requested in a November 8, 2001, letter that DOE provide information on the schedule for ISM annual reviews, the review processes being used, and an evaluation of the adequacy of those processes. DOE forwarded the requested information on January 25, 2002. Analysis of the DOE response showed significant differences existed among the annual review processes being used to maintain and improve ISM. A May 2002 ISM Forum also revealed that broad variation in rigor and senior management attention existed with respect to annual reviews. In an August 8, 2002, letter the Board notified DOE of the results of its analysis and its concern regarding the variability in the conduct of annual ISM reviews. The Board pointed out that one outcome of the May ISM Forum--a commitment to conduct a workshop on maintaining and improving ISM systems--provided an opportunity to resolve some of the problems associated with the annual ISM review process; the Board also offered suggestions for the workshop. DOE included all of the Board's suggested topics in the workshop agenda. The workshop's final report provided a series of recommendations for strengthening the annual ISM update process that will fully address the Board's concerns as expressed in earlier letters. If properly implemented, the Board believes these recommendations will greatly strengthen ISM implementation.


4.1.3Reliability and Configuration Management of Vital Safety Systems

Unless proper protection is provided, the operation of many of DOE's defense nuclear facilities could pose significant hazards to the environment, the public, and workers. Typically the designs of these facilities include safety systems intended to control the hazards present. The availability, operability, and conditions specifying operational limits for these systems are included in the written agreements established by DOE with its contractors as conditions for authorizing the performance of work. Many of the facilities were constructed decades ago and are undergoing deterioration from aging. For that reason alone, it is essential that safety systems be maintained.

In Recommendation 2000-2, Configuration Management, Vital Safety Systems, the Board urged DOE to ensure the operability of these systems by (1) assessing their reliability and operability; (2) requiring that contractor personnel responsible for configuration management maintain the design basis and operating limits; (3) confirming that DOE's technical staff has the requisite number of qualified subject matter experts; and (4) inserting necessary legal requirements into DOE directives and contracts.

In response to the Board's actions, DOE has taken steps to ensure the operability of vital safety systems. DOE completed an initial assessment of each of the vital safety systems in high-priority defense nuclear facilities. Using the findings from this assessment, DOE conducted in-depth reviews of specific systems and programs (such as control of drawings and configuration management) known to be problem-ridden. These reviews uncovered significant weaknesses in the operability of several systems, leading to further evaluation and sometimes to repairs. DOE also revised its directives to include a requirement for contractors to identify system engineers. The sites have begun staffing these programs and developing the appropriate qualification and training programs. In addition, DOE issued the first draft of a major revision to the handbook on ventilation design.

Overall, improvements have been made in ensuring that vital safety systems remain fully operable. However, significant work remains to be accomplished by DOE and its contractors.


4.1.4 Site-Specific ISM Reviews and Improvements

In October 2001, the Board issued a letter to DOE that highlighted numerous deficiencies in the ISM system of the Oak Ridge environmental management contractor, such as inadequate facility hazard classification, missing DOE health and safety orders in the contract, and improper safety basis documentation. In response to the Board's letter, DOE and the contractor conducted a top-to-bottom review of their ISM programs and prepared a comprehensive corrective action plan. In 2002, DOE and the contractor completed more than 150 actions to strengthen the ISM system, including inserting 25 DOE health and safety orders into the contract, conducting training in safety basis fundamentals for key personnel, and hiring additional technical staff. The Board believes that DOE and the contractor are making adequate progress toward rectifying the serious deficiencies in the ISM program.

In the fall of 2001, the Board noted that the feedback and improvement program of a Hanford contractor was weak and a corrective action plan had not been devised. Given these weaknesses and the significant changes being made to the ISM system, the Board suggested that DOE complete a focused ISM System Verification Review for the revised program. In September 2002, at the urging of the Board, a focused review of the ISM system of the Office of River Protection and the contractor was completed. The review team concluded that significant improvement had occurred, that the ISM system is now structured for continuous improvement, and that it is therefore adequate for safe tank farm operations.

At the end of 2001, the Board commended DOE's Rocky Flats Field Office (DOE-RFFO) for continuing to strive toward improving ISM at the site. That office performed a rigorous annual ISM update review that identified much-needed improvements in activity-level work planning and DOE-RFFO oversight. Subsequently, the Board observed that DOE-RFFO was making slow progress in undertaking the corrective actions resulting from the annual ISM update. After an on-site review in late February 2002, the Board requested that DOE report to the Board on actions needed to improve the response to annual ISM update reviews. DOE has developed suitable corrective actions. As a result of these actions by the Board, DOE-RFFO has strengthened the activity-level work planning process and oversight by DOE of activity-level planning. The Board's efforts also led DOE-RFFO to better implement and track needed corrective actions as identified in the annual ISM reviews.


4.2 HEALTH AND SAFETY DIRECTIVES


4.2.1 Improvement of Directives

During 2002, the Board received 28 new or revised drafts of health and safety directives and associated standards from DOE for review. Highlights of the Board's reviews follow:


4.2.2 Implementation of Directives

A directive only contributes to health and safety if it is rigorously and competently carried out in the field. In 2002, the Board continued to scrutinize closely the implementation of health and safety directives. Examples of the Board's work include:


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

On December 11, 2002, the Board issued Recommendation 2002-3, Requirements for the Design, Implementation, and Maintenance of Administrative Controls. In this recommendation, the Board highlighted the fact that the prevention and mitigation of potential accidents inherent in the mission activities at defense nuclear facilities require DOE and its contractors to identify accident scenarios and then establish effective and reliable safety controls to address them. (12)

The Board noted that engineered safety controls are preferred over administrative controls because, in general, engineered controls are more reliable and effective. In many applications, however, DOE and its contractors have concluded that discrete operator actions or administrative programs are required to address consequences of accidents that would otherwise be unacceptable. The Board has identified a number of flawed administrative safety controls that are proposed or in use at various defense nuclear facilities. In many cases, DOE and its contractors have asserted that the methods used to establish these administrative controls comply with existing DOE directives.

After further analysis, the Board concluded that the DOE directives system does not contain requirements adequate to ensure that the design, implementation, and maintenance of important safety-related administrative controls will be effective and reliable. As a result, the Board recommended that DOE promulgate a set of requirements for safety-class and safety-significant administrative controls to establish appropriate expectations for the design, implementation, and maintenance of these important safety controls. The Board also recommended that DOE take action to ensure that all existing administrative controls that serve as safety-class or safety-significant are evaluated against these new requirements and upgraded as necessary.


4.3 TECHNICAL COMPETENCE


4.3.1 Competence of DOE and Contractor Personnel

During 2002, the Board continued to examine the competence of key health and safety personnel at defense nuclear facilities. A number of years ago, DOE established a Federal Technical Capabilities Panel to respond to the Board's concerns in this area. Several initiatives resulted in marginal improvements, but not with enough substance to justify optimism that this issue was well in hand. In May 2002, the Board noted that the NNSA Administrator and the DOE Assistant Secretary for Environmental Management were enacting major personnel realignments that promised improved performance on the part of their organizations. Other actions in this area during 2002 included the following:


4.3.2 System Engineers and Federal Subject Matter Experts

Recommendation 2000-2, Configuration Management, Vital Safety Systems, urged DOE to develop formal requirements for training and qualification of competent subject matter experts in vital safety systems (system engineers) for both federal and contractor organizations. As part of its response to this recommendation, in 2001 DOE issued a significant modification to DOE Order 420.1, Facility Safety, defining responsibilities and training requirements for contractors' system engineers. DOE also revised Order 433.1, Maintenance Management Program for DOE Nuclear Facilities, to include requirements for establishing a system engineer program for the management of vital safety systems.

During 2002, the Board evaluated DOE's efforts to institutionalize the use of system engineers and federal subject matter experts for vital safety systems at defense nuclear facilities throughout the DOE complex. The Board's staff conducted reviews of DOE's implementation of this requirement at six DOE sites: SRS, ORNL, Pantex, LANL, ORP, and the Richland Operations Office. Staffing of system engineers and federal subject matter experts varied considerably from site to site; only SRS was able to satisfy most of the direction prescribed in DOE standards. The Board's staff found that the federal programs at the Amarillo Site Office, and the Los Alamos Site Office were understaffed and lacked adequate definition of roles and responsibilities for subject matter experts.

During the review at Hanford, the staff noted significant deficiencies in the implementation of Recommendation 2000-2. Specifically, the qualification and training programs for ORP's subject matter experts on vital safety systems lacked the rigor required for these individuals to provide effective oversight of the contractors. The system engineering program at Fluor Hanford was weak, with few requirements for training and qualifying a system engineer. The site has since informed the Board that corrective actions are being taken to redress these deficiencies. The staff also found weaknesses in this area at RFETS. For example, the system engineers who were assigned to vital safety systems had not been required to participate in the work control processes for substantial modification, troubleshooting, and repair of the systems. This situation has been corrected.

In a September 2002 letter to DOE, the Board rejected DOE's list of federal personnel who are filling positions as subject matter experts in DOE's field and area offices. Numerous inconsistencies and gaps were noted in this list, including many vacant positions with no plans to fill them; vacant positions to be filled from within the current DOE organization for which no candidate had been identified; and safety system categories listed as non-existent, in conflict with information provided in the original report of January 2002. DOE is now in the process of resolving these discrepancies and establishing a plan to fill vital technical positions. The Board will continue to emphasize to DOE the importance of assigning qualified system engineers and federal subject matter experts to vital safety systems.


4.4 NUCLEAR FACILITY DESIGN REVIEWS

One of the Board's statutory responsibilities is review of the design and construction of defense nuclear facilities to ensure that adequate health and safety requirements are identified and implemented. These facilities must be designed and constructed in a manner that will support safe and efficient operations for 20 to 50 years. This in turn requires a robust design process to ensure that appropriate health and safety controls are identified and properly implemented early in the process. ISM provides the framework for this process. The Board's expectation is that the design and construction phases of defense nuclear facilities will demonstrate clear and deliberate implementation of ISM principles and core functions, clearly codified in manuals of practice and implemented on design and construction projects. The following are examples of the Board's design review work in 2002:


5. INFORMING THE PUBLIC

The Board keeps the public informed of its work through public meetings, quick responses to public requests for documents, effective responses to public inquires into health and safety issues, outreach activities of the Board's site representatives, and an Internet website.


5.1 PUBLIC MEETINGS

During 2002, the Board conducted a public meeting in Pleasanton, California, near LLNL. This meeting focused on LLNL's implementation of Recommendations 2000-2, 94-1, and 2000-1, and the adequacy of LLNL's support for nuclear explosive operations at the Pantex Plant.


5.2 RESPONDING TO PUBLIC REQUESTS

The Board responded to numerous public requests for documents and information during 2002. The Board also responded to 16 requests filed under the Freedom of Information Act (FOIA). The average response time was 11 working days, as compared with the statutory requirement of 20 working days. The Board has posted on its website a complete list of FOIA requests processed since 2000.


5.3 ELECTRONIC ACCESS

The Board redesigned its website (www.dnfsb.gov) in 2002 to keep pace with rapid changes in Internet technologies, and to meet federal regulations and security requirements. Restructuring the site with state-of-the-art technology has made it easier to update with limited staff, thus ensuring timely posting of essential documents. The improved design has made the website more attractive and easier for the public to use, and has improved the process of recruiting for potential applicants. The redesigned website also enhances accessibility for individuals with disabilities, and offers convenient and thorough public access to the Board's oversight work.

The Board established a priority to comply with the Government Information Security Reform Act and other federal standards for information security. In furtherance of that objective, the Board subjected its information security systems to an independent audit. While the audit found no significant weaknesses, it identified ways to improve the Board's security policies and procedures. The recommendations from the audit are now being implemented to ensure that the Board's information security posture is capable of countering continual and changing cyber threats.


5.4 INQUIRIES INTO HEALTH AND SAFETY ISSUES

The Board often receives information regarding potential health and safety hazards from private citizens or from employees at defense nuclear facilities. The Board treats these matters with the utmost seriousness by assigning members of its legal and technical staff to investigate or inquire further. These inquiries, which may involve interviews, review of documents, and site visits, are continued until the Board is able to reach a technical judgment on the issues raised. If the Board finds that a health or safety hazard exists, it takes prompt action to inform DOE and closely monitors DOE's corrective actions. When the Board receives information on matters outside its jurisdiction, such as alleged criminal activities or unlawful personnel practices, it refers the information to the appropriate federal agency for action.

During 2002, the Board directed inquiries into health and safety issues at DOE Headquarters, Hanford, LANL, Pantex, and Fernald. The Fernald inquiry resulted in improvements to hazard categorizations used in planning for the safe execution of cleanup. The headquarters inquiry resulted in increased attention to quality assurance in such areas as design and procurement. Additionally, the inquiry resulted in improved DOE and DOE contractor activities to prevent the introduction of suspect/counterfeit items into safety or mission-sensitive applications, and improved programs to respond to emergent problems concerning suspect/ counterfeit items. However, a recent Board staff review identified an erosion in DOE activities regarding suspect/counterfeit items and shortcomings in DOE's response to a Department of Defense notification of a suspect/counterfeit parts alert. Suspect/counterfeit parts, items, and equipment continue to be supplied to DOE and constant attention is required to detect, prevent the installation, and, where installed, to remove potentially discrepant items which could pose a threat to the health and safety of workers and the general public. The Board continues to devote substantial resources to assist DOE in implementing effective quality assurance programs and effective controls on suspect/counterfeit items.


5.5 SITE REPRESENTATIVE ACTIVITIES

The Board enhances its on-site health and safety oversight of defense nuclear facilities by assigning experienced technical staff members to full-time duty at priority DOE sites: Pantex, Hanford, RFETS, SRS, Y-12, and LANL. Site representatives conduct first-hand assessments of nuclear safety management to identify health and safety concerns promptly. They meet regularly with the public, union members, Congressional staff members, and public officials from federal, state, and local agencies. The Board receives regular briefings from its site representatives in person, and maintains continuous contact with them using all available media.



APPENDIX A


RECOMMENDATION 2002-1





RECOMMENDATION 2002-2

 

 



RECOMMENDATION 2002-3

 

 

 



APPENDIX B

Reporting Requirements
Date of Letter Subject Response
Required 		Response
Due
December 27 Address secondary confinement system design deficiencies and
primary confinement systems at the Y-12 Highly Enriched
Uranium Materials Facility		 Report 90 Days
December 16 Management of structural design margins and plans to
systematically review the Hanford Waste Treatment Plant design 		Report 45 Days
November 13 Address criticality safety for operations in Building 9212 and
actions taken to ensure the continued adequacy of the Y-12
criticality safety program		 NNSA
Report
Contractor
Report		 60 Days

60 Days
November 13 DOE actions to ensure that controls, such as continuous air
monitors and radiation alarm monitors, are afforded protection
required by safety-significant designation at the Pantex Plant		 Briefing 60 Days
November 4 DOE resolutions of safety and design deficiencies at the Hanford
Waste Treatment Plant		 Report 60 Days
September 23 Safe storage of sodium fluoride (NaF) traps stored in Building
3019A at the Oak Ridge National Laboratory		 Briefing 60 days
August 9 Recommendations 94-1 and 2000-1 Implementation Plan, Revision
2, plans and schedules for stabilizing nuclear material at LANL		 Briefing
IP Rev.
Date
 30 Days
No Time
Specified
August 1 Design agency designation of a single integrated point of contact
for each weapon system		 Briefing 30 Days
July 19 Describe the seismic-detection and alarm system test program for
the Savannah River Tritium Extraction Facility and identify the
safety design feature to be incorporated in the event the
aforementioned system proves impractical or ineffective		 Report 60 Days
July 17 Outline specific actions DOE will take to implement
recommendations of the DOE Commission on Fire Safety and
Preparedness		 Report 60 Days
July 12 Address issues concerning verification of plutonium oxide
stabilization		 Report 60 Days
June 27 Summarize DOE's plan for further development of alternative
technologies for removal of cesium from salt wastes at SRS		 Report 60 Days
May 20 Measures taken to improve the safe management of inactive nuclear
materials at sites managed by NNSA		 Report 120 Days
May 13 Fire protection issues for Building 9212, B-1 Wing, at the Y-12
National Security Complex		 Report 60 Days
April 23 Identified deficiencies in new Plutonium-238 Scrap Recovery Line
at the Los Alamos National Laboratory		 Report 60 Days
April 19 Emergency power system at the Lawrence Livermore National
Laboratory's Plutonium Facility (Building 332)		 Briefing 30 Days
March 29 Recommendations on the high-level waste operations at the
Savannah River Site		 Report 60 Days
March 21 Issues raised in DNFSB/TECH-32 on the Savannah River Site
canyon utilization		 Report 60 Days
March 7 Issues on depleted uranium storage at the Savannah River Site Report 120 Days
March 7 Preliminary design of the Sandia National Laboratories
Underground Reactor Facility		 Report 60 Days
February 22 Design requirements and guidance and status of quality assurance
improvement at the Los Alamos National Laboratory		 Report 60 Days
February 15 Hanford's Multi-Canister Overpack (MCO) in relation to Recommendation 94-1 Report 60 Days


APPENDIX C
CORRESPONDENCE


The Board's 2002 letters are organized below in two ways, first by strategic plan area and second by site or facility. Some letters pertain to more than one strategic plan area or site; in these cases, the letter is listed only once.


I. STRATEGIC AREA LISTS

Strategic Area of Planning I: Complex-wide Issues

January 28 letter to the Deputy Secretary of Energy concerning the Nuclear Air Cleaning Handbook.

January 31 letter to Secretary Abraham responding to DOE's letter proposing closure of Recommendation 98-1.

February 15 letter to the Assistant Secretary for Environmental Management regarding Multi-Canister Overpack in relation to Recommendation 94-1.

February 22 letter to the Deputy Secretary of Energy on the Quality Assurance Improvement Plan.

March 19 letter to the Assistant Secretary of Energy for Environmental Management forwarding a staff issue report on feedback from deactivation and decommissioning activities.

March 22 letter to the Assistant Secretary for Environmental Management in reference to Recommendation 2001-1.

March 29 letter to the Assistant Secretary for Environmental Management on the expertise of industry groups.

March 29 letter to Secretary Abraham on the order review in progress.

April 19 letter to the Under Secretary for Nuclear Security on the calendar year 2002 master schedule of external NNSA assessments.

May 20 letter to the Deputy Administrator for Defense Programs forwarding a staff issue report on the review of inactive nuclear materials management at DOE nuclear weapons laboratories.

June 7 letter to Secretary Abraham commending the Facility Representative Program and the selection of Mr. Brian Harkins as the 2001 Facility Representative of the Year.

July 11 letter to the Deputy Administrator of Naval Reactors concerning receipt of the NNSA/Naval Reactors report on radiological waste disposal and environmental monitoring, occupational safety and health, and occupational radiation exposure.

July 12 letter to the Assistant Secretary for Environmental Management with an enclosed issue report regarding the approved guidelines for verifying thermal stabilization of plutonium oxide.

July 17 letter to Secretary Abraham on the recommendations of the DOE Commission on Fire Safety and Preparedness.

August 8 letter to Secretary Abraham on the Integrated Safety Management annual review process.

August 9 letter to Secretary Abraham on DOE's Implementation Plan for Recommendations 94-1 and 2001-1.

August 9 letter to the Honorable Baron P. Hill on the Waste Pits Remedial Action Project.

September 18 letter to Secretary Abraham on Recommendation 2000-2 actions.

September 23 letter to Secretary Abraham on Recommendation 2002-1.

September 23 letter to Secretary Abraham on safety and hazard analysis methodology at DOE defense nuclear facilities.

October 3 letter to Secretary Abraham forwarding Recommendation 2002-2.

November 4 letter to Secretary Abraham on Integrated Safety Management.

November 15 letter to the Assistant Secretary for Environmental Management requesting a briefing on the vapor-space corrosion program.

November 22 letter to Secretary Abraham approving DOE's request for an extension to respond to Recommendation 2002-2.

December 11 letter to Secretary Abraham forwarding Recommendation 2002-3.

December 19 letter to the Deputy Administrator for Defense Programs regarding the Tritium Extraction Facility at SRS.

December 31 letter to the Deputy Administrator for Defense Programs regarding DOE's September 20 response to the Board's May 20 letter on inactive actinide materials.


Strategic Area of Planning II: Safe Management and Stewardship of Nuclear Weapons Stockpile and Components

January 15 letter to the Acting Deputy Administrator for Defense Programs enclosing a staff issue report on verification of hazard assessment at LLNL.

January 18 letter to the Under Secretary of Energy, Science, and Environment on environmental management activities of DOE's Oak Ridge Operations Office.

February 22 letter to the Deputy Administrator for Defense Programs forwarding a report on design requirements and guidance and status of quality assurance improvements at LANL.

March 7 letter to the Deputy Administrator for Defense Programs forwarding a staff issue report on the safety basis and readiness of the Waste Examination Facility at the Nevada Test Site.

March 7 letter to the Deputy Administrator for Defense Programs enclosing a staff issue report on the preliminary design of the Sandia Underground Reactor Facility.

March 11 letter to the Deputy Administrator for Defense Programs enclosing a staff report on the deactivation of LLNL's heavy element facility.

March 25 letter to the Deputy Administrator for Defense Programs on compliance with procedures at Pantex.

March 25 letter to the Deputy Administrator for Defense Programs forwarding three staff issue reports on the Highly Enriched Uranium Materials Facility at Y-12.

March 25 letter to the Deputy Administrator for Defense Programs enclosing a staff issue report on the disposition of various radioactive and hazardous materials stored at Y-12.

April 19 letter to the Deputy Administrator for Defense Programs enclosing a staff issue report on the emergency power system at LLNL's Plutonium Facility (Building 332).

April 23 letter to the Under Secretary for Nuclear Security and Administration forwarding a staff report on the new 238Pu Scrap Recovery Line at LANL.

May 8 letter to Secretary Abraham on DOE's Implementation Plan for Recommendation 99-1.

May 13 letter to the Deputy Administrator for Defense Programs enclosing a staff issue report on fire protection for B-1 Wing of Building 9212 at Y-12.

July 30 letter to the Under Secretary of Energy, Science, and Environment on the proposal for obtaining medical isotopes from the uranium-233 stored at Oak Ridge National Laboratory, and the shutdown of the Building 3019 complex.

August 1 letter to the Acting Administrator of NNSA concerning actions being taken to ensure support of safety initiatives at the Pantex Plant.

August 6 letter to the Deputy Administrator for Defense Programs forwarding a staff report on the status of lightning protection and electrical systems at Pantex.

August 6 letter to the Deputy Administrator for Defense Programs forwarding a staff report on lightning protections systems at LANL.

September 23 letter to the Assistant Secretary of Environmental Management forwarding a staff report on safe storage of sodium fluoride traps at ORNL.

September 23 letter to the Acting Administrator of NNSA forwarding a staff report on fire protection at Pantex.

October 3 letter to the Deputy Administrator for Defense Programs forwarding a staff report on conduct of operations and training preparations for a contractor's operational readiness review at Y-12.

November 13 letter to the Deputy Administrator for Defense Programs establishing a 60-day reporting requirement for addressing criticality safety at Y-12.

November 13 letter to the Deputy Administrator for Defense Programs establishing a 60-day reporting requirement on controls to protect against significant exposure to radiological hazards at Pantex.

November 15 letter to the Deputy Administrator for Defense Programs regarding the need to restart disassembly and inspection operations for the W84 Program.

December 19 letter to Secretary Abraham regarding the implementation of Seamless Safety for the 21st Century at the Pantex Plant.

December 27 letter to the Deputy Administrator for Defense Programs establishing a 90-day reporting requirement on the Highly Enriched Uranium Materials Facility at Y-12.

December 31 letter to the Deputy Administrator for Defense Programs on the Highly Enriched Uranium Materials Facility at Y-12.


Strategic Area of Planning III: Safe Disposition of Hazardous Remnants of Weapons Production

February 5 letter to the Assistant Secretary for Environmental Management forwarding a staff issue report on electrical and instrumentation and control systems at Hanford's Plutonium Finishing Plant.

February 15 letter to the Assistant Secretary for Environmental Management on Recommendation 94-1.

March 4 letter to the Assistant Secretary for Environmental Management on high-level waste salt processing capability at SRS.

March 19 letter to the Assistant Secretary for Environmental Management enclosing a staff issue report on activity-level work planning and feedback and improvement at RFETS.

March 21 letter to Secretary Abraham forwarding DNFSB/TECH-32, Savannah River Site Canyon Utilization.

March 29 letter to Secretary Abraham formally closing Recommendation 96-1, and requesting a report on DOE's approach for treatment and disposition of the waste in Tank 48 at SRS.

March 29 letter to Secretary Abraham on Recommendation 2001-1.

May 22 letter to Secretary Abraham on Recommendation 94-1.

June 5 letter to the Assistant Secretary for Environmental Management forwarding a staff issue report reviewing maintenance at the Hanford Spent Nuclear Fuel Project.

June 11 letter to the Assistant Secretary for Environmental Management forwarding a staff issue report on Recommendation 94-1/2000-1 stabilization activities at the Hanford Plutonium Finishing Plant.

June 11 letter to the Assistant Secretary for Environmental Management on Recommendation 2001-1.

June 26 letter to the Assistant Secretary for Environmental Management enclosing a staff issue report on the H-Canyon ventilation system at SRS.

June 27 letter to the Assistant Secretary for Environmental Management requesting a summary of DOE's plan for further development of alternative technologies for the removal of cesium from salt wastes at SRS.

July 30 letter to the Assistant Secretary for Environmental Management on the seismic design of the Pretreatment, Low-Activity Waste, and High-Level Waste Facilities of the Hanford Waste Treatment Plant.

September 9 letter to the Assistant Secretary for Environmental Management on the Waste Feed Delivery Transfer System at Hanford.

November 4 letter to the Assistant Secretary for Environmental Management forwarding a staff issue report on safety and design basis activities at the Hanford Waste Treatment Plant.

November 4 letter to the Assistant Secretary for Environmental Management enclosing a staff issue report on documented safety analysis for the concentration, storage, and transfer facilities at SRS.

November 8 letter to Secretary Abraham on F-Canyon at SRS.

November 14 letter to the Assistant Secretary for Environmental Management forwarding staff observations on the Hanford High Level Waste Building "Load Path Report."

December 13 letter to Congressman Porter on the hazard categorization of the Waste Pits Remedial Action Project at Fernald.

December 16 letter to the Assistant Secretary for Environmental Management forwarding a staff issue report on the status of the Implementation Plan for Recommendation 2000-2.

December 16 letter to Secretary Abraham establishing a 45-day reporting requirement regarding safety issues at the Hanford Waste Treatment Plant project.


II. SITE/FACILITY LIST

Fernald Closure Site

December 13 letter to Congressman Porter on the hazard categorization of the Waste Pits Remedial Action Project.

Hanford Site

February 5 letter to the Assistant Secretary for Environmental Management forwarding a staff issue report on electrical and instrumentation/control systems at the Plutonium Finishing Plant.

February 15 letter to the Assistant Secretary for Environmental Management on Recommendation 94-1.

June 5 letter to the Assistant Secretary for Environmental Management forwarding a staff issue report reviewing maintenance at the Spent Nuclear Fuel Project.

June 11 letter to the Assistant Secretary for Environmental Management forwarding a staff issue report on Recommendation 94-1/2000-1 stabilization activities at the Plutonium Finishing Plant.

July 30 letter to the Assistant Secretary for Environmental Management on the seismic design of the Pretreatment, Low-Activity Waste, and High-Level Waste Facilities of the Waste Treatment Plant.

September 9 letter to the Assistant Secretary for Environmental Management on the waste feed delivery transfer system.

November 4 letter to the Assistant Secretary for Environmental Management forwarding a staff issue report on safety and design basis activities at the Waste Treatment Plant.

November 14 letter to the Assistant Secretary for Environmental Management forwarding staff observations on the High Level Waste Building's "Load Path Report."

December 16 letter to the Assistant Secretary for Environmental Management forwarding a staff issue report on the status of the Implementation Plan for Recommendation 2000-2.

December 16 letter to Secretary Abraham establishing a 45-day reporting requirement on safety issues at the Waste Treatment Plant.

Los Alamos National Laboratory

February 22 letter to the Deputy Administrator for Defense Programs forwarding a report on design requirements and guidance and the status of quality assurance improvements.

April 23 letter to the Under Secretary for Nuclear Security and Administration of NNSA forwarding a report on the new 238Pu Scrap Recovery Line.

August 6 letter to the Deputy Administrator for Defense Programs forwarding a staff report on a review of lightning protection systems.

Lawrence Livermore National Laboratory

January 15 letter to the Acting Deputy Administrator for Defense Programs enclosing a staff issue report on verification of hazard assessments.

March 11 letter to the Deputy Administrator for Defense Programs enclosing a staff report on the deactivation of LLNL's heavy element facility.

April 19 letter to the Deputy Administrator for Defense Programs enclosing a staff issue report on the emergency power system at the Plutonium Facility, Building 332.

Nevada Test Site

March 7 letter to the Deputy Administrator for Defense Programs forwarding a staff issue report on the safety basis and readiness of the Waste Examination Facility.

Oak Ridge/Y-12

January 18 letter to the Under Secretary of Energy, Science, and Environment concerning the environmental management activities of the Oak Ridge Operations Office.

March 25 letter to the Deputy Administrator for Defense Programs forwarding three staff issue reports on the Highly Enriched Uranium Materials Facility at Y-12.

March 25 letter to the Deputy Administrator for Defense Programs enclosing a staff issue report on the disposition of various radioactive and hazardous materials stored at Y-12.

May 13 letter to the Deputy Administrator for Defense Programs enclosing a staff issue report on fire protection for the B-1 Wing of Building 9212 at Y-12.

July 30 letter to the Under Secretary of Energy, Science, and Environment on obtaining medical isotopes from the uranium-233 stored at ORNL, and the shutdown of the Building 3019 complex.

September 23 letter to the Assistant Secretary of Environmental Management forwarding a staff report on safe storage of sodium fluoride traps at ORNL.

October 3 letter to the Deputy Administrator for Defense Programs forwarding a staff report on conduct of operations and training preparations for a contractor's operational readiness review at Y-12.

November 13 letter to the Deputy Administrator for Defense Programs establishing a 60-day reporting requirement on criticality safety at Y-12.

December 27 letter to the Deputy Administrator for Defense Programs establishing a 90-day reporting requirement on the Highly Enriched Uranium Materials Facility at Y-12.

December 31 letter to the Deputy Administrator for Defense Programs regarding the Highly Enriched Uranium Materials Facility at Y-12.

Pantex Plant

March 25 letter to the Deputy Administrator for Defense Programs on compliance with procedures.

May 8 letter to Secretary Abraham on DOE's Implementation Plan for Recommendation 99-1.

August 1 letter to the Acting Administrator of NNSA concerning support for the implementation of safety initiatives.

August 6 letter to the Deputy Administrator for Defense Programs forwarding a staff report on the status of lightning protection and electrical systems.

September 23 letter to the Acting Administrator of NNSA forwarding a staff report on fire protection.

November 13 letter to the Deputy Administrator for Defense Programs establishing a 60-day reporting requirement on ensuring controls to protect against significant exposure to radiological hazards.

November 15 letter to the Deputy Administrator for Defense Programs regarding the need to restart disassembly and inspection operations for the W84 Program.

December 19 letter to Secretary Abraham regarding the implementation of Seamless Safety for the 21st Century.

Rocky Flats Environmental Technology Site

March 19 letter to the Assistant Secretary for Environmental Management enclosing a staff issue report on activity-level work planning and feedback and improvement.

May 22 letter to Secretary Abraham on Recommendation 94-1.

Sandia National Laboratories

March 7 letter to the Deputy Administrator for Defense Programs enclosing a staff issue report on the preliminary design of the Underground Reactor Facility.

Savannah River Site

March 4 letter to the Assistant Secretary for Environmental Management on high-level waste salt processing capability.

March 7 letter to the Assistant Secretary for Environmental Management on the issues outlined in the forwarded staff issue report on depleted uranium storage.

March 21 letter to Secretary Abraham forwarding DNFSB/TECH-32, Savannah River Site Canyon Utilization.

March 29 letter to Secretary Abraham formally closing Recommendation 96-1, and requesting a report on DOE's approach for treatment and disposition of the waste in Tank 48.

March 29 letter to Secretary Abraham on Recommendation 2001-1.

June 11 letter to the Assistant Secretary for Environmental Management on Recommendation 2001-1.

June 26 letter to the Assistant Secretary for Environmental Management enclosing a staff issue report on the H-Canyon ventilation system.

June 27 letter to the Assistant Secretary for Environmental Management requesting a summary of DOE's plan for further development of alternative technologies for the removal of cesium from salt wastes.

July 19 letter to the Deputy Administrator for Defense Programs concerning the Tritium Extraction Facility.

November 4 letter to the Assistant Secretary for Environmental Management enclosing a staff issue report on documented safety analysis for concentration, storage, and transfer facilities.

November 8 letter to Secretary Abraham on F-Canyon.

December 19 letter to the Deputy Administrator for Defense Programs regarding the Tritium Extraction Facility.


APPENDIX D
ADMINISTRATIVE ACTIVITIES


INFORMATION TECHNOLOGY AND SECURITY

The Board has continued to make improvements to the information technology (IT) resources provided to its staff. Desktop hardware and software are continually upgraded to ensure that the Board has the latest tools available.

Improvements in IT resources have also allowed the Board to provide expanded services to the public. The Board's public website has been completely redesigned. The new format makes it easier for the public and other interested parties to locate documents. An expanded career opportunities section has been added so that the website can become one of the Board's primary recruiting tools. The redesigned website is also compliant with Section 508 of the Rehabilitation Act, making it possible for visually impaired persons to navigate the site.

The Board has also placed a heightened emphasis on IT security. Even before the terrorist attacks of September 11, the Board was evaluating IT security. Based on the results of an in-depth analysis of the existing IT security program, the Board has initiated numerous upgrades. These include updating the Board's existing perimeter defenses; enhancing and centralizing the Board's anti-virus capability; improving and integrating the Board's incident handling capability with those of other federal agencies, such as the Federal Computer Incident Response Center and the National Infrastructure Protection Center; and evaluating the use of two-factor authentication devices to provide stronger user authentication.

STAFF

As of December 31, 2002, the Board employed 95 full-time staff in addition to the three Board Members. The Board continued its aggressive recruitment program to attract the brightest engineering students from colleges and universities across the country, as well as experienced engineering professionals. This year, technical recruiters visited 10 campuses and 10 career fairs, and the Board continued its recruitment outreach program through the National Society of Black Engineers and Mexican-American Engineers and Scientists.

DISPUTE RESOLUTION PROGRAMS

The Board, like other federal agencies, is required by the Administrative Dispute Resolution Act of 1996 to provide an alternative dispute resolution program for use in resolving appropriate disputes. During 2000, the Board established such a program, making innovative use of cooperative agreements with other agencies to resolve disputes economically.


APPENDIX E
HUMAN RESOURCES


As clearly recognized by the Congress when evaluating the Board, the ability to effectively carry out an independent technical oversight program throughout the DOE weapons complex depends upon the technical capability of the Board Members and staff:

The conferees believe that the DNFSB is a unique Federal agency, in that its mission [is] to oversee the activities of another federal department whose work is highly technical and potentially dangerous, and that to properly carry out its mission, not only the DNFSB members but also its limited staff must be technically competent in all major phases of nuclear safety. (13)

Simply stated, the Board's ability to fulfill its safety mission rests heavily on attracting and retaining top-caliber technical staff. The Board has been successful in creating a work environment that emphasizes excellence as the standard for staff performance, and rewards its staff accordingly. The pay banding and pay for performance programs developed and implemented by the Board have proven to be effective in hiring technical talent, holding employees accountable for their performance, and rewarding outstanding performance on the job.

The Board's success in accomplishing these goals has been recognized by independent audits conducted by the Office of Personnel Management (OPM) and the Institute of Public Administration. For example, OPM completed an extensive survey and review of the Board's human resources management programs in August 2000 and reported the following:

[The Board's] employees believe that supervisors communicate job expectations, that performance appraisals are fair, and that awards are based on performance. High performance is continually recognized, both monetarily and non-monetarily. Employees recognize the award-achievement connection. [This] indicates how much the Board differs from the rest of the Government in terms of performance management.

The Board's enabling legislation grants authority for excepted service hiring and classification. Using this authority, along with recruitment and relocation bonuses, student loan repayments, and retention allowances, the Board has been successful in competing for scientific and technical staff in a competitive employment market.

The challenges involved in recruiting and retaining a high-quality, diverse workforce can be grouped into two categories: (1) competition from the private sector, and (2) fiscal constraints. Competition for top engineering professionals is intense. Even with the special hiring and pay authorities granted to the Board, private industry can easily promise higher salaries and benefits. The Board has also found that the federal downsizing campaigns of the 1990s, coupled with the perception that the federal bureaucracy stifles creativity and fails to encourage and reward outstanding work, have damaged its recruiting campaigns. Recruitment and retention of recent college engineering graduates, especially women and minorities, is difficult in the current job market, and will become even more challenging with the renewed activity in the commercial nuclear industry.

Despite these problems, the Board has assembled a professional staff of exceptional technical capability. Staff members' expertise covers all major aspects of nuclear safety: nuclear, mechanical, electrical, chemical, and structural engineering, as well as physics and metallurgy. Most mid- to senior-level technical staff members possess practical nuclear experience gained from duty in the United States Navy nuclear propulsion program, the nuclear weapons field, or the civilian nuclear reactor industry. Both the Board and its staff include individuals experienced in environmental impact assessments and regulatory processes. Four of the Board's attorneys have technical degrees, and one is a licensed professional engineer.

Seven technical staff members are located at priority DOE sites. There is one site representative at the Pantex Plant near Amarillo, Texas; two at Hanford near Richland, Washington; two at SRS near Aiken, South Carolina; and one each at RFETS near Boulder, Colorado, and LANL in New Mexico.

The Board expects its engineers and scientists to maintain the highest level of technical knowledge, encouraging them to improve their skills continually through academic study. Currently, 87 percent of the staff hold advanced degrees, 29 percent of which are at the Ph.D. level. Younger technical staff members have been recruited through the Board's professional development program. Entry-level employees recruited into this 3-year program receive graduate-school education and intensive on-the-job training guided by experienced technical mentors. Currently, there are 11 entry-level employees in this program. Three completed their master's degrees in the summer of 2002 and are in their third-year field assignment. By the summer of 2003, 3 more of these individuals should be awarded a master's degree in an engineering discipline. The Board's professional development program remains extremely useful in attracting and retaining high-quality entry-level engineers and preparing them for challenging assignments in their fields.


APPENDIX F
LIST OF ABBREVIATIONS AND ACRONYMS


Am/Cm
Board
CSSX
CFR
DOE
DNFSB
DSA
DWTF
EOC
EPS
FOIA
FTS
FY
GPRA
Hanford
HEUMF
HLW
INEEL
ISM
IT
ITP
LANL
LAW
LLNL
MCOs
MOU
NaF
NCSP
NNSA
NTS
OPM
ORNL
ORP
ORR
Pantex
PDCF
PDP
QA
RA
RFETS
RFFO
SNFP
SNL
SRS
SS-21
SSCs
TA
TEF
TRU
USQ
WIPP
WTP
Y-12
232U
233U
238		 Americium/Curium
Defense Nuclear Facilities Safety Board
Caustic-side Solvent Extraction
Code of Federal Regulations
Department of Energy
Defense Nuclear Facilities Safety Board
Documented Safety Analysis
Decontamination and Waste Treatment Facility
Emergency Operations Center
Emergency Power System
Freedom of Information Act
Fuel Transfer System
Fiscal Year
Government Performance and Results Act
Hanford Reservation
Highly Enriched Uranium Materials Facility
High-level Waste
Idaho National Engineering and Environmental Laboratory
Integrated Safety Management
Information Technology
In-Tank Precipitation Facility
Los Alamos National Laboratory
Low Activity waste
Lawrence Livermore National Laboratory
Multi-Canister Overpacks
Memorandum of Understanding
Sodium Fluoride
Nuclear Criticality Safety Program
National Nuclear Security Administration
Nevada Test Site
Office of Personnel Management
Oak Ridge National Laboratory
Office of River Protection
Operational Readiness Review
Pantex Plant
Pit Disassembly and Conversion Facility
rofessional Development Program
Quality Assurance
Readiness Assessment
Rocky Flats Environmental Technology Site
Rocky Flats Field Office
Spent Nuclear Fuel Project
Sandia National Laboratories
Savannah River Site
Seamless Safety for the 21st Century
Structure, systems and components
Technical Area
Tritium Extraction Facility
Transuranic
Unreviewed Safety Question
Waste Isolation Pilot Plant
Waste Treatment Plant
Y-12 National Security Complex
Uranium-232
Uranium-233
Plutonium-238


__________________

1. See Appendix A for the full text of the recommendation.

2. See Appendix A for the full text of the recommendation.

3. Also found in Appendix A.

4. See Appendix A for the full text of the recommendation.

5. See Appendix A for the full text of the recommendation.

6. Also found in Appendix A.

7. The terms "disassembly" and "dismantlement" are not synonymous. Disassembly refers to the activities associated with taking apart a weapon for purposes of inspecting or testing its components, while dismantlement is a permanent action to render the weapon no longer usable.

8. See Appendix A for the full text of the recommendation.

9. Hazard categories are defined in Appendix A to 10 CFR Part 830. A Hazard Category 3 facility is one where the hazard is of "only local [sic] significant consequences."

10. The Board is a party to a Memorandum of Understanding (MOU) that coordinates health and safety oversight at RFETS. The MOU, titled "Memorandum of Understanding Governing Regulation and Oversight of Department of Energy Activities in the Rocky Flats Environmental Technology Site Industrial Area," was executed by the Board, DOE, the Environmental Protection Agency, and the Colorado Department of Public Health and Environment on February 15, 1996. It can be viewed on the Board's website at: http://www.dnfsb.gov/pub_docs/rfets/ mou_19960215_rf.html.

11. See Appendix A for the full text of this recommendation.

12. See Appendix A for the full text of this recommendation.

13. National Defense Authorization Act for Fiscal Year 1991, Conference Report, H.R. Conf. Rep. No. 923, 101st Cong. 2nd Sess. 767 (1990).