February 2007, Board Seventeenth Annual Reports to Congress On Board-Related Activities

Tabl= e of Contents

Summ= ary of Accomplishments in 2006.........= ................................................................... = 7

Outs= tanding Safety Problems of Defense Nuclear Facilities..= ...................................... 14

Sect= ion 1: Introduction ..........................................= ........................................................ 19

1.1...... Background .= ...........................................................................= ............................... 19

1.2...... Oversight Strategy ....................................................................= ............................. 19

1.3...... Strategic Plan ........................................................................= ................................ 20

Sect= ion 2: Nuclear Weapons Operations .= ..................................................................... 23

2.1...... Safe Conduct of Stockpile Management ..........................................= ..................... 23

2.1.1... Pantex Plant ..= ...........................................................................= ................. 23

2.1.2... Y-12 National Security Complex .............................................................. 26

2.1.3... Savannah River Site Tritium Operations ..........................................= ......... 28

2.1.4... Nuclear Material Packaging .................................................................= ..... 28

2.2...... Safe Conduct of Stockpile Stewardship ..........................................= ...................... 29

2.2.1... Los Alamos National Laboratory .............................................................. 29

2.2.2... Lawrence Livermore National Laboratory ..........................................= ....... 30

2.2.3... Nevada Test Site 2.2.4... Sandia National Laboratories .................................................................= ... 33

2.2.5... Research and Development for Explosives Safety .................................... 33

Sect= ion 3: Nuclear Materials Processing and S= tabilization ......................................... = 35

3.1 ...= ................................................. 35

3.1.1... Complex-Wide ..= ...........................................................................= ............. 35

3.1.2... Plutonium .....= ...........................................................................= .................. 35

3.1.3... Uranium .......= ...........................................................................= .................. 36

3.1.4... Neptunium .....= ...........................................................................= ................ 36

3.2...... Stabilization of Spent Nuclear Fuel ..........................................= ............................. 37

3.2.1... Hanford Site ..= ...........................................................................= ................. 37

3.2.2... National Spent Nuclear Fuel Program ..........................................= ............. 37

3.3...... Waste Management ......................................................................= ......................... 38

3.3.1... High-level ....= ...........................................................................= .................. 38

3.3.2... Low-Level Waste and Transuranic Waste ..........................................= ....... 39

3.4...... Facility Deactivation and .................................................................= ...................... 41

3.4.1... Overview ......= ...........................................................................= ................. 41

3.4.2... Fernald Closure Project ..................................................................= ........... 41

3.4.3... Miamisburg Closure Project .................................................................= ..... 41

3.4.4... Savannah River Site ......................................................................= ............ 42

3.4.5... Hanford Site ..= ...........................................................................= ................. 42

3.4.6... Idaho Cleanup Project ....................................................................= ........... 42

Sect= ion 4:&nbs= p; Nuclear Faci= lities Design and Infrastructure ........= ..................................... 45

4.1...... Introduction ..........................................................................= ................................. 45

4.2...... Hanford Site ..........................................................................= ................................ 45

4.3...... Savannah River Site ...................................................................= ........................... 47

4.4...... Y-12 National Security Complex .................................................................= ......... 48

4.5...... Los Alamos National Laboratory .................................................................= ......... 49

4.6...... Pantex Plant ..........................................................................= ................................ 49

4.7...... Idaho Cleanup Project .................................................................= .......................... 50

4.8...... Nevada Test Site ......................................................................= ............................. 50

4.9...... Seismic Hazard Analysis .................................................................= ...................... 50

Sect= ion 5:&nb= sp; Nuclear Safe= ty Programs and Analysis ........= .............................................. 53

5.1...... Federal Oversight .....................................................................= ............................. 53

5.1.1... Overview ......= ...........................................................................= ................. 53

5.1.2... Recommendations 95-2 and 2004-1 .......................................................... 53

5.1.3... DOE Oversight Policy and Order ............................................................. 54

5.1.4... Vital Safety Systems .....................................................................= ............ 55

5.1.5... Activity-Level Work Planning .................................................................= . 55

5.1.6... Small Business Contracting .................................................................= ...... 55

5.2...... Health and Safety Directives .................................................................= ................ 55

5.2.1... Improvement of Directives ................................................................= ........ 55

5.2.2... NNSA Policy Letters ......................................................................= .......... 56

5.2.3... Natural Phenomena Hazards ................................................................= ..... 56

5.2.4... Worker Safety Rulemaking .................................................................= ...... 56

5.2.5... Hazard Categorization ....................................................................= ........... 57

5.2.6... Scope of the Directives System .................................................................= 57

5.3...... Safety Programs .......................................................................= ............................. 57

5.3.1... Administrative Controls ..................................................................= .......... 57

5.3.2... Active Confinement Systems .................................................................= ... 58

5.3.3... Quality Assurance ........................................................................= ............. 58

5.3.4... Software Quality Assurance .................................................................= ..... 59

5.3.5... Risk Assessment ..........................................................................= ............. 59

5.3.6... Criticality Safety .......................................................................= ................. 59

5.3.7... Readiness Reviews ........................................................................= ........... 60

5.4...... Technical Competence ..................................................................= ........................ 61

5.4.1 = Federal 61

5.4.2... Criticality Safety Engineers .................................................................= ...... 61

5.4.3... Federal Facility Representatives ................................................................ = 62

Sect= ion 6: Public Outreach and Agency Administration ..........................................= .. 63

6.1...... Public Hearings .......................................................................= .............................. 63

6.2...... Responding to Public Requests .................................................................= ............ 63

6.3...... Electronic Access .....................................................................= ............................. 63

6.4...... Inquiries Into Health and Safety Issues ..........................................= ....................... 63

6.5...... Site Representative Activities .................................................................= ............... 63

6.6...... Human Resources .......................................................................= .......................... 64

6.7...... Information Technology and Security ..........................................= ......................... 64

6.8...... Dispute Resolution Programs .................................................................= ............... 65

6.9...... Financial Management ..................................................................= ........................ 65

Appendices

A........ Recomm= endations Cited ..............................= ......................................................... 67

B........ Report= ing Requirements .......................= ................................................................. 69=

C........ Corres= pondence ....................................= ................................................................ 71<= span style=3D'mso-bidi-font-size:10.0pt'>

Summ= ary of Accomplishments in 2006

The nuclear weapons program of the Department of Energy (DOE), which includes nuclear weapons operations conducted by the National Nuclear Security Administration (NNSA), is a complex and hazardous enterprise. Missions include maintenance of the national nuclear arsenal, dismantlement of surplus weapons, stabilization a= nd storage of surplus nuclear materials, disposition and disposal of hazardous waste, and cleanup of surplus facilities and sites. Some of these missions are carried = out with aging facilities while others demand the construction of new facilitie= s. The constant vigilance of the Defen= se Nuclear Facilities Safety Board (Board) is required to ensure that all of t= hese 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 that are summarized briefly below and in more depth in the main body of the= report. These improvements are descri= bed in accordance with the Board's four strategic areas of concentration:

Nu= clear Weapons Operations;
Nu= clear Materials Processing and Stabilization;
Nu= clear Facilities Design and Infrastructure; and
Nu= clear Safety Programs and Analysis.

Nuclear Weapons Operations

The Board's strategic performance goal for this area is to ensure that DOE operations directly supporting the nuclear stockpile and defense nuclear research are conducted in a manner that provides adequate protection of the health and safety of the workers and the public. The Board's safety oversight activi= ties in this area focus on assembly and disassembly of weapons; processing and storage of uranium, plutonium, and tritium; and research, development, manu= facturing, and testing.

As a result of the Board's efforts during 2006, DOE has taken actions to upgrade= the safety of these activities. T= hese actions include improving safety systems and controls in aging facilities, achieving safe packaging of nuclear weapons materials, improving the formal= ity of nuclear explosive and nuclear processing operations, enhancing the quali= ty of engineered safety systems, and correcting deficiencies in the safety bas= es for new and ongoing activities.

Specific examples of safety improvements in weapons operations made by DOE in conseq= uence of the Board's work are given below. Cross-references are provided to se= ctions in the body of this report where further details can be found.

Multiple Sites:

DOE is implementing improved requirements for development, evaluation, and documentation of nuclear weapon response to external stimuli. (Recommendation 98-2; Board le= tter dated December 14, 2005)(Sec. 2.1.1)

DOE is revising two principal deliverables of its implementation plan for Recommendation 2005-1: (1) the repackag= ing prioritization methodology, and (2) the nuclear material packaging man= ual. (Recommendation 2005-1; Board letters dated April 24 and May 1, 2006)(Sec. 2.1.4)

Pantex Plant (Sec. 2.1.1):

As a part of the implementation plan for Recommendation 98-2, DOE implemented Seamless Safety for the 21st Century processes for weapons programs with insensitive main charge high explosives (the W87, B61, and B83 program= s). (Recommendation 98-2)

DOE completed the safe dismantlement of all W56 war reserve units, including certain units th= at required the development of new tooling and procedures. (Recommendation 98-2; Board le= tter dated July 20, 2004)

DOE is taking a more comprehensive approach toward evaluating multi-unit operations. (staff-to-staff meeting, April= 2006)

DOE completed a three-= year effort to implement more than 200 Technical Safety Requirements. (Recommendation 98-2)

DOE identified actions= to improve the nuclear explosive safety process in response to the Top-Do= wn Review advocated by the Board. (staff-to-staff meeting, June = 2005)

Y-12 National Security Complex (Sec. 2.1.2):

DOE is performing maintenance-related structural fixes in the 9212 Complex and plans to increase maintenance funding and pursue other facility infrastructure improvements to reduce material-at-risk in this facility. (Board letter dated April 20, = 2005)

DOE upgraded the classification of key fire protection systems in the 9212 Complex to s= afety-class. (Board letters dated May 13,2002 and February 28, 2006)

DOE developed a plan to improve conduct of operations. (Site Representative Weekly Re= ports)

DOE is improving the Uranium Holdup Survey Program. (Site Representative Weekly Re= ports)

Los Alamos National Laboratory (Sec. 2.2.1):

DOE took actions to en= sure the continuity of the laboratory's institutional corrective actions programs as the laboratory transitioned to a new prime contractor. (Public Hearing, March 22, 200= 6)

DOE is examining deficiencies in confinement ventilation at the Plutonium Facility. (Recommendation 2004-2; Board = letter dated May 31, 2005)

DOE developed plans to address deficiencies in fire protection. (Board letters dated March 31,= 2003 and May 31, 2005)

DOE eliminated a single point of failure vulnerability in the high-voltage transmission lines = that provide off-site power to the laboratory. (Board letters dated May 5, 19= 95 and September 22, 1999)

Lawrence Livermore National Laboratory (Sec. 2.2.2):

DOE was able to resume normal operations in the Plutonium Facility after ensuring that safety-related findings by the Board and DOE'S Office of Independent Oversight had be= en investigated and procedures revised as needed for safe operations. (Board letters dated November = 3, 2004 and March 8, 2005)

DOE developed a revised documented safety analysis for the Plutonium Facility that represents a significant improvement over previous versions of the safety basis for this facility. (Board le= tter dated May 10, 2006)

DOE developed procedur= es and processes to identify and record the configuration of vital safety systems and to begin the process of maintaining a configuration manage= ment program for these systems. (Board letter dated November 3, 2004)

Nevada Test Site (Sec. 2.2.3):

DOE is performing rigo= rous reviews of the safety bases for subcritical experiments, the Criticali= ty Experiments Facility Project, and defense nuclear facilities. (Board letters dated March 27,= 2006 and September 22, 2006)

DOE continued to make improvements in the facilities and processes necessary to dispose of a damaged nuclear weapon. = (Board letter dated June 19, 2006)

DOE is assessing vital safety systems and safety management programs at the Device Assembly Facility. (Board letter = dated November 28, 2005)

DOE is mapping cracks = and water leaks, fixing water leaks, and completing key seismic-related analyses at the Device Assembly Facility. (Board letters dated March 18,= 2005 and August 16, 2006)

Sandia National Laboratories (Sec. 2.2.4):

DOE has continued to correct deficiencies in safety analyses and to remedy significant shor= tfalls in the site's integrated safety management system. (Board letters dated September= 27, 2004 and October 8, 2004)

Nuclear Materials Processing and Stabilization

This area of work includes oversight of DOE's efforts to stabilize remnant mater= ials from past nuclear facility operations, packaging and storage of those materials, and final disposition = in approved waste repositories. The Board= also monitored DOE's efforts to decontaminate and decommission retired nuclear facilities. Materials include= d in DOE's stabilization efforts are liquid high-level radioactive wastes, spent nuclear fuel, inactive radioactive actinide materials (which include uranium and plutonium), low-level wastes, and transuranic wastes.

Some of the Board's reviews in this area focused on specific issues at individual facilities, while others involved safety topics with broad implications for multiple defense nuclear facilities. Specific examples of safety improve= ments made by DOE in response to the Board's actions are given below. Cross-references are provided to se= ctions in the body of this report where further details can be found.

Complex-wide Safety Issues:

DOE acknowledged safety issues associated with the processing of transuranic waste and drafted= a new standard designed to achieve consistency and enhanced safety in ha= ndling of transuranic waste across the complex. (Transuranic Waste Authorizati= on Basis Workshop, March 2006; Board letter dated January 29, 2007)(Sec. 3.3.2)=

DOE established a test= ing program and a new expert panel to study corrosion mechanisms in tanks = that store liquid high-level wastes. This currently impacts primari= ly the Hanford Waste Storage Tanks. (Board letters dated January <= span style=3D'mso-bidi-font-size:12.5pt'>18, 2005 and June 1, 2005)(= Sec. 3.3.1)

DOE conducted analyses= and identified new safety controls for hydrogen deflagrations in piping and vessels that contain high-level wastes at the Hanford and Savannah Riv= er Sites. (Board letters dated Nov= ember 4, 2002 and October 17, 2005)(Sec. 3.3.1)

Fernald Closure Project:

DOE safely completed f= inal site closure at the Fernald Site in Ohio. DOE's Office of Environmental Management transferred responsibility for the site to the Office of Le= gacy Management. (Board lette= rs dated August 7, 2003 and February 2, 2005)(Sec. 3.4.2)

Hanford Site:

DOE directed that transuranic waste drums found to contain hydrogen gas be vented until = the hydrogen dissipates to below 5 percent by volume, instead of 15 percen= t, which was far greater than the lower flammability limit. (staff-to-staff meeting, March= 2006)(Sec. 3.3.2)

DOE postponed excavati= on of a burial ground containing spent nuclear fuel and other radioactive material. DOE plans to i= mprove work planning and criticality safety prior to conducting the work. (Site Representative Weekly Reports)(Sec. 3.3.2)

Savannah River Site:

DOE removed combustible materials from the K-Area Material Storage facility, improving the fire protection posture there. (Annual Reports to Congress on Plutonium Storage at Savannah River Site, 2004, 2005, 2006)(Sec. 3.1.2= )

DOE finished the stabilization of pre-existing neptunium solutions, marking the complet= ion of all Recommendation 94-1 and 2000-1 milestones at the Savannah River= Site. (Recommendations 94-1 and 2000-l)(Sec. 3.1.1 and 3.1.4)

Nuclear Facilities Design and Infrastructure

The Board's strategic performance goal for this area is to ensure that new defe= nse nuclear facilities and major modifications to existing facilities are desig= ned and constructed in a manner providing adequate protection of the health and safety of workers and the public. In the past few years, there has be= en a substantial increase in the number of design and construction projects under the Board's jurisdiction. DOE= has undertaken design and construction projects with a projected total cost of about $20 billion. The Board continues to devote extensive resources to ensure that designs for defense nuclear facilities incorporate multiple layers of safety controls commensur= ate with the hazards.

DOE is not consistently addressing safety issues early in the design process. <= span style=3D'mso-spacerun:yes'> Moreover, in an increasing number o= f new projects, DOE planned to make use of closely-coupled "design build&quo= t; techniques for large-scale facilities, including some that will require hazardous processes that lack definition. This approach entails considerable = risk when combined with DOE's shortage of personnel qualified to adequately mana= ge such projects. To highlight t= hese problems and to gain further information, the Board began a series of public hearings in December 2005 on incorporating safety into design and construct= ion. The series continued through = 2006, and the Board is preparing for a third public hearing to be held in the fir= st quarter of 2007. This latest = hearing will focus on early issue identification, improved communications between t= he Board and DOE, and timely resolution of safety issues early in the design effort.

Specific examples of safety improvements in design and infrastructure accomplished a= s a result of the Board's work are given below. Cross-references are provided to se= ctions in the body of this report where further details can be found.

Hanford Site (Sec. 4.2):

DOE continued working = to correct potential safety flaws in the design of the Waste Treatment Pl= ant. Progress was-made in coa= ting of structural steel for fire resistance and the development of design bases for mitigation systems used to prevent hydrogen deflagrations and detonations. DOE also has undertaken a seismic borehole project. The Board expects that ground = motion modeling using data due to this drilling program will effectively vali= date the seismic design ground motion. DOE also developed new structu= ral design criteria to address structural design issues raised by the Boar= d. (Board letters dated October 1= 7, 2005 and September 7, 2006)

DOE has improved the design for confinement of radioactive materials and worker protection = for the Demonstration Bulk Vitrification Project. (Board letter dated September = 7, 2005)

DOE is developing a revised safety basis for the Sludge Treatment Sub-project of the K-Bas= in Closure Project. When th= is work is finished in early 2007, the Board can complete its review of t= he project's design. (Board letter dated January 5, 2006)

Idaho National Laboratory (Sec. 4.7):

DOE directed the Integrated Waste Treatment Unit project to use a more conservative and commonly-used computer code for estimating radiological consequences f= or co-located workers and the public from postulated accidents. Further, the project conducted= a review of key safety analysis inputs and subsequently changed them for= many of the postulated accidents. These changes resulted in a mo= re technically defensible safety design basis. (Board letter dated January 24, 2007)

Los Alamos National Laboratory (Sec. 4.5):

DOE decided to classify the fire suppression system and the active confinement ventilation sys= tem for the Chemistry and Metallurgy Research Replacement Project facility= as safety class and safety significant, respectively. This will be the first DOE fac= ility to be designed and constructed with a safety-class fire protection sys= tem. If properly implemented,= this action should result in acceptable safety controls for this facility. = (staff-to-staff meetings; Site Representative Weekly Reports)

Nevada Test Site (Sec. 4.8):

DOE is performing a new structural and seismic analysis, plans to address water leaks, and is preparing a new safety analysis for the Critical Experiments Facility.= However, the facility structure still has numerous cracks that are considered abnormal for a nuclear facility. The Board is considering further action on this subject. (Board letter dated March 18, = 2005)

Savannah River Site (Sec. 4.3):

DOE undertook an exten= sive geotechnical site characterization program at the Salt Waste Processing Facility site, involving drilling and sampling of subsurface data, lab= oratory analysis of samples, and geotechnical analyses. Completion of the geotechnical engineering work at the Salt Waste Processing facility, including comp= rehensive DOE and peer reviews, will be critical to demonstrating that the desig= n is adequate to withstand seismic hazards. Significant improvements in the structural analysis methodologies are also being implemented. (Board letters dated August 27= , 2004 and January 10, 2007)

DOE successfully and safely started up the Tritium Extraction Facility. (Board letter dated December 1= 9, 2002)

DOE corrected weakness= es in the hazards analysis for= the 3013 Container Surveillance and Storage Capability Project. (Board letter dated January 29, 2007)

Y-12 National Security Complex (Sec. 4.4):

DOE assigned additional personnel to monitor construction activities at the Highly Enriched Uranium Materials Facility and initiated other corrective actions in response to the Board's observations. (Site Representative Weekly Re= ports)

Nuclear Safety Programs and Analysis

The Board's strategic performance goal for this area is to ensure that DOE develops, maintains, and implements regulations, contract requirements, guidance, and safety programs that ensure adequate protection of the health= and safety of workers and the public. The Board's oversight activities in= this area focus on generally applicable safety standards and on issues affecting= a variety of defense nuclear facilities.

As a result of the Board's efforts during 2006, DOE has taken actions to strengt= hen the technical competence of its contractors and federal employees, to estab= lish and implement safety standards, and to improve the quality of engineered sa= fety systems. DOE has also taken m= easures to enhance the effectiveness of oversight and integrated safety management.=

Specific examples of improvements in nuclear safety programs and analysis made in co= nsequence of the Board's work are given below. Cross-references are provided to se= ctions in the body of this report where further details can be found.

DOE strengthened its directives for oversight of complex, high-hazard nuclear operations and made progress implementing the new requirements in the complex. (Recommendation 2004- l)(Sec. = 5.1.2, 5.1.3)

DOE developed a new integrated safety management manual to clarify its expectations concer= ning implementation of integrated safety management by DOE personnel.
(Recommendation 2004- l)(Sec. 5.1.2)

DOE developed and implemented a process and criteria for delegating authorities to field personnel for fulfilling assigned safety responsibilities. (Recommendation 2004-1)(Sec. 5= .1.2)

DOE developed and exec= uted a Senior Technical Safety Manager Course. (Recommendation 2004- l)(Sec. = 5.1.2, 5.4.1)

DOE developed a direct= ive on "operating experience" and provided direction and a sched= ule for implementation. (Recommendation 2004- l)(Sec. = 5.1.2)

DOE established two Central Technical Authorities with associated support staff that centr= alize technical expertise and operational awareness to assure adequate and proper implementation of nuclear safety requirements. (Recommendation 2004-1 )(Sec. = 5.1.2)

DOE strengthened the oversight of nuclear criticality safety through more effective reviews= by the Criticality Safety Support Group. (Recommendation 97-2)(Sec. 5.3= .6)

DOE restructured and strengthened the Corporate Technical Intern Program. (Recommendation 2004-l)(Sec. 5= .4.1)

DOE developed and issu= ed a Ventilation System Evaluation Guidance document that identifies a set = of design and performance attributes that ventilation systems are being e= valuated against for identification of potential upgrades. (Recommendation 2004-2)(Sec. <= span style=3D'mso-bidi-font-size:13.0pt'>5.3.2)

Outstanding Safety Problems of Defense Nuclear Facilities

Integration of Safety in the Design of = New Defense Nuclear Facilities

The Board believes that improvement in the incorporation of safety in design of= new defense nuclear facilities is necessary. Therefore, the Board began a series= of public hearings, one in December 2005 and a second in July 2006, concerning= the integration of safety in design. During the initial public hearing, the Board focused on the adequacy of DOE's exis= ting directives related to the design of new facilities. As a result of the Board's first pu= blic hearing, DOE acknowledged that safety was not being integrated consistently into the early stages of the design of new defense nuclear facilities. DOE is revising its relevant direct= ives. These directives are expected to ma= ndate an appropriate set of requirements designed to better integrate safety into= the design of new defense nuclear facilities at the earliest stages of project management.

During the second public hearing, the Board further explored integration of safety= in design and the progress being made in implementing DOE's safety in design initiati= ves. DOE has made some progress in revising its directives. The Order was recently revised to r= eflect senior DOE management's objective of early integration of safety into the design process. In particular= , DOE Order 413.3A, Program and Project Managem= ent for the Acquisition of Capital Assets, requires that safety design repo= rts be prepared at the conceptual design and preliminary design stages, in addi= tion to the preliminary documented safety analysis prepared at the final design stage. These reports are envi= sioned to contain an evaluation of the safety aspects of the design. The Order delineates the need to ch= arter an Integrated Project Team led by the Federal Project Director at the conceptual design stage and further clarifies the safety role of DOE's Cent= ral Technical Authority, Chief of Defense Nuclear Safety, and Chief of Nuclear Safety. These are positive ch= anges that will enhance safety in design.

The Board is being proactive with DOE in promoting the timeliness of issue resolution.

The Board's staff has met with DOE headquarters personnel, federal project personnel, and contractor personnel to discuss several key projects, includ= ing the Uranium Processing Facility at the Y-12 National Security Complex and t= he Integrated Waste Treatment Unit at Idaho National Laboratory. These meetings have been aimed at developing a mutual understanding of the safety requirements for these new facilities and establishing common expectations for early design maturity a= nd early identification of safety issues and their resolution.

Finally, the Board has scheduled a third public hearing for March 2007. This hearing will be devoted to ear= ly issue identification, communication of Board issues to DOE, issue managemen= t, and timely issue closure or resolution.

Reinvigorating Integrated Safety Management

In 1995, the Board issued Recommendation 95-2, urging DOE to integrate work planning and safety planning more effectively. The methodology that evolved from t= his recommendation and from DOE's implementation plan is termed integrated safe= ty management. Integrated safety= management is a structured, comprehensive, common-sense approach to performing work sa= fely. Through integrated safety management, the Board has encouraged DOE to identify and implement measures= to protect the public, workers, and the environment from nuclear, chemical, and physical hazards. The identification of hazards and development of protective measures should be integrated.

In 2001, DOE achieved a major goal in its commitment to integrated safety management by verifying through comprehensive assessments that the basic elements of integrated safety management had been implemented at defense nuclear facilities. This was a commendable achievement. Over= the next three years, however, implementation faltered. In Recommendation 2004-1, the Board identified the need to reinvigorate integrated safety management through te= chnical and operational excellence based on nuclear safety standards subjected to rigorous oversight. DOE's implementation plan of June 2005, and its subsequent revision in October 20= 06, contained three major thrusts, one of which directly addresses integrated safety management.

In 2006 the Board closed Recommendation 95-2 after determining that the Recomm= endation 2004-1 implementation plan and the recently-issued Integrated Safety Management System Manu= al contain the actions necessary to reinvigorate the program. While progress has been made in 200= 6, overseeing the execution of DOE's implementation plan will continue to be a major focu= s of the Board's work in 2007.

Reliable Operation of Safety Systems

The Board remains committed to ensuring that DOE properly maintains safety syst= ems at defense nuclear facilities. Many defense nuclear facilities were constructed decades ago.

Especially in light of the aging of these facilities, protective features must be maintained in a serviceable and effective condition. For new facilities, on the other ha= nd, the Board focuses its attention on ensuring that safety systems are correct= ly identified, designed, and constructed.

Unfortunately, the Board continues to identify weaknesses in programs critical to continued reliable operation of safety systems: maintenance, testing, surveillance, quality assurance, detection and removal of counterfeit parts, configuration management, training, conduct of operations, and confinement strategies. DOE is working to make improvements= in many of these areas in respon= se to related recommendations from the Board, such as Recommendations 2000-2, 200= 2-1, 2004-1, and 2004-2. However, = as DOE continues to extend the life of aging facilities, and budgets tighten, ther= e is constant pressure to reduce the number of safety systems, to provide less effective maintenance, or to defer necessary infrastructure improvements.

A typical example of this issue exists at the 9212 Complex at Y-12 National Security Complex. This collec= tion of structures, built between 1947 and 1958, has numerous seismic deficienci= es, including missing bolts, missing or structurally inadequate braces, and inadequate beam supports. The= Board highlighted these issues in letters dated April and November 2005. DOE's response indicated that the m= ain long term action necessary to support safe operation is to construct the planned Uranium Processing Facility, which will be designed to efficiently = meet modern safety and security requirements. However, DOE has not fully defined = the remedies required to keep the 9212 Complex operational prior to completion = of the Uranium Processing Facility. The Board will continue to stress t= o DOE the importance of ensuring the long-term reliability of vital safety systems and the infrastructure needed to maintain them.

Safe Retrieval, Handling, and Stabiliza= tion of Nuclear Materials

The Board continues to provide close oversight of DOE's efforts to safely retri= eve, treat, and dispose of high-level wastes, spent fuel sludges, inactive actinides, and transuranic wastes. Many of these activities present significant programmatic and safety challenges to DOE. For example, the project to retrieve radioactive sludges from the K-Basins at the Hanford Site has experienced m= any delays and cost overruns during the past decade. DOE has isolated some sludge in sui= table containers to prevent release to the environment but faces new challenges i= n safely treating the sludge in a timely fashion.

At both the Hanford Site and the Savannah River Site, DOE is responsible for t= he safe storage of tens of millions of gallons of high-level waste tanks that = have exceeded their original design lives. While DOE has taken action to prolo= ng the lives of the tanks, high waste levels in the tanks continue to make transfer and treatme= nt operations difficult. Potenti= al waste leaks and mistransfers threaten the safety of workers and the environ= ment. The Board works with DOE to e= nsure that it continues to focus on the highest priority safety issues.

Many of DOE's facilities around the nation store large quantities of transuranic wastes in drums, a significant portion of which are buried under soil and in poor condition. The drums pose safety hazards, including contamination, high radiation, and potential explosions from the generation of hydrogen gas and volatile organic compoun= ds. The Board has urged DOE to improve = the consistency and rigor of the safety controls for these hazards. (Board letters dated January 5, 200= 6, January 17, 2006, January 18, 2007 and January 29, 2007) Improved safety be= comes more important as DOE begins to retrieve and treat remote-handled transuran= ic wastes that generate very high radiation fields and must be handled by remote-controlled equipment. DOE is planning to ship remote-handled wastes = from the Idaho Cleanup Project to the Waste Isolation Pilot Plant in 2007.

In 2006, the Board reviewed two principal deliverables of DOE's implementation plan for Recommendation 2005= -1: (1) nuclear material packagi= ng requirements and (2) a repackaging prioritization methodology. The Board found that fundamental er= rors in analyses and narrowing of scope had substantially precluded the intended benefits of both documents. T= he Board identified these errors in analysis and reasoning in letters dated Ap= ril 24, 2006 and May 1, 2006. DOE= 's responses, provided in letters dated June 8, 2006 and July 21, 2006, were n= ot satisfactory to the Board. Discussions between the Board and D= OE resulted in a DOE letter dated July 27, 2006, rescinding several of its responses. Further discussions between the Board and DOE have resulted in substantial progress toward resolving the Board's concerns. DOE subsequently revised its implementation plan for Recommendation 2005-1 in a letter dated November 22, 2006, to reflect the delays in completing these t= wo principal deliverables. The B= oard will continue to hold DOE to commitments it made to improve nuclear material packaging for protection of workers.

Deactivation and Decommissioning Operations

DOE continues to deactivate, decontaminate, and decommission many facilities at sites such as the Idaho Cleanup Project, Hanford Site, Savannah River Site,= Oak Ridge National Laboratory, and the Miamisburg Closure Project. In the past, the Board has noted that operating contractors lack the expertise to plan and conduct deactivation and decommissioning work. (Examples include the Board's lette= rs dated February 11, 2005 and February 14, 2005.) In these cases, DOE must bring in managers and workers who are familiar with the unique hazards of these activities and who understand the continua= lly changing nature of a facility undergoing decommissioning. Specialists are needed in nuclear criticality safety, fire protection, contamination control, and remote measurement of nuclear materials in piping, vessels, and systems. The Board will continue to provide = close oversight of these projects.

1. = Introduction

1.1&nbs= p; Background

The Defense Nuclear Facilities Safety Board is an independent federal agency established by Congress in 1989. = Simply stated, the Board's m= andate under the Atomic Energy Act is safety oversight of nuclear weapons faciliti= es managed by the Department of Energy. The nuclear weapons program remains= a complex and hazardous operation. DOE must maintain in readiness a nu= clear arsenal, dismantle surplus weapons, dispose of excess radioactive materials, maintain aging facilities, clean up surplus facilities, and construct new, complex, one-of-a-kind, high-hazard facilities for many purposes. All of these functions must be carr= ied out in a manner that protects the public, workers, and environment.

Congress established the Board as an independent agency to provide sound technical safety oversight of DOE's defense nuclear weapons facilities and operations= . For that reason, the Board is compo= sed of respected experts in the field of nuclear safety. The Board has, in turn, assembled a permanent staff with broad experience and competence in all major aspects of safety.

The Board has established site offices at six high-priority defense nuclear sit= es: Pantex Plant in Texas, Los Alamos National Laboratory in New Mexico, Y-12 National Security Complex in Tennes= see, Savannah River Site in South Carolina, Hanford Site in the State of Washing= ton, and Lawrence Livermore National Laboratory in California. The site offices provide the Board = with a continuous presence at these locations. At other locations, the Board maint= ains safety oversight by means of regular onsite reviews by members of its techn= ical staff.

During the Board's 17 years of operation, its priorities have evolved with changes= in the nuclear weapons program. = The Board uses its Strategic Plan, required by the Government Performance and Results Act, to ensure that its limited resources remain focused on the mos= t significant health and safety challenges and keep pace with shifts in those challenges = from year to year. The Board's hea= lth and safety oversight activities are closely tied to goals and objectives em= bodied in this plan.

This Annual Report summarizes the Board's work during calendar year 2006. Sections 2, 3, 4, and 5 des= cribe progress in the four major areas of the Board's operations: Nuclear Weapons Operations, Nuclear Materials Processing and Stabilization, Nuclear Facilities Design and Infrastructure, and Nuclear Safety Programs and Analysis. Section 6 explains the Board's inte= ractions with the public and reports on administrative matters. Appendix A lists all recommendations cited in this report, Appendix B lists all reporting requirements imposed o= n DOE in 2006, and Appendix C contains a full list of the Board's 2006 correspond= ence.

1.2&nbs= p; Oversight Strategy

Maintaining an effective safety oversight program that fulfills the broad mandates of t= he Board's enabling legislation requires continuing reassessment of health and safety conditions throughout DOE's defense nuclear complex. The Board concentrates its resource= s on the most hazardous operations and complex safety issues, guided by its Strategic Plan and the following principles.

Oversight Role - As an oversight but not a regulat= ory agency, the Board uses a variety of statutory powers to ensure adequate protection of the public and worker health and safety. While the Board is empowered to identify current and potential safety problems and to recommend soluti= ons, DOE remains responsible for taking actions based on the Board's insigh= ts.

Risk-Based Oversight - The Board's safety oversight activities are prioritized predominantly on the basis of risk to the public and workers, types and quantities of nuclear and hazardous mate= rial at hand, and hazards of the operations involved.

Technical Competence - The Board has endeavored s= ince its inception to ensure that DOE obtains and maintains the high level = of technical expertise essential to the management of nuclear activities.=

Line Management - Primary responsibility for safety resides in DOE and contractor management. Safety oversight can reinforce= but not substitute for the commitment of line management and workers to sa= fe work planning and performance.

Clear Expectations - Effective safety management deman= ds that safety expectations be clearly defined and tailored to specific hazards. Work instructio= ns that are clear, succinct, and relevant to the work are more likely to = be embraced by workers.

Effective Transition Planning - The Board's safety oversig= ht of defense nuclear facilities is coordinated with other federal agenci= es and with state governments to ensure a smooth transition from deactiva= tion and decommissioning to environmental regulation.

The Board is provided by statute with a number of tools to carry out its missio= n. Among these are recommendations (typically broad and comprehensive in nature), reporting requirements (focu= sed on specific safety issues), and public hearings (used to obtain information= from DOE, other expert sources, and the public at large). Since 1989 when the Board began ope= rations, it has issued 48 formal recommendations, comprising 221 individual sub-reco= mmendations. In that same period of time, the Board has issued 184 reporting require= ment letters and held 94 public hearings.

1.3 = Strategic Plan

The Board organizes its safety work by merging the broad health and safety mand= ate of its statute with the requirements of the Government Performance and Resu= lts Act. The Board's Strategic Pl= an identifies the serious hazards of handling nuclear weapons and weapons materials, and disposing of aging and surplus facilities. These hazards include:

Tons of radioactive and toxic materials throughout the defense nuclear complex, some stored in= an unstable state.

Aging facilities that require ever-increasing maintenance and surveillance to assure safety.=

The potential for accidental releases caused by inadequate safety controls, human errors, equipment malfunctions, chemical reactions, building fires, detonation= s, and criticality events.

Natural phenomena such= as wildfires, earthquakes, extreme winds, floods, and lightning.

Given these hazards, safety can be assured by the adoption of a conservative engineering philosophy that hinges on reliable systems and multiple layers = of protection. This concept is c= alled "defense in depth," and it has been a precept of nuclear safety in the United States for many decades. Defense in depth is especially impo= rtant with respect to the handling of high explosives in proximity to radioactive material.

The Board's Strategic Plan sets forth four general goals:

Nuclear Weapons Operations: Operations that directly support the nuclear stockpile and defense nuclear research are conduct= ed by DOE in a manner that ensures adequate protection of the health and safety of workers and t= he public.

Nuclear Materials Processing and Stabilization: Processing, stabilizing, and disposing of hazardous nuclear materials are performe= d by DOE in a manner that ensures adequate protection of the health and saf= ety of workers and the public.

Nuclear Facilities Design and Infrastructure: New defense nuclear facilities and major modifications to existing facilities are designed and constructed by D= OE in a manner that ensures adequate protection of the health and safety = of workers and the public.

Nuclear Safety Prog= rams and Analysis: Regulations, requiremen= ts, guidance, and safety management programs adequate to protect public he= alth and safety, including workers, are developed and implemented by DOE.

2. = Nuclear Weapons Operations

2.1&nbs= p; Safe Conduct of Stockpile Management

Stockpile management refers to the industrial aspects of maintaining the nation's nuc= lear weapons stockpile. Examples o= f the Board's activities to improve health and safety in stockpile management are discussed in the following subsections.

2.1.1 &nb= sp; Pantex Plant

The Pantex Plant, located near Amarillo, Texas, serves a central role in stockpile management. Operations at the site include asse= mbly, disassembly, dismantlement, and surveillance of weapons, as well as interim storage of special nuclear material removed from retired weapons. In 2006, the Board sought health and safety improvements in weapons ope= rations, requirements for the evaluation of weapons response to external stimuli, im= plementation of the special tooling program, and implementation of multi-unit operations= .

Nuclear Explosive Safety. In response to a commitment = made to the Board in 2005, DOE conducted a comprehensive "Top-Down Review"= ; of its nuclear explosive safety directives to determine if existing requiremen= ts are being implemented effectively, and to propose improvements to the requirements for ensuring the safety of nuclear explosive operations. On November 2, 2006, the Assistant = Deputy Administrator for Military Application and Stockpile Operations issued a corrective action plan to implement 11 of the 20 recommendations from the T= op-Down Review. The Board is conducti= ng its own review of the nuclear explosive safety process and has identified a num= ber of additional issues to be addressed in 2007.

W88 Cell Operations. During 2006, Los Alamos Nati= onal Laboratory requested that the W88 program take steps to restart cell operat= ions to perform disassembly and inspection on a limited number of units to suppo= rt a high priority, safety-related significant finding investigation. In order to meet this request in a = timely manner, the Pantex Plant contractor requested a temporary exemption from the documented safety analysis requirements of 10 CFR (Code of Federal Regulati= ons) Part 830, Nuclear Safety Management= , subpart B. In a letter dated August 9, 2006, the Board requested that t= he Deputy Administrator for Defense Programs consider compensatory measures for the proposed disassembly and inspection operations. In addition, the Board requested justification for proposed rebuild operations and any additional operations performed beyond the three units identified by Los Alamos, and that NA-10 consider the impact of the proposed operations on the timely implementation= of a Seamless Safety for the 21st Century process for W88 cell operations. The Deputy Administrator provided t= he requested information to the Board and issued a temporary exemption limited= to the disassembly and inspection and rebuild of three specific units. Direct observation of sensitive operations by laboratory experts was instituted as an additional safety mea= sure.

To ensure a safe approach to restart of W88 cell operations, the Board observed the limited scope nuclear explosive safety study, DOE'S readiness assessmen= t, and disassembly of the first W88 unit, which was in process at the end of 2= 006. The Board is continuing to pr= ess DOE to develop a firm schedule for implementing an SS-21 process for W88 operat= ions.

Recommendation 98-2. NNSA management continued to provide the Board with regular briefings on the status of commitments in the implementation plan for Recommendation 98-2. DOE completed the commitment to imp= lement an SS-21 process for a weapons program with insensitive main charge explosi= ves by implementing such a process for the B61, B83, and W87 programs in 2006.<= /p>

In May 2006, DOE issued a revision to Hazard Analysis Reports for Nuclear Explosive Operations (DOE= -STD-3016), which was intended in part to close the commitment in the implementation pl= an for Recommendation 98-2 to provide further guidance on expectations for the development and documentation of weapons response information. In a letter dated August 16, 2006, = the Board provided comments to DOE on the revision to the standard. DOE briefed the Board on its respon= ses to the Board's comments and described its planned approach to ensuring that ha= zard analysis reports and weapons response information were adequate. However, follow-up reviews by the B= oard found that there was still no clear plan for implementing improved processes for developing and documenting weapons response information. Therefore, in a letter dated Decemb= er 15, 2006, the Board requested that the Final Assessment Report required by the = implementation plan for Recommendation 98-2 include an explicit description of DOE's plans= and criteria for review and approval of the design agencies' processes for expe= rt elicitation, expert judgment, and peer review as required by DOE-STD-3016.<= /p>

Cell Gap Analysis. The Board evaluated calculat= ions of leakage through gaps in cells.

These calculations were performed to better understand the consequences of potent= ial accidents at the Pantex Plant. Based on= these calculations, leakage through cell gaps does not appear to be an issue for accident scenarios involving single-unit operations. However, there is still a concern t= hat accident consequences for multi-unit operations involving certain systems in certain facilities could challenge the evaluation guidelines. DOE will perform additional analyse= s to provide assurance that the evaluation guidelines will not be challenged for multi-u= nit operations.

Electrostatic Discharge. The Board evaluated efforts = by DOE and the weapons design

agencies to characterize potential electrostatic discharge effects and the response = of sensitive components to them. Progress has been made in defining = the environments and the associated hazards; however, the Board has identified = the need for additional clarification with respect to furniture (e.g., tooling = and equipment), capacitive coupling between the insulting objects and other nea= rby charged objects, the assumption of electrical isolation of tools within the= established standoff boundary, and resonance conditions and effects.

Special Tooling Program. In a letter dated December <= span style=3D'mso-bidi-font-size:12.5pt'>15, 2004, the Board expressed co= ncern that continuing weaknesses in the Special Tooling Program could have an adv= erse impact on the safety of nuclear explosive operations that rely on specially designed tools to eliminate or minimize hazards. In response, DOE conducted a comprehensive, independent review of tooling program deficiencies and commi= tted to implementing corrective actions. The Board reviewed the program in M= arch 2006 and determined that the safety and efficiency of nuclear explosive operations had been enhanced.

Seamless Safety for the 21st Century. In 2006, the Board evaluated= the start-up of the Seamless Safety processes for the W87 and B61 Disassembly <= span style=3D'mso-bidi-font-size:11.5pt;mso-bidi-font-family:Arial'>& Inspection and Rebuild Programs and the B83 Disassembly & Inspection Program. The enhanced processes utilize upgr= aded procedures, redesigned tooling, and fewer handling and lifting steps. These improvements make the operati= ons significantly safer and more efficient than their predecessors.

Safety of Dismantlement Operations. The Board evaluated process development and execution of the W56 dismantlement campaign at Pantex. The Board urged DOE to ensure that = laboratory expertise, both active and retired, was applied to resolve technical challe= nges that arose to help ensure the safe and successful completion of the dismantlement campaign. Disma= ntlement of all W56 war reserve units was safely completed in June 2006.

The Board continued to evaluate DOE's plans to dismantle an older weapons system not protected by modern safety controls. The Board expressed concern to DOE regarding proposed disassembly activities at non-DOE facilities that did not have adequate safety programs and systems. DOE no longer plans to use such facilities; dismantlement operations are now planned for Pantex facilities.=

Conduct of Operations. In response to a Board letter issued in May 2005 identifying deficiencies in the conduct of nuclear explo= sive operations at Pantex, DOE initiated efforts to address the cause of the deficiencies and to develop both near- and long-term plans to improve the conduct of operations. After a follow-up review, the Board issued a letter to DOE in March 2006, re-emphasizing the importance of a consistently high degree of formality in= the conduct of nuclear explosive operations, and favorably noting the extensive involvement of senior contractor management in developing and implementing improvements in conduct of operations at Pantex. As proposed improvements are implem= ented and the process matures, the Board expects to see continued improvement in = this area. The Board is continuing= to evaluate improvements in the formality of work through daily operational ov= ersight provided by its site representatives.

Multi-Unit Operations. The Board is evaluating the = safety implications of the implementation of multi-unit nuclear explosive operatio= ns at Pantex, which are being pursued in support of increasing throughput. In response to the Board's observations, Pantex is taking a more comprehensive approach to evaluating the implementation of multi-unit operations, including analyzing human factors considerations. In addition, the Board has urged Pa= ntex to become more closely involved with studies being performed by the design agencies that will aid in evaluating the increase in risk associated with performing multi-unit operations.

Technical Safety Requirement Implementa= tion. In October 2006, the contrac= tor at Pantex completed the implementation of more than 200 Technical Safety Requirements.

Continued engagement by the Board during this three-year effort resulted in the imple= mentation of some new controls and improved the overall quality of the safety basis documents. DOE has so far ver= ified implementation of 138 of t= hese controls. The Board will cont= inue to monitor implementation of Technical Safety Requirements.

2.1.2&n= bsp; Y-12 National Security Complex

Y-12 National Security Complex is a manufacturing facility located in Oak Ridge,= Tennessee. Stockpile management activiti= es at Y-12 include production, maintenance, refurbishment, dismantlement, evaluat= ion, and storage of certain components of nuclear weapons. Production activities include manuf= acture or re-manufacture of unique nuclear weapons components. The Board's most recent efforts to improve safety at Y-12 concentrated on highly enriched uranium processing, conduct of operations, fire protection, and the safety of several new or modified processing capabilities.

9212 Complex Seismic Deficiencies. The 9212 Complex at Y-12 is a collection of structures built between 1947 and 1958 for processing highly enriched uranium. While updat= ing the complex's safety basis in 2004, DOE noted numerous seismic deficiencies, in= cluding missing bolts, missing or structurally inadequate braces, inadequate beam supports, and designs that are deficient when measured by current design requirements for nuclear facilities. In addition to the facility structure, internal systems are subject to seismic failure, including tall glass columns and sight glasses, can restraints, storage racks, and storage tanks.

In response to Board letters issued = in April and November 2005, DOE agreed to perform maintenance-related fixes and other practical facility modifications to the 9212 Complex and to perform a revie= w to identify other actions needed to support safe operations. DOE provided the results of this re= view to the Board in November 2006. The reviewers concluded that the most practical approach to improving the safety posture of the 9212 Complex is to reduce the inventory of nuclear materials= in the facility. DOE plans to in= crease maintenance funding and pursue other facility infrastructure improvements w= hile working to accomplish that inventory reduction.

DOE's response also indicated that the main long term action necessary to support safe processing of highly enriched uranium at Y-12 is to construct the plan= ned Uranium Processing Facility, which will be designed to efficiently meet mod= ern safety and security requirements. By year's end, however, DOE had not defined the point at which more aggressive remedies would be required to ke= ep the 9212 Complex operational, should this facility be delayed, and what tho= se remedies would entail. The Bo= ard is continuing discussions with DOE on this matter.

9212 Complex Safety Analysis. The Board reviewed a draft v= ersion of the documented safety analysis for the 9212 Complex, the final Y-12 faci= lity to implement a safety basis in accordance with 10 CFR Part 830. The Board noted weaknesses associat= ed with the calculation of off-site consequences that resulted in improper classification of safety systems, including certain fire protection systems= . The Board communicated these issues= to DOE in a letter in February 2006. In response, DOE upgraded the classification of key fire protection systems to safety-class. Discussions continue with DOE on the safety analysis methodology for Y-12 facilities.

Conduct of Operations. The Board had noted overall = improvement in the proper conduct and formality of nuclear operations at Y-12 during re= cent years. However, following sev= eral operational errors and events at this facility, the Board urged DOE to cons= ider special action to achieve consistent, disciplined operations in Y-12 nuclear facilities. Examples included= failure to adhere to criticality safety requirements, an inadvertent hazardous gas release, and conduct of a nuclear operation without proper authorization. <= span style=3D'mso-spacerun:yes'> DOE evaluated the concerns and conc= luded that the events were generally caused by lack of adherence to procedures or nonconservative decisions by operations personnel upon encountering an unanticipated condition. DOE developed a plan in December 2006 that outlines actions to address these ca= uses. With proper implementation, t= he plan should improve conduct of operations at Y-12.

Uranium Holdup Survey Program. The Y-12 Uranium Holdup Survey Program = is used to monitor accumulations of enriched uranium in process systems to pro= tect against an inadvertent criticality. DOE developed a corrective action p= lan to address issues identified by both DOE's and the Board's assessment in 2005 = and for operational events in 2006 where the program failed to identify fissile material accumulations. During 2006, DOE made progress on equipment upgrades and in improving the formalit= y in identifying and responding to high accumulations of enriched uranium. DOE also implemented a new approach= to evaluate uranium holdup using design features, periodic cleanout, and routi= ne hold-up monitoring in combination for all uranium process operations that r= ely on the holdup program.

Criticality Safety. In April, the Uranium Holdup Survey Program indicated a large = holdup in a filter in a system providing vacuum to uranium casting furnaces. Initial criticality safety assessme= nts concluded that lack of moderation was the only remaining contingency preclu= ding a criticality accident. Subsequently, a moderator (oil) was observed to have leaked from the filter housing. This represented a serious safety c= oncern. The Board provided input rega= rding assay procedures, criticality calculations, and the approach to filter clea= nout for DOE's consideration in developing a recovery plan. The Board's input resulted in a more demonstrably safe recovery operation.

Fire Protection. In response to Board correspondence in 2002, DOE developed a ten-year comprehensive improvement = plan for fire protection at Y-12. Significant improvements were subsequently made in many facets of fire protection, such as maintenance of systems, analysis of fire hazards, and inspection of fire barriers. Progress stalled in 2006 due to a c= ut in funding for the project. The Board qu= eried DOE on plans for completing the project. DOE committed to provide a revised = plan in early 2007.

Quality Assurance. Because of quality assurance problems found during construction of the Highly Enriched Uranium Materials Facility, and other site-wide quality assurance problems identified in early 2006, DOE developed a site-wide corrective action plan. The Board reviewed the plan and pro= vided specific comments. Based on t= his feedback, DOE chartered a local steering group to review the effectiveness = of completed corrective actions, and the contractor provided corporate-level resources to conduct a review of corrective action progress.

Conduct of Engineering. In 2005, Y-12 personnel disc= overed that the design of a new vessel installed for blending enriched uranium materials would not preclude a criticality accident in a water intrusion scenario. A design change was necessary to correct this deficiency. Subs= equently, the Board found that a planned Y-12 investigation of this engineering deficiency had not been completed. In response to an inquiry by the Bo= ard, Y-12 completed the investigation and developed corrective actions. The Board found that the corrective actions did not fully address the lack of an appropriate design review of t= he new installation. At year's e= nd, Y-12 was evaluating its engineering protocols regarding performance of design reviews for the installation of new process equipment and systems.

2.1.3      = Savannah River Site Tritium Operations

Tritium Extraction Facility.= The Tritium Extraction Facil= ity will be used to extract tritium from target rods irradiated in commercial l= ight water reactors. The extracted tritium will be used to replenish tritium reserves for the nation's nuclear weapons stockpile. During 200= 6, the Board reviewed startup preparations, observed readiness reviews conducted by the contractor and by DOE, and as the year ended, monitored the startup of nuclear operations. During th= e readiness reviews, the contractor demonstrated the ability to safely perform extracti= on evolutions, but did not demonstrate the ability to routinely conduct these evolutions w= ithout frequent work interruptions or compensatory actions to address equipment reliability issues. Frequent problems were encountered with the ventilation system, the Tritium Rod Preparation Module, various cranes, several electronic procedures, and the = Tritium Air Monitoring System. While = these problems were handled correctly, the Board encouraged the Savannah River Si= te to take full advantage of site programs for System Health Reports and performance monitoring, because repeated equipment problems can lead to complacency (i.e., deficient conditions become viewed as normal) and other conduct of operations problems.

2.1.4      = Nuclear Material Packaging

Recommendation 2005-1. The Board issued Recommendat= ion 2005-1 to provide more reliable protection for workers from the hazards associated with storage and handling of nuclear materials. The recommendation stated, and DOE accepted, the fundamental principle that this would be achieved by issuing a requirement that "nuclear material packaging meet technically justified criteria for safe storage and handling." In 2006, the Board reviewed two pri= ncipal deliverables of DOE'S implementation plan for Recommendation 2005-1: (1) a methodology for assigning priorities to repackaging operations, and (2) a manual for these operations= .

The methodology was issued by DOE on March 31, 2006. In a letter dated April 24, 2006, the Board pointed out erro= rs in analysis and reasoning. DO= E's response, provided in a letter dated July 21, 2006, was not satisfactory to= the Board and was partially rescinded by DOE in a letter dated July 27, 2006, pending further discussions between DOE and the Board. DOE subsequently revised its implementation plan for Recommendation 2005-1 in a letter dated November 22= , 2006, noting that the methodology was being further evaluated based on comments f= rom the Board and would be revised and reissued, if warranted, by February 28, = 2007.

In its implementation plan, DOE committed to issuing packaging requirements fo= r "materials that are stored outside of an approved engineered contamination confinement barrier, such as a glovebox or packages meeting DOE-STD-3013 and/or DOE-STD-3028." These req= uirements are to be issued as a new DOE Nuclear Material Packaging Manual, a draft version of which = was sent to Board for comment on March 31, 2006. In a letter to DOE dated May 1, 2006, the Board identified deficiencies that would undermine the safety benefits of the manual if not appropriately resolved, such as wording that would allow the sites to exclude many hazard= ous nuclear materials from the scope of the manual without ensuring that adequa= tely engineered protection would be provided for workers. DOE's response, provided in a letter dated June 8, 2006, was not satisfactory to the Board. Further discussions between the Boa= rd and DOE have resulted in substantial progress toward resolving the Board's comm= ents on the draft packaging manual. DOE's revised implementation plan f= or Recommendation 2005-1 commits to submitting the packaging and storage requirements document into DOE's Directives System by February 28, 2007. The Board will continue to ensure t= hat DOE meets its commitment to improve nuclear material packaging for protecti= on of its workers.

2.2      =         Safe Conduct of Stockpile Stewardship

Stockpile stewardship refers to activities carried out in the absence of underground nuclear weapons testing to ensure confidence in = the safety, security, and reliability of nuclear weapons in the nation's stockp= ile. Stockpile stewardship includes using past nuclear test data in combination with future non-weapons test da= ta and aggressive application of computer modeling, experimental facilities, a= nd simulations. Safety aspects of activities at the major sites engaged in stockpile stewardship are discusse= d in the following subsections.

2.2.1      = Los Alamos National Laboratory

Los Alamos National Laboratory, located in New Mexico, is the DOE weapons labor= atory with the largest number of defense nuclear facilities and weapons-related activities. In 2006, a new contracting structure was put in place for management of the laboratory. The Board focused its attention on institutional corrective actions, federal oversigh= t, active confinement ventilation, nuclear criticality safety, fire protection, and transuranic waste operations.

Institutional Corrective Actions. The Board spent considerable effort, including holding a public hearing on March 22, 2006, reviewing DOE's institutional corrective action pr= ograms and heightening awareness of the need to maintain these programs through contract transition. Correcti= ve actions focus on key areas including safety, quality assurance, software qu= ality assurance, conduct of engineering, safety bases, conduct of operations, environmental risk management, and training. The Board has urged DOE to adequate= ly fund corrective action plans.

Federal Oversight. On October 1, 2006, DOE bega= n a two-year pilot of a new federal oversight model at the Los Alamos Site Offi= ce. The pilot increases the federal pre= sence in nuclear and high hazard facilities and relies on the contractor's assura= nce systems to monitor less hazardous operations. The Board objected to the concept o= f the pilot and raised specific concerns including the lack of compensatory measu= res in oversight for the period of time it takes for the contractor's assurance system to reach full effectiveness and maturity; the absence of federal ove= rsight of radiological facilities under the pilot; and significant weaknesses in t= he technical capability of the federal workforce.

Confinement Ventilation at the Plutonium Facility. The current saf= ety basis for the Plutonium Facility relies on a passive confinement strategy t= hat does not credit active confinement ventilation for protecting the public fr= om postulated accidents. In resp= onse to issues raised by the Board, a comprehensive set of airflow calculations = was performed to estimate potential releases under accident conditions. The analysis demonstrated that the passive confinement strategy was inadequate, and the laboratory developed preliminary compensatory measures and alternatives for the confinement stra= tegy. Under the implementation plan= for the Board's Recommendation 2004-2, confinement ventilation at this facility= is now being assessed on a high priority basis with an accelerated schedule. <= span style=3D'mso-spacerun:yes'> The Board will continue to review a= nd provide feedback to DOE.

Fire Protection. On May 15, 2006, the Board received DOE's response to issues previously identified by the Board regard= ing the need to define a multi-year strategy for timely resolution of all fire protection deficiencies and achievement of site-wide improvements. Issues requiring resolution included incomplete documentation and delays in the completion of inspections, tests, and maintenance; untimely implementation of fire hazard analysis recommenda= tions; no formal plan to address the Baseline Needs Assessment for fire and emerge= ncy services; no long-term contract for fire and emergency services with Los Al= amos County; and fire alarm systems in several defense nuclear facilities still requiring upgrades. DOE is currently updating the strategy to reflect additional scope and funding adjustments. Overall, the Boa= rd has succeeded in increasing management attention to the fire protection problem= s, but these problems will take additional analysis, time, and attention to fu= lly resolve.

Transuranic Waste Operations. The Board has been closely following efforts to safely dispose of the laboratory's large inventory of transuranic waste, which is packaged in drums and other containers within several hundred meters of the site boundary. Some of the highest consequence acc= idents postulated at the laboratory involve this transuranic waste inventory. The Board has urged DOE to expediti= ously develop a viable disposition pathway for this waste.

Support of Nuclear Weapons Operations at Pantex. In August 2006, the Board assess= ed the laboratory's protocols for support of operations at the Pantex Plant. With respect to elements of the Boa= rd's Recommendation 2002-2, the Board found a lack of succession planning for we= apons system experts. The Board also observed a lack of progress toward developing a formalized expert elicitati= on (or expert judgment) process for review of weapons response information, wh= ich in part led to the Board's December 15, 2006, letter to DOE requesting its = plans for the review and approval of these essential design agency processes.

Power Grid Infrastructure Upgrade Proje= ct. In reports dated May 5, 1995, December 5, 1996 and September 22, 1999, the Board noted that a single-point failure vulnerability existed in the high-voltage transmission lines that provide off-site power to the laboratory. A failure at this single point, whe= re aerial transmission lines from each of the independent feeds crossed, could have isolated the laboratory from off-site power for an extended time until repairs could be performed. In response, DOE initiated a projec= t to eliminate this single-point failure vulnerability by providing an independe= nt power feed to the existing Western Tech Area substation. Construction of the independent pow= er feed was completed in 2006, and overall project completion is scheduled for spring 2007.

2.2.2      = Lawrence Livermore National Laboratory

Lawrence Livermore National Laboratory, 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 consulting on the s= urveillance and dismantlement of nuclear weapons. Most defense nuclear activities are= conducted in the Superblock complex, which includes the Plutonium Facility and the Tritium Facility. During 2006= , the Board conducted reviews of resumption of operations in the Plutonium Facili= ty, configuration management of vital safety systems at the Superblock faciliti= es, criticality safety, fire protection, and conduct of operations.

Resumption of Plutonium Facility Operat= ions. In January 2005, DOE's Offic= e of Independent Oversight and Performance Assurance issued a report identifying serious def= iciencies in the administrative control programs mandated by the Technical Safety Req= uirements for the Plutonium Facility (including the configuration management program)= , as well as deficiencies in the supporting analyses for safety systems. Because of these findings, the labo= ratory suspended programmatic operations in the Plutonium Facility. The Board issued a letter to DOE on= March 8, 2005, cautioning against resuming operations until the assessment report= 's findings had been adequately studied and requesting a report on planned corrective actions. On Octobe= r 11, 2005, DOE authorized the resumption of limited operations in the Plutonium Facili= ty using a process for achieving and verifying readiness found generally accep= table by the Board. In April 2006, = the Board observed the laboratory's readiness assessment to remove the remaining compensatory measures and return to normal operations, and determined that operations could safely resume. On May 23, 2006, DOE authorized the laboratory to resume normal operations.

Configuration Management. In a November 2004 letter, t= he Board identified the apparent lack of configuration management of vital saf= ety systems at Lawrence Livermore facilities. DOE responded on January 4, 2005, agreeing that prompt action needed to be taken to review the configuration = and condition of all vital safety systems in defense nuclear facilities at the laboratory. During 2005, DOE completed evaluations of the application of configuration management for the vital safety systems at Lawrence Livermore defense nuclear facilities and d= eveloped plans to establish the needed configuration management program. During 2006, the laboratory establi= shed procedures and processes to maintain an interim configuration management sy= stem. The Board reviewed this syste= m and found it to be reasonably adequate to support operations while a more durab= le institutionalized program is developed and implemented.

Criticality Safety. In response to the Board's Recommendation 97-2, DOE established an interim capability at the laborator= y in 2006 for hands-on criticality safety training that meets DOE- STD-1135-99, = Guidance for Nuclear Criticality Safety Engineer Training and Qualification. <= /span>Training classes previously held at Los Alamos National Laboratory had been halted pending the establishment of a suitable location. Lawrence Livermore conducted the fi= rst hands-on training class in September 2006.

2.2.3      = Nevada Test Site

The Nevada Test Site is located in southern Nevada, about 75 miles northwest of= Las Vegas. Stockpile activities a= t the Test Site include test readiness preparations, planning for the disposition= of damaged nuclear weapons, and subcritical experiments. Underground testing of nuclear weap= ons is no longer being conducted; however, the site is maintained in a state of re= adiness should national security requirements demand the resumption of underground testing. The Board seeks to e= nsure that if testing is resumed, it will be done safely. During 2006, the Board focused its attention on the Device Assembly Facility, test readiness posture, capabili= ty to dispose of a damaged nuclear weapon, subcritical experiments, and conduc= t of transuranic waste operations.

Device Assembly Facility. The Device Assembly Facility= is a key structure at the Nevada Test Site, intended to house diverse operations including nuclear explosive operations and criticality experiments. In 2004, the Board requested that DOE assess the Device Assembly Facili= ty's safety systems and management programs. DOE attempted to respond by using t= he site office's assessment program, but this was ineffective in delivering a comprehensive assessment. The= Board wrote to DOE again on November 28, 2005, requesting that more aggressive ac= tion be taken with respect to the assessment of the safety systems and management programs needed to ensure that the Device Assembly Facility is ready for planned increases in the scope of work. In response, DOE developed assessment plans for each vital safety system and safety management program and began assessments in 2006. Assessments and corrective actions = will continue in 2007.

The Board evaluated the physical condition of the Device Assembly Facility and found extensive rainwater leakage and extensive cracking in the facility's walls and floors. The Board a= dvised DOE in a letter dated Marc= h 18, 2005, that an immediate and thorough evaluation was needed. DOE has taken suitable remediation actions, but the Board is still concerned that the extensive cracking might have been the result of poor construction practices that adversely affected= the concrete's in situ strength. = The Board has advised DOE that it would be prudent to evaluate the in situ conc= rete compressive strength using non-destructive investigation techniques, assess= the potential for long-term rebar corrosion, and assure confinement and leak ti= ghtness of the bays and cells. Howeve= r, DOE has declined to perform in situ testing of the concrete. The Board is considering further ac= tion on this subject.

Damaged Weapons. The Board has consistently highlighted to DOE the need to develop the programs and infrastructure necessary to safely dispose of a damaged nuclear weapon or improvised nucle= ar device. G Tunnel at Nevada Test Site is the location DOE has selected for these activities. In a March 28, 2005 letter to DO= E, the Board noted the slow progress in defining and executing an action plan for addressing known problems with G Tunnel. The Board subsequently determined t= hat DOE no longer had a clear plan for meeting this programmatic need. In a June 19, 2006 letter to DOE, t= he Board requested that DOE explain the required state of facility readiness a= nd its plans for safety improvements, because it did not appear the mission and hazards had changed. DOE resp= onded with a new statement of policy for the disposition mission at the Test Site, including a new scope of operations at G Tunnel. In follow-up d= iscussions, DOE stated that a revised safety analysis is being developed that will iden= tify safety controls and upgrades appropriate for the new scope of operations. <= span style=3D'mso-spacerun:yes'> The Board expects the new analysis = to be available for review in 2007.

Subcritical Experiments. The Board reviewed preparati= ons for subcritical experiments at the Test Site and identified inadequate nucl= ear safety management programs. D= OE made improvements for the UNICORN experiment in 2006 in areas such as safety basis reviews, implementation of controls, = and readiness reviews. As a resul= t, UNICORN had a more complete documented safety analysis and thorough verification of readiness. Th= e Board has stressed to DOE that it is essential to carry the improved practices and formality forward for future subcritical experiments and as part of maintai= ning nuclear test readiness.

Safety Basis Reviews. The Board continued to revie= w the safety bases for nuclear facilities and activities, including the Device Assembly Facility, Criticality Experiments Facility Project, Ula Complex, Radioactive Waste Management Complex, G Tunnel, subcritical experiments, and onsite transportation. Althou= gh the safety bases are improving substantially, in 2006 the Board identified deficiencies in submitted documented safety analyses and technical safety requirements, classification of a facility, and in a Transportation Safety Document. Several iterations = of DOE review and document revision are needed to develop and implement adequate safety bases.

Lightning Protection and Electrical Sys= tems. In 2003 and 2005, the Board noted deficiencies in lightning protection and in electrical systems. In the past three years, DOE has made gradual improvements. In 2006, a site-wide directive for the lightning protection program was completed, as well as lightning protection studies. As a result, the Test Site now has = a technical basis to identify appropriate controls for lightning protection for hazardo= us operations and has implemented a site-wide lightning protection program and controls. Remaining electrica= l safety issues include oil-insulated transformers at the Device Assembly Facility, = an antiquated ventilation system in = G Tunnel, and the need to demonstrate the adequacy of the Faraday cage in the operati= ons alcove in G Tunnel.

2.2.4      = Sandia National Laboratories

Sandia National Laboratories are located in Albuquerque, New Mexico, and Livermore= , California. Major defense nuclear facilit= ies at Sandia, most of which are located in Technical Area V at the New Mexico site, include the Annular Core Research Reactor, Auxiliary Hot Cell Facility, Gamma Irradiation Facility, and Sandia Pulsed Reactor Facility. In September 2004, the Board issued a letter questioning the adequacy of safety bases at Sandia. Subsequently, the Boa= rd issued a letter asking for a schedule of actions to be taken to ensure that integrated safety management is fully implemented at Sandia. Follow-up reviews performed by the = Board during 2006 found that DOE has continued to make progress toward completing= the corrective actions for the identified deficiencies.

2.2.5      = Research and Development for Explosives Safety

The Board reviewed research and development on high explosives and weapon deton= ator safety for Pantex Plant operations, as conducted at both Los Alamos and Lawrence Livermore National Laboratories. The laboratories are testing detona= tors for electrostatic discharge hazards and reviewing the safety of operations = with certain detonators at Pantex. One very positive outcome has been the installation of special static dissipati= ve flooring in certain Pantex Plant facilities as an engineered safety control= to mitigate electrostatic discharge concerns for a weapons system. The Board also reviewed work at Los Alamos and Lawrence Livermore to determine the effects of aging on weapon explosives. Low-velocity impa= ct and mechanical strength testing are being used to model and predict the propert= ies of aged explosives. The Board= observed from these data that a certain aged explosive was safe for planned operatio= ns.

DOE briefed the Board on the Enhanced Surveillance Campaign in December 2006. This campaign has funded significant research and development on the effects of aging on numerous st= ockpile components with safety implications. Recent accomplishments include rese= arch and development support for stockpile transformation and infrastructure, significant finding investigations, annual assessments of weapons systems, = and new diagnostics for stockpile surveillance.

5. = Nuclear Safety Programs and Analysis

5.1&nbs= p; Federal Oversight

5.1.1 = Overview

To meet its statutory health and safety mandate, the Board must continuously assess DOE's ability to achieve adequate oversight of contractor work. Oversight, in this context, includes Federal line-management assessment of contractors, contractor self-assessme= nt, and independent assessment of both Federal and contractor work. For much of the work conducted in t= he defense nuclear complex, DOE relies upon contractors to perform inherently risky activities in government-owned facilities. These activities are nevertheless governed by nuclear safety requirements promulgated by the government. Thus, DOE fills three simultaneous = roles: owner, customer, and regulato= r. Preventing conflict among these rol= es requires a complex oversight system strained by competing demands that must= be reconciled to ensure that the overall mission is achieved safely.

5.1.2 = Recommendations 95-2 and 2004-1

The Board continued driving DOE to improve its oversight of complex, high-hazar= d nuclear operations. One important asp= ect of that oversight is integrated safety management, a concept that evolved from Recommendation 95-2 and is= being further developed and implemented in response to Recommendation 2004-1. The basic tenets of this approach p= rovide the framework for safely performing all of the diverse hazardous activities= in the defense nuclear complex. = Integrated safety management provid= es for a single safety management program rather than multiple, unintegrated progr= ams (e.g., quality assurance and environmental management). Nuclear safety is an important but= not exclusive target, because nonradioactive hazardous materials and operations= can also present significant risk. Integrated safety management builds= upon standards of safe practice for nuclear, chemical, and other hazardous operations to ensure protection of the public, workers, and the environment= . In 2006, the Board issued a technic= al report, Integrated Safety Management: = The Foundation for an Effective Saf= ety Culture (DNFSB/TECH-36). T= his report documents a detailed examination of the current status and effective= ness of integrated safety management systems at the seven NNSA weapons sites, su= mmarizes failures and good practices, and proposes changes to enhance the effectiven= ess of these systems.

DOE completed the following actions in 2006:

· designated a chair for the Integrated Safety Management Council;

· established two Central Technical Authorities with associated technical support staff;

· issued a new DOE policy and order on DOE oversight;

· implemented a nuclear safety research functi= on;

· strengthened the technical qualification program for Federal safety assur= ance personnel;

· implemented a formal safety delegation and assignment process; and

· took steps to improve the implementation of = the "feedback and improvement" function, including issuance of a new = DOE Order describing the Operating Experience Program.

DOE also performed a review of Recommendation 2004-1 implementation plan commit= ments. Based on the results of the r= eviews and experience with implementation to date, DOE developed a revision to the plan that the Board found acceptable. The Board also took this opportunit= y to close Recommendation 95-2. The Board concluded that the Recommendation 2004-1 plan and the recently-issued= DOE Manual 450.4-1, Integrated Safety Management System Manual, contained the actions necessa= ry to reinvigorate integrated safety management.

5.1.3 = DOE Oversight Policy and Order

In accordance with the implement= ation plan for Recommendation 2004-1, DOE issued a new policy and order (Order 22= 6.1, Implementation of Department of Energy Oversight Policy) on federal oversight, bringing together for the first time specific guidance and detailed requirements for federal oversight of safety, security, and business operations. In development is an oversight guide providing more detailed guidelines= and lines of inquiry. These steps= are intended to ensure a more uniform process for oversight of DOE's activities.

The order was scheduled to be implemented by DOE and its contractors by Septemb= er 2006. In early 2006, the Board's reviews showed that most sites ne= eded to fill a substantial gap to fully implement these safety requirements by t= he required date. In March 2006, the Board provide= d to DOE the results of a detailed review of the technical assessment, safety sy= stem oversight, and management walkthrough programs at the Savannah River Operat= ions Office. The Board's report no= ted a substantial gap between current performance and the requirements of Order 2= 26.1, and expressed concern with the limited actions taken at that time to implem= ent the new order.

In response to the Board's March 2006 letter, DOE assigned a lead at Savannah River for implementing the new requirements, conducted a formal gap analysi= s, and developed an implementation plan. In addition, DOE developed a new Integrated Performance Assurance Manual and plans to conduct structured and comprehensive assessments of the contractor's performance starting in 2007. While significant improvements were= made in 2006, progress was hindered by a number of DOE staffing deficiencies. The Board is also concerned that th= e decision to increase the number of contractors at Savannah River and the increased u= se of small business contracts in the future will make the situation even more challenging.

The Board's March 2006 letter also requested that DOE provide its implementation plans for the new directives across the complex and encouraged DOE to take aggressive steps to implement the 226 series of directives. These steps could include assigning= a lead for implementing the new requirements, performing a formal gap analysi= s, and developing an implementation plan. Without these, or similar positive = steps, the Board had little confidence that the programs would be implemented with= in the one-year requirement. DOE provided plans to the Board for implementing the directives in June 2006, a= nd more detailed implementation plans in September 2006. At the end of 2006, however, implementation of the new directives was still not complete. The Board will continue to follow implementation and effectiveness of the federal oversight programs in 2007.=

5.1.4 = Vital Safety Systems

In response to Recommendation 2000-2, DOE has taken steps to ensure the operability of vital safety systems. During 2006, at the request of the = Board, DOE reported its progress. Ba= sed on a detailed review of the information provided, the Board has concluded that= two sites, Lawrence Livermore National Laboratory and the Los Alamos National L= aboratory, have not fully implemented a program to verify configuration management of vital safety systems.

5.1.5 = Activity-Level Work Planning

The Board has continuously emphasized the importance of ensuring that hazards a= re identified and controlled, work is performed in a careful manner in accordance with the safety controls, and that DOE uses appropriate feedback mechanisms to ensure continuous improvement at the individual activity level. In its implementation plan for Recommendation 2004-1, DOE acknowledged = the need to strengthen this area and committed to enhanced focus on work planni= ng and work control at the field office level. In 2006, the Board continued to provide technical oversight of activity-level work planning within the DOE complex. Reviews of three activities at the Hanford site and one at Oak Ridge National Laboratory were conducted. At both of these sites, DOE had made significant improvements, but it is too early to tell if these changes have been fully captured in institutional policies and procedures.

5.1.6 = Small Business Contracting

Section 6022(c) of Public Law 109-13 mandated that the Administrator of the Small B= usiness Administration, Chief Counsel for Advocacy of the Small Business Administration, Chairman of the Defense Nuclear Facilities Safety Board, Secretary of Energy, and Administrator of NNSA jointly conduct a study on m= eans to promote opportunities for small business participation in DOE'S contract= ing system. While the study cover= ed contracting for all DOE facilities, the Board limited its involvement to contracts at defense nuclear facilities.

The Board provided its input to DOE for the report on September 2, 2005 and DOE= issued the final report on June 27, 2006. The Board noted that in exercising = its safety oversight responsibilities, it has no preference on the size of contractors managing defense nuclear facilities or activities. The Board expects defense nuclear w= ork to be conducted safely. Hence, r= egardless of the size of the contractor, work should be conducted under the same contractual requirements, with the same degree of formality, and with the s= ame level of safety oversight by DOE and the Board. The Board noted that substantially increasing the number of prime contractors increases the number of DOE staff necessary to discharge non-delegable safety functions. DOE is already short of trained sta= ff.

5.2&nbs= p; Health and Safety Directives

5.2.1 = Improvement of Directives

In 2006, as part of its ongoing review of new and revised DOE directives, the Board evaluated and provided constructive critiques of 38 directives dealing with nuclear design criteria, maintenance management, worker protection, emergency management, and project management. At year's end, the Board's staff was working to resolve safety issues on 23 directives. Work was completed on these directi= ves:

·= = DOE Order 151.1X, Comprehensive Emergency Management System<= /span>

·= = DOE Order 251.lX, Directives Program

·= = DOE Order 413.3A, Program and Project Management for the Acquisition of Capital Asset= s

·= = DOE Order 420.lB, Facility Safety

·= = DOE Guide 424.1-lA, Implementation Guide for Use in Addressing Unreviewed Safety

·= = Question Requirements

·= = DOE Order 452.lC, Nuclear Explosive and Weapon Surety Program<= /span>

·= = DOE Order 452.2C, Safety of Nuclear Explosive Operations<= /span>

·= = DOE Standard 1104, Review and Approval of Nuclear Facility Safety Basis Docume<= /i>nts

·=       =    DOE Manual 450.5-1, Integrated Safety Management Manual

<= /o:p>

5.2.2        NNSA Policy Letters

On several occasions the Board expressed concern over a new family of directiv= es called "policy letters" that had no standing in DOE's directives system. In response, NNSA agr= eed to suspend applying these documents to defense nuclear facilities until a satisfactory directives system architecture was developed. Changing course, NNSA decided to eliminate the policy letter system entirely and replace it with a new directives system. In 2006, N= NSA presented to the Board its plans for new directives to be issued in 2007.

5.2.3        Natural Phenomena Hazards

In an August 27, 2004 letter to DOE, the Board requested improved technical crite= ria for systems, structures, and components relied upon to confine radioactive materials threatened by natural phenomena. In 2005, DOE provided a revision to= DOE Guide 420.1-2, Guide for the M= itigation of Natural Phenomena Hazards for DOE Nuclear Facilities and Non-nuclear Fac= ilities. The Board provided comments = on this revision, suggesting that DOE consider adopting the consensus standard American National Standards Institute/American Nuclear Society Standard 2.2= 6-2004, Categorization of Nuclear Faci= lity Structures, Systems, and Components for Seismic Design, rat= her than revising the guide. DOE = has elected to adopt this national consensus standard by providing guidance for= its implementation in a new standard, DOE-STD-1189, Integration of Safety into the Design Process.<= /span>

<= /o:p>

5.2.4        Worker Safety Rulemaking

On December 8, 2003, DOE published in the Federal Register a proposed rule on worker protection, 10 CFR Part 85 1, = Worker Safety and Health. This action was required und= er the Bob Stump National Defense Authorization Act, Public Law 107-314, which directed DOE to promulgate regulations on worker safety and health, rather = than rely exclusively on a contractual approach. On January 26, 2005, DOE published a revised proposed rule for public comment. The Board's comments on this rule stressed tightening the proposed exemption criteria, strengthening the tailoring process, and complying with the oversight themes of Recommendation 2004-1. DOE modified the prop= osed rule considerably based on input from the Board, and published the final ru= le on February 9, 2006. The Boar= d also provided oversight of DOE's development of DOE Guide 440.1-8, Implementation Guide for Use with 10 CF= R Part 851, Worker Safety and Health Program, which was issued in January 2007. The rule's full impleme= ntation is required by May 2007.

5.2.5      = Hazard Categorization

In a letter dated June 26, 2006,= the Board requested that DOE review and address issues associated with the implementation of DOE-STD-1027-92, Hazard Categorization and Accident Analysis Techniques for Compliance with DOE Ord= er 5480.23, Nuclear Safety Analysis Reports, Change Notice 1. The letter described specific problems observed throughout the complex, including inappropriate exclusion= of sealed sources from facility inventories, the interaction between hazard categorization and criticality safety, and poorly defined technical bases f= or threshold values. Improper application = of the standard can result in non-conservative facility hazard categorization and a reduced set of safety requirements and controls. DOE responded on October 25, 2006, = with a letter committing to the establishment of a working group to address these = and other weaknesses in the standard and develop a path forward for resolution, which will be available by March 2007.

5.2.6      = Scope of the Directives System

In response to previous input fr= om the Board, DOE offered changes to DOE Policy 251.1, Directives Program Policy, DOE Order 251.1X, DOE Directives Program, and= DOE Manual 251.1-lX, Directives Program M= anual. The Board's oversight result= ed in a significantly improved seri= es of directives that provide the framework for the development of all other safe= ty directives. The directives in the 251 ser= ies were published in August 2006.

5.3&nbs= p;      Safety Programs

5.3.1      = Administrative Controls

Contractors at defense nuclear facilities are required by DOE's principal nuclear safet= y rule (codified in 10 CFR Part 8= 30) to submit documented safety analyses and controls for approval. To meet this requirement, many contractors have developed new safety analyses and, perhaps more importantl= y, new safety controls. In many cases, the choice of the= se new safety controls was limited because the installed equipment had been built years or even decades ago. Th= is led some contractors to reclassify existing equipment as safety-related and to = rely on safety-related administrative controls rather than engineered features. = In Recommendation 2002-3, the Board advised DOE to improve its guidance= for the use of administrative controls at defense nuclear facilities.

Responding to the recommendation, DOE developed and implemented a plan to improve the reliability and effectiveness of = administrative controls that serve important safety functions. As a key step in the implementation= plan, DOE developed and issued a new standard, Specific Administrative Controls (DOE-STD-1186), and in 2006, compl= eted the commitments outlined in the implementation plan for Recommendation 2002= -3. Of particular note, DOE revised the= safe harbor methodology associated with the performance of safety analyses (DOE-STD-300= 9, Preparation Guide for U.S. Department of Energy Nonreactor Nuclear Facility Documented Safety Analyses) to reflect the requirements associated with specific administrative controls. = The Board intends to conduct indepe= ndent verification reviews to assess the effectiveness of implementation.

5.3.2      = Active Confinement Systems

The Board issued Recommendation 2004-2 to ensure that a reliable and effective control would be available to mitigate the consequences of potential accide= nts at defense nuclear facilities that rely on confinement ventilation systems.= DOE has now screened all Hazard Cat= egory 2 and 3= defense nuclear facilities against criteria designed to identify those with the pot= ential for benefitting from the intent of the recommendation. DOE also completed another major milestone in February 2006, developing and issuing its Ventilation System Evaluation Guidance document. This document identifies a set of design and performance attributes that ventila= tion systems should be evaluated against for identification of potential upgrade= s. Several pilot facilities have been identified by DOE to which these attributes will be applied, in order to id= entify potential improvements, before the guidance document is applied to the rest= of Hazard Category 2 and 3 facilities that were identified earlier in the year. The evaluation process will be comp= leted over the next two years, resulting in significant improvement in the safety posture of defense nuclear facilities across the complex.

In 2006, DOE submitted a revised implementation plan to reflect delays that have occurred. The Board objected to these changes= in an August 2006 letter, noting that DOE had removed the Central Technical Autho= rity from the review and concurrence process and eliminated the Central Technical Authority's responsibility for ensuring technical adequacy. The Board also objected to the remo= val of the Program Secretarial Officer from the review and approval process for exceptions, giving that authority over to the site manager. Over the Board's objections, DOE el= ected to follow the revised implementation plan. The Board has been informed that the Office of Environmental Management and the National Nuclear Security Admini= stration have provided guidance to explain the coordination and level of reviews exp= ected by these program offices for ventilation system evaluations, including revi= ew and oversight by the Central Technical Authorities and subsidiary offices. = The Board is evaluating DOE's implementation plan and will closely follow the implementation of the recommendation in 2007.

5.3.3      = Quality Assurance

During 2006, the Board continued to urge DOE to improve the implementation of qual= ity assurance programs. In accordance with = its Quality Assurance Improvement Plan, DOE is reviewing quality assurance processes at its various sites and developing corrective actions where need= ed. The Quality Assurance Working Group (under the auspices of the Energy Facility Contractors Group) continues to assist DOE in making these improvements. The actions taken as part of NNSA's "Quality Assurance Roadmap to Excellence" also continue to have a positive effect. The Board al= so provided representation at the biannual meeting of the American Society of Mechanical Engineers' committee devoted to NQA- 1, Quality Assurance Program Requirements for Nuclear Facilities<= /i>.=

5.3.4      = Software Quality Assurance

The safe design and operation of many defense nuclear facilities is assured, in part, by analysis and operational support provided by computer software. In January 2002, the Board issued Recommendation 2002-1 to force significant changes in DOE's policies and practices regarding software desi= gn, implementation, testing, configuration management, and training of personne= l in order to address longstanding safety deficiencies in these areas. During 2006, the newly revised DOE = Order 414.1C,= Quality Assurance, that contained new software quality assurance requirements, was added to NNSA contracts. At this point, DOE= has completed all but one action in the implementation plan. DOE performed a gap analysis on its toolbox of codes to determine the actions needed to bring them into complia= nce with software quality assurance qualification criteria. However, the funding to upgrade cod= es based on the gap analysis results has not been available. DOE will brief the Board on its pla= n for correcting this deficiency in 2007.

5.3.5      = Risk Assessment Methodologies

Previously, the Board conducted a comprehensive assessment of DOE's policies, programs, processes, and procedures with respect to the use of quantitative risk assessment and related methodologies. This review found that DOE widely employed quantitative risk assessment but without adequate controls over quality and applicability. Th= is in turn causes risk management plans, risk mitigative actions, and residual ri= sk identification to be inadequate. DOE responded by offering to develo= p a policy governing the use of risk assessment methodologies at defense nuclear facilities.

In a letter to DOE dated Novembe= r 23, 2005, the Board found deficiencies in the policy as written and objected to the s= low pace of its development. As a result of the Board's observations and concerns, DOE has chartered a working group comprising representatives from the major program offices, field elements, national laboratories, and major contractors to guide the efforts in this area. This group has developed a draft po= licy, along with draft implementation guidance, which is scheduled to be released= for general comment in early 2007. The Board will continue to oversee DOE's progress in developing an effective po= licy and useful implementing guidance to govern the use of risk assessment methodologies at DOE facilities.

5.3.6      = Criticality Safety

The Board continued to monitor DOE's progress in improving nuclear criticality safety programs. The Board re= viewed a DOE report entitled Status o= f the Department of Energy Nuclear Criticality Safety Program for Calendar Year <= /span>2005 (February 8, 2006), and in a le= tter dated June 28, 2006, noted favorably the positive influence of the Criticality Sa= fety Support Group, the improved stability of funding for the criticality progra= m, and the increased frequency 'of reviews under the Criticality Safety Monito= ring Program. However, the Board w= as concerned about several items that are fundamental to the health of DOE'S nuclear criticality safety program and requested that DOE provide an estima= te of when critical experiments would be started at Nevada Test Site and a sta= tus report on staffing and training. In October 2006, DOE responded t= o the Board that critical experiment operations at Nevada Test Site are planned t= o resume in late 2009, and the experimenters will undergo requalification in accorda= nce with a training plan to be finalized in 2007. DOE also identified sites that requ= ire additional criticality safety resources to provide effective oversight and = has taken action to acquire and qualify these resources. Finally, a number of engineer train= ing courses devoted to criticality matters were held at Lawrence Livermore Nati= onal Laboratory this past summer, after a nearly two-year hiatus throughout the complex.

The Board has also closely followed efforts by Los Alamos National Laboratory t= o correct program deficiencies identified during an October 2005 review. A review in early August found that progress in completing the corrective actions had stalled. Subsequently, the Board issued a le= tter on September 22, 2006, asking DOE what compensatory measures would be put in place until the laboratory's program deficiencies could be corrected. DOE responded in a letter dated Nov= ember 2, 2006, stating that it has increased oversight of the laboratory's progra= m and assigned a full-time individual to oversight. A limited review of compensatory me= asures taken for current operations determined that there were no immediate criticality safety concerns. = DOE will meet periodically with contractor management to monitor progress on corrective actions. The Board= will continue to monitor progress and oversight effectiveness.

At Lawrence Livermore's Plutonium Facility, a review by the Board identified t= wo noncompliances with requirements of American National Standards Institute/American Nuclear= Society Standard 8.19, Administrative Practices for Nuclear Criticality Safety. The Board described these noncompliances to DOE in a letter dated October 11, 2006. On November 22, 2006, DOE directed the laboratory to take action; improvements= in the laboratory's criticality safety program have now been made.

5.3.7        Readiness Reviews

In a September 14, 2005 letter to DOE, the Board highlighted some instances of reduced rigor in the selection of readiness review processes for defense nuclear facilities. Such redu= ced rigor affects the application of design requirements and preparation of safety documents. One cause for this situation appeared to be inconsistent interpretation and implementation of rules and orders that apply to new Hazard Category 1, 2, and 3 nucl= ear facilities and major modifications to existing nuclear facilities. In the cases noted by the Board, DO= E used nonconservative interpretations that could lead to less vigorous readiness reviews and omission of required reviews of design and safety documentation= . As a result, DOE conducted a focuse= d review at two sites and found inconsistent interpretation and application of these nuclear safety definitions. D= OE will brief the Board before these definitions are revised in the DOE direct= ive.

The Board had also identified several problems with the planning and conduct of startup readiness reviews at the Savannah River Site in late 2005. As a result, the Board provided ext= ensive oversight of the 17 contractor and DOE readiness reviews that were conducte= d at the Savannah River Site during 2006 to ensure the subsequent corrective act= ions were producing the desired effect. In general, a significant improveme= nt was observed. That being said, the Board disagreed with a contractor decision in a particular case in which a readiness review commenced before the supporting authorization basis had be= en approved. The Board also iden= tified other problems with specific readiness reviews: frequent equipment reliabil= ity issues, lack of prerequisites in a plan of action, disclosure of an emergen= cy drill scenario ahead of time, and reviewer actions that could bias their re= view. Feedback from the Board on th= ese issues allowed corrective actions to be taken to ensure they remained isola= ted cases.

Similarly, the Board identified weaknesses with the Idaho process for determining read= iness to begin venting of remote-handled transuranic waste drums. DOE-Idaho gave approval to perform a readiness assessment for a new Hazard Category 2 activity instead of a more rigorous operational readiness review as required by DOE Order 425.lC, <= span style=3D'mso-bidi-font-weight:bold'>Startup and Restart of Nuclear Faciliti= es, wit= hout receiving an exemption from DOE headquarters. DOE's Office of Environmental Manag= ement issued a memorandum to all of its sites providing clear expectations for implementing the requirements of the order.

5.4       Techn= ical Competence

5.4.1        Federal

In accordance with the implementation plan for Recommendation 2004-1, DOE prep= ared a corrective action plan in August 2005 to address federal technical compet= ency issues. The action plan focus= ed on several major areas including: (1) conducting a functional workforce analysis as a basis for meeting the needs= of DOE's missions for the next five years; (2) establishing a voluntary corpor= ate accreditation process for the Technical Qualification Program based on the Institute of Nuclear Power Operation model; (3) reestablishing the corporate Technical Leadership Development Program to hire and develop new engineers;= and (4) strengthening the qualification program for Senior Technical Safety Managers. DOE plans to revise= its Federal Technical Capability Manual to incorporate changes in federal techn= ical capability expectations developed as part of the implementation plan. DOE will also conduct a follow-on l= ine management review of the effectiveness of their corrective action plan.

DOE achieved several successes in pursuing the corrective action plan. In May 2006, DOE conducted the init= ial accreditation review of the Technical Qualification Program at the site off= ice for the Y-12 National Security Complex. The Y-12 Site Office had a solid pr= ogram and served as a good benchmark for this accreditation process. DOE budgeted $2 million for fiscal = year 2008 to reestablish the Corporate Technical Intern Program, which would fund ten interns. DOE developed and executed a Senior Technical Safety Manager overview course in Albuquerque in February 2006 for qualified managers in the process of requalification and = for new manager candidates to assess gaps in their knowledge level. DOE will use lessons learned from t= his course to improve its next scheduled course. DOE is also strengthening its qualification criteria with mandatory performance activities through a significant revision to DOE-STD-1075, Senior Technical Safety Manager Functional Area Qualification Standar= d. DOE expects to issue this st= andard later in 2007.

5.4.2        Criticality Safety Engineers<= /p>

In 2006, the Board assessed the nuclear criticality training and staffing at several DOE site offices in the area of nuclear criticality safety oversigh= t. The Board found that several DOE si= te offices continue to be either understaffed or not staffed at all in the are= a of oversight. Some of the proble= ms with contractor programs can be traced to ineffective oversight by DOE site= offices. By October 2006, DOE was acti= vely seeking to fill criticality safety positions at the Nevada Site Office, Los= Alamos Site Office, and Savannah River Operations Office. In the meantime, technical support in the criticality safety area is be= ing provided to these sites through DOE's Albuquerque Service Center. At the Los Alamos Site Office, a ge= neral engineer has also been assigned as a full-time criticality safety engineer.= He is required to complete qualific= ation as an expert by April 2008, but DOE is exploring mechanisms to accelerate his qualification progress.

5.4.3      = Federal Facility Representatives

The Board conducted on-site reviews of the staffing levels and training of DOE's facility representatives at the Pantex, Sandia, and Los Alamos Site Offices= . The Board found that both staffing = and training were inadequate in all three offices. DOE agreed and took steps to improv= e its activity-specific hazard training and to develop a more rigorous means of establishing a minimum staffing level at each office. However, DOE continues to experience difficulty maintaining the desired number of qualified facility representat= ives at too many sites.

Number	Date	Title
94-1<= /o:p>	May 26, 19= 94	Improved Schedule for Remediation in the Defense Nuclear Facilities Complex
95-2<= /o:p>	October 11= , 1995	Safety Management
97-2<= /o:p>	May 19, 19= 97	Continuati= on of Criticality Safety at Defense Nuclear Facilities in the Department of Ene= rgy
98-2<= /o:p>	September = 30, 1998	Safety Management at the Pantex Plant
2000-1	January 14= , 2000	Prioritiza= tion for Stabilizing Nuclear Materials
2000-2	March 8, 2= 000	Configurat= ion Management, Vital Safety Systems
2001-1	March 23, = 2001	High-Level= Waste Management at the Savannah River Site
2002-1	September = 23, 2002	Quality Assurance for Safety-Related Software
2002-2	October 3,= 2002	Weapons Laboratory Support of the Defense Nuclear Complex
2002-3	December 1= 1, 2002	Requiremen= ts for the Design, Implementation, and Maintenance of Administrative Controls
2004-1	May 21, 20= 04	Oversight = of Complex, High-Hazard Nuclear Operations
2004-2	December 7= , 2004	Active Confinement Systems
2005-1	March 10, = 2005	Nuclear Ma= terial Packaging

Date<= /b>	Site or Topic	Response	Due
January 5	K-Basins at Hanford	Briefing	90 days
January 17	Work Planning at Oak Ridge	Briefing	--
March 3	DOE Oversight Policies	Report	90 days
March 27	Criticality Experiments	Report	60 days
March 27	Vital Safety Systems	Report	60 days
April 24	Rec. 2005-1 Repackaging Methodology	Report	30 days
May 1	Comments on DOE Manual 441.1	Report	30 days
June 19	NNSA plans for G-Tunnel	Report	60 days
June 26	DOE Standard 1027	Report	120 days
June 28	Nuclear Criticality Safety	Report	90 days
August 15	DOE Order 226.1	Report	30 days
September 22	Critical Experiments Facility	Report	--
September 22	Criticality Safety at Los Alamos	Report	45 days