EXECUTIVE SUMMARY
During the past seven years, the Defense Nuclear Facilities Safety Board (Board) has witnessed profound changes in the mission of the Department of Energy (DOE). In early 1990, DOE faced numerous issues concerning the safety of its operations at several facilities in the defense nuclear complex. A number of facilities had been shut down for extended periods (e.g., the K- and L-Reactors at the Savannah River Site and certain production facilities at the Rocky Flats Environmental Technology Site); they would remain shut down. In addition, with the end of the Cold War, the mission of the complex shifted from the production of plutonium and tritium and the fabrication, assembly, and testing of nuclear weapons to the stewardship of the remaining weapons stockpile, the dismantlement of nuclear weapons removed from service, and the cessation of nuclear weapons testing. DOE was also faced with the daunting task of bringing numerous facilities to a safe shutdown condition and cleaning up the radioactive contamination that had accumulated during approximately fifty years of weapons production.
The Board has retained its flexibility during this continuing transitional period, adapting to DOE's evolving mission. During 1996, the Board devoted significant attention to ensuring the safe stabilization of residues and waste, set the framework for integrated safety management programs across the defense nuclear complex, and stimulated DOE progress toward upgrading the technical expertise of its staff. These accomplishments could not have been realized without the substantial cooperation of Secretary O'Leary and those with line management responsibility, notably Deputy Secretary Charles Curtis and Under Secretary Thomas Grumbly.
Significant progress has been made in improving the safety of operations in the defense nuclear complex. This has been accomplished by both DOE and the Board working together, with mutual respect for our separate roles and responsibilities.
A summary of accomplishments in 1996 follows. Many of these achievements relate to matters pursued by the Board during a period of years. Most represent milestones in continuing programs for protecting the health and safety of workers, the public, and the environment.
In achieving this progress, the Board has demonstrated the value of a small, dedicated, technically competent group conducting oversight of safety at DOE facilities. Successes result from the ability of the Board and its staff to interact with DOE and contractor officials at all appropriate levels in a timely fashion. As a result, badly needed changes and safety improvements are acknowledged more readily by the officials involved at all levels, and corrective actions are expedited. This scenario has been acted out many times over, in almost all the areas of safety interest that have commanded the Board's attention.
The Board looks forward to meeting future challenges in helping DOE improve safety management plans at defense nuclear facilities. These challenges will be met, and the safety of workers and the public will be enhanced, by the Board's ongoing programs for monitoring DOE's activities to ensure the safety and reliability of the weapons in the stockpile; verifying the safe dismantlement of nuclear weapons; overseeing the processing of production residues and handling of contaminated waste; and confirming the safety of deactivation, decommissioning, and restoration of former production facilities.
Table of Contents
Section
2 MAJOR TECHNICAL ACTIVITIES OF THE BOARD DURING 1996
2.1 -- Activities Related to Stewardship of the Weapons Stockpile
2.1.1 -- Pursuit of an Integrated Approach to Safety in DOE's Nuclear Explosive Operations
2.1.2 -- Activities Related to Specific Sites/Facilities/Activities
2.2 -- Cross-Cutting Activities
2.2.1 -- Development and Implementation of Sound Nuclear Safety Standards
2.2.2 -- Processing and Storage of Surplus Special Nuclear Materials
2.2.3 -- Establishment of Sound Integrated Safety Management Systems
2.2.4 -- Technical Expertise of DOE Staff
2.2.5 -- Status of DOE Functions, Authorities, and Responsibilities Manual for Nuclear Safety (FAR Manual)
2.2.6 -- Operational Readiness Review Activities
2.2.7 -- Operational Radiological Safety
2.2.8 -- Health Effects of Plutonium Uptake by Workers
2.3 -- Activities Related to Decontamination and Decommissioning
2.3.1 -- Rocky Flats Environmental Technology Site
2.3.2 -- Hanford Site
2.4 -- Activities Related to Design, Construction, and Initial Operations
2.4.1 -- Savannah River Site
2.4.2 -- Rocky Flats Environmental Technology Site
2.4.3 -- Los Alamos National Laboratory
2.4.4 -- Hanford Site
2.4.5 -- Gaseous Diffusion Plants at Oak Ridge, Portsmouth, and Paducah
2.5 -- Activities Related to Plutonium Stabilization
2.5.1 -- Savannah River Site
2.5.2 -- Rocky Flats Environmental Technology Site
2.5.3 -- Hanford Site
2.6 -- Activities Related to Waste Management
2.6.1 -- Implementation of Recommendation 94-2
2.6.2 -- Hanford High-Level Waste Tank Farms
2.6.3 -- Waste Characterization
2.6.4 -- Tank Waste Remediation System
3.1 Personnel Recruitment
3.2 -- Official Site Visits by Board Members and Staff
3.3 -- Public Interaction with the Board
3.4 National Performance Review Objectives
3.4.1 -- Starting Without Encumbrances
3.4.2 -- Reducing Regulatory Burden
3.4.3 -- Excepted Service and Pay for Performance
3.4.4 -- "No Frills" Approach to Operations
3.4.5 -- Effective Organization Structure
3.4.6 -- Management Continuity
3.4.7 -- Experienced Leadership
3.4.8 -- Information Technology
4.1 -- Broad Safety Issues
4.2 -- Evolving Technical Challenges
4.3 -- Long-Range Goals
4.4 -- Near-Term Objectives
4.5 -- Site-Specific Objectives 4-8
APPENDIX A -- RECOMMENDATION 96-1
APPENDIX B -- PROGRESS TOWARD IMPLEMENTING PROVISIONS OF THE GOVERNMENT PERFORMANCE AND RESULTS ACT OF 1993 (GPRA)
The Manhattan Project, initiated in the early days of World War II, is generally recognized as the start of the nuclear age. Since then, the Department of Energy (DOE) and its predecessor agencies, the Atomic Energy Commission and the Energy Research and Development Administration, have produced considerable quantities of special nuclear materials and designed, manufactured, tested, and maintained the weapons in the nation's nuclear arsenal. During most of the last fifty years, the nuclear weapons complex operated without independent external oversight. In 1988, Congress, mindful of the accumulating public health and safety issues involving many of the aging defense nuclear facilities, enacted into law the creation of the Defense Nuclear Facilities Safety Board (Board). The five- member Board, composed of "respected experts in the field of nuclear safety with a demonstrated competence and knowledge relevant to the independent investigative and oversight functions of the Board," was empowered to provide advice and recommendations to the Secretary of Energy to ensure adequate protection of public and worker health and safety at DOE's defense nuclear facilities. The Board became functional in late October 1989, when the charter Board members were sworn in.
The Board is responsible for independent oversight of all activities relating to nuclear safety within DOE's nuclear weapons complex. Today, DOE is actively engaged in the ongoing process of disassembling nuclear weapons, maintaining the remaining weapons in the stockpile in a safe and reliable condition, and conducting research focused on ensuring the continued stewardship of the stockpile. In addition, considerable attention is currently being devoted to safe disposition of fissionable material removed from disassembled weapons and of material remaining in the system following the abrupt cessation of many production activities more than seven years ago. Many of DOE's current activities are associated with cleanup of extensive radioactive contamination resulting from decades of production.
Its enabling statute, 42 USC § 2286, et seq., requires the Board to review and analyze facility and system design, operations, practices, and events, and make recommendations to the Secretary of Energy that are necessary to ensure adequate protection of public health and safety. The Board must consider the technical and economic feasibility of implementing the recommended measures, and the Secretary must report to the President and Congress if implementation of a recommendation is impracticable because of budgetary considerations. If an imminent or severe threat to public health or safety is determined to exist, the Board is required to transmit its recommendations to the President, as well as to the Secretaries of Energy and Defense.
The Board is required by law to review and evaluate the content and implementation of health and safety standards, including DOE's orders, rules, and other safety requirements pertaining to the design, construction, operation, and decommissioning of DOE defense nuclear facilities. The Board must then recommend to the Secretary of Energy any specific measures, such as changes in the content and implementation of those standards, that it believes should be adopted to ensure that the public health and safety are adequately protected. The Board is further required to review the design of new defense nuclear facilities before their construction begins, as well as modifications to older facilities, and to recommend necessary changes. The Board's review and advisory responsibilities continue throughout the full life cycle of facilities, including the shutdown and decommissioning phases.
The Board may conduct investigations, issue subpoenas, hold public hearings, gather information, conduct studies, establish reporting requirements for DOE, and take other actions in furtherance of its review responsibilities. These ancillary functions relate to the accomplishment of the Board's primary function, which is to assist DOE in identifying and correcting health and safety problems at defense nuclear facilities. The Department and its contractors at defense nuclear facilities are required to cooperate fully with the Board.
The terms of the enabling statute give clear guidance about what Congress expected the Board to do and in what manner. Congress expected the Board's oversight to have many of the same positive results as formal regulation: assurance that DOE is implementing a program that provides for the safe management of the production and use of defense nuclear materials, which, in turn, gives reasonable assurance of no undue risk to workers and the public, and protects the environment. Congress was well aware that DOE had issued safety policies and standards of good practice. However, Congress was also aware that these practices needed upgrading, and that DOE and contractor operations in the past had left extensive residual contamination in buildings and the surrounding environment. DOE's problem appeared to be primarily a failure to establish clear expectations of its contractors and to build safety compliance into the fabric of work planning and execution.
During the past seven years, the Board has focused much of its attention on examining the standards identified by DOE as codes of good practice, the way DOE defines what is expected of its contractors in the performance of the Department's mission, and the means by which such requirements are enforced. These elements are basic to any safety management program, whether internally or externally driven. The most significant deficiencies in these basic elements have been communicated to DOE by means of the recommendation process set forth in the Board's enabling statute. These recommendations not only describe perceived deficiencies, but also provide guidance as to what the Board believes are advisable solutions. Implementation plans for addressing the issues identified in these recommendations are then submitted by the Secretary for Board approval. The Board follows the progress of each required action program until the planned action has been completed. To date, the Board has issued 34 sets of recommendations containing 149 specific recommendations; these are discussed in detail later in this report.
In meeting its responsibilities, the Board recognizes DOE's legitimate need to do its essential national defense work without unjustifiable delay. Through assignment of its staff to monitor and review work involving design, construction, or preparations for readiness to operate, the Board has been able to keep its safety reviews synchronized with DOE activities. Technical concerns that arise during these reviews are frequently resolved by the technical staffs of DOE, the Board, and contractors without the need for formal action-forcing measures by the Board. If the Board determines there are unresolved safety issues that require resolution before work proceeds, it can define those issues and recommend their resolution by the Department. In the case of operations at the Rocky Flats Environmental Technology Site, Congress required that before resumption of plutonium operations in specified buildings, the Board determine to its satisfaction that DOE's response to specific recommendations of the Board adequately protects public health and safety.
In addition to its reviews of the basic elements and structure of DOE's safety management program, the Board has given priority attention to particular facilities and activities considered to represent the greatest safety risks—mainly those that now comprise the remaining portions of the nuclear weapons complex devoted to (1) the stewardship, maintenance, and surveillance of nuclear weapons; (2) the stabilization of hazardous remnants of weapons production; and (3) the storage of strategic and highly radioactive materials. For those facilities and operations representing significant hazards, the Board is actively pressing DOE to develop improved safety management programs that would result in clearly defined systems and components important to safety, technical specifications defining limiting conditions for operation, and the infrastructure needed to support maintenance and safety in operation. This has already been done for a number of facilities and operations. The extension of this effort to high-risk facilities is the thrust of Recommendation 95-2, Safety Management, the end goal of which is to have safety management programs that are not only well defined, but also tailored to the diverse operations of the DOE complex.
With respect to decommissioning of defense nuclear facilities, the Board has thus far paid particular attention to those facilities in transition to cleanup or environmental restoration under the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA) and the Resource Conservation and Recovery Act (RCRA). CERCLA and RCRA statutes are administered by the Environmental Protection Agency (EPA) and the states. The Board is working cooperatively with EPA and the states to effect a smooth transition to CERCLA and RCRA oversight by the states involved, and has recently signed cooperative agreements with the State of Colorado, EPA, and DOE with respect to activities at the Rocky Flats Environmental Technology Site.
The Board is required by statute to report to Congress each year concerning its oversight activities, its recommendations to the Secretary of Energy, and safety improvements achieved at defense nuclear facilities as a result of its activities. This report responds to that requirement. It is organized as follows:
In addition, two appendices are provided: Appendix A contains the Federal Register notice for Recommendation 96-1, while Appendix B describes the Board's progress toward implementation of the provisions of the Government Performance and Results Act of 1993.
2. MAJOR TECHNICAL ACTIVITIES OF THE BOARD DURING 1996
This section reports on major technical activities of the Board during 1996 in the following areas:
2.1 ACTIVITIES RELATED TO STEWARDSHIP OF THE WEAPONS STOCKPILE
Nuclear weapons remain a vital part of U.S. national security. With the end of the Cold War, the manufacture of nuclear weapons ceased, and with the Administration's commitment to conclude a Comprehensive Test Ban Treaty, all underground testing of nuclear weapons ended as well. DOE's strategy for dealing with this significantly changed mission is embodied in its Stockpile Stewardship and Management Plan. Formalized by the Secretary of Energy on December 19, 1996, this plan provides for continuation of the ongoing defense missions at eight DOE sites, and includes appropriate adjustments consistent with post-Cold War national security policies. This new approach also calls for construction of selected facilities with enhanced experimental capabilities; these facilities will be operated at the various national laboratories. Weapons manufacturing capability at existing plants will be maintained, but the plants' capacity will be appropriately reduced. In addition, the capability for manufacturing components of plutonium pits will be reestablished at a national weapons laboratory.
These changes will have a significant impact on the way DOE assures safety in its facilities for research, manufacturing, assembly, disassembly, and testing of nuclear weapons. For example, existing weapon systems will remain in the nation's stockpile significantly longer than in the past. New methods will be necessary to ensure that operations involving nuclear weapons remain safe while the weapons are in the custody of the Department. In addition, in the absence of underground nuclear testing, alternative means of testing and confirming the safety of weapons at all stages in their life cycle are being developed.
The Board will continue to assess the safety implications of these changes and monitor DOE's implementation of the Stockpile Stewardship and Management Plan.
2.1.1 Pursuit of an Integrated Approach to Safety in DOE's Nuclear Explosive Operations
Since late 1991, when it was assigned oversight responsibility for the assembly, disassembly, and testing of nuclear weapons, the Board has been assessing the safety management programs for the design, operation, and maintenance of facilities for nuclear explosive operations and comparing such programs with other nuclear programs both within and outside the DOE complex. These reviews have led the Board to conclude that substantially enhanced safety could be achieved by improved integration of explosive safety management programs and other nuclear safety programs.
As a result, the Board issued two recommendations (93-1 and 93-6) and a reporting requirement. The Board determined that two distinct and inconsistent safety management programs existed at nuclear explosive facilities—one for nuclear explosive operations and another for operations involving nuclear materials not combined with explosive materials. Further, the Board noted that the existing safety management system for nuclear explosive operations was largely expert-based, as opposed to the more standards-based approach that was pioneered by the commercial nuclear industry and was in the process of being implemented at DOE's other nuclear facilities. The Board identified two potential problems associated with DOE's expert-based approach:
These issues are discussed further in the subsections below.
During the past three years, the Board has interacted frequently with DOE to improve the management of safety in nuclear explosive operations. Fifteen letters have been sent to DOE containing specific observations regarding the nuclear explosive safety study process and its integration with other facility safety processes. Beneficial changes have resulted, as subsequent discussions in this report indicate (see Section 2.1.2).
Access to Weapons Expertise. In Recommendation 93-6, Maintaining Access to Nuclear Weapons Expertise in the Defense Nuclear Facilities Complex, the Board urged DOE to establish formal programs to capture knowledge possessed by nuclear weapons experts who are retiring or otherwise leaving the program. The Board considers such information to be essential to the safe maintenance of the enduring nuclear stockpile, the safety of dismantlement programs at the Pantex and Oak Ridge Y-12 plants, and the retention of the capability to safely resume nuclear testing should that course of action be directed by the President.
DOE's initial attempts to implement Recommendation 93-6 were not successful, as noted in the Board's sixth annual report. The Board staff worked closely with DOE to develop a revised implementation plan, which was subsequently submitted to the Board in February 1996. The Board has noted significant progress in DOE's execution of this plan during the remainder of 1996. Several examples can be cited. First, the Oak Ridge Y-12 Plant and the DOE Oak Ridge Operations Office institutionalized and implemented an effective knowledge preservation program. Second, the Sandia National Laboratories implemented a knowledge preservation program that showed good promise. Third, the Lawrence Livermore National Laboratory took steps to start and conduct an effective program to capture the knowledge of retirees. Finally, the Los Alamos National Laboratory developed a program that placed considerable emphasis on documenting the expertise of senior weapons design personnel, including retirees, for both Pantex and Nevada Test Site operations.
This progress has been accompanied by some difficulty in ensuring that the weapons laboratories complement their efforts to preserve weapon design information with actions to capture operational safety information. The Board sees the need for improvement in this area at all the weapons laboratories and will continue its oversight of this matter.
Recommendation 93-1. In early 1993, the Board issued Recommendation 93-1,Standards Utilization in Defense Nuclear Facilities, recommending that DOE address the differences between the safety requirements applicable to nuclear explosive facilities and those applicable to other defense nuclear facilities. In response, DOE issued an implementation plan aimed at ensuring that the requirements governing the safety of nuclear explosive operations would be fully integrated with those for other defense nuclear operations.
Later in 1993, the Board established a reporting requirement calling on DOE to address specific issues associated with the nuclear explosive safety study process used by the Department to ensure the safety of its nuclear explosive operations. DOE responded with a Nuclear Explosive Safety Study Corrective Action Plan (NESSCAP), which identified several fundamental improvements in the nuclear explosive safety study process. In addition, the plan committed DOE to resolving issues associated with contamination by and dispersal of plutonium and other radioactive material, addressing the evaluation of environmental safety and health requirements during nuclear explosive operations, and improving the planning and conduct of appraisals of nuclear explosive weapon safety. Moreover, with the Board's approval, DOE combined that plan with the implementation plan for Recommendation 93-1, to ensure that the requirements governing the safety of nuclear explosive operations would be fully integrated.
During 1996, DOE completed the revision of its nuclear explosive safety orders. The orders package now includes the two applicable orders, an implementation guide, a technical standard on the safety study process, a second technical standard on performing hazard analysis, and an interim rule on the Personnel Assurance Program. These new safety requirements meet the objectives of both the NESSCAP and Recommendation 93-1. When fully implemented, they will better ensure that operations at those facilities that assemble, disassemble, and test nuclear weapons will provide the requisite protection of the public, workers, and the environment.
Several issues will continue to require Board attention during implementation of these requirements. For example, the quality of documentation and reports will need to be improved to meet the new guidelines in the standard. The Board and its staff will continue to work with DOE in developing guidance for the conduct of nuclear explosive safety study reviews. The goal of such technical interactions is to ensure that these reviews provide a thorough technical analysis of the potential hazards of the operations, determine the safety impact of procedural and equipment changes, and resolve potential safety issues prior to operation.
DOE has recently formed a task force to integrate facility Safety Analysis Reports with operations Hazard Analysis Reports, and to address deficiencies at the interface between safety and hazard analyses. The Board will continue to follow the development of DOE's standard on hazard analysis for nuclear explosive operations. In addition, the Board will follow closely DOE's activities designed to ensure that the analyses of specific weapons operations complement the safety analyses of the facilities, and that the two together are appropriately comprehensive.
DOE's Assistant Secretary for Defense Programs has recently concluded that the safety practices applied to nuclear explosive operations must be extended to subsidiary operations involving nuclear weapons. The Board supports this decision.
2.1.2 Activities Related to Specific Sites/Facilities/Activities
Safety Management of Research and Development at the Weapons Laboratories. As discussed briefly in Section 2.1, the three weapons laboratories (Los Alamos National Laboratory, Lawrence Livermore National Laboratory, and Sandia National Laboratories) have taken on a greatly increased role under DOE's Stockpile Stewardship and Management Plan. The laboratories will be shouldering new responsibilities in the areas of production and surveillance, in addition to expanded research and development.
It is recognized that work planning, which includes the analysis of hazards and the subsequent development and formal implementation of preventive and mitigative controls,
needs considerable improvement at some research and development facilities of the weapons laboratories. For example, at Los Alamos National Laboratory, there have been several recent incidents and accidents whose root causes could be traced directly to inadequate understanding of the hazards or lack of implementation of protective measures. Work planning will continue to receive increased emphasis throughout 1997.
The Board's efforts in safety management have kept pace with those of DOE. In 1995, the Board asked the Department to prepare a report addressing the proper manner of ensuring that nuclear research and development at the laboratories is conducted safely and in accordance with safety requirements that do not unduly impede the creative process. This reporting requirement, which served as a precursor to the Board's technical report on Safety Management and Conduct of Operations, DNFSB/TECH-6, and Recommendation 95-2 (see Section 2.2.3), noted that the nuclear safety standards made obligatory by DOE for its operating contractors have general applicability to the wide diversity of DOE activities. Although DOE's safety policy and the applicable standards permit a "graded" approach, in which the formality of operations varies in form and degree depending on the nature and extent of the hazards involved, just what is acceptable has never been well defined, nor is its definition apparent from case histories. This is especially true for the weapons laboratories, where there are far more research and development activities under way than production activities, and in which the mix of skills for research and development is much different from that for production.
The weapons laboratories have maintained that safety management programs should reflect this difference. The Board also believes that DOE requirements need not be applied in the same way at both production facilities and research and development laboratories; i.e., it is not a "one size fits all" situation. Believing that the laboratories are in the best position to define a safety management program for facilities where research and development functions are dominant, the Board has encouraged them to do so. The reaction of management at the laboratories has been positive, as evidenced by the progress being made in developing integrated safety management programs in response to Recommendation 95-2 (discussed further below).
In a parallel but separate activity, the Secretary of Energy's Advisory Board was asked to review the Department's management of its laboratories. Among other conclusions, the Advisory Board's review committee, chaired by Robert Galvin, stated that the laboratories were subject to excessive micro-management in the form of a multiplicity of DOE internal and external audits of laboratory operations.
In response to the Galvin report, DOE established an Environment, Safety and Health (ES&H) Oversight Pilot initiative, in which all three weapons laboratories currently participate. This study is intended to determine whether DOE's on-site appraisal activities could be reduced substantially through increased dependence on the results of the laboratories' self-assessment programs. It became evident in 1996 that all of those programs will require significant upgrading before they can provide adequate assurance of effective safety. This conclusion was reached by DOE field personnel as they monitored the progress of the initiative, and was confirmed by reviews conducted by the Board staff at the three weapons laboratories. The required improvements are expected to be incorporated in the laboratories' integrated safety management plans.
Pantex Plant. The Pantex Plant, located outside Amarillo, Texas, is DOE's remaining site for the assembly, disassembly, and surveillance of nuclear weapons. In addition, it serves as an interim storage site for retired weapons and strategic reserve plutonium. Pantex also plays a central role in DOE's plans for stockpile stewardship and management.
The Board has continued its review of the content and implementation of safety basis documents at Pantex. During the past year, the Board has monitored activities at Pantex to develop new Safety Analysis Reports and Technical Safety Requirements, and to improve the Unreviewed Safety Question Determination (USQD) process used for reviewing and correcting such documents. The Board notes that its previous efforts have resulted in improvements in the analysis and control of safety, and that the newer Safety Analysis Reports and Basis for Interim Operations documentation also represent an improvement.
The Board continues to find problems, however, with the Pantex safety basis documents. For example, the Board staff found that the DOE-approved safety limit for temperature control of environmental chambers used to age nuclear explosives artificially was set at the exact temperature at which a runaway reaction could be expected, and therefore it did not provide an adequate margin of safety. After the Board brought this shortcoming to DOE's attention, the Department initiated a broad-based effort to upgrade and properly integrate safety management at Pantex. DOE developed a short-term plan that included action to suspend approval of activities in the environmental chambers, pending the establishment of a firmer basis for safety controls and better assurance of acceptable implementation of those controls. A longer-term effort will be to evaluate all of the current processes used at Pantex to assess safety and develop safety controls. This evaluation is intended to identify areas of overlap (i.e., where streamlining is possible to accelerate the implementation of safety improvements), gaps (i.e., where a hazard may go unidentified or unmitigated), and control measures that merit augmentation.
On a related matter, the Board is working with DOE to improve the Pantex USQD process. During the past year, the Board identified several conceptual errors in the process used to determine whether proposed changes in activities or questions raised about an existing activity have significant safety implications. These errors led to an understatement of the safety significance of some changes. As a result of constructive interactions with the Board and its staff, DOE and its contractor have changed the way USQs are processed at Pantex. This action led Pantex to declare that changes to operations, such as the use of portable x-ray equipment in nuclear explosive assembly cells, constitute positive USQs. For activities that are declared a positive USQ, Pantex developed adequate controls to prevent or mitigate the risks and to execute the activities safely.
Improved Conduct of Operations and Use of Standards—Safety of operations involving nuclear explosives at Pantex is managed through strict adherence to explicit procedures that have been developed, approved, and followed verbatim by knowledgeable personnel. It has long been a common objective of the Board and DOE that those procedures not only be technically sufficient to ensure safety, but also be written so that users can understand them. This is essential at a time when many older and more experienced workers are retiring. Pantex evaluated all of its critical-use procedures to ensure that they are not too complicated and are sufficiently easy to read, understand, and follow. Pantex now has assurance that the procedures can be used effectively by the technicians who perform hands- on nuclear explosive operations. Pantex has also developed a schedule for converting old procedures to a new format that is clearer and easier to follow.
Integrated Plan—Three long-term initiatives to improve safety are under way at Pantex. First, as part of the Seamless Safety-21 process, activities involving nuclear explosives are being redesigned to improve safety. Second, in support of the project for upgrading Safety Analysis Reports, operations at Pantex will be reanalyzed to ensure that hazards are adequately controlled. Finally, in parallel with these two safety efforts, DOE is in the process of adopting a new set of orders that rely on consensus standards for nuclear operations.
In the last year, with encouragement from the Board, DOE developed its first integrated plan for implementing each of the above safety improvement programs. This plan represents a cooperative effort among DOE, its Pantex contractor, and the national weapons laboratories. It identifies improvements and efficiencies that will allow DOE to expeditiously convert its improved safety concepts into true safety benefits in Pantex operations.
During the past several years, DOE has significantly improved its program for assessing the safety of operations with nuclear explosives. The improved process, as described in the new DOE Orders 452.1, Nuclear Explosive and Weapon Safety Program, and 452.2, Safety of Nuclear Explosive Operations, together with their associated implementing guides and standards, will increase the technical rigor of nuclear explosive safety reviews and the quality of technical information on which these reviews will be based. Much of the improvement has been guided by DOE's implementation plan for Recommendation 93- 1 and the NESSCAP, which responded to the Board's reporting requirement of December 8, 1993 (see Section 2.1.1).
The scope of the Board's interest in integrated safety of nuclear explosive operations includes potential impacts on operational safety from facility, process, and human hazards, as well as hazards inherent in the materials being worked. Nuclear explosive safety studies have historically been defined by, and restricted to, consideration of only those scenarios that would result in nuclear detonation, the detonation or deflagration of high explosives, or fire in the vicinity of a combination of high explosives and nuclear materials. Since the early development of nuclear weapons, nuclear explosive safety studies have emphasized the need for a heightened degree of assurance against unintended nuclear detonation. However, nuclear explosive safety study groups reviewed only those operations involving the assembly of pits and high explosives, in which an accident could potentially result in a nuclear yield. One of the upgrades to the process defined in the recently revised DOE Order 452.2 is a widening of the scope of the studies to cover all operations where pits and high explosives are collocated, even if they are not being assembled. DOE has been working to improve the conduct of nuclear explosive safety studies by implementing requirements in the new orders.
Part of the success of DOE's integrated plan for Pantex is due to a concept in the new Order 452.2 called revalidation, which was introduced by DOE to provide a limited-scope safety review as a basis for extending the expiration date for a nuclear explosive safety study. Revalidations are performed to ensure that the operation studied by the original nuclear explosive safety study has not been altered as a result of subsequently approved changes. Board review of the first several revalidations identified concerns with the process as it was being implemented. Further guidance was then issued by DOE, and the revalidation requirements in the DOE Standard on the Nuclear Explosive Safety Study Process were strengthened. Revalidations bridge the gap between DOE's old and new processes for safety review during the transition to Seamless Safety-21. The Board will continue to watch for improvements in the conduct of revalidations.
Nevada Test Site. Although all underground weapons testing at the Nevada Test Site has been suspended, the Board is continuing its oversight of the safety of subcritical experiments and the planned operations of the Device Assembly Facility.
Safety Oversight of Subcritical Experiments—As part of DOE's Stockpile Stewardship and Management Program, the weapons design laboratories had planned to conduct two subcritical experiments in 1996 at the Nevada Test Site. These experiments were to involve devices containing both high explosives and special nuclear materials in configurations that, by design, could not achieve criticality. The first of these "subcritical" experiments was scheduled to be conducted by Los Alamos National Laboratory in June 1996; the second was scheduled to be carried out by Lawrence Livermore National Laboratory approximately one month later.
The Board staff conducted several reviews at the Nevada Test Site and at Los Alamos National Laboratory to evaluate (1) the hazard analyses prepared by the laboratory for its experiment, (2) DOE's review and authorization process, and (3) the safety management system for the subcritical experiment program. The results of these reviews indicated that, given the low level of hazards, the laboratory's hazard analyses and the resulting plan for a safety management approach were adequate. However, it was not apparent that DOE had a well-defined plan for, or expectations for development of, the necessary authorization basis, technical review, or integrated safety management of subcritical experiments in general. Consequently, in a June 1996 letter, the Board urged the Department and the national weapons laboratories to develop a comprehensive safety management plan addressing the full range of potential hazards associated with future subcritical experiments, and noted that the plan should be graded according to the risk associated with the activity.
DOE subsequently deferred the initial subcritical experiments until 1997, and they have not yet taken place. However, during 1996, the Board and its staff continued to discuss the development of an integrated safety management system for these experiments. In response to the Board's encouragement and guidance, the DOE Nevada Operations Office and the laboratories have developed a promising approach. This approach is to be documented in new Nevada Operations Office orders, which are expected to be finalized in early 1997 and used for future subcritical experiments.
The Board will continue to review the safety bases for the individual subcritical experiments, as well as DOE's review and authorization for these experiments. Review of the hazard analysis for the experiment to be conducted by Lawrence Livermore National Laboratory is scheduled for early 1997.
Device Assembly Facility—The Device Assembly Facility at the Nevada Test Site is a new facility for nuclear explosive operations. Although originally intended for the assembly of one-of-a-kind nuclear test devices, the facility is being modified to accommodate a broader range of operations, such as disassembly, modification, staging, maintenance, repair, retrofit, and surveillance of nuclear weapons.
During 1996, the Board evaluated the adequacy of the facility's safety systems, its safety authorization basis (including facility plans and procedures), and the Device Assembly Facility Nuclear Explosive Safety Master Study. In addition, the Board staff identified and called to DOE's attention deficiencies in the electrical distribution and fire protection systems. The Department addressed these deficiencies in coordination studies for protection devices, anticipated electrical system upgrades, and a consolidated fire hazard analysis.
DOE expects that the facility will commence operations during 1997. Activities will include the assembly of subcritical experiments, the preparations for test readiness exercises, and possibly the conduct of research on surveillance of weapons.
Oak Ridge Y-12 Plant. Activities conducted at the Oak Ridge Y-12 Plant include the manufacture, surveillance, and dismantlement of nuclear weapon components fabricated from both highly enriched and depleted uranium. Since DOE's Stockpile Stewardship and Management Plan calls for retaining this capability at the Y-12 Plant, the Board has focused significant attention on reviewing safety-related matters at the site. Several examples of recent Board activities regarding nuclear safety at Y-12 are discussed below.
Conduct of Operations and Criticality Safety—Recommendation 94-4, Deficiencies in Criticality Safety at the Oak Ridge Y-12 Plant, discussed weaknesses in criticality safety programs, as well as the adequacy of experience, training, and performance of personnel both at DOE and in contractor operations. In accordance with its implementation plan for this recommendation, DOE and its Y-12 contractor undertook a number of initiatives considered vital to resumption of operations. For example, immediate steps were taken to correct safety deficiencies, and those steps were validated through a formal restart process conducted in accordance with applicable DOE orders. Corrective actions were initiated in 1995 and are scheduled to be completed in 1998.
During the past three years, the Board and its staff have had numerous interactions with DOE regarding restart activities. In addition, DOE has performed several independent functional area assessments (i.e., training, conduct of operations, and criticality safety) in accordance with commitments in the implementation plan. Each assessment found that, in general, DOE has made significant progress toward meeting its commitments in 1996. The evaluators also noted that continued improvement is still called for in those areas which have been restarted, and that significant work is still needed in those mission areas where restart has not yet occurred, particularly with respect to nuclear criticality safety. The Board will continue to interact closely with DOE as enriched uranium operations (discussed further below) are restarted to support national security programs.
Processing of Excess In-process Highly Enriched Uranium—In late 1995, the Board issued one of its ongoing series of technical reports, Status of Highly Enriched Uranium Processing Capability at Building 9212, Oak Ridge Y-12 Plant (DNFSB/TECH-9). In that report, the Board staff observed that in-process, highly enriched uranium materials comprise the largest portion of materials at risk in Building 9212, and that these materials contribute significantly to the radiation doses received by personnel at Y-12. DOE has declared a large amount of this material to be excess to mission needs. The sheer bulk of this material poses problems for managing the inventory and for controlling the radiation exposure of workers. The Board concluded that it would be prudent for DOE to process the material at the earliest opportunity, once Y-12 management has upgraded the authorization basis for Building 9212 and demonstrated its readiness to operate.
In a February 1996 letter forwarding its technical report to DOE, the Board asked DOE to describe actions that would be taken to characterize and catalogue the excess highly enriched uranium residues, and to establish priorities for processing these residues when enriched uranium operations are restarted at the Y-12 Plant. During 1997, and continuing into 1998, the Board will monitor progress toward the successful processing of this material.
Tritium Production Issues. Tritium is a radioactive isotope of hydrogen used in the nation's nuclear weapons. It has a relatively short half-life (12.3 years) and must be replaced periodically in order for the weapons to function as designed. Tritium was last produced in the Savannah River Site K-Reactor, which was shut down in 1988. Currently, DOE does not have the capability to produce tritium.
During the fiscal year 1993 budget process, Congress required the Administration to prepare and submit a report on the tritium stockpile and the necessary schedule for resuming production. In October 1995, the Secretary announced the results of a Programmatic Environmental Impact Statement for Tritium Supply and Recycle. The preferred alternative was a dual-track strategy under which the Department would begin work on two promising tritium production options: use of an existing commercial light water reactor, and construction of a linear accelerator. Current plans require the new tritium facilities to be operational between 2005 and 2010, depending on the required number of weapons in the stockpile.
The Savannah River Site has been selected as the preferred location for an accelerator, should one be constructed. Under this alternative, tritium is produced by exposing targets to an accelerator proton beam, following which the target assemblies are processed to extract the tritium. Under either alternative, new processing facilities to extract the tritium from reactor- or accelerator-irradiated targets are planned for construction at the Savannah River Site.
Starting in fiscal year 1997, the Board intends to review the preliminary designs for these proposed facilities. The Board expects to continue its reviews of these projects as they progress through the detailed design phase into construction, startup, and operation.
Mound Laboratory. The Mound Laboratory (Mound) is currently involved in the cleanup of nuclear waste and in the safe shutdown and decommissioning of facilities formerly used for the production, repackaging, and off-site shipment of nuclear materials. The Board has monitored the radiological safety aspects of DOE's project for unloading more than 500 special tritium reservoir units at Mound. During the past year, only about half of the reservoirs scheduled to be unloaded have actually been unloaded. The main contributor to the slip in schedule was a three-month work suspension to resolve a tritium inventory discrepancy that was eventually attributed to accounting and calibration errors. The Board will continue to review the remaining tritium operations at Mound to ensure that safety issues arising during the final stages of shutdown are properly resolved; the Board has some concern that the level of technical expertise available to complete the remaining tritium operations may be inadequate to deal with technical issues that may arise.
A number of issues are common to several facilities or sites, or in many cases to the entire defense nuclear complex. These crosscutting issues are examined in the following subsections. They include DOE's overall actions to develop and implement sound nuclear safety standards; the emerging program for processing and storing surplus special nuclear materials; the establishment of sound integrated safety management systems; the technical expertise of DOE staff members in both Headquarters and field organizations; the clear and unequivocal articulation of the authorities and responsibilities of DOE staff members; the implementation of adequate reviews of readiness for initiation or resumption of operations; the improvement of the Department-wide program for operational radiological safety; and the health effects of plutonium uptake by workers.
2.2.1 Development and Implementation of Sound Nuclear Safety Standards
In its enabling statute, 42 U.S.C. § 2286 et seq., the Board is assigned responsibility for review and evaluation of ". . . the content and implementation of the standards relating to the design, construction, operation, and decommissioning of defense nuclear facilities of the Department of Energy (including all applicable Department of Energy orders, regulations, and requirements) at each Department of Energy defense nuclear facility." In addition to requirements imposed by statute, DOE sets requirements for its contractors through one or both of the following vehicles:
During 1995 and 1996, DOE embarked upon a major undertaking—the Order/Requirement Reduction and Streamlining effort—to revise, improve, and upgrade many of its requirements. The scope of this ongoing effort includes substantial revisions to requirements covering administrative, procurement, and technical aspects of the way DOE conducts its business. These requirements are set forth in a small number of rules and in hundreds of DOE orders covering the broad spectrum of the Department's responsibilities. The undertaking involves large commitments of the Department's technical, administrative, and legal staffs.
Of the many hundreds of orders in effect when the revision process was initiated, 51 were related to nuclear safety matters for which the Board has oversight responsibilities. The Board has carefully evaluated the revision effort to the extent that it has addressed these 51 orders. The Board staff conducted an extensive review of each of the original set of 51 safety orders and each of the new safety orders and rules proposed to replace them. Based on that review, the Board staff determined that a majority of the requirements and guidance in most of the safety-related orders should be retained.
In July and September of 1995, the Board held public meetings to review DOE's development process for "new" safety orders and rules. During these meetings, the Board staff testified that the requirements in some of the proposed rules or draft orders did not represent an adequate set of requirements and guidance for establishing DOE's safety management program. Based in part on that testimony, the Board concluded that DOE needed to examine more closely the total set of requirements and guidance encompassing nuclear safety. During the September meeting, DOE representatives committed to completing a "crosswalk" for each of the requirements in the previously existing set of 51 safety-related orders, mapping each old requirement to a specific element in the proposed new set.
The Board also held two public meetings on this subject during 1996. The first was on November 7, the second on December 12. At the November meeting, the Board staff reported that DOE had completed its crosswalk. In addition, the staff presented its review and evaluation of the new orders and proposed rules. Of the set of new safety orders in place at the end of 1996, only six were complete and judged by the Board staff to be adequate: DOE 430.1, Life Cycle Asset Management; DOE 425.1, Startup/Restart; DOE 151.1,Emergency Management System; DOE 225.1, Accident Investigations; DOE 231.1, Safety and Health Reporting Requirements; and DOE 451.1, National Environmental Policy Act Compliance Program. The remaining orders require additional changes.
On the basis of its review of proposed nuclear safety rules, the Board staff concluded that the technical aspects of the rules appeared to be sound, and that the proposed rules retained the essential elements of the predecessor orders. However, policy and legal questions remained regarding the provisions for granting exemptions from regulatory requirements and for rule implementation. These questions were communicated to DOE.
At the December public meeting, DOE managers concurred in the analysis of the orders completed by the Board staff and proposed an action plan for making needed changes to the new safety orders. With respect to proposed rules, DOE staff members agreed with the Board staff regarding exemption language. With respect to other issues raised regarding the nuclear safety rules, however, DOE representatives stated that certain internal Department matters required resolution before further discussion could take place. Both DOE management and the Board expressed a desire to resolve the outstanding issues quickly. Even if full agreement on the content of the new orders and proposed rules can be reached expeditiously, some implementation issues will remain.
2.2.2 Processing and Storage of Surplus Special Nuclear Materials
In Recommendation 94-1, Improved Schedule for Remediation in the Defense Nuclear Facilities Complex, the Board recommended that all plutonium metal and oxide be stored in conformance with the then-existing draft of a standard for long-term storage. The Board also urged DOE to expedite preparations to repackage plutonium metal in contact with or in proximity to plastic because of the risk that the hydrogen generated by radiolytic decomposition of the plastic could give rise to an explosion.
DOE initially intended to issue the storage criteria as "guidance" with loose specifications, allowing individual sites to develop specific local requirements. The Board ultimately convinced DOE of the need for a technical standard for the safe long-term storage of plutonium that would provide specific requirements whose fulfillment could be measured—a standard that could be applied throughout the defense nuclear complex. That standard was subsequently issued in December 1994 as DOE-STD-3013-94. As a result of the Board's participation in the review and revision of this standard, important changes were incorporated, thereby establishing acceptable criteria for safely storing plutonium.
DOE is now using this standard as the basis for the following:
DOE reports that all plutonium known to be in direct contact with plastic (the higher- hazard condition) has now been repackaged and that work is progressing to repackage plutonium in proximity to plastic. The Mound Laboratory has shipped its plutonium to the Hanford Site and Los Alamos National Laboratory for repackaging.
2.2.3 Establishment of Sound Integrated Safety Management Systems
In Recommendation 95-2, issued in late 1995, the Board urged DOE to institutionalize a process of integrated safety management for activities at defense nuclear sites. It is the Board's view that effective implementation of Recommendation 95-2 has the potential to upgrade DOE's program for ensuring nuclear safety throughout the defense nuclear complex. To support the achievement of this most important goal, individual Board members expended considerable time and energy throughout 1996 in communicating with DOE Headquarters, field, and contractor elements about the intent of this recommendation.
In Recommendation 95-2, the Board advocated the issuance of complex-wide standards to govern the development, approval, and implementation of integrated safety management. The integrated use of safety management functions and processes to facilitate the conduct of work in achieving site missions is a major objective of this recommendation.
The Secretary of Energy accepted Recommendation 95-2 in January 1996 and submitted an implementation plan in April 1996. In responding to the recommendation, DOE stated that "the Department and Contractors must systematically integrate safety into management and work practices at all levels so that missions are accomplished while protecting the public, the worker, and the environment."
In accepting DOE's implementation plan, the Board stressed the following:
DOE has made progress in meeting the commitments of its implementation plan. A Safety Management Implementation Team was established early in the process to oversee the execution of the commitments and internal management actions outlined in the plan. A DOE policy to institutionalize the Department's safety management system—DOE P 450.4, Safety Management System Policy—was issued in final form in mid-October 1996. An acceptable contract clause was developed that will require contractors to follow the objectives, guiding principles, and functions for safety management. Encouraging as this progress has been, much work will be needed throughout 1997 and beyond to implement fully the intent of this overarching Board recommendation.
The Board was briefed in June and July 1996 on the approaches being taken by the various contractors who are implementing integrated safety management systems at the priority facilities. These briefings indicated that while some projects were progressing more rapidly than others, an encouraging start was evident overall. To assist DOE in developing guidance for Recommendation 95-2 implementation efforts, the Board commented, in an early October 1996 letter, on what it had observed in the contractors' briefings that appeared to reflect particularly effective and useful practices.
Since not all of the ten priority facility briefings to the Board contained firm schedules for implementation of integrated safety management systems, DOE provided a separate set of milestones in early October. Board review of these milestones revealed several issues, which include the following:
Resolution of these issues will require both DOE and Board effort in 1997.
2.2.4 Technical Expertise of DOE Staff
The report of the Senate Armed Services Committee on S. 1085 that accompanied the legislation establishing the Board includes the following statement: "The Board is expected to raise the technical expertise of the Department substantially. . . ." The technical qualifications of DOE personnel who are assigned safety-related responsibilities merit continued attention. The Department faces the diminution of the extensive background and experience in weapons that once resided in contractor organizations. Also, to administer effectively the upgraded approach to safety management advocated by DOE will require highly experienced staff.
The Board has issued a number of formal recommendations addressing this subject, including 90-1, 92-7, 93-2, 93-3, and 93-6. In addition, numerous letters, as well as reports generated by the Board's technical staff, have been specifically directed to the technical qualifications of DOE's safety managers. Despite DOE's actions in this arena, the number of highly qualified technical personnel added to the Department during the 1994-95 period remained minimal.
In January 1996, the Board held a public meeting in Washington, D.C., to address this issue. At that meeting, members of the Board staff who had studied this matter reported the following observations:
As a result of the January public meeting, a joint DOE/Board conference was held, at which a plan for attacking the critical unmet staffing needs of the Department was addressed. Two members of the Board and the Under Secretary of Energy, along with senior representatives of DOE Headquarters and Field Office Management and members of the Board staff, participated in this conference to focus on developing specific courses of action to address the DOE technical expertise issue. As a result of the conference, a plan to attack the critical staffing needs of the Department and to improve its cadre of Senior Technical Safety Managers was initiated by the Under Secretary.
A key action item resulting from the conference was to have Operations Office managers and Headquarters line management review their organizations and identify the required senior technical safety management positions (existing, as well as those that should be created). Approximately 250 such positions were identified.
A second key action item was for DOE to increase substantially its use of existing excepted service authority. By the end of 1996, DOE had filled a total of 59 excepted service positions, with another 22 in various stages of recruitment and staffing.4 Since DOE's authorization to fill 200 technical excepted service positions expires in October 1997, it is imperative that DOE give prompt attention to these efforts.
Despite encouraging signals from the conference, however, DOE is still experiencing difficulties in meeting its goals. Therefore, a second joint conference is tentatively scheduled for the spring of 1997. Given the expected long-range nature of any solution to this issue and the need to maintain the momentum represented by these initial actions, the Board will undoubtedly be required to sustain its active participation on a continuing basis.
Through efforts related to the joint conference, DOE has addressed issues associated with standards for various management-level technical positions, and a revision to the radiological protection standard is in process. Nevertheless, the Board believes that qualification standards in several other functional areas are marginal, and most of the standards require specific improvements. Further, and of perhaps greater importance, approved training activities and acceptable equivalencies to meet competencies identified in technical qualification standards have not yet been fully identified, developed, or promulgated.
It is not clear that this program will accomplish its objective, especially in a DOE environment in which increasing demands are placed on a dwindling staff. However, the Board remains intensely interested and intends to monitor the effectiveness of the program closely.
Finally, a success story can be reported in this area of interest. As a result of the Board's continuing emphasis on DOE's lack of adequate numbers of highly qualified technical personnel, the Richland Operations Office (DOE-RL) identified a need for added technical strength in the areas of radiological control and nuclear safety. The Board strongly encouraged DOE-RL to use the Department's excepted service hiring authority to acquire the necessary "seed" talent.
During the summer of 1996, DOE-RL received more than 300 applications for the eight identified positions and interviewed more than 100 people. The Board's continuing attention to this issue ensured technical competence and demanding interview techniques on the part of the DOE-RL Technical Review Board performing screening of resumes and interviews. As a result of this recruitment effort, eight new hires with substantial technical credentials were added to the DOE-RL staff.
DOE continues to experience changes in programs and organization. An important element of these ongoing changes is the delegation of broad operational responsibilities to field organizations. Yet in spite of the reorganization of managerial processes, poor definition of the authorities and responsibilities of DOE staff members continues to be a fundamental weakness affecting the Department's ability to ensure safety. During the past three years, the Board has placed substantial emphasis on the need for DOE to establish a clear definition of roles and responsibilities for nuclear safety within the Department. Departmental changes have outpaced corresponding changes to the FAR Manual, which is therefore out of date.
In July 1995, in response to Recommendation 94-5, DOE committed to delivering an approved, revised FAR Manual by February 1, 1996. In the implementation plan for Recommendation 95-2, this schedule was subsequently revised to mid-September 1996, and a requirement was added that ". . . the Department roles and responsibilities in the FAR Manual . . . be consistent with changes in the safety management organization instituted pursuant to this Implementation Plan." The importance of this issue was also emphasized at the joint DOE/Board conference discussed in Section 2.2.4 above. A specific DOE Action Item arising from that conference addressed the role of the federal employee in the DOE defense nuclear complex, especially the need to reflect ownership of issues related to safety management of Departmental facilities. DOE noted that "this responsibility can be shared, but DOE's portion is not diminished."
An updated draft document, the DOE Safety Management Functions, Responsibilities and Authorities Manual (FRAM), was delivered to the Board in July 1996. The Board provided comments to DOE in mid-August; a revised FRAM was then provided to the Board in October. Based on a review of the revised manual by its staff, the Board concluded that significant deficiencies limit the usefulness of the draft FRAM. In its present form, it cannot act as a stand-alone statement of the Department's assignment of functions, responsibilities, and authorities. Detailed comments were forwarded to DOE. As a result, DOE concluded that the manual cannot be issued until additional details, to be provided by an integrated series of subtier documents (Level 2 FRAMs), are developed. DOE has indicated that this effort cannot be completed before May 1997.
The Board has continued to emphasize the importance it attaches to the issuance of an updated FRAM, and to DOE's ensuring that its line management clearly understands its responsibilities.
2.2.6 Operational Readiness Review Activities
Since its inception, the Board and its staff have carefully reviewed preparations for starting or restarting activities at defense nuclear facilities and the conduct of associated readiness reviews. Confirmation of readiness to proceed is a major element of an acceptable safety management program as outlined in Recommendation 95-2, Safety Management. The Board has made a number of other recommendations that have addressed standards for performance of Operational Readiness Reviews, including Recommendations 90-4, 91-3, 91- 4, 92-3, 92-5, and 92-6.
Throughout 1996, the Board and its staff continued to monitor readiness for startup or restart of activities and conduct of readiness reviews throughout the complex, including the following:
In general, the Board continues to observe improvements in preparations by line management for startup or restart of operations and the conduct of readiness reviews.
2.2.7 Operational Radiological Safety
The Board's initiatives during the past five years have led to distinct improvements in radiological control programs throughout the DOE complex. In November 1996, the Board determined that the major purposes of Recommendation 91-6 on improving the DOE program for radiological protection of workers and the public had been met. This recommendation is now closed. However, continued vigilance and strong technical leadership at all levels of DOE management will be required if DOE is to continue to meet its declared goal of excellence in radiological protection performance.
Since its establishment, the Board has advocated improvement in DOE's complex- wide radiological protection program. In addition to monitoring Department-level policy and requirements regarding radiological protection, the Board and its staff have made numerous visits to assess the overall adequacy of site radiological protection programs and the degree of their conformance with existing DOE guidance. In addition, the Board staff has been especially active recently in reviewing the development of DOE's proposed revisions to its radiological protection rule, 10 CFR 835.
During the first year and a half following its establishment, the Board conducted assessments and reviews of radiological protection programs at several DOE defense nuclear facilities. As a result of these efforts, the Board identified significant weaknesses in DOE's radiological protection program and in December 1991 issued Recommendation 91-6, Radiation Protection for Workers and the General Public at DOE Defense Nuclear Facilities. In this recommendation, the Board identified a need for increased DOE attention in five major areas: (1) DOE management and leadership in radiological protection programs, (2) radiological protection standards and practices at defense nuclear facilities, (3) training and competence of health physics technicians and supervisors, (4) analysis of reported occurrences and correction of radiological protection program deficiencies, and (5) understanding of and attention to radiological protection issues by DOE and its contractor organizations.
The Board has consistently urged DOE to improve its radiological protection program and, in Recommendation 91-6, it explicitly encouraged the Department to strive toward excellence in this area. DOE responded to Recommendation 91-6 by strengthening its policies, standards, training, oversight, and organizational infrastructure for the Department- wide radiological protection program. In June 1992, partly in response to Board urging, DOE incorporated mandatory radiological controls, requirements, and practices in its newly issued Radiological Control Manual. Late in 1993, DOE codified its radiological protection requirements in 10 CFR 835, which included as-low-as-reasonably-achievable (ALARA) provisions.
As part of the 1995 consolidation of its health and safety orders, DOE redesignated the Radiological Control Manual as simply a guidance document, covering any gaps left by this action with pertinent requirements contained in DOE Notice 441.1, Radiological Protection for DOE Activities. The Board found that these standards provide an adequate framework for an acceptable occupational radiological protection program. The guidance thus promulgated is consistent with standards applicable to the commercial nuclear industry.
During 1996, the Board conducted assessments of work planning practices, with particular attention to radiological protection programs at the Hanford Site, the Rocky Flats Environmental Technology Site, the Los Alamos National Laboratory, the Idaho National Engineering Laboratory, and the Oak Ridge Y-12 Plant. The greatest emphasis was on the Hanford Site, where deficiencies in the radiological protection program are long-standing, and where a continuing lack of both management attention and technical expertise was evident. Considerable improvement in the level of technical expertise at Hanford resulted (see Section 2.2.4 above).
The Board and its staff also reviewed proposed changes to the rule on Occupational Radiation Protection, 10 CFR Part 835. Among the issues raised by the Board staff and resolved by DOE were dose limits, use of the terms "survey" and "monitoring," and requirements for calibration of equipment such as air samplers. DOE published an amendment to 10 CFR 835 for public comment in late December 1996. The Board will continue to work with DOE staff during the public comment period, staying abreast of comments, their resolution, and changes made in the final rule.
2.2.8 Health Effects of Plutonium Uptake by Workers
The Board has been influential in arranging for the reactivation of and a modest increase in funding for a long-term study of individuals who have received known radiation exposures from internal deposition of plutonium. Affected individuals were examined every five years from 1951 through 1991. The target group includes nineteen surviving workers (seven others have died) who were exposed during the time they worked at Los Alamos National Laboratory in the early days of the nuclear arms race.
The forty-year study of known and measurable plutonium deposition in these individuals constitutes hard evidence that the radioactive element is not as hazardous as generally believed. Reacting to criticism that DOE lacked public credibility, DOE's Office of Environment, Safety and Health (ES&H) transferred the study from Los Alamos National Laboratory to the Department of Health and Human Services' National Institute for Occupational Safety and Health (NIOSH). Two years later, NIOSH decided to drop the program, alleging that it was too small to be statistically significant, and ES&H subsequently decided not to fund it.
In response to urging from the Board and action by Under Secretary Thomas Grumbly when he was informed of the situation, DOE has once again resumed the study, under the direction of Dr. George Voelz, an internationally recognized expert, who had directed the study from 1970 through 1988. A funding level of $90,000 is earmarked for this work during fiscal year 1997, but none is currently available for fiscal year 1998. The Board believes that adequate funding should be made available to continue the health studies of the remaining former employees with known plutonium contamination.
2.3 ACTIVITIES RELATED TO DECONTAMINATION AND DECOMMISSIONING
As DOE's mission has changed from production to cleanup, the Board has increased its attention to the decommissioning of production facilities. This shift has included greater emphasis on the safety standards to be used during decommissioning and closer scrutiny of programs aimed at ensuring the health and safety of workers, as well as the offsite public, during the stabilization and deactivation phases of decommissioning (see Section 2.5 for a discussion of stabilization of residual radioactive materials). DOE initiatives to develop pilot programs on enhanced work planning are designed to involve workers along with safety professionals in work planning. These pilot programs are leading to improved safety awareness and to incorporation of appropriate safety measures in work plans.
The Atomic Energy Act requires the Board to review and evaluate the content and implementation of standards (including applicable DOE orders, regulations, and requirements) relating to the design, construction, operation, and decommissioning of each DOE defense nuclear facility. Decommissioning commences in earnest when DOE determines that facilities are no longer needed to support the weapons program; the facilities are then scheduled for deactivation and eventual dismantlement or reuse. The Board has defined terms related to decommissioning and clarified its jurisdiction and responsibilities during the decommissioning process in its policy document PS-3 and its technical report on Regulation and Oversight of Decommissioning Activities at Department of Energy Defense Nuclear Facilities (DNFSB/TECH-12).
As described in these documents, decommissioning has different meanings for different agencies. In the context of Board oversight of a DOE defense nuclear facility under the Atomic Energy Act, decommissioning starts at the end of operations and ends when radioactive materials have been adequately removed from the facility. DOE, for its own purposes, has broken down the period following operations into phases such as stabilization, deactivation, and decommissioning. Although this has caused no conflicts, clarification of terms is needed for jurisdictional purposes. The above documents also clarify that, regardless of the term applied to the phases in the life of a facility, the Board's interest follows the hazards to worker and public health and safety posed by the radioactive materials involved.
DNFSB/TECH-12 goes on to describe the interactions that occur among the Board and other regulators as a facility progresses through decommissioning (from operations to environmental restoration). Board interest in a facility diminishes as radioactive hazards are removed, whereas Environmental Protection Agency (EPA) and state interests increase as the facility progresses through cleanup to environmental restoration and release for limited or unrestricted use. DNFSB/TECH-12 suggests principles of cooperation to streamline the transition and minimize the impact of multiple regulators on DOE activities.
On the basis of understandings with EPA and associated state authorities, DOE is proceeding to decontaminate excess facilities to the extent required to maintain and monitor them safely until they can be dismantled or converted to other uses, and environmental restoration can be accomplished under provisions of the Resource Conservation and Recovery Act (RCRA), the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA), or applicable state statutes as appropriate. Provisions of those statutes bring such actions under the oversight of EPA and/or the affected states, as well as the Board.
In keeping with its interest in following hazards to the health and safety of workers and the public, the Board has focused its attention with regard to deactivation and decommissioning primarily on the Rocky Flats Environmental Technology Site (RFETS), the Hanford Site, and the Savannah River Site—three locations DOE has selected for early cleanup:
To avoid duplication of the regulation and oversight of decommissioning, the Board, along with DOE, EPA, and the State of Colorado, developed a Memorandum of Understanding (MOU) that coordinates their respective oversight and regulatory authorities during the cleanup of RFETS. Coordinated efforts under such an MOU should minimize the impact of multiple regulators on DOE activities, while accommodating each agency's statutory mandate. Specifically, one agency with jurisdiction over a given DOE activity takes a primary role, and the other regulatory or oversight agencies with jurisdiction or special expertise take secondary roles, advising the primary agency or working through that agency to discharge their jurisdictional responsibilities. The MOU neither expands nor diminishes statutory powers, and DOE need only work directly with one agency and follow a set of consolidated and agreed-upon requirements. DOE, EPA, the State of Colorado, and the Board executed the RFETS MOU in February 1996. It was then issued as an appendix to the final Rocky Flats Cleanup Agreement.
The Board has pursued cooperative arrangements with other states that have DOE sites involved in substantial decommissioning activities. For example, the Board is now working with the State of Tennessee and DOE to establish an informal protocol to ensure that CERCLA activities at the Oak Ridge National Laboratory Molten Salt Reactor Experiment are coordinated with the Board's health and safety activities. Close cooperation among the parties should help prevent duplication and negative impacts on the DOE cleanup schedule. This protocol may be expanded, as mutually agreed, to accommodate future decommissioning activities at Oak Ridge.
2.3.1 Rocky Flats Environmental Technology Site
The Board has identified Building 771 at RFETS as one of the highest-priority facilities in the DOE nuclear weapons complex to be inventoried for decommissioning. Plutonium processing and research and development in the building have been shut down since 1989. Under DOE's planning, deactivation is scheduled to begin during fiscal year 1998, with decommissioning due to start two years later. Many of the processes carried out in Building 771 involved weapons-grade plutonium dissolved in strong acid solutions. On a number of occasions in the past, these solutions have leaked from equipment and contaminated various areas of the building. A significant amount of plutonium is held up in the production equipment, including gloveboxes, ventilation ducting, filters, and inaccessible areas. More than 10 kilograms (kg) of plutonium is held up in ductwork alone, with unknown quantities in equipment, tanks, and piping.
Building 779, previously used for research and development of processes for handling special nuclear materials, is to be a pilot project for deactivation of other high-hazard buildings. Deactivation, which is expected to last about three years, is presently under way with removal of special nuclear materials and remaining chemicals. Deactivation and decommissioning will overlap, with dismantlement of process equipment due to begin in March 1997.
Deactivation of the Uranium Trioxide (UO3) Facility. The UO3 Facility was formerly used to convert uranyl nitrate hexahydrate solution from the PUREX Plant into UO3 powder. The facility's last operating campaign was completed in June 1993, after which deactivation began immediately.
Deactivation of the UO3 Facility is intended to establish a passively safe and environmentally secure configuration and to preserve that configuration for up to ten years. DOE considers the project to be completed. Currently, the plant is unoccupied and contains no portable equipment or furniture. Nearly all radioactive or hazardous materials have been removed. Only minimal effort is required for surveillance and maintenance activities. All process equipment, instrumentation, and systems for heating, ventilation, and air conditioning have been shut down. The building doors and gates in the perimeter fence are locked to limit access. The facility is entered only to conduct quarterly surveillance visits or to correct deficiencies identified during previous surveillance entries.
The Board completed a review of the authorization basis for the UO3 Facility applicable during this period of the facility's life cycle and found that for the near term, the existing framework of implementation and safety management provides adequate protection for workers, the public, and the environment. However, the environmental restoration contractor has not demonstrated that long-term surveillance and maintenance activities will provide the same level of protection. Furthermore, the ability to plan adequately for and manage an emergency situation has not been demonstrated.
The PUREX Facility and the B-Plant. The PUREX Facility processed irradiated fuel from the Hanford production reactors for the recovery of plutonium and uranium between 1956 and 1972. It was restarted in 1983 and continued to operate until 1990. The B-Plant had several functions during its 50-year life, the most recent of which was the removal of cesium and strontium from high-level radioactive waste.
DOE intends for PUREX to follow a deactivation process similar to that used at the UO3 Facility. The deactivation of PUREX neared completion during 1996, and DOE expects completion by early 1997. Deactivation of the B-Plant is scheduled to begin during 1997, following the model developed for the UO3 and PUREX facilities (see Section 2.4.4).
The C-Reactor. The C-Reactor is a surplus production reactor originally scheduled to be the first of eight to be dismantled at the Hanford Site. In lieu of dismantling, DOE now intends to place the C-Reactor in a cocoon for a period of up to 75 years before dismantlement is completed.
C-Reactor cocooning consists of demolishing and removing or burying all the structures and the fuel pool, with the exception of the walls immediately surrounding the graphite reactor block. The reactor block and walls are then to be sealed and capped for the long term.
DOE expects that this method will provide a safe storage mode during this extended period and reduce the risks and costs of prolonged maintenance. In addition, DOE believes that the use of a cocoon could demonstrate technology improvements with the potential to reduce cost, improve safety, and lessen environmental liabilities within the DOE complex. Technologies developed at the C-Reactor could be transferred quickly to other Hanford facilities, where similar reactors and dozens of other large facilities require action, as well as to facilities elsewhere in the defense complex.
105-N Basin Cleanout. The N-Reactor is a surplus dual-purpose production reactor that operated from 1963 through 1987. The 105-N Basin contained irradiated fuel assemblies discharged from the N-Reactor during its operating lifetime. In 1989, the reactor was completely defueled, and all remaining spent fuel was removed from the basin. Debris removal began in 1995 and currently continues. Debris remaining in the basin includes highly radioactive hardware (greater than 1 rad per hour on contact) that was irradiated in the reactor, basin sediment, and basin water.
The Board staff observed basin cleanout activities during 1996 and reviewed applicable safety documentation. These reviews, as well as assessments completed by DOE and other independent reviews, identified weaknesses in the contractor's safety documentation. Hazard and safety analyses made assumptions that could not be fully supported, and the adequacy of protective measures in place was questionable. Subsequently, the contractor reverified and formalized its safety controls under the scrutiny of DOE. The Board continues to monitor these activities as the contractor upgrades safety documentation and continues 105-N Basin cleanout.
2.4 ACTIVITIES RELATED TO DESIGN, CONSTRUCTION, AND INITIAL OPERATIONS
While the overall budget and manpower of the DOE defense nuclear complex are shrinking, there are still several large construction projects under way or in advanced planning stages. In some cases, new facilities are needed to ensure the safety and reliability of existing nuclear weapons and to provide component testing capabilities in the absence of future underground nuclear testing. Other new facilities are needed to stabilize and store large quantities of high-level nuclear waste, plutonium, and other hazardous legacies of the production of nuclear weapons.
The Board's statutory mission includes responsibility for reviewing the design of new defense nuclear facilities, monitoring the construction of new facilities, and making health and safety recommendations to the Secretary of Energy related to new construction. This obligation applies not only to altogether new, free-standing facilities, such as the Actinide Packaging and Storage Facility at the Savannah River Site (described below), but also to substantial modifications of existing facilities. In many cases, ambitious remodeling of old facilities, such as the Chemistry and Metallurgy Research Building at Los Alamos National Laboratory and Building 371 at Rocky Flats, will be more difficult technically than construction of completely new buildings.
In-Tank Precipitation (ITP) Facility. The ITP Facility is a pretreatment facility used to concentrate and remove radioactive fission products from high-level waste liquids. The separated fission products will be processed at the Defense Waste Processing Facility. The decontaminated liquids are to be processed at the Saltstone Facility.
In the ITP process, tetraphenylborate is added to the contents of a waste storage tank, causing cesium and certain other fission products to precipitate out of the liquid waste. During the process, chemical and radiolytic decomposition of the tetraphenylborate occurs, liberating substantial quantities of highly flammable benzene. Test results suggest that the precipitated cesium and potassium tetraphenylborate solids, as well as the excess tetraphenylborate in solution, may also be vulnerable to rapid decomposition by catalytic attack. If the precipitated solids should decompose, the resulting benzene release could be very large indeed. Such an event would pose a major flammability hazard.
This potential hazard was a key factor in the Board's decision to issue Recommendation 96-1, In-Tank Precipitation System, Savannah River Site, in August 1996. The Board strongly urged DOE not to proceed with large-scale process testing in the ITP Facility until the mechanisms by which flammable gases are generated, retained, and released in the ITP process are better understood, and appropriate safety measures to prevent a deflagration are in place.
The Board's review of the safety basis for ITP disclosed further that the maximum percentage of oxygen permitted in the vapor space in the tank was inadequately justified. The tank involved (Tank 48) has an inerting system intended to keep the percentage of oxygen in the vapor space below the minimum concentration required to support combustion. However, the percentage of oxygen required for combustion varies for different admixtures of gases, and the safety evaluation for ITP did not show whether the chosen oxygen limit was appropriate for the gas compositions that could exist in Tank 48. When informed of this problem, Savannah River Site personnel performed additional calculations to justify the limit, updated the safety evaluation, and added a new control on tank operations to prevent hydrogen from accumulating to a concentration that would invalidate the new analysis.
The output from the ITP Facility will eventually serve as another feed stream to the Defense Waste Processing Facility, where high-level waste is vitrified. The latter facility is currently operating and has enough feed material to operate for several years before the output from ITP will be needed.
The Board regards process safety at ITP as one of the highest-priority issues in the complex. The combination of benzene and high-level waste being created at ITP is a unique hazard that will need to be carefully analyzed and controlled, and the potential problem has not yet been fully resolved. The Board is closely monitoring DOE's efforts to characterize ITP's chemical process to ensure that sufficient understanding is developed to support safe operations. The Board is also carefully evaluating safety systems being developed for ITP to ensure that process controls are adequate, and that preventive and mitigative controls will protect facility workers and the public from undue risk.
Actinide Packaging and Storage Facility. A new Actinide Packaging and Storage Facility is to be constructed at the Savannah River Site. This new facility will be required to meet the storage standard for plutonium metal and oxide discussed in Section 2.2.2. It will incorporate plutonium stabilization and packaging equipment, along with sufficient vault space to permit extended interim storage of the site's plutonium. In a recent Record of Decision, DOE stated its intention to store up to 10 metric tons of surplus plutonium in the expanded Actinide Packaging and Storage Facility. This facility will also store plutonium from the Rocky Flats Environmental Technology Site, as well as material already at the Savannah River Site.
Conceptual design documentation for the facility was completed during 1996; detailed design will begin in the second quarter of 1997. Construction is scheduled to start at the end of 1998 and to be completed by 2001. During 1996, the Board staff reviewed the safety aspects of the conceptual design documentation; safety aspects of the detailed design will be reviewed during 1997.
2.4.2 Rocky Flats Environmental Technology Site
In 1993, DOE formulated plans for the consolidated storage of special nuclear material in Building 371 at the Rocky Flats Environmental Technology Site. The Board reviewed the design of the building, including its capacity to withstand external forces from natural phenomena (e.g., earthquakes and high winds). Based on its reviews, the Board concluded that activities to prepare Building 371 for an extended storage mission were neither logical nor sufficiently broad in scope to ensure protection of the health and safety of the public and workers since, in due course, Building 371 will contain a large part of DOE's supply of plutonium.
In Recommendation 94-3, Rocky Flats Plutonium Storage, the Board urged DOE to use systems engineering methods in the development of an integrated plan for addressing the civil engineering, structural, and seismic safety issues and evaluations related to the planned use of Building 371. In October 1995, DOE completed an analysis which determined that the building could be made structurally adequate provided several structural upgrades were performed. In September 1996, the Board accepted an integrated program plan that requires the completion of required upgrades to those structures, systems, and components which provide safety functions; the development of a safety management program; and the initiation of actions toward DOE's preferred alternative of constructing an interim storage vault in lieu of using Building 371. In late 1996, the structural upgrades were designed and installed, thus making the building structurally adequate for the interim storage mission.
2.4.3 Los Alamos National Laboratory
Capability Maintenance and Improvement Project and Upgrades to Technical Area-55 and the Chemistry and Metallurgy Research Building. The objectives of the Capability Maintenance Improvement Project are to (1) improve the capability to carry out current missions by maintaining and improving facilities and (2) develop the capacity for limited-scale manufacturing of plutonium pits for nuclear weapons. The project involves Technical Area-55 (TA-55), the Chemistry and Metallurgy Research Building, and some non- nuclear facilities and infrastucture. The cost of the program is expected to be about $360 million. The conceptual design report is expected to be completed in early 1997. The Board has conducted an initial review of the Capability Maintenance and Improvement Project and the planned upgrades to the Chemistry and Metallurgy Research Building to identify any safety-related issues. The need to specify more clearly the roles and responsibilities at the Los Alamos National Laboratory was highlighted to laboratory management. Also, since some assumed scenarios regarding safeguards and security have the potential to affect safety within nuclear facilities, the importance of clarifying requirements for safeguards and security early in the design process was noted.
Upgrades to the Nuclear Materials Storage Facility at Technical Area-55. The Nuclear Materials Storage Facility is to be upgraded and used for storage of special nuclear material needed at the Los Alamos National Laboratory. To date, no special nuclear material has been stored at the facility, and major modifications are needed to make the facility usable. In its review of the conceptual design for the upgrades to the facility, the Board identified several issues, including potentially out-of-specification placement of reinforcing steel in the concrete walls. As a result of this review, cognizant personnel at the laboratory have developed a plan to resolve the flawed conditions. Replacement of some structural members may be required.
Integrated Safety Management and Authorization Basis. The Board has reviewed the Los Alamos National Laboratory's progress in developing an integrated safety management system for TA-55 and has had a number of informal discussions in this regard with laboratory management. Technical management approaches to reviewing proposed activities, including analyses of process hazards, continue to be reviewed. TA-55 management has been encouraged to place increased emphasis on risk reduction. In addition, specific issues related to safety management have been evaluated. For example, the Board staff noted that the laboratory does not have an adequate electrical safety program. The Board expects such a program to be incorporated into the integrated safety management system under development. The Board staff also identified a need for operating limits related to degradation of the system supplying water for fire suppression.
In late 1995, DOE began deactivating the B-Plant at the Hanford Site. This facility was used in several defense production and waste management missions during its 50-year life, the last being the removal of cesium and strontium from high-level radioactive waste stored in the Hanford tanks.
The Board's review of the B-Plant found that over the lifetime of the plant, a large amount of radioactive material had been deposited on the operating high-efficiency particulate air (HEPA) filter in the exhaust ventilation system. The filter unit in use at the time of the Board's evaluation showed signs of degradation due to its age and the resulting exposure to radiation. A new unit was made available for service after appropriate checkout and testing. Three previously retired filter units were also heavily contaminated with radioactive material. Although these three units were isolated by water seals, such seals do not provide a reliable means for isolating airborne radioactivity.
Although DOE and its contractors had previously discussed retiring the degraded filter, it remained in service. When the Board pointed out the safety issues involved, which were documented in a report prepared by the Board staff, DOE removed the filter from service and placed the new unit in operation. DOE also decided to construct a new exhaust filter system to bypass the existing system, and to replace the water seals with physical barriers. These actions significantly reduced the potential for a radiological release to the environment in the event of a failure of the operating exhaust filter unit.
2.4.5 Gaseous Diffusion Plants at Oak Ridge, Portsmouth, and Paducah
Approximately 50,000 cylinders containing more than 500,000 metric tons of depleted uranium hexafluoride (UF6) gas from the production of enriched uranium for both defense and civilian purposes are stored outdoors at gaseous diffusion plants in Oak Ridge, Tennessee; Portsmouth, Ohio; and Paducah, Kentucky. In early 1995, the Board found that the corrosion-resistant coatings of these cylinders had not been maintained and that many cylinders were being handled and stored under conditions that could lead to increased breaching of the cylinders. To protect against further cylinder breaches and the resulting potential for dispersion of large amounts of UF6 to the environment, the Board issued Recommendation 95-1, Improved Safety of Cylinders Containing Depleted Uranium, in May 1995, recommending that DOE address the problem promptly. The Secretary of Energy accepted the Board's recommendation and submitted an acceptable implementation plan in October 1995.
During 1996, the Board reviewed DOE's progress in implementing Recommendation 95-1, and found that significant actions have been taken to slow the degradation of cylinders. Substantial progress has been made in several areas, including removing cylinders from direct ground contact, painting the areas of cylinders most vulnerable to corrosion, completing design and construction of several new and improved cylinder storage yards, and establishing a pilot program at the Paducah Gaseous Diffusion Plant to demonstrate a method for recoating entire cylinders (approximately 1,500 cylinders have been recoated under this pilot program).
The actions of DOE in 1996 indicate an understanding of the intent of Recommendation 95-1. While significant action has been taken, more remains to be done, including the establishment of cylinder coating programs to recoat cylinders in storage at all three sites. The Board will continue to monitor DOE's progress toward implementation of Recommendation 95-1.
2.5 ACTIVITIES RELATED TO PLUTONIUM STABILIZATION
In the Board's early years, stabilization of plutonium and other nuclear raw materials was not a prominent issue. During the era of active weapons production, plutonium and other weapons materials were in demand as feed materials. Any plutonium-rich scrap from weapons fabrication processes was quickly recycled. When older weapons were retired and disassembled, the plutonium they contained was quickly reused for the production of new weapons. Only small amounts of plutonium or plutonium-rich scrap were ever allowed to remain in storage for more than a few months. This situation changed dramatically starting in 1989.
DOE shut down weapons production activities at many defense nuclear facilities during the period from 1989 to 1992. In most of those facilities, substantial quantities of plutonium, uranium, and irradiated fuel were in storage awaiting processing. In many cases, the storage configurations were intended to be temporary and were not considered safe for long periods of time. Plutonium in reactive forms or in temporary, unsealed containers needed to be converted to stable metallic or oxide forms and placed in durable, sealed containers. Irradiated fuel needed to be removed from temporary storage in water basins, and converted to stable forms for long-term storage.
In order to deal with the wide scope of the material instability problem, the Board issued Recommendation 94-1, Improved Schedule for Remediation in the Defense Nuclear Complex, which called for an aggressive timetable for removing plutonium and irradiated fuel from temporary storage and placing the materials in stable forms for safe long-term storage.
The implementation plan for Recommendation 94-1 also calls for stabilization of solutions containing other actinides. These actinide solutions are chemically unstable and readily dispersible. Stabilization has required restarting certain processes in older facilities, as well as installing new processing capability in some other facilities. The Board's close and continuing attention to facility preparations and stabilization activities and DOE's response to Recommendation 94-1 have led to the following key accomplishments:
The following subsections detail activities and issues related to plutonium stabilization at the Savannah River Site, the Rocky Flats Environmental Technology Site, and the Hanford Site.
In Recommendation 94-1, the Board urged DOE to expedite processing of deteriorating Mark 16 and Mark 22 aluminum-alloy spent fuel stored in basins at the Savannah River Site. In its implementation plan for this recommendation, DOE committed to begin stabilizing the fuel by November 1996. Although DOE had planned to conduct additional studies of the feasibility of dry storage, the Board pointed out problems involved in pursuing these dry storage plans and identified other rapidly corroding nondefense fuel that had previously been predicted by DOE to remain stable for another ten years. In an earlier technical report, the Board had established the technical basis for concluding that stabilization of the fuel by chemical separation is a better alternative. The Board's attention to this matter contributed to a DOE decision to stabilize this particular spent fuel by processing it in the Savannah River Site canyon facilities.
The conversion of the fuel into more manageable components (i.e., feed for the Defense Waste Processing Facility and low-enriched uranium) did not begin on the desired schedule. A delay in processing of the material resulted from a DOE and contractor review of the adequacy of the seismic analyses of the F- and H-Canyons. The Board and its staff participated in an aggressive review of the analytical effort and supported a DOE decision to resume processing in the F-Canyon. A decision on the adequacy of the H-Canyon was pending