RECOMMENDATION 92-5 TO THE SECRETARY OF ENERGY pursuant to 42 U.S.C.  2286a(5) Atomic Energy Act of 1954, as amended. Dated: August 17, 1992 The changes in defense-related plans in the Department of Energy are beginning to have a profound effect on the activities directed to systematic upgrading of the conduct of operations at defense nuclear facilities, plans that have often been discussed between the Board and its staff, on the one hand, and members of your staff on the other. The Rocky Flats Plant presents an excellent example of the major changes being made by DOE while reconfiguring the nuclear weapons complex. It had been planned that as the Rocky Flats Plant moved toward resumption of production of plutonium components of nuclear weapons, a succession of facilities would be readied for renewed operation, beginning with Building 559 (the analytical chemistry laboratory), and followed by Building 707 and then others. This process was to include systematic upgrading of the quality of operations in each case, including Operational Readiness Reviews by the contractor and by DOE to verify that the desired improvements had been accomplished by line management. Resumption of operations is now proceeding in Building 559, in accordance with this process and following the path proposed in your Implementation Plan for the Board's Recommendations 90-4 and 91-4. You have announced, however, that in light of international developments, plutonium production operations will not be resumed at the Rocky Flats Plant, and future activities there will be confined to cleanup and decontamination of the site, decommissioning of some facilities and parts of others, and placing of some facilities and parts of others in a state of readiness for resumption of operations in the future in the event such a step should be needed. Thus for most facilities at Rocky Flats there is now a major change from the mission and activities previously planned and for which the Board's Recommendations and your implementation plans specific to the Rocky Flats Plant were to be applied, for those recommendations were predicated upon resumption of plutonium production. At a number of other defense nuclear facilities, similar changes are taking effect. Many facilities are now scheduled for cleanout, shutdown, and decommissioning. Some are to be devoted to aspects of cleanup and decommissioning of sites and of facilities located 2 within sites. Some are slated to be placed in a standby mode, available for restart at a later date if needed. Some are to be continued in operation either in reduction of the stockpile of nuclear weapons or in the maintenance of a reduced stockpile and improvement of its safety. Some of these facilities have been inactive for long periods of time. Some are to become involved in operations that differ from past usage. Experience shows that when operations are resumed at a facility that has been idle for an extended period, or a facility is operated in a new mode, there is an above-average possibility of mistakes, equipment failures, and violations of safety requirements, that could cause accidents. We believe that special attention is needed at such times. The appropriate measures to be followed depend on specific features of the facility, the nature of the planned campaign of use, and the long-term plan for the facility. For example, one needs to know if further campaigns are likely, of the same or different kinds; if the facility is to be decommissioned after the planned use; or if it is to be placed in a standby mode. The Board has found, through experience at the Savannah River Sites and the Rocky Flats Plant and other defense nuclear facilities, that an extended period of time has been required at major facilities to develop an acceptable style and level of conduct of operations. Accomplishing the cultural changes you have required and meeting safety standards comparable to those required of the civilian nuclear industry remains an ongoing challenge. Major improvements have been necessary including development of configuration control, revised and acceptable safety analysis, revised Limiting Conditions of Operation derivative from the safety analysis, operating procedures consistent with the configuration and the safety analysis, and training and qualification of operators for the new mode of operation. Continued improvement has been sought by the Board. The Board has been informed that DOE does not intend to devote equivalent time and resources to improving the quality of operation at a facility being restarted only for a short campaign or intended for use only in a short campaign in a different mode, but would on a cost-benefit basis use a graded approach, always being sure, however, to take whatever compensatory and other measures are needed to ensure the acceptable level of safety. The definition and exposition of a graded approach as it is meant to be used in ordering the conduct of operations have not been provided. In discharging its responsibilities in the context of the new defense-related plans of the Department of Energy, the Board intends to carefully review future operations at defense nuclear facilities on a case-by-case basis, starting in each 3 instance from the best information as to the intended future use of the facility. Any proposals to use special measures or controls to compensate for deviations from those ordinarily used to achieve high quality conduct of operations will be closely scrutinized. Therefore, it is requested that as you decide the future status of individual defense nuclear facilities you inform the Board, designating which ones are to continue in operation and their mission, which are to be shut down for decommissioning within a short time period, which are to be used for an extended time period and then shut down for decommissioning, and which are to be moved to a standby mode (along with the schedule for this). Regardless of the category, the Board believes that operation and maintenance of defense nuclear facilities in all modes should be in accordance with the Nuclear Safety Policy statement that you issued on September 9, 1991 as SEN-35-91, and the safety goals stated therein. The Board also believes that, to the extent practicable, facilities that are to be shut down and decommissioned should be cleaned up, and hazards from radiological exposures sufficiently reduced that access can be made freely without need for precautions against radioactivity, and facilities meant for standby status should be placed in such a condition that sudden need to reactivate them would not subject a new operating group to unacceptable radiation hazards. In furtherance of this view it is recommended that: 1. For defense nuclear facilities scheduled for long term continued programmatic defense operations or for other long term uses such as in cleanup of radioactive contamination or in storage of nuclear waste or other nuclear material from programmatic defense operations, the Department of Energy should institute a style and level of conduct of operations comparable to that toward which DOE has been working at Building 559 at the Rocky Flats Plant and the K-Reactor at the Savannah River Site, and which is at least comparable to that required for commercial nuclear facilities, addressing at a minimum the areas referred to above in connection with style of conduct of operations. 2. Where a facility, after a long period of idleness for whatever reason, is being readied for new use or reuse, special care should be taken to ensure that the line organization, both DOE 4 and contractor, has the technical and managerial capability needed to carry out its responsibilities. Appropriate and effective Operational Readiness Reviews should be conducted by the contractor and by DOE before restart of the facility, to establish confidence that line management has provided satisfaction of safety requirements. Where national security requirements lead to urgent need to restart such facilities before necessary upgrades can be fully completed, compensatory measures should be instituted and their adequacy in ensuring the desired level of safety should be confirmed through appropriate independent review. 3. For facilities designated for the various other future modes of use (such as standby), DOE should undertake to develop specific criteria and requirements that ensure meeting the safety goals enunciated in your Nuclear Policy Statement (SEN- 35-91). Accomplishment of these criteria and requirements by line management should be confirmed by appropriate independent review. /s/ John T. Conway Chairman