Recommendation 90-4, Operational Readiness Review at the Rocky Flats Plant
Problem Statement:
"In several visits to Rocky Flats, the Board and its experts have reviewed aspects of operations and activities. These reviews have been directed toward ensuring adequate protection of public health and safety and concern matters that have an important bearing on resumption of plutonium processing operations. The Board's reviews have included such operations-related activities as reconstruction of drawings of systems important to safety (?red-lining'), development and validation of plant operating procedures, and training and requalification of plant operators in plutonium processing operations.
"Several of these contractor activities, which would ordinarily be conducted in sequential manner, are being carried forward concurrently. Because of the interdependence of these activities, the Board has not yet been able to predict their adequacy at the time of proposed resumption of plutonium processing operations. For example, at the time of our most recent visit, no training lesson plans had been approved and less than one-third had been submitted for review. Training materials that were reviewed contained extensive on-the-job examination and performance requirements leading to requalification. This process will be time-consuming.
"Usual practice in restarting a nuclear facility after an extended outage is the conduct of a comprehensive operational readiness review. Aware of the benefits of this practice in ensuring that public health and safety are adequately protected, and in view of the situation, the Board recommends that such a readiness review be carried out at Rocky Flats prior to resumption of operations."
Comment:
Note that "usual practice in restarting a nuclear facility after an extended outage is the conduct of a comprehensive operational readiness review." [Emphasis added] DOE should not have had to be told this by the Board.
Recommendation 93-1, Standards Utilization
Problem Statement:
"The Board has noted significant progress by DOE in the issuance of new and revised nuclear safety orders that more explicitly delineate requirements in such areas as: unreviewed safety question determinations, technical safety requirements, nuclear safety analysis reports, design requirements and nuclear criticality safety. However, the Board's ongoing review of the use of standards in defense nuclear facilities has disclosed a number of potential inconsistencies in the manner in which DOE Orders related to nuclear safety are applied at facilities that produce and process fissile materials, relative to those facilities that assemble, disassemble, and test nuclear weapons. The Board notes that DOE orders differentiate between nuclear safety and ?nuclear explosive safety,' (the latter is defined by DOE Order 5610.11, Nuclear Explosive Safety); however, the Board considers that certain basic safety principles apply to the handling of fissile materials, regardless of the form that the material is in.
"For example, a number of orders related to nuclear safety are explicitly excluded from applicability to facilities that assemble, disassemble and test nuclear weapons, while others are applicable only to ?nuclear facilities,' (as defined by DOE Order 5480.5, Safety of Nuclear Facilities). Those that apply to ?nuclear facilities do not necessarily apply to facilities that assemble, disassemble and test nuclear weapons. In other technical areas, such as quality assurance, essentially different programs have been put in place (i.e., DOE-AL directives QC-1 and QC-2, as opposed to DOE Order 5700.6C).
"The Board is committed to ensuring the level of safety assurance at those facilities that assemble, disassemble and test nuclear weapons is at least as rigorous as that required at other defense nuclear facilities and that it can be measured to compare with the level of safety assurance provided to the public and site workers by commercial nuclear material processing facilities."
Comment:
DOE should have been able to see on its own the need to assure the consistency of the DOE Orders applicable to nuclear safety at facilities that produce and process fissile materials and at facilities that assemble, disassemble, and test nuclear weapons.
Recommendation 91-6, Radiation Protection for Workers and the General Public at DOE Defense Nuclear Facilities
Problem Statement:
"The Board and its staff have conducted extensive reviews of radiation protection programs at DOE Headquarters and several DOE sites in the defense nuclear facilities complex. In particular, the SRS health and radiological protection programs have been reviewed on several occasions.
"After an inquiry into worker exposures to tritiated water from a moderator water spill at the site, the Board transmitted a report to the Secretary of Energy on May 31, 1991, that reviewed the management and radiation protection issues, as well as other factors that DOE and its contractor identified as root causes of the spill. Before completion of that report, the Board had directed its staff to continue the review of technical radiation protection issues that had been surfaced during the inquiry. In October, 1990, the Board's staff reviewed the SRS radiation protection program, that is included by SRS within what are commonly referred to as Health Protection (HP) program and Health Physics program. Board staff conducted follow-up reviews in February and April 1991. Staff reports based on the October 1990 and February 1991 trips were provided to DOE's Defense Programs personnel in letters from the Board dated November 1, 1990, and June 10, 1991, respectively. In its transmittal letter of June 10, 1991, the Board indicated it was giving consideration to the possibility of developing recommendations to the Secretary of Energy in the radiation protection area after further Board review.
"On June 20, 1991, representatives from DOE's Defense Programs, the DOE Savannah River Site Special Projects Office, and the operating contractor at SRS briefed the Board and its staff on radiation protection program issues. As a follow- up to that briefing, the Board conducted a site visit at SRS in July 1991. During that visit, Board Members interviewed SRS HP personnel and supervisors.
"The most recent Board staff assessment of DOE's radiation protection program and the operating contractor's HP program at SRS occurred during the period September 27 through October 10, 1991. The Board's staff reviewed relevant documents, attended briefings and discussions with DOE and operating contractor personnel at DOE Headquarters and at SRS, and observed selected evolutions at reactor and non-reactor facilities.
"Other independent organizations and committees have documented required improvements in DOE's radiation protection program, including the Institute for Nuclear Power Operations (INPO) in December 1990, the Advisory Committee on Nuclear Facility Safety in Section 5 of its final report dated November 13, 1991, and the final DOE Operational Readiness Review (ORR) team in its report for Savannah River's K-reactor, dated November 1991.
"Primarily as a result of these assessments at Savannah River, but also because of other reviews at Rocky Flats Plant and elsewhere in the defense nuclear facilities complex, the Board has found a need for increased DOE attention in five major areas: (1) DOE management and leadership in radiation protection programs; (2) radiation 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 radiation protection program deficiencies; and (5) understanding and attention to radiation protection issues by individuals in DOE and its contractor organizations."
Comment:
DOE had sufficient evidence of its radiation protection problems to have instituted a comprehensive program of corrective action on its own initiative. Moreover, note that DOE was informed by letter in June 1991 that the Board was considering the possibility of developing recommendations. Recommendation 91-6 was not issued until December 1991; DOE therefore had six months in which to take the initiative, but failed to do so.