Recommendation 91-1, Strengthening the Nuclear Safety Standards Program for DOE's Defense Nuclear Facilities:

"... Therefore, the Board recommends:

4. that the Department critically reexamine its existing infrastructure for standards development and implementation at Head-quarters to determine if organizational or managerial changes are needed to (1) emphasize the priority and importance of standards to assuring public health and safety; (2) expand the program to facilitate the rapid development and implementation of standards; and (3) streamline the DOE approval process for standards; and

5. that the Department reexamine the corresponding organizational units at DOE's principal Operations and Field Offices and DOE contractor organizations to determine if those organizations' standards infrastructure, responsibilities and resources would also benefit from changes to reflect improvements at Headquarters which strengthen and expedite standards development and implementation." [Emphasis added]

Recommendation 91-6, Radiation Protection for Workers and the General Public at DOE Defense Nuclear Facilities:

"... 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." [Emphasis added]

"Therefore, the Board recommends that:

2. DOE review existing radiation protection training programs, and develop and implement a plan for an expanded training program that includes consideration of the following elements:...

b. Delineation of the level of knowledge, skills, abilities, and other qualifications necessary for each generic radiation protection personnel position within the DOE complex, based on professional and industry standards and guidance. This should include association and/or interaction with professional health physics organizations such as the Health Physics Society and American Board of Health Physics certification for appropriate professionals.

c. Determination of the current level of knowledge of radiation protection managers, professionals, supervisors, and technicians, by means of written, oral, and practical examinations.

d. Delineation of the existing and supplemental training necessary to ensure that radiation protection personnel meet the qualifications of their respective positions.

e. Evaluation of individuals after supplemental training to ensure that they meet the qualifications for their positions.

3. The Department critically examine its existing infrastructure for radiation protection program development and implementation at DOE Headquarters to determine if resource, organizational, or managerial changes are needed....

4. The Department examine the corresponding radiation protection organizational units at DOE's principal Operations and Field Offices and DOE contractor organizations to determine if those organizations' radiation protection programs' infrastructure, responsibilities, and resources can be strengthened...." [Emphasis added]

Recommendation 92-2, DOE's Facility Representative Program at Defense Nuclear Facilities:

"Therefore, the Board recommends that for defense nuclear facilities:

1. The Secretary of the Department of Energy expeditiously carry out a comprehensive analysis of the existing DOE Facility Representative programs....

b. ...Consideration should be given to evaluating:

(1) Qualification requirements and recruitment practices employed in selecting prospective DOE Facility Representatives;

(6) DOE personnel practices and procedures that provide incentives and impediments to making the position of DOE Facility Representative attractive and career-enhancing. At a minimum, restraints imposed by the practice of measuring responsibility predominantly in terms of numbers of individuals supervised should be addressed....

d. At the conclusion of the analysis, an estimate should be prepared of the personnel and management resources that would be required to establish and maintain an effective DOE Facility Representative Program, and which reflects the results of the analysis.

2. Utilizing the results of the comprehensive analysis, the Secretary of the Department of Energy establish a formal program to select, train, and assign DOE Facility Representatives for the defense nuclear facilities.

a. In establishing this program, DOE should be prepared to modify personnel practices and programs as necessary to establish a beneficial and effective DOE Facility Representative Program.

b. This program should give consideration to:

(1) Delineating DOE Facility Representative selection requirements, including specified standards of educational achievement, professional experience, technical aptitude, and forcefulness...." [Emphasis added]

Recommendation 92-4, Multi-Function Waste Tank Facility at the Hanford Site:

"... The DOE organization responsible for the project needs to have technically qualified personnel in numbers sufficient to provide direction and guidance to contractors performing all phases of the effort and to assess the effectiveness of contractor efforts.

"The Board's view of the Hanford MWTF's conceptual design performed to date is that the design does not clearly present and delineate those aspects that ensure that the public health and safety can adequately be protected. In particular, the MWTF appears to be a project 1) without a well-defined mission or functional requirements (e.g., waste treatment or storage), 2) predetermined to consist of four one-million-gallon tanks regardless of their intended uses, and 3) managed without sufficient regard for technical issues and engineering involvement.

"... However, to ensure that appropriate nuclear safety characteristics are included in the design efforts, the Board recommends the following to the Secretary of Energy:

1. Establish a plan and methodology that results in a project management organization for the MWTF project team that assures that both DOE and the contractor organization have personnel of the technical and managerial competence to ensure effective project execution." [Emphasis added]

Recommendation 92-5, Discipline of Operation in a Changing Defense Nuclear Facilities:

"In furtherance of this view it is recommended that:...

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 and contractor, has the technical and managerial capability needed to carry out its responsibilities." [Emphasis added]

Recommendation 92-6, Operational Readiness Reviews (ORRs):

"The Board believes that among the features of an acceptable ORR are the following:...

(d) The DOE review should include assessment of the technical and managerial qualifications of those in the DOE field organization who have been assigned responsibilities for direction and guidance to the contractor, including the Facility Representative...." [Emphasis added]

Recommendation 92-7, Training and Qualification:

"Primarily as a result of assessments conducted by the Board's staff at the Hanford Site, the Pantex Plant, the Savannah River Site non-reactor facilities, the Oak Ridge Y-12 Plant, and the Rocky Flats Plant, but also because of reviews conducted elsewhere in the defense nuclear facilities complex, the Board believes there is a need for DOE to take action to further strengthen training of technical personnel at defense nuclear facilities.... Therefore, in keeping with the Board's statutory requirements and recognizing the priority DOE has placed on the facilities listed above, the Board recommends for these sites that:...

2. Where it is found to be necessary, the Department strengthen organizational units responsible for training and qualification at the DOE Field Offices, DOE Area Offices, and contractor organizations responsible for defense nuclear facilities at these sites, especially to include the appropriate technical qualifications of the personnel assigned to defense nuclear activities....

3. The Department accelerate efforts internal to DOE to improve training and qualification programs of operations, maintenance, and technical support personnel at defense nuclear facilities. An integral part of this effort should be an assessment of the roles and effectiveness of technical oversight groups to ensure that these groups' reviews, at all organizations and levels within the defense nuclear facilities complex, appropriately recognize the importance of training and qualification to public health and safety. The Department's program should also consider restructuring on-site technical oversight groups to ensure that training and qualification are afforded adequate attention and team members possess the technical expertise necessary to effectively evaluate training and qualification programs of operations, maintenance, and technical support personnel."

Recommendation 93-3, Improving DOE Technical Capability in Defense Nuclear Facilities Programs:

"... Nevertheless, the level of scientific and technical expertise in the DOE of defense nuclear facilities and operations has been declining. The Defense Nuclear Facilities Safety Board in its last three annual reports has observed that:

?... the most important and far-reaching problem affecting the safety of DOE defense nuclear facilities is the difficulty in attracting and retaining personnel who are adequately qualified by technical education and experience to provide the kind of management, direction, and guidance essential to safe operation of DOE's defense nuclear facilities.'

"The Board has not been alone in calling attention to the problem. Congressional perception of the need to upgrade DOE technical expertise is evident in the Board's enabling legislation. The need for such upgrading is further underscored by assessments made by a number of other groups over the past decade, as the attached excerpts from their reports indicate."

[NOTE: the "attached excerpts" referred to above were provided as an Attachment to Recommendation 93-3. They have been included in Appendix B to this report and are therefore not reprinted here.]

"The Board believes that a more aggressive, broad-based, and well-coordinated program directed at the enhancement of the technical capabilities of the DOE staff should be defined and implemented. More specifically the Board recommends that DOE:

1. Establish the attraction and retention of scientific and technical personnel of exceptional qualities as a primary agency-wide goal....

3. Develop a broadly based program, giving consideration to the following:

a. DOE Internal Initiatives.

(1) Develop a set of mutually supportive actions which DOE could take, within existing personnel structures, to enhance capabilities. Measures that could be considered include:

(a) Plan and execute a system for using attrition to build technical capability....

(e) Establish initiatives designed to take advantage of skills of marginal technical performers and retrain them.

(f) Expand Headquarters/Field personnel exchange programs for highly qualified junior technical staff to promote understanding of all aspects of technical issues including their resolution....

c. DOE Internal Assessments.

(1) Perform an in-depth assessment of educational and experience requirements of key positions and develop both a short-term and long-term plan for key personnel development. Such assessment could include:

(a) Identification of qualifications (education and experience) required in key positions (above GS-14) in DOE Headquarters and field organizations with responsibilities for safely carrying out the defense nuclear program.

(b) Evaluation of incumbents for their ability to meet such qualification requirements.

(c) Evaluation of current availability within DOE of fully qualified personnel to fill these positions.

(2) Develop an action plan to meet needs thus identified." [Emphasis added]

Recommendation 93-4, Health and Safety Factors Associated with DOE's Management and Direction of Environmental Restoration Management Contracts:

"These reviews at Fernald have shown weaknesses in DOE's technical direction of contractor performance, the contractor's conduct of operations, and the level of knowledge of personnel. With respect to the first weakness, a lack of technical vigilance on the part of DOE-Fernald (DOE-FN) allowed the ERMC contractor to start operations at the UNH project in April 1993 without (1) conducting a DOE-FN-required readiness review and without (2) informing and obtaining the approval of either the DOE-FN manager or the DOE headquarters project office to start the operation.

"The incidents at Fernald and at other sites, taken together, also suggest that DOE's technical management and oversight structure for ERMC contracts are in need of upgrading.... Based upon observations of the Fernald project, the Board has concern stemming from health and safety considerations that (1) DOE may not have sufficient numbers of competent, trained headquarters and field personnel to technically manage such contracts, and (2) contracts may be negotiated and signed before DOE has developed internal plans on how to carry out its technical management and oversight responsibilities.

"The Board is aware that you have recently announced initiatives to reform DOE contract management.... The Board would encourage, in the interests of public and worker health and safety, that the planned review of contracting mechanisms and practices also encompass the DOE technical direction and oversight structure. The Board believes that competence and effectiveness in technical aspects of management are essential to assure that contract services are provided in a manner which meets health and safety objectives.

"... The contractor [should] normally not be allowed to commence operations involving radioactive materials until DOE's plan for technical management of site activities has been put into effect. This means, among other things, that the relevant DOE site and headquarters offices have been adequately staffed with qualified persons to provide competent technical direction, guidance, and oversight of the contractor's operations.

"Therefore, the Board recommends that:...

6. DOE immediately establish a group of technically qualified Facility Representatives at Fernald to monitor the ongoing activities of daily operations at the site...." [Emphasis added]

Recommendation 93-5, Hanford Waste Tanks Characterization Studies:

"Therefore, the Board recommends that DOE:

1. Undertake a comprehensive reexamination and restructuring of the characterization effort with the objectives of accelerating sampling schedules, strengthening technical management of the effort, and completing safety-related sampling and analysis of watch list tanks within a target period of two years, and the remainder of the tanks by a year later...." [Emphasis added]

Recommendation 94-4, Deficiencies in Criticality Safety at Oak Ridge Y-12 Plant:

"Accordingly, the Board recommends that:...

(3) DOE evaluate the experience, training, and performance of key DOE and contractor personnel involved in safety-related activities at defense nuclear facilities within the Y-12 Plant to determine if those personnel have the skills and knowledge required to execute their nuclear safety responsibilities (in this regard, reference should be made to the critical safety elements developed as part of DOE's response to the Board's Recommendation 93-1)....

(4) DOE take whatever actions are necessary to correct any deficiencies identified in (3) above in the experience, training, and performance of DOE and contractor personnel." [Emphasis added]

Recommendation 95-2, Safety Management:

"We recognize that the various DOE organizational units which may be delegated review and approval authority for S/RIDs and associated Safety Management Programs may not have enough individuals with qualifications in the technical specialties required to carry out effectively the streamlined process being recommended. This means that technical assistance may need to be retained from elsewhere to compensate for such personnel deficiencies where they exist. It also means that DOE may need to augment its own technical expertise so as not to be obliged to continue indefinitely to rely on technical assistance from outside DOE.

"...Therefore, the Board recommends, that DOE:...

5. Take such measures as are required to ensure that DOE itself has or acquires the technical expertise to effectively implement the streamlined process recommended." [Emphasis added]