[Federal Register Volume 69, Number 109 (Monday, June 7, 2004)]
[Notices]
[Pages 31815-31817]
From the Federal Register Online via the Government Publishing Office [www.gpo.gov]
[FR Doc No: 04-12741]
=======================================================================
-----------------------------------------------------------------------
DEFENSE NUCLEAR FACILITIES SAFETY BOARD
[Recommendation 2004-1]
Oversight of Complex, High-Hazard Nuclear Operations
AGENCY: Defense Nuclear Facilities Safety Board.
ACTION: Notice, recommendation.
-----------------------------------------------------------------------
SUMMARY: The Defense Nuclear Facilities Safety Board has unanimously
approved Recommendation 2004-1, for DOE to consider. Recommendation
2004-1 deals with Oversight of Complex, High-Hazard Nuclear Operations.
DATES: Comments, data, views, or arguments concerning the
recommendation are due on or before July 7, 2004.
ADDRESSES: Send comments, data, views, or arguments concerning this
recommendation to: Defense Nuclear Facilities Safety Board, 625 Indiana
Avenue, NW., Suite 700, Washington, DC 20004-2001.
FOR FURTHER INFORMATION CONTACT: Kenneth M. Pusateri or Andrew L.
Thibadeau at the address above or telephone (202) 694-7000.
Dated: June 1, 2004.
John T. Conway,
Chairman.
[Recommendation 2004-1]
Oversight of Complex, High-Hazard Nuclear Operations
Dated: May 21, 2004.
Background
In furtherance of its statutory duty to oversee the Department of
Energy's
[[Page 31816]]
(DOE) protection of workers and the public from hazards at defense
nuclear facilities operated for DOE and the National Nuclear Safety
Administration (NNSA), the Defense Nuclear Facilities Safety Board
(Board) conducted eight public hearings to examine DOE's current and
proposed methods of ensuring safety at its defense nuclear facilities.
In these hearings, the Board also sought to benefit from the
lessons learned as a result of investigations conducted following the
Columbia Space Shuttle disaster and the discovery of the deep corrosion
in the reactor vessel head at the Davis-Besse Nuclear Power Plant. The
Board received testimony from representatives of the Nuclear Regulatory
Commission; the Naval Reactors Program; the Columbia Accident
Investigation Board; the Deputy Secretary of Energy; the Administrator
of NNSA; DOE's Under Secretary of Energy, Science and Environment;
DOE's Assistant Secretary for Environment, Safety, and Health; and
selected site managers of DOE's facilities, senior contractor managers,
and members of the public.
The overall objective of the hearings was to gather information
that could be helpful in assessing DOE's proposals for changing the
methods it uses for contract management and nuclear safety oversight,
as they have been controlled through the DOE Directives System. NNSA
has proposed shifting responsibility for safety oversight from DOE
Headquarters to the DOE field offices and site contractors. The key
question the Board sought to address was: Will modifications proposed
by DOE/NNSA to organizational structure and practices, as well as
increased emphasis on productivity, improve or reduce safety, and
increase or decrease the possibility of a high-consequence, low-
probability nuclear accident?
DOE's programs for national security and environmental protection
are complex, with potentially high consequences if not safely
performed. Mishandling of nuclear materials and radioactive wastes
could result in unintended nuclear criticality, dispersal of
radioactive materials, and even nuclear detonation. DOE has a long and
successful history of nuclear operations, during which it has
established a structure of requirements directed to achieving nuclear
safety. That structure is based on such methods as defense in depth,
redundancy of protective measures, robust technical competence in
operations and oversight, extensive research and testing, a Directives
System embodying nuclear safety requirements, Integrated Safety
Management, and processes to ensure safe performance.
The United States owns the defense nuclear facilities at which its
programs are carried out by a government agency--DOE. Each such
facility is operated by a contractor that was selected by DOE on the
basis of being best suited to conduct the work for DOE at that site.
Under the original Atomic Energy Act of 1946 and continuing to date in
the Atomic Energy Act of 1954, as amended, the government officials in
charge (i.e., the Secretary of Energy and other line officers) have a
statutory responsibility to protect health and minimize danger to life
or property. In any delegation of responsibility or authority to lower
echelons of DOE or to contractors, the highest levels of DOE continue
to retain safety responsibility. While this responsibility can be
delegated, it is never ceded by the person or organization making the
delegation. Contractors are responsible to DOE for safety of their
operations, while DOE is itself responsible to the President, Congress,
and the public.
This reality was highlighted during the course of the Board's
hearings. Many important lessons were cited in the testimony provided.
These included the importance of a centralized and technically
competent oversight authority, central control of technical safety
requirements and waivers for departure from those requirements, an
ability to operate in a decentralized mode when appropriate, a
willingness to accept criticisms, the need for retention of technical
expertise and capabilities at high levels of any organization in which
technical failure could have high consequences, and an awareness that
complacency can arise from a history of successes. DOE representatives
testified that DOE's attention to safety has continued to improve with
better on-site oversight and self-assessment programs, use of
Integrated Safety Management, careful attention to safety statistics,
and stabilization and disposal of high risk nuclear materials. However,
cause for concern with regard to the potential increase in the
possibility of nuclear accidents was also evident in: (1) The increased
emphasis on productivity at the possible expense of safety, (2) the
loss of technical competency and understanding at high levels of DOE's
and NNSA's organizational structure, (3) the apparent absence of a
strong safety research focus, and (4) the reduced central oversight of
safety.
Clearly, safety performance can benefit from attention to detail
and lessons learned from small incidents and minor accidents. However,
failures leading to high-consequence, low-probability accidents would
likely have their roots in interactions between engineering failures
and improper human actions. Because the consequences of large nuclear
accidents would be unacceptable, the nuclear weapons complex cannot
permit them to occur. While the potential for such accidents cannot be
completely eliminated, their likelihood can be held to an insignificant
level by rigorous attention to Integrated Safety Management with
technical and operational excellence based on nuclear safety standards
subject to rigorous oversight. In addition, nuclear safety must be
founded on solid research, analysis, and testing to ensure an adequate
understanding of energetic initiating mechanisms under off-normal
conditions.
DOE has taken some preliminary steps toward its proposed changes in
safety practices. These actions may have contributed to some
unfortunate consequences, such as the following:
A glovebox fire occurred at the Rocky Flats closure site,
where, in the interest of efficiency, a generic procedure was used
instead of one designed to identify and control specific hazards.
Apparently, success of the cleanup project resulted in management
complacency. DOE site management had given the impression that safety
was less important than progress, and contract management had not
emphasized oversight of work control processes.
Downsizing of safety expertise has begun in NNSA's NA-53
organization, while field organizations such as the Albuquerque Service
Center have not developed an equivalent technical capability in a
timely manner. As a result, NNSA field offices are left without an
adequate depth of understanding of such important matters as seismic
analysis and design, training of nuclear workers, and protection
against unintended criticality.
DOE's Office of Environmental Safety and Health, with
assistance from some sites and contractors, has reviewed DOE Directives
to simplify safety requirements, with the objective of supporting
accelerated operations that are also more efficient. This shift has led
to proposals for downgrading some worker safety Directives to the level
of guidance and modifying some radiation protection requirements. It
has also led to a proposed modification of the Order on Worker Safety
and Health to reduce requirements for protecting workers from the
consequences of fires,
[[Page 31817]]
explosions, and discharges from high-pressure systems.
Proposed modifications to DOE and NNSA's organizational structure,
manpower, contract management, oversight policies and practices, and
safety directives could have unintended consequences. These include
reduction of defense in depth, potentially inconsistent safety-related
decisions caused by decentralization of safety authority, emphasis on
performance as opposed to safety, and reduction of technical capability
at key points in the organizational structure. DOE and NNSA line
managers could be left with inadequate awareness of safety issues.
As a result of testimony it has received, the Board is not
convinced of the benefit of the changes to DOE's and NNSA's
organizational structure and practices as they have been described. The
Board cautions that if any such changes are made, they must be done
formally and deliberatively, with due attention given to unintended
safety consequences that could reduce the present high level of nuclear
safety. DOE should take full advantage of lessons learned from safety
problems discovered by National Aeronautics and Space Administration
and Nuclear Regulatory Commission, and it should learn from the success
of the good organizational and safety practices championed by the Naval
Reactors Program. The Board needs to be sure that any fundamental
reorganization does not degrade nuclear safety, and that the likelihood
of a serious accident, facility failure, construction problem, or
nuclear incident will not be increased as a result of well-intentioned
changes.
As a result of testimony received at the public hearings and the
potential effects on safety at defense nuclear facilities outlined
above, the Board recommends:
1. That delegation of authority for nuclear safety matters to field
offices and contractors be contingent upon the development and
application of criteria and implementing mechanisms to ensure that:
a. Oversight responsibility includes the capability for examining,
assessing, and auditing by all levels of the DOE organization,
b. The technical capability and appropriate experience for
effective safety oversight is in place, and
c. Corrective action plans consistent with recommendations
resulting from internal DOE and NNSA reviews of the Columbia accident
and the Davis-Besse incident are issued.
2. That to ensure that any features of the proposed changes will
not increase the likelihood of a low-probability, high-consequence
nuclear accident, DOE and NNSA take steps to:
a. Empower a central and technically competent authority
responsible for operational and nuclear safety goals, expectations,
requirements, standards, directives, and waivers;
b. Ensure the continued integration and support of research,
analysis, and testing in nuclear safety technologies; and
c. Require that the principles of Integrated Safety Management
serve as the foundation of the implementing mechanisms at the sites.
3. That direct and unbroken line of roles and responsibilities for
the safety of nuclear operations--from the Secretary of Energy and the
NNSA Administrator to field offices and sites--be insured according to
appropriate Functions, Responsibilities, and Authorities documents and
Quality Assurance Implementation Plans.
4. That prior to final delegation of authority and responsibility
for defense nuclear safety matters to the field offices and
contractors, DOE and NNSA Program Secretarial Officers provide a report
to the Secretary of Energy describing the results of actions taken in
conformance with the above recommendations.
John T. Conway,
Chairman.
[FR Doc. 04-12741 Filed 6-4-04; 8:45 am]
BILLING CODE 3670-01-P