DOE Response to Recommendation 2019-1 of the Defense Nuclear Facilities Safety Board, Uncontrolled Hazard Scenarios and 10 CFR 830 Implementation at the Pantex Plant, 20868-20870 [2019-09782]

Agencies

• DEPARTMENT OF ENERGY

[Federal Register Volume 84, Number 92 (Monday, May 13, 2019)]
[Notices]
[Pages 20868-20870]
From the Federal Register Online via the Government Publishing Office [www.gpo.gov]
[FR Doc No: 2019-09782]


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DEPARTMENT OF ENERGY


DOE Response to Recommendation 2019-1 of the Defense Nuclear 
Facilities Safety Board, Uncontrolled Hazard Scenarios and 10 CFR 830 
Implementation at the Pantex Plant

AGENCY: Department of Energy.

ACTION: Notice.

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SUMMARY: On February 20, 2019, the Defense Nuclear Facilities Safety 
Board issued Recommendation 2019-1, Uncontrolled Hazard Scenarios and 
10 CFR 830 Implementation at the Pantex Plant, to the Department of 
Energy. In accordance with the Atomic Energy Act of 1954, the Secretary 
of Energy's response to the Recommendation is provided in this notice.

DATES: Comments, data, views, or arguments concerning the Secretary's 
response are due on or before June 12, 2019.

ADDRESSES: Please send to: Defense Nuclear Facilities Safety Board, 625 
Indiana Avenue NW, Suite 700, Washington, DC 20004.

FOR FURTHER INFORMATION CONTACT: Mr. Christopher Chaves, Office of the 
Departmental Representative to the Defense Nuclear Facilities Safety 
Board, Office of Environment, Health, Safety and Security, U.S. 
Department of Energy, 1000 Independence Avenue SW, Washington, DC 
20585, or telephone number (301) 903-5999, or email 
[email protected].

SUPPLEMENTARY INFORMATION: On February 20, 2019, the Defense Nuclear 
Facilities Safety Board issued Recommendation 2019-1, Uncontrolled 
Hazard Scenarios and 10 CFR 830 Implementation at the Pantex Plant, to 
the Department of Energy. Recommendation 2019-1 was published in the 
Federal Register on March 19, 2019 (84 FR 10196). In accordance with 
section 315(c) of the Atomic Energy Act of 1954 (42 U.S.C. 2286d(c)), 
the Secretary of Energy's response to the Recommendation is printed in 
full at the conclusion of this notice.

    Signed in Washington, DC, on May 6, 2019.
Joe Olencz,
Departmental Representative to the Defense Nuclear Facilities Safety 
Board, Office of Environment, Health, Safety and Security.
April 16, 2019

The Honorable Bruce Hamilton
Chairman
Defense Nuclear Facilities Safety Board
625 Indiana Avenue, NW, Suite 700
Washington, DC 20004

    Dear Chairman Hamilton:
    The Department of Energy (DOE) acknowledges receipt of Defense 
Nuclear Facilities Safety Board (Board) Recommendation 2019-1, 
Uncontrolled Hazard Scenarios and 10 CFR 830 Implementation at the 
Pantex Plant, which was published in the Federal Register on March 19, 
2019.
    The Department shares the Board's view that we should continue to 
improve the configuration management and implementation of the safety 
basis for nuclear explosive operations at the Pantex Plant. Processes 
are in place at the Pantex Plant to ensure all nuclear explosive 
operations are planned and executed in a manner that protects the 
environment, the public, and the worker. I accept Recommendation 2019-
1, which aligns with improvement actions that the Department of 
Energy's National Nuclear Security Administration (DOE/NNSA) has 
already taken as outlined in the DOE/NNSA Administrator's January 28, 
2019, response to Draft Recommendation 2018-1, Uncontrolled Hazard 
Scenarios and 10 CFR 830 Implementation at the Pantex Plant (see 
enclosure). We look forward to briefing the Board on improvement 
actions planned and underway.
    The Department is committed to the safe operation of its nuclear 
facilities consistent with the principles of Integrated Safety 
Management and the Department's nuclear safety requirements. We will 
continue to prioritize Pantex safety basis efforts and maintain a 
dialogue with your staff. I have assigned Geoffrey L. Beausoleil, 
Manager, DOE/NNSA Production Office,

[[Page 20869]]

to be the Department's responsible manager for this recommendation.
    If you have any questions, please contact Mr. Geoffrey L. 
Beausoleil at (865) 576-0752

    Sincerely,
    Lisa E. Gordon-Hagerty

    Enclosure
ENCLOSURE
    Department of Energy's National Nuclear Security Administration's 
(DOE/NNSA) Administrator January 28, 2019, Response to DNFSB Draft 
Recommendation 2018-1, Uncontrolled Hazard Scenarios and 10 CFR 830 
Implementation at the Pantex Plant.

General Comments

    Throughout last year, DOE/NNSA and Consolidated Nuclear Security 
(CNS), the Pantex Management & Operating Contractor, have taken 
numerous actions aimed at improving the quality, configuration 
management, and implementation of the Pantex Plant (Pantex) safety 
basis. Key actions during this period include the following:
    [ssquf] In September 2018, DOE/NNSA approved a Safety Basis 
Supplement (SBS) by CNS that fulfilled two primary objectives. First, 
the SBS provides a framework for analyzing and addressing legacy issues 
in the Pantex safety basis associated with scenarios previously 
determined not to require application of safety controls because they 
were evaluated to be ``sufficiently unlikely.`` Requirements have been 
established to assure ``sufficiently unlikely`` scenarios are 
identified and resolved. Second, the SBS included significant 
improvements in safety protocols through the identification of 
compensatory measures for preventing events that could result from 
``Falling Man`` scenarios. CNS has implemented the new ``Falling Man`` 
compensatory measures in all active nuclear explosive cells and bays.
    [ssquf] In October 2018, DOE/NNSA initiated a project to identify 
options for ``redesigning`` the Pantex safety basis, with the goal of 
reducing the complexity of the safety basis activities and documents; 
simplifying development, review, approval, and maintenance of the 
documents; and correspondingly improving implementation of the 
identified safety controls. Members of this project team include 
representatives from DOE/NNSA, the production plants, the national 
laboratories, and the Nevada National Security Site. This initiative 
will take substantial effort to achieve, but is essential for ensuring 
the long-term success of the Pantex national security mission.
    [ssquf] DOE/NNSA approved a comprehensive Corrective Action Plan by 
CNS that includes numerous actions for improving the Pantex safety 
basis development process and addressing legacy-improvement 
opportunities in the current documents. Execution of this plan will 
drive significant progress in the overall quality of the Pantex safety 
basis within the next two years. To date, CNS has completed all actions 
on schedule.
    Several elements of the DNFSB's Draft Recommendation arise from 
inconsistencies between long-standing Pantex practices and DOE guidance 
documents. Examples include DNFSB concerns related to the structure of 
the Pantex Unreviewed Safety Question (USQ) procedure, the longevity of 
some Justifications for Continued Operations, and the frequency within 
which safety control implementation is re-verified. By definition, the 
referenced DOE Guides (e.g., DOE Guide 423.1-1B, Implementation Guide 
for Use in Developing Technical Safety Requirements, and DOE Guide 
424.1-1B, Implementation Guide for Use in Addressing Unreviewed Safety 
Question Requirements) provide supplemental information that DOE/NNSA 
uses to encourage performance of operations and activities across the 
complex with a focus on best practices. Similarly, several of the 
concerns in the DNFSB's Draft Recommendation related to Special Tooling 
are understood to be suggestions to adopt industry best practices 
rather than reflecting deficiencies against DOE regulations or 
requirements. DOE/NNSA identified similar issues with the Special 
Tooling program as part of our oversight activities. DOE/NNSA will 
ensure the DNFSB suggestions are evaluated as it continues to develop 
additional improvement actions, but do not believe the issues result in 
challenging adequate protection of public health or safety.

Safety Controls Associated With Low-Probability/High-Consequent Events

    The DNFSB raised concerns that some scenarios determined to be 
``sufficiently unlikely`` (i.e., expected to occur between once-in-a-
million and once-in-a-billion years) in the applicable Pantex safety 
basis documents did not have clearly identified safety controls for 
preventing or mitigating the potentially high consequences (e.g., 
worker fatality, environmental radiological contamination, or public 
radiological exposure). DOE/NNSA provides the following perspective 
regarding these concerns:
    [ssquf] As noted in the DNFSB's Draft Recommendation, questions 
associated with ``new information`` related to potential accident 
scenarios are evaluated via the Pantex Problem Identification and 
Evaluation process and the requirements in DOE-NA-STD-3016-2018, Hazard 
Analysis reports for Nuclear Explosive Operations. This process ensures 
that appropriate operational restrictions or compensatory measures are 
implemented while resolving any potential safety issues associated with 
the adequacy of safety controls. During the past year, DOE/NNSA has 
verified this process has been effectively executed by CNS, and has 
driven improvements to the process as warranted.
    [ssquf] One of the concerns raised by the DNFSB, associated with 
the adequacy of safety controls for ``sufficiently unlikely`` 
scenarios, was reliance on Key Elements of Safety Management Programs 
to prevent high-consequences during potential ``Falling Man`` 
scenarios. In September 2018, the DOE/NNSA approved a SBS that 
identified additional ``Falling Man`` controls, which are structured, 
credited, and protected as Specific Administrative Controls (SACs) 
rather than programmatic Key Elements. As noted above, CNS implemented 
these ``Falling Man`` SACs in all active nuclear explosive cells and 
bays.
    [ssquf] Other than the control adequacy issues discussed above, the 
remaining control adequacy concerns generally relate to weaknesses in 
the safety basis documentation. The two most common examples are (a) 
controls that are already implemented in the field but are not 
specifically linked to and credited for scenarios in the safety basis 
that were dispositioned as ``sufficiently unlikely`` and (b) scenarios 
that were inappropriately deemed as ``sufficiently unlikely`` in the 
safety basis where, lacking sufficient technical bases, they are not 
credible (e.g., the scenario would require deliberate or malicious 
procedural violations).
    The aforementioned SBS provides a framework for evaluating and 
categorizing these documentation-related issues. CNS developed a 
Corrective Action Plan that DOE/NNSA approved in November 2018 that 
includes commitments to perform extent-of-condition reviews of all 
Pantex safety basis documents by the end of 2019, with the objective of 
identifying and correcting all instances of these documentation-related 
issues. To date, CNS has executed on schedule the actions captured in 
this Corrective Action Plan.

Configuration Management of the Pantex Safety Basis

    The DNFSB raised concerns related to the processes used to maintain

[[Page 20870]]

configuration management of the Pantex safety basis. Specifically, the 
DNFSB expressed concern that: (a) updates to Pantex safety basis 
documents are not always completed on an annual basis; (b) the Pantex 
USQ procedure allows discrepant-as-found conditions to be corrected 
without suspending impacted operations or making necessary 
notifications; and (c) some Justifications for Continued Operations 
(JCOs) are extended beyond a year. DOE/NNSA provides the following 
perspectives regarding these concerns:
    [ssquf] The DNFSB's concern related to the timeliness of updating 
safety basis documents appears to be based on data collected during 
2017. The vast majority of Pantex safety basis documents were updated 
on-time in 2018, the lone exception being the update associated with 
the Site-wide Safety Analysis Report. CNS is committed to updating this 
document by March 2019. The aforementioned Corrective Action Plan, 
approved by DOE/NNSA in November 2018, includes actions to revise the 
administrative procedures for developing and revising Pantex safety 
basis documents. These actions specifically identify improving 
configuration management of safety basis documents as an objective, 
which, when executed effectively, should preclude similar issues from 
occurring in the future.
    [ssquf] The DNFSB's Draft Recommendation states that ``the Pantex 
USQ procedures allow three days to correct discrepant-as-found 
conditions... without stopping operations, notifying DOE, or initiating 
the Pantex process for addressing a potential inadequacy of the safety 
analysis.`` While the Pantex USQ procedure does allow three days to 
correct a discrepant-as-found condition prior to declaring a Potential 
Inadequacy of the Safety Analysis, and given that 10 CFR 830 Subpart B 
does not have rules for specific numeric durations (other than ``as 
appropriate'') Pantex procedures require: (a) suspending operations 
whenever a safety question is raised (e.g., discovery of discrepant-as-
found conditions); (b) making appropriate notifications to the DOE/NNSA 
Production Office (NPO); and (c) initiating the DOE-Approved Pantex USQ 
process. Therefore, we believe the proper safety control is in place.
    [ssquf] The DNFSB's Draft Recommendation includes a concern with 
the processes for handling JCOs and the extension of some for an 
extended period of time. The goal in the Pantex USQ procedure of 
addressing JCOs in less than a year is derived from guidance in DOE 
Guide 424.1-1B. The intent is to ensure JCOs and their compensatory 
measures are used to address temporary changes to the safety basis 
until permanent solutions can be identified and incorporated. While one 
year is a viable goal for limiting use of a JCO, it is not always 
practical to resolve issues in nuclear or nuclear explosive operations 
in that time frame. Many of the issues identified in JCOs involve 
complex operations or hazard scenarios where a permanent solution 
cannot be developed without extensive analysis or physical changes to 
facilities, systems, or equipment. Several JCO extensions were to allow 
additional time to develop permanent solutions, instead of 
incorporating compensatory measures into the safety basis only to 
revise the documents again once the permanent solution was developed. 
Each extension was approved by the Safety Basis Approval Authority 
after NPO fully evaluated the JCO conditions and compensatory measures, 
and concluded operations could be continued safely with implementation 
of the JCO compensatory measures.

Special Tooling Program

    The DNFSB expressed concerns that deficiencies exist within the 
Pantex Special Tooling Program. Examples of the identified deficiencies 
include: (a) inconsistencies between Pantex tooling procedures and site 
practices; (b) additional Non-Destructive Evaluation techniques being 
used to inspect welds on tooling; (c) reliance on worker knowledge and 
skill-of-the-craft during tooling inspection, maintenance, and testing 
activities; ( d) tool-specific performance criteria not being listed in 
the Pantex safety basis; and ( e) weaknesses in analysis and testing 
for mechanical impact scenarios involving tooling. DOE/NNSA provides 
the following perspectives regarding these concerns:
    [ssquf] Subsequent to the DNFSB's September 2017 review, tooling-
specific deviations from Pantex procedures were reviewed and confirmed 
that continued use of the subject tools meets applicable requirements. 
Additional corrective actions have been taken to prevent recurrence of 
the inconsistencies.
    [ssquf] Subsequent to the DNFSB's September 2017 review, CNS 
engaged an outside expert to review the Pantex welding program, who 
concluded that Pantex processes meet expectations. That is, welds are 
performed and inspected by qualified welders in accordance with 
applicable industry standards.
    [ssquf] Pantex tools are maintained and tested by trained and 
qualified journeymen mechanics in accordance with programmatic and 
tool-specific requirements.

[FR Doc. 2019-09782 Filed 5-10-19; 8:45 am]
 BILLING CODE 6450-01-P