Documents & Resources
Alliance for Nuclear Accountability
immediate release: Tuesday, November 27, 2018
Watchdog groups call for Congress to protect nuclear weapons communities—stop DOE limitations on Safety Board
Watchdog groups from across the country are insisting the Department of Energy withdraw DOE Order 140.1, a controversial order that would compromise safety at dozens of facilities in the US nuclear weapons complex, and are asking key Congressional committees to annul the revised order and preserve the critically important prerogatives of the Defense Nuclear Facilities Safety Board (DNFSB).
DOE MUST RESTORE DEFENSE NUCLEAR FACILITIES SAFETY BOARD ACCESS TO INFORMATION, NUCLEAR SECURITY FACILITIES, AND PERSONNEL
On May 14, 2018, the Department of Energy (DOE) Deputy Secretary approved DOE Order 140.1 Interface with the Defense Nuclear Facilities Safety Board, which limits release of information, limits the DNFSB’s access to nuclear security sites, and personnel. The impacts are already being felt by Congress, the Board, DOE contractors and workers, and in communities located near some of the most dangerous nuclear facilities across the nation.
The Alliance for Nuclear Accountability has reviewed DOE Order 140.1 and believes it imposes a level of constraint on DNFSB that jeopardizes the important mission of the Safety Board. In fact, it may well violate the legislation that established the Board. ANA groups and the public at major DOE sites have come to rely on the Safety Board’s expertise to identify and hold accountable the DOE and National Nuclear Security Administration for worker and public safety related issues.
November 27, 2018
RE: DOE Order 140.1 should be annulled by Congress
Dear House/Senate Armed Services Committee Members:
We are writing to ask that you annul the May 2018 DOE Order 140.1, Interface with the Defense Nuclear Facilities Safety Board and reinstate the previous DOE Order 140.1.
The Defense Nuclear Facilities Safety Board (“DNFSB” or “Safety Board”) was established by Congress in September 1988 (Public Law 100-456) in response to growing concerns about health and safety protection that the Department of Energy (“DOE”) was providing the public and workers at defense nuclear facilities. In so doing, Congress sought to provide the general public with an independent source of critical oversight to add assurance that DOE’s defense nuclear facilities are safely designed, constructed, operated, and decommissioned. Over the past 30 years, the Safety Board’s authority and funding has been supported by Congress on a bi-partisan basis.
Alliance for Nuclear Accountability
Kathy Crandall Robinson (Washington, DC): 202 577 9875
Joni Arends (New Mexico): 505 986 1973
Tom Carpenter (Washington state): 206 419 5829
Tom Clements (South Carolina): 803 834 3084
Jay Coghlan (New Mexico): 505 989 7342
Don Hancock (New Mexico): 505 262 1862
Ralph Hutchison (Tennessee): 865 776 5050
Marylia Kelley (California): 925 443 7148
Watchdog groups from across the nuclear weapons complex are pushing back against a new Department of Energy order that severely constrains the oversight capacity of the Defense Nuclear Facilities Safety Board [DNFSB] at an August 28 hearing in Washington, DC. Kathy Crandall Robinson will speak at the hearing.
Members of the Alliance for Nuclear Accountability, a national network of organizations that addresses nuclear weapons production and waste cleanup issues, hail the work of the DNFSB as a critical guard against DOE and National Nuclear Security Administration efforts to cut corners on safety.
“The Safety Board works outside of the media spotlight,” said Tom Clements, Director of Savannah River Site Watch in Columbia, South Carolina.
“Its value to the public is immeasurable. DNFSB frequently provides information about SRS operations which DOE fails to communicate. The role of the Safety Board should be expanded, not curtailed.”
Marylia Kelley, Executive Director of Tri-Valley CAREs in Livermore, California, said, “The DNFSB is absolutely vital to worker and public safety. I have spent 35 years monitoring Livermore Lab. I can tell you that workers and community members rely on the Safety Board to do its job—every day!”
Los Alamos Cleanup At the Crossroads:
Treat All Los Alamos Lab Radioactive Wastes Consistently
The Defense Nuclear Facilities Safety Board’s role and responsibility includes gathering information regarding the hazards to the public and workers posed by the management of transuranic (TRU) wastes at Los Alamos National Laboratory (LANL), as well as the Department of Energy’s (DOE) plans to address those hazards. The Board will examine DOE’s actions taken or inadequacies addressed in the current safety policies of the various facilities that manage or store TRU wastes at LANL. The Board is also interested in understanding actions taken to improve TRU waste management at LANL after the improper handling and treatment of TRU wastes that resulted in a ruptured barrel that shut down the Waste Isolation Pilot Plant (WIPP).
LANL In No Hurry With Emergency Response Plans
In the recent letter, the Defense Nuclear Facilities Safety Board told DOE that they were concerned with the pace and completeness of the emergency preparedness and response efforts at Los Alamos National Laboratory (LANL). The Board is an independent organization that provides recommendations and advice regarding public health and safety issues at Department of Energy (DOE) defense nuclear facilities.
After LANL recently confessed “[a] sustainable, comprehensive, and coordinated training and drills program has not been fully implemented as required” per DOE requirement Comprehensive Emergency Management System, the Board staff made some preliminary observations indicating weaknesses in emergency preparedness and response at LANL. And the Safety Board plans to perform a comprehensive review of emergency preparedness and response programs at LANL in early 2016.
Some of the preliminary observations were –
- The emergency response plans that involve the inappropriately remediated nitrate salt drums, like the one that exploded and shut down WIPP, have not been updated to reflect the current understanding of the release hazards. Consequently, pre-planned evacuation zones may be not be large enough for members of the public in the event of an accident.
- Planning and conduct of emergency drills and exercises do not ensure that scenarios are sufficiently challenging and minimize artificiality and simulation and do not represent the full spectrum of credible accident types.
- Exercises show the inability to effectively shelter laboratory workers in place during a release of hazardous materials.
- Radios don’t work much of the time.
These types of problems should not consistently be showing up where safety is a priority. It will be interesting to see how much of a factor these emergency preparedness issues played in LANS, the current Lab for-profit management contractor, losing its job.
We hope the new LANL contractor can keep safety first.
A Los Alamos National Laboratory fact sheet touts the Lab as a plutonium “center of excellence”. However, the Laboratory Director paused operations in the Plutonium Facility on June 27, 2013. (The Plutonium Facility, called PF-4, is located at Technical Area 55 at Los Alamos National Laboratory (LANL). PF-4 is home for the Lab’s plutonium work, including nuclear weapons component production.) The pause was based on issues identified during safety reviews and findings from recent assessments. For one, the Defense Nuclear Facilities Safety Board (Board) performed a review of the Criticality Safety Program at Los Alamos National Laboratory (LANL) in May 2013. (The Board is an independent organization within the executive branch chartered with the responsibility of providing recommendations and advice to the President and the Secretary of Energy regarding public health and safety issues at Department of Energy (DOE) defense nuclear facilities.) This review identified significant non-compliances with DOE requirements and industry standards in the Lab’s Criticality Safety Program (CSP). In addition, this review identified criticality safety concerns around operations at the Plutonium Facility. The Board noted that some of these deficiencies are long standing and indicated flaws in federal oversight and contractor assurance. Much plutonium work, especially work with a high potential for criticality, will be stopped through the rest of 2013.
Nuclear criticality safety is defined as “protection against the consequences of an inadvertent nuclear chain reaction, preferably by prevention of the reaction.” The most potentially dangerous aspect of a criticality accident is the release of nuclear radiation if it maintains a self-sustaining nuclear chain reaction.
To date, the only thing self-sustaining is the Lab’s inability to address its criticality issues and yet still convince Congress to keep funding plutonium work there. To prevent bad things from happening, DOE’s regulations and directives require contractors to evaluate potential accident conditions and put in place appropriate controls and safety measures. History shows that the Los Alamos Laboratory just cannot do this, even though much of the work is performed on plutonium pits, the primaries of nuclear weapons. Even though actual need for this work has not been proven, the Lab has entrenched itself as the only place in the country where plutonium pits can be made, developed, and tested.
For fiscal year 2014, the budget request for nuclear ‘weapons activities’ at LANL was $1.4 billion. The exact amount that is spent on plutonium operations in PF-4 is unknown to us, but the budget request for 2014 for Directed Stockpile Work, which is where major parts of the plutonium operations are located, was $460 million. This is a 23% increase over last year’s budget. The funding pours into the Lab regardless of whether the Lab is actually doing any work, which is frequently stopped.
Here’s history of criticality problems and work stoppages at Los Alamos Laboratory:
In 2005, an assessment determined that LANL’s expert-based Criticality Safety Program (CSP) was not compliant with applicable DOE requirements and industry standards.
In 2006, LANS developed a Nuclear Criticality Safety Program Improvement Plan.
In 2007, in response to concerns raised by the Board’s staff, LANL determined that the authorized loading of vault storage rooms in PF-4 could lead to a critical configuration.
In 2008, the Government Accountability Office reported concerns about nuclear safety at LANL are long-standing. Problems included 19 occasions since 2003 where criticality safety requirements were violated, such as storing materials in quantities higher than safety limits allow, 17 of 19 of the site’s nuclear facilities operating without proper safety documentation, reported inadequacies in safety systems, radiological releases, and four enforcement actions for significant violations of nuclear safety rules.
Los Alamos Report for Week Ending April 3, 2009
LANL management placed the facility in stand-by mode until roughly 125 safety evaluations could be re-evaluated.
Los Alamos Report for Week Ending October 2, 2009
The Plutonium Facility was placed in standby mode because management declared the fire suppression system inoperable based on recent hydraulic calculations that concluded the system was not able to achieve the water coverage required. LANL had performed a system adequacy analysis in 2008. The hydraulic calculation completed for the system identified that 13 of approximately 100 hydraulic areas did not meet the requirement.
Los Alamos Report for Week Ending October 16, 2009
A general evacuation alarm was caused by a Criticality Alarm System signal because of a loss of all facility ventilation and failure of the Facility Control System at the Plutonium Facility. The facility was in standby mode during this event due to previously identified issues with the fire suppression system and, therefore, limited personnel were in the facility.
Los Alamos Report for Week Ending September 10, 2010
Operations in Plutonium Facility were suspended because potentially explosive ammonium nitrate was discovered in two filter ducts.
Los Alamos Report for Week Ending December 3, 2010
It was revealed that greater than 1000 items, or about 20%, of the total vault holdings are items packaged in potentially vulnerable containers with taped slip-top lids rather than in robust safety-significant containers that include a HEPA-filtered vent. The presence of these slip-top containers requires respirator use whenever operators access the vault. In FY10, LANL made meaningful progress in addressing these legacy materials.
In 2011, an event occurred at PF-4 in which fissile material handlers violated procedural requirements and criticality safety controls while moving and photographing plutonium rods.
Beginning in 2012, LANS experienced an 18-month exodus of criticality safety professionals from its criticality safety group. LANS currently employs 2 full-time and 2 part-time qualified criticality safety analysts, in addition to 3 part-time subcontractors—far fewer than the 17 criticality safety analysts it has determined to be necessary to support operations, meet mission goals, and maintain the CSP.
Los Alamos Report for Week Ending April 20, 2012
Plutonium Facility personnel use a software program called MAR Tracker to track plutonium that is used in the facility. A system engineer discovered an error in
MAR Tracker that caused only a small subset of applicable facility containers (roughly 1700 out of 13000 containers) to be checked during the required annual MAR surveillance. The Plutonium Facility was placed in Standby Mode.
Los Alamos Report for Week Ending June 15, 2012
LANL identified a number of fuel rods in TA-35 Building 27 that were not consistent with the criticality safety evaluation for the facility. Operations at this building had previously been suspended in late-May due to the discovery of three fuel rods that were not in the facility or institutional tracking systems.
Los Alamos Report for Week Ending December 14, 2012
LANL identified that the Criticality Safety Evaluations (CSEs) for two rooms did not adequately address the potential for interaction effects between storage locations. Plutonium Facility management suspended operations in these two vault rooms.
Los Alamos Report for Week Ending February 15, 2013
LANL began a focused training program (“boot camp”) to provide an intensive learning environment for new criticality safety staff. The program consisted of nine modules including: nuclear theory; criticality safety calculation methods; ANSI/ANS, DOE and LANL criticality safety standards and requirements; criticality safety evaluations; and criticality alarm and detection systems. This program along with on-the-job training and performance demonstrations was to provide a mechanism for achieving full qualification as a LANL criticality safety analyst. Conduct of the boot camp was part of the LANL corrective action plan for improving the nuclear criticality safety program.
Los Alamos Report for Week Ending May 3, 2013
The laboratory completed criticality safety assessments at LANL nuclear facilities. The review teams identified 3, 4, and 6 findings for TA-55, CMR, and Area G, respectively. In all cases, the assessments concluded adequate implementation of the Criticality Safety Program with the exception of identified findings. Notably, one of the findings at Area G identified that supervisors and operations center personnel did not have an adequate understanding of criticality safety requirements. Area G management paused operations based on this finding and conducted appropriate training to resolve this issue.
In May 2013, the staff of the Defense Nuclear Facilities Safety Board (Board) performed a review of the Criticality Safety Program at Los Alamos National Laboratory. This review identified significant non-compliances with applicable Department of Energy requirements and industry standards in the implementation of the Criticality Safety Program. The Board’s staff identified the following non-compliances during its review:
• Most criticality safety controls are not incorporated into operating procedures.
• Operators typically do not utilize written procedures when performing work.
• Fissile material labels do not list parameters relevant to criticality safety (e.g., mass).
• Some fissile material operations lack Criticality Safety Evaluations (CSEs).
• Some CSEs do not analyze all credible abnormal conditions.
Los Alamos Report for Week Ending June 28, 2013
The Laboratory Director paused programmatic activities at the Plutonium Facility. The pause was directed based on issues identified during procedural and criticality safety reviews and findings from recent assessments. Reviews at PF-4 have identified a number of procedural issues and the need for clarification and improvement of criticality safety controls.
Los Alamos Report for Week Ending July 26, 2013
Plutonium Facility personnel identified several criticality safety issues associated with recent construction activity. Even though plutonium work was paused, the Laboratory Director and the Facility Operations Director (FOD) approved construction activities that had the potential to affect nuclear materials.
For more information, please read the LAMonitor article By John Severance
Safety board visits LANL
LANL loses track of nuclear materials
Plutonium operations placed in standby mode
In an April 20, 2012 report, the Safety Board charged with oversight of defense nuclear facilities reported that the system used to track nuclear materials in the Plutonium Facility at Los Alamos National Laboratory was operating erroneously. The system apparently only kept track of 1,700 out of 13,000 containers of nuclear “materials at risk” (MAR). This omission caused the facility to exceed its limits for MAR located in individual containers and outside of gloveboxes at least 15 times.
If one is operating a facility with large quantities of fissionable nuclear materials it is very important to know where the materials are at all times because stacking too much plutonium in one place can cause a criticality event or worse. After the error was noticed, the Lab manually started to verify container MAR amounts manually. “To date, fifteen containers, all housed in the facility’s vault, have been identified with contents that exceed the MAR limit of 7500 g WG-Pu [Weapons Grade Plutonium] equivalent.” That’s a lot to lose track of because these limits help the facility to comply with the seismic requirements of operations in the Lab’s earthquake fault zone.
Normal operations have been terminated in the 150,000 square foot Plutonium Facility and the facility has been placed in “Standby Mode.” How much does a shutdown cost taxpayers?
How long has the Lab violated these limits? The report states that the tracking error was introduced during software development, apparently due to a “miscommunication” between the software developers and the security personnel. The MAR tracker program performs other required MAR limit surveillances in the facility. Are these other surveillances reliable? This incident also calls into question other Lab software, such as programs that model contaminant transport.
The Defense Nuclear Facility Safety Board Report is here.
In the latest of a string of fire system deficiencies on Wednesday September 30th, LANL management declared the fire suppression system inoperable in PF-4 at TA-55. Facility activities were placed in stand-by mode, which were still stood down as of three weeks later on Oct. 23rd.
DNFSB explained that the stand down was based on recent hydraulic calculations that concluded the system does not achieve the water density coverage required. Basically, the sprinklers in 13 of approximately 100 fire suppression areas at PF-4 cannot meet the current required gallons per minute estimated to effectively extinguish a fire. (Read the Oct. 2nd-23rd DNFSB reports)
One has to wonder – What is the cost to the taxpayer of PF-4 being stood down for nearly a month?
These reports come on the heels of last week’s DNFSB recommendation that the Lab must immediately do something about its risk to the public of a seismically induced fire at PF-4, which was estimated to exceed the DOE guidelines by more than 100 times. In a worst-case situation, an earthquake-induced fire could set free enough breathable plutonium that a person on the perimeter of the facility would receive a lethal dose of radiation.
Speaking of seismically induced fires, I am reminded of a March 2007 LANL report, Seismic Fragility of the LANL Fire Water Distribution System (LA-14325), which explains how numerous valves in the fire water distribution system at the Lab would have to be manually closed to insure proper pressure to facilities on fire after a seismic event.
Granted, these may be low probability events, but they have high consequences. The Lab is playing with fire by not adequately funding upgrades to its existing fire systems now, before embarking construction of any new facilities.
An October 27 press release from the Project on Government Oversight (POGO)
“Defense Board Catches Los Alamos Trying to Dodge Plutonium Safety Vulnerability” revolves around a new Defense Nuclear Facilities Safety Board (DNFSB) revelation of public safety vulnerability and seismic issues at TA-55 (The Lab’s plutonium Technical Area).
The DNFSB has been very patient on the safety issues at TA-55. In a September 23, 2005 weekly report, they stated that LANL needed to try to justify a passive confinement strategy, continue plans to reduce radioactive materials, and to seismically upgrade the glove-box supports that have not already been upgraded. These issues are still unaddressed as of the latest DNFSB report.
Seismic issues run deep at Los Alamos. NNSA currently has plans to construct and operate the Chemistry and Metallurgy Research Replacement–Nuclear Facility (CMRR–NF) to support plutonium operations as a replacement for portions of the Chemistry and Metallurgy Research (CMR) facility, a 1950’s structure that faces significant safety and seismic challenges. In 1999, a fault was discovered under the old CMR building, which has been neglected, contaminated, and has several abandoned wings. This fault was the major reason given to build a new facility 1.2 miles away at TA-55.
The Lab has big plans for plutonium. In December 2008, NNSA released a Record of Decision for its Complex Transformation Environmental Impact Statement that keeps manufacturing and research and development involving plutonium at Los Alamos and blesses the building of the CMRR-NF. This decision was a combination of two alternatives – a Distributed Centers of Excellence and a Capability-Based alternative. But to compensate for the nearby fault lines, the CMRR-NF is now being designed with 10-foot thick concrete floors and there are plans being designed to pump grout into a layer of fragile volcanic ash under the proposed facility. Current construction estimates for this facility are $2 billion.
The Lab has been negligent in taking care of its plutonium flagship, TA-55. It has not been a good steward of plutonium missions. Los Alamos is the wrong location, seismically. Congress must seriously consider ending this unnecessary plutonium work.