Defense Nuclear Facilities Safety Board

1. Defense Nuclear Facilities Safety Board DNFSB Staff Perspective on Changes to DOE Directives and Standards Jeffrey L. Shackelford

2. The Board has a statutory requirement to review and evaluate the content and implementation of Directives and Standards at Defense Nuclear Facilities Enabling Statute of the Defense Nuclear Facilities Safety Board (42 U.S.C. § 2286) § 2286a. Functions of the Board. [Atomic Energy Act, Sec. 312] (a) In general. The Board shall perform the following functions: (1) Review and evaluation of standards. The Board shall review and evaluate the content and implementation of the standards relating to the design, construction, operation, and decommissioning of defense nuclear facilities of the Department of Energy (including all applicable Department of Energy orders, regulations, and requirements) at each Department of Energy defense nuclear facility. The Board shall recommend to the Secretary of Energy those specific measures that should be adopted to ensure that public health and safety are adequately protected. The Board shall include in its recommendations necessary changes in the content and implementation of such standards, as well as matters on which additional data or additional research is needed.

3. Board Recommendations Specifically Related to DOE Directives and Standards • 1990-2, Codes and Standards • 1991-1, Safety Standards Program • 1993-1, Standards Utilization in Defense Nuclear Facilities • 1994-5, Integration of DOE Safety Rules Orders, and Other Requirements Other Board Recommendations and Letters Have Resulted in the Development of or Significant Revisions to DOE Directives and Standards • DOE Standard 1186, Specific Administrative Controls • DOE Standard 1189, Integration of Safety Into the Design Process • Recommendation 2009-1, Risk Assessment Methodologies at Defense Nuclear Facilities • DOE Guide 424.1-1B, Implementation Guide for Use in Addressing Unreviewed Safety Question Requirements • 2010-1, Safety Analysis Requirements for Defining Adequate Protection for the Public and Workers And Many Others…. Orders of Interest to the Board http://www.dnfsb.gov/board-activities/doe-orders-of-interest

4. Staff Directives Review Process DOE Coordination with Staff Directives Lead Lead Reviewer and Subject Matter Experts Assigned Management Review Staff Communication and Resolution of Comments Case Study - DOE Standard 3009 Broad Staff Distribution and 16 Active Reviewers Senior Staff and Subject Area Experts 181 Substantive Comments and Concerns • Relaxation of current expectations for protection of the workers • Crediting of self protective actions for worker protection in lieu of controls • Relaxation of fundamental safety principles such as defense-in-depth and hierarchy of controls

5. Beyond Design Basis Events Staff Comment on the Proposed Revision to DOE Standard 3009 • [Comment] Very little useful guidance is provided relative to BDBEs. This lack of definitive expectations and guidance is likely to lead to a minimization of meaningful effort in this important area. DOE’s recent commitments to study and address BDBEs implied that there would likely be the need for meaningful improvements in the safety posture at a number of facilities. The lack of forceful guidance is unlikely to foster any such improvements. • [Suggestion] Expand the guidance on the need for a systematic evaluation of BDBEs. Further, articulate an expectation that for certain BDBEs, cost effective controls should be identified to provide an additional margin of safety beyond that which is formally established by credited controls.

6. Discussion • DNFSB Contact • Jeffrey L. Shackelford • Jeffs@dnfsb.gov • 202-694-7122