Departmental Representative to the Defense Nuclear Facilities Safety Board

6.0 DNFSB POLICY

6.1 DNFSB Oversight of Design and Construction Projects of DOE Defense Nuclear Facilities

Both DOE and the Board have a vested interest in the identification and resolution of potential nuclear safety issues as early as possible in the design phase so as to not negatively impact the cost, scope or schedule. The Department’s directives for design and construction projects include its 413 series of directives, particularly DOE Order 413.3, Program and Project Management for the Acquisition of Capital Assets and associated guidance documents, particularly DOE Guide 413.3-1, Managing Design and Construction: A Systems Approach. DOE also developed and implemented DOE Standard 1189-2016, Integration of Safety into the Design Process.

On July 24, 2017, the Board issued Policy Statement 6 (PS-6) entitled, Policy Statement on Oversight of Design and Construction of Defense Nuclear Facilities. PS-6 describes how the Board fulfills its statutory duty to review design and construction projects. Specifically, the Board’s oversight reviews are to be accomplished with “defined scope and durations at specified and logical points in the process and document the review results in four formal reports to the Board:

1. Conceptual design (including the Safety Design Strategy and the Conceptual Safety Design Reports);
   
   
2. Final design (including Preliminary Documented Safety Analysis);
   
   
3. Construction (including Quality Assurance Program, design compliance of a selective subset of installed safety systems, structures, and components, and specified Technical Safety requirements); and
   
   
4. Commissioning (a selective subset of safety programs including aspects of startup and testing, Technical Safety Requirements, and associated procedures).
   
   

The Board will decide whether or not to transmit these reports to the Secretary of Energy, with the objective being to:

1. Provide timely and formal communications to DOE so that the Board’s independent advice, analysis, and recommendations may be factored into the normal DOE decision-making process to the maximum extent possible.
   
   
2. Track DOE’s efforts and progress regarding safety items identified in formal communications from the Board. Tracking will cease once:
   
   
1. DOE formally communicates its decision regarding resolution of the safety items to the Board; and
   
   
2. The Board formally responds, nominally within 90 days, to DOE’s communication.
   
   
3. Use any of the Board’s statutory tools to inform DOE and the public of design or construction safety items.
   
   

DNFSB PS-6 is accessible at the following link: https://www.dnfsb.gov/policies

6.2 DNFSB Oversight of Decommissioning Activities at DOE Defense Nuclear Facilities

The DNFSB oversight of defense nuclear facility decommissioning activities is governed by its Policy Statement 3 (PS-3) entitled, Policy Statement on Board oversight of Department of Energy decommissioning activities at defense nuclear facilities, issued on August 19, 1996. PS-3 states that “the Board's principal oversight function during the decommissioning phase of a facility is to ensure that appropriate nuclear safety rules, orders, and procedures are developed by DOE and then put in practice while the facility is being taken out of service.”

Thus, the Board's objective during decommissioning is identical to its objective during any other phase of a facility's life cycle. PS-3 provides the Board’s definition of “decommissioning” and also discusses various activities including deactivation, decontamination, final process runs, removal of special nuclear material, residues, and wastes, and other activities necessary to ensure adequate protection of public health and safety.

DNFSB PS-3 is accessible at the following link: https://www.dnfsb.gov/policies