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GAO-14-79R: 

GAO:
United States Government Accountability Office: 
441 G St. N.W. 
Washington, DC 20548: 

October 25, 2013: 

Congressional Committees: 

Nuclear Weapons: Information on Safety Concerns with the Uranium 
Processing Facility: 

The Y-12 National Security Complex in Oak Ridge, Tennessee, is the 
National Nuclear Security Administration's (NNSA) site for conducting 
enriched uranium activities, producing uranium-related components for 
nuclear warheads and bombs, and processing nuclear fuel for the U.S. 
Navy.[Footnote 1] NNSA is a separately organized agency within the 
Department of Energy (DOE). According to NNSA, the Y-12 plant's 
current enriched uranium operations, which are conducted in four 
separate buildings, have key shortcomings including (1) an inefficient 
workflow; (2) continually rising operations and maintenance costs due 
to facility age; and (3) processes that could expose workers to 
radiological contamination, among other things. To address these 
issues, in 2004, NNSA decided to construct a new Uranium Processing 
Facility (UPF).[Footnote 2] According to NNSA, the UPF will: 

* consist of a single, consolidated facility less than half the size 
of existing facilities; 

* reduce costs by using modern processing equipment; and: 

* incorporate features to increase worker protection and environmental 
health and safety. 

The work carried out at several of DOE's defense nuclear facilities 
involves dangerous nuclear materials and hazardous chemicals.[Footnote 
3] For example, the UPF will process highly enriched uranium as well 
as beryllium, a hazardous metal essential for nuclear operations. 
Contractors are responsible for safely designing, constructing, and 
operating DOE's defense nuclear facilities. DOE's oversight of how 
these facilities' safety systems are designed and operated is critical 
to ensuring the health and safety of workers, the public, and the 
environment.[Footnote 4] To assess safety conditions at DOE's defense 
nuclear facilities, Congress created the Defense Nuclear Facilities 
Safety Board (Safety Board)--an independent executive branch agency--
in 1988. The Safety Board has broad oversight responsibilities 
regarding these facilities but does not have the authority of a 
regulator.[Footnote 5] 

At the request of the Senate Appropriations Committee, Subcommittee on 
Energy and Water Development and in accordance with the Fiscal Year 
2013 National Defense Authorization Act, GAO is required to submit 
quarterly reports on the UPF.[Footnote 6] Our first report was issued 
in July 2013 and found that (1) key assumptions contained in multiple 
cost estimates proved to be inaccurate and were the primary factors 
that contributed to the UPF's cost increase from $1.1 billion in 2004 
to $6.5 billion in 2012, and (2) the UPF contractor did not adequately 
manage and integrate the design work subcontracted to four other 
contractors and therefore the UPF's roof will have to be raised 13 
feet to ensure the processing equipment would fit into the facility, 
which resulted in approximately $540 million in additional costs. 
[Footnote 7] Based on discussions and agreement with your offices, our 
objective for this second report was to identify the concerns, if any, 
that the Safety Board has raised with the UPF and the actions, if any, 
NNSA has taken to address those concerns. 

To do this work, we reviewed key DOE management orders and standards 
that establish project management and safety requirements for 
constructing new nuclear facilities. In addition, we reviewed UPF 
safety-related documents prepared by DOE, NNSA, and the UPF contractor 
as well as multiple safety assessments of the UPF conducted by the 
Safety Board. We interviewed UPF contractor representatives 
responsible for developing key safety documents as well as NNSA 
officials who oversee this process. In addition, we visited the Y-12 
plant and received safety-related briefings from NNSA and contractor 
officials. We also interviewed and received briefings from Safety 
Board staff responsible for conducting oversight of the UPF. 

We conducted this performance audit from April 2013 to October 2013 in 
accordance with generally accepted government auditing standards. 
Those standards require that we plan and perform the audit to obtain 
sufficient, appropriate evidence to provide a reasonable basis for our 
findings and conclusions based on our audit objectives. We believe 
that the evidence obtained provides a reasonable basis for our 
findings and conclusions based on our audit objectives. 

Background: 

The Safety Board exercises broad oversight over DOE facilities. 
Specifically, the Safety Board: 

* reviews DOE's safety and design documentation to ensure that DOE is 
complying with its own requirements and processes for integrating 
safety into the design process; 

* issues "project letters" to DOE at major project milestones to 
document the results of these reviews and communicate significant 
safety issues; and: 

* holds occasional public hearings to address concerns about DOE's 
safety practices, including an October 2012 hearing on the UPF in 
Knoxville, Tennessee. 

In 1990, we first designated DOE program management as an area at high 
risk of fraud, waste, abuse, and mismanagement.[Footnote 8] In January 
2009, to recognize the progress made at DOE's Office of Science, we 
narrowed the focus of the high-risk designation to two DOE program 
elements, NNSA and the Office of Environmental Management.[Footnote 9] 
In February 2013 we issued our most recent high-risk update, in which 
we narrowed this focus to major projects (i.e., projects over $750 
million) at NNSA and the Office of Environmental Management.[Footnote 
10] DOE has taken some steps to address our concerns, including 
developing an order in 2010 that defines DOE's project management 
principles and process for executing a capital asset construction 
project.[Footnote 11] NNSA is required to manage the UPF in accordance 
with this order. The project management process defined in Order 
413.3B requires DOE projects to go through five management reviews and 
approvals, called "critical decisions" (CD), as they move forward from 
project planning and design to construction to operation. The CDs are: 

* CD 0: Approve a mission-related need. 

* CD 1: Approve an approach to meet a mission need and a preliminary 
cost estimate. 

* CD 2: Approve the project's cost, schedule and scope targets. 

* CD 3: Approve the start of construction. 

* CD 4: Approve the start of operations. 

In June 2012, the Deputy Secretary of Energy reaffirmed CD 1 for the 
UPF and approved a phased approach to the project, which will defer 
significant portions of the facility's original scope. This deferral 
was due, in part, to the project's increased cost estimate and to 
accelerate the completion of the highest priority scope. Table 1 shows 
the UPF's phases, scope of work, cost estimate as of June 2012, and 
key project dates. 

Table 1: Uranium Processing Facility (UPF) Phases, Scope of Work, Cost 
Estimate as of June 2012, and Project Dates: 

Phase: Phase I; 
Scope of work: UPF building exterior, all support systems, Building 
9212 capabilities (uranium purification and casting); 
Cost estimate as of June 2012: $4.2 to $6.5 billion; 
Project dates: CD 2 expected in 2015[A]; CD 3 expected in 2015; 
CD 4 expected in 2025. 

Phase: Phase II; 
Scope of work: Building 9215 (machining) and Building 9998 
capabilities (product certification); 
Cost estimate as of June 2012: NNSA has not established a cost 
estimate; 
Project dates: CD 4 expected from 2030 and 2036. 

Phase: Phase III; 
Scope of work: Building 9204-2E capabilities (assembly and 
dismantlement); 
Cost estimate as of June 2012: NNSA has not established a cost 
estimate; 
Project dates: CD 4 expected from 2030 and 2036. 

Source: NNSA. 

[A] The project management process defined in DOE Order 413.3B 
requires DOE projects to go through five management reviews and 
approvals, called "critical decisions" (CD), as they move forward from 
project planning and design to construction to operation. 

[End of table] 

Key interim safety documents are to be completed by the contractor and 
approved by NNSA prior to CD 1, 2, and 3 milestones, while a final 
safety document is to be completed and approved prior to CD 4. 
According to Order 413.3B, these interim and final documents are to 
identify how the UPF's nuclear material and hazardous chemicals will 
be handled, the potential accidents and hazards associated with the 
facility's operations, and the controls employed to mitigate or 
prevent their impact on workers and the public. Another DOE document--
DOE Standard 1189: Integration of Safety into the Design Process--
provides guidance on how these interim and final safety documents are 
to be prepared, among other things. For example, it directs DOE and 
NNSA to analyze and address fire protection, nuclear criticality, and 
natural hazards, such as earthquakes.[Footnote 12] According to this 
standard, the interim safety documents help ensure that safety issues 
are explicitly identified and addressed early in the design phase to 
reduce costly late reversals. Thus, these interim safety documents are 
to be used to develop the UPF's final safety document, which provides 
the basis for ensuring that the facility can be operated safely with 
respect to workers, the public, and the environment. According to 
Order 413.3B, facilities cannot begin operations until their final 
safety documents are approved. 

Results in Brief: 

In 2010, members of the Safety Board raised concerns that NNSA was 
deviating from the process established by DOE Order 413.3B and DOE 
Standard 1189 to develop the UPF's CD 2 interim safety document and was, 
therefore, not ensuring that safety was adequately integrated into the 
UPF's design. NNSA then took actions to follow the established process, 
and Safety Board staff stated that NNSA's corrective actions 
addressed many of their concerns. As of June 2013, the Safety Board 
had identified 15 specific safety concerns with the UPF's design, and 
NNSA has taken or agreed to take actions to address 14 of these concerns. 
In addition, on August 26, 2013, the Safety Board sent NNSA a project 
letter that identified 12 additional specific safety concerns based on 
the CD 2 interim safety document approved by NNSA in February 2013. 
The Safety Board has also raised general concerns with NNSA's plans to 
defer the installation of some uranium processing capabilities into the 
UPF at a later date and after the UPF is operational. 

The Safety Board Has Identified Concerns with the UPF, and NNSA Has 
Taken Actions to Address Most of Them: 

Members of the Safety Board have raised concerns that NNSA was deviating 
from the process established by DOE Order 413.3B and DOE Standard 1189 to 
develop the UPF's CD 2 interim safety document, and therefore not 
ensuring that safety was adequately integrated into the UPF's design. 
According to NNSA officials and Safety Board staff, in 2008, when DOE 
issued DOE Standard 1189 on how these documents are to be prepared, 
the UPF was to be one of the pilot projects for implementing the new 
standard. However, in 2009, NNSA decided to expedite the UPF by 
combining the CD 2 and CD 3 milestones, eliminating the development of 
the interim safety document for CD 2, and focusing on the development 
of alternative safety documents.[Footnote 13] On several occasions in 
2010, members of the Safety Board expressed concerns to NNSA regarding 
its initial decision to cancel the CD 2 interim safety document, and, 
according to NNSA officials, a subsequent UPF independent project 
review in 2010 recommended that the project follow the safety document 
development process established by DOE Order 413.3B and DOE Standard 
1189. In 2011, NNSA directed the UPF contractor to develop the 
required CD 2 interim safety document, and the contractor completed a 
revised version of the document in September 2012. NNSA approved the 
CD 2 interim safety document in February 2013 with 11 conditions that 
the UPF contractor must address in subsequent safety documents, such 
as improving the reliability and robustness of venting systems. Safety 
Board staff said that it is not unusual for interim safety 
documents to be approved with conditions, as they can be addressed in 
subsequent safety documents. See enclosure I for a timeline of the 
development of the UPF's CD 2 interim safety document. 

As of June 2013, the Safety Board also identified 15 specific safety 
concerns with the UPF's design, and NNSA has taken actions --or has 
agreed to take actions--to address 14 of these concerns.[Footnote 14] 
See enclosure II for a description of the Safety Board's concerns, 
NNSA's actions to address the concerns, and the status of the safety 
concerns. Safety Board staff and NNSA officials agreed that none of 
the 15 concerns should prevent the UPF from reaching CD 2 in 2015 as 
scheduled. According to NNSA officials and Safety Board staff, 1 of 
these concerns--that the contractor had not developed an adequate 
corrective action plan to address structural engineering issues, among 
other things, previously identified by the Safety Board--has been 
fully addressed. For 7 other concerns, NNSA has presented evidence 
that the Safety Board's staff believe is reasonable to fully address 
the concerns, and the Safety Board is currently in the final stages of 
reviewing the agency's actions.[Footnote 15] Six other concerns remain 
open while NNSA is completing the corrective actions, which Safety 
Board officials said they will review once the actions are completed. 
[Footnote 16] For the final concern--about the methodology used to 
calculate the rate at which radioactive material would settle out of 
the atmosphere in the event of an accident--Safety Board staff and 
NNSA officials said that they are not likely to agree on a path to 
resolution, and NNSA has conducted additional analyses to clarify its 
position. 

On August 26, 2013, the Safety Board sent NNSA a project letter that 
acknowledged the agency's progress in addressing the Safety Board's 
previously identified concerns with the UPF. However, the Safety Board 
said that NNSA must continue to improve the effectiveness of the UPF's 
safety controls and strengthen oversight to ensure planned controls 
can reliably perform their safety functions. In addition, the Safety 
Board identified 12 additional specific safety concerns, such as those 
related to potential fire and explosion scenarios, based on the CD 2 
interim safety document approved by NNSA in February 2013. See 
enclosure III for a description of these 12 additional concerns. 
According to NNSA officials, the agency is currently reviewing the 
Safety Board's letter and preparing a response. Safety Board staff 
said that additional concerns may be raised as UPF completes final 
design and moves into construction. 

In addition to the specific safety concerns raised above, the Safety 
Board has also raised general concerns with NNSA's plans to defer the 
installation of some uranium processing capabilities into the UPF at a 
later date and after the UPF is operational. As discussed above, NNSA 
currently plans to install uranium processing capabilities into the 
UPF in phases, after the building's exterior, support systems, and 
some processing capabilities have been completed. However, NNSA 
officials said that the agency does not plan to complete final design 
and safety work for the deferred capabilities until after the initial 
phase of the UPF is operational, which NNSA expects to occur in 2025. 
Safety Board officials stated that if NNSA encounters any challenges 
while finalizing the design and safety controls for the deferred 
scope, it will have much less flexibility to address them since the 
building will already have been constructed. Currently, NNSA plans to 
begin and complete subsequent UPF phases between 2030 and 2036. Safety 
Board staff stated that this project execution strategy introduces 
safety-related risks that will challenge the project's ability to 
integrate safety into the design. For example, at an October 2012 
public hearing on the UPF, a senior Safety Board staff member noted 
that other DOE projects that have attempted similar complex execution 
strategies, such as the Hanford Waste Treatment Plant, which chose a 
strategy that allowed construction to begin prior to completing 
design, have had little or no success. In the UPF project, NNSA has 
decided to defer scope for key manufacturing and machining operations 
and will add them back to UPF sometime after it is built, which the 
senior Safety Board staff member said was similar to the Hanford Waste 
Treatment Plant decision to begin construction before completion of 
design, and magnified the impacts on the plant's cost and schedule 
when safety-related issued were discovered late in the design process. 
[Footnote 17] According to NNSA officials and the UPF contractor, the 
UPF project team plans to continue developing the design of the 
deferred scope capabilities to a level of maturity that will ensure 
all process equipment will fit into the building and the proper safety 
controls for the entire facility are identified. As noted in our July 
2013 report, a failure to ensure that the UPF contained sufficient 
space for all the processing equipment already resulted in 
approximately $540 million in additional costs.[Footnote 18] 

In addition, Safety Board staff stated that performing a major 
modification to an operating nuclear facility can present safety 
issues if not carefully planned and executed. The UPF Federal Project 
Director, in testimony at the Safety Board's October 2012 public 
hearing on the UPF, generally agreed with this concern and said that 
NNSA will need to address a number of safety risks during subsequent 
phases of the project, such as risks to the facility's fire 
protection, ventilation, and criticality safety systems, as well as 
risks associated with additional construction workers operating in 
close proximity to hazardous materials and processes. According to 
NNSA officials, the UPF project team will need to conduct and document 
additional safety analyses to ensure that construction activities meet 
DOE's safety requirements. Safety Board officials said that they are 
monitoring NNSA's efforts to perform the engineering work necessary to 
safely incorporate the deferred scope into the UPF's design, and may 
raise additional specific safety issues as the design progresses. 

While we are currently not making any recommendations for 
congressional consideration or agency action, we will continue to 
review the UPF as required by the National Defense Authorization Act 
for Fiscal Year 2013, and may make recommendations in the future if 
warranted. 

Agency Comments: 

We provided a draft of this report to NNSA and the Safety Board for 
review and comment. NNSA provided technical comments, which we incorporated 
into the report as appropriate. NNSA’s written comments are reproduced in 
enclosure IV. On October 3,2013, we received technical comments via email 
from the Safety Board’s UPF Project Lead, which we incorporated into the 
report as appropriate. 

We are sending copies of this report to the appropriate congressional 
committees, the Secretary of Energy, the Administrator of NNSA, the 
Chairman of the Safety Board, the appropriate congressional committees, 
and other interested parties. This report also is available at no charge 
on the GAO website at [hyperlink, http://www.gao.gov]. 

If you or your staff members have questions concerning this report, 
please contact me at (202) 512-3841 or trimbled@gao.gov. Contact 
points for our Offices of Congressional Relations and Public Affairs 
may be found on the last page of this report. Key contributors to this 
report were Jonathan Gill, Assistant Director; Patrick Bernard; and 
Will Horton. 

Signed by: 

David C. Trimble: 
Director, Natural Resources and Environment: 

Enclosures--4: 

List of Committees: 

The Honorable Carl Levin: 
Chairman: 
The Honorable James M. Inhofe: 
Ranking Member: 
Committee on Armed Services: 
United States Senate: 

The Honorable Dianne Feinstein: 
Chairwoman: 
The Honorable Lamar Alexander: 
Ranking Member: 
Subcommittee on Energy and Water Development: 
Committee on Appropriations: 

United States Senate: 
The Honorable Howard P. "Buck" McKeon: 
Chairman: 
The Honorable Adam Smith: 
Ranking Member: 
Committee on Armed Services: 
House of Representatives: 

The Honorable Rodney P. Frelinghuysen: 
Chairman: 
The Honorable Marcy Kaptur: 
Ranking Member: 
Subcommittee on Energy and Water Development: 
Committee on Appropriations: 
House of Representatives: 

[End of section] 

Enclosure I: Timeline of the Development of the Uranium Processing 
Facility's Critical Decision 2 Interim Safety Document: 

The National Nuclear Security Administration (NNSA)--a separately 
organized agency within the Department of Energy (DOE)--is required to 
manage the Uranium Processing Facility (UPF) project in accordance 
with DOE Order 413.3B, which establishes the agency's project 
management principles and process, including protocols for planning 
and executing a project.[Footnote 19] This process requires DOE 
projects to go through five management reviews and approvals as they 
enter each new phase of work, called "critical decisions" (CD). Key 
interim safety documents are to be completed by the contractor and 
approved by NNSA prior to CD 1, 2, and 3 milestones, while a final 
safety document is to be completed and approved prior to CD 4. 
According to Order 413.3B, facilities cannot begin operations until 
their final safety documents are approved. 

However, in 2009, NNSA decided to expedite the UPF by combining 
several CD milestones, eliminating the development of the interim 
safety document for CD 2, and focusing on the development of 
alternative safety documents.[Footnote 20] After members of the 
Defense Nuclear Facilities Safety Board--an independent executive 
branch agency created by Congress to assess safety conditions and 
operations at DOE's defense nuclear facilities--raised concerns that 
NNSA was deviating from the process established by DOE Order 413.3B, 
NNSA directed the UPF contractor to develop an interim safety document 
for CD 2. Figure 1 describes the timeline by which the required CD 2 
interim safety analysis was developed by the UPF contractor and 
reviewed and approved by NNSA. 

Figure 1: Development of the Uranium Processing Facility's Required CD 
2 Interim Safety Analysis: 

[Refer to PDF for image: timeline] 

July 2011: 
The UPF contractor developed a CD 2 interim safety document, and 
submitted it for NNSA review and approval. 

January 2012: 
NNSA completed its review and directed the UPF contractor to address 
110 significant comments. For example, NNSA raised concerns about the 
assumptions the contractor used to analyze the potential effects of 
facility fires. 

April 2012: 
The Defense Nuclear Facilities Safety Board issued a public letter to 
NNSA that also identified multiple significant issues with the 
contractor’s July 2011 interim safety document, such as concerns that 
the project did not use adequate assumptions when planning for 
radiological accidents. 

September 2012: 
The UPF contractor completed a revised version of the CD 2 interim 
safety document, and submitted it for NNSA review and approval. 

February 2013: 
NNSA approved the CD 2 interim safety document with 11 conditions that 
the contractor must address in subsequent safety documents and 
analyses, such as improving the reliability and robustness of venting 
systems. Safety Board officials stated that their preliminary 
observation is that the revised CD 2 interim safety document has 
addressed many of the Board’s concerns and that many of NNSA’s 11 
conditions match their own remaining concerns. Safety Board officials 
also said that it is not unusual for interim safety documents to be 
approved with conditions, as the conditions can be addressed in 
subsequent safety documents. 

Source: NNSA. 

Note: DOE's Office of Health, Safety, and Security, among other 
things, develops safety policy and conducts independent oversight of 
compliance with DOE's safety regulations and directives, and 
enforcement activities. In addition, this office conducted an 
independent review of the UPF's CD 2 interim safety document. The 
review concurred with the overall conclusions of NNSA's review, 
including the decision to approve the document subject to additional 
conditions for proceeding to the next stage of design. See U.S. 
Department of Energy, Independent Oversight Appraisal of the Uranium 
Processing Facility Safety Basis Preliminary Safety Design Report 
Process at the Y-12 National Security Complex (Washington, D.C.: May 
2013). 

[End of figure] 

[End of section] 

Enclosure II: Safety Concerns Identified by the Defense Nuclear 
Facilities Safety Board with the Uranium Processing Facility as of 
June 2013 and Actions Taken by the National Nuclear Security 
Administration to Address Those Concerns: 

Actions taken by the National Nuclear Security Administration (NNSA) 
to address safety concern: 

Safety concern number: 1; 
Safety concern identified by the Defense Nuclear Facilities Safety 
Board (Safety Board) with the Uranium Processing Facility (UPF): The 
UPF contractor had not developed an adequate corrective action plan to 
address structural engineering issues, among other things, previously 
identified by the Safety Board; 
Status of one safety concern where NNSA has completed corrective 
action: According to the Safety Board staff, the UPF contractor took 
appropriate actions--such as identifying the controls needed to 
prevent internal explosions--to address the Safety Board's concern. 

Status of seven safety concerns where the Safety Board's technical 
staff believes there is reasonable evidence that NNSA has fully 
addressed these concerns, and the Safety Board is currently in the 
final stages of reviewing the agency's actions: 

Safety concern number: 2; 
Safety concern identified by the Defense Nuclear Facilities Safety 
Board (Safety Board) with the Uranium Processing Facility (UPF): Some 
potential facility hazards were not analyzed, or the frequency or 
consequences of these hazards were assumed to be limited[A]; 
Status of one safety concern where NNSA has completed corrective 
action: NNSA, among other things, revised its analyses of the UPF's 
hazards to address the Safety Board's concerns by, for example, 
identifying additional safety controls for fires. 

Safety concern number: 3; 
Safety concern identified by the Defense Nuclear Facilities Safety 
Board (Safety Board) with the Uranium Processing Facility (UPF): The 
project lacks a defensible methodology for analyzing fires resulting 
from an earthquake; 
Status of one safety concern where NNSA has completed corrective 
action: NNSA conducted a new analysis providing additional details on 
its methodology. 

Safety concern number: 4; 
Safety concern identified by the Defense Nuclear Facilities Safety 
Board (Safety Board) with the Uranium Processing Facility (UPF): The 
scenario for accidents involving a nuclear criticality is not 
reasonably conservative[B]; 
Status of one safety concern where NNSA has completed corrective 
action: NNSA clarified and revised the amounts of radiation that were 
assumed in its criticality accident scenario, and identified an 
additional safety system to provide shielding for workers located near 
UPF who could be exposed to dangerous radiation levels during a 
criticality accident. 

Safety concern number: 5; 
Safety concern identified by the Defense Nuclear Facilities Safety 
Board (Safety Board) with the Uranium Processing Facility (UPF): The 
analysis of one accident scenario is not adequate, as it does not 
consider all plant conditions, such as explosions initiated by a fire, 
that could increase the dispersal of hazardous materials[C]; 
Status of one safety concern where NNSA has completed corrective 
action: NNSA provided additional information on, among other things, 
the impact of potential explosions on the fire scenario. 

Safety concern number: 6; 
Safety concern identified by the Defense Nuclear Facilities Safety 
Board (Safety Board) with the Uranium Processing Facility (UPF): The 
UPF project downgraded the ventilation system's seismic rating, 
meaning that the ventilation system will not be designed to ensure 
confinement of hazardous materials following an earthquake; 
Status of one safety concern where NNSA has completed corrective 
action: NNSA upgraded a portion of the ventilation system to ensure 
confinement in the event of an earthquake. 

Safety concern number: 7; 
Safety concern identified by the Defense Nuclear Facilities Safety 
Board (Safety Board) with the Uranium Processing Facility (UPF): The 
UPF project downgraded the seismic rating of the facility's 
criticality prevention controls, meaning that the controls will not be 
designed to reliably survive an earthquake and prevent a criticality 
accident; 
Status of one safety concern where NNSA has completed corrective 
action: NNSA committed to upgrade the seismic rating of certain 
criticality prevention controls. 

Safety concern number: 8; 
Safety concern identified by the Defense Nuclear Facilities Safety 
Board (Safety Board) with the Uranium Processing Facility (UPF): The 
UPF project team has stated its intent to implement Institute of 
Electrical and Electronics Engineers standards for the reliability of 
safety controls used to prevent explosions but has not formally 
detailed this approach in the project's planning documents; 
Status of one safety concern where NNSA has completed corrective 
action: NNSA clarified that these standards are included in UPF design 
documents. 

Status of six safety concerns where NNSA is completing the corrective 
action, which Safety Board officials said they will review once the 
actions are completed: 

Safety concern number: 9; 
Safety concern identified by the Defense Nuclear Facilities Safety 
Board (Safety Board) with the Uranium Processing Facility (UPF): The 
UPF project downgraded the seismic rating of the criticality accident 
alarm system, meaning that the system will not be designed to function 
during and following an earthquake, relying instead on fire alarms to 
initiate evacuation after an earthquake[D]; 
Status of one safety concern where NNSA has completed corrective 
action: NNSA clarified that it expects the contractor to ensure worker 
response to an earthquake would be the same as worker response to a 
criticality alarm. 

Safety concern number: 10; 
Safety concern identified by the Defense Nuclear Facilities Safety 
Board (Safety Board) with the Uranium Processing Facility (UPF): The 
structural engineering design is robust, but a Safety Board letter 
raised a technical and quality assurance concern associated with a 
computer program, which is in use at multiple projects across DOE, 
including the UPF, for analyzing soil-structure interaction; 
Status of one safety concern where NNSA has completed corrective 
action: NNSA is conducting multiple studies that are intended to 
resolve technical and quality issues with the computer program. 

Safety concern number: 11; 
Safety concern identified by the Defense Nuclear Facilities Safety 
Board (Safety Board) with the Uranium Processing Facility (UPF): The 
fire suppression system was assumed to be sufficient to protect 
against both large and small fires. However, small fires may not 
provide sufficient heat to activate the fire suppression system, or 
may be located in gloveboxes--a containment system of secured gloves 
attached to a box that allows workers to process nuclear material 
inside the box without risk of contamination--where the suppression 
system will not provide coverage; 
Status of one safety concern where NNSA has completed corrective 
action: NNSA conducted a new analysis of fire scenarios, including, 
among other things, limiting the quantities of hazardous materials in 
certain gloveboxes. The Safety Board staff communicated further 
concerns with this analysis, such as the potential for concurrent 
fires in multiple gloveboxes and NNSA's failure to demonstrate that 
the fire suppression system will control hazardous material releases 
from smaller fires occurring outside of gloveboxes. In response, NNSA 
committed to performing additional analyses to address the Safety 
Board's concerns. 

Safety concern number: 12; 
Safety concern identified by the Defense Nuclear Facilities Safety 
Board (Safety Board) with the Uranium Processing Facility (UPF): The 
functional requirements for the fire suppression system are incomplete 
and do not address the potential for reactive materials contained in 
gloveboxes getting wet in the event of an earthquake, potentially 
causing explosions; 
Status of one safety concern where NNSA has completed corrective 
action: NNSA committed to (1) demonstrating that an explosion is not 
credible in this scenario, or (2) providing additional safety controls, 
such as water-tight containers for water-reactive materials. 

Safety concern number: 13; 
Safety concern identified by the Defense Nuclear Facilities Safety 
Board (Safety Board) with the Uranium Processing Facility (UPF): The 
UPF project office is understaffed for providing effective safety 
oversight of the project, with many personnel sharing project 
management and technical oversight responsibilities; 
Status of one safety concern where NNSA has completed corrective 
action: NNSA: (1) committed to filling seven key management positions 
in 2012; (2) hiring specific subject matter experts in 2013-2014, such 
as in fire protection, ventilation, criticality, quality assurance, 
and construction oversight; and, (3) prepared a detailed staffing plan. 
According to an NNSA official, as of March 2013 the project hired 
additional safety personnel, and had been approved to fill an 
additional 10 specialist positions, such as fire safety engineers and 
criticality engineers. 

Safety concern number: 14; 
Safety concern identified by the Defense Nuclear Facilities Safety 
Board (Safety Board) with the Uranium Processing Facility (UPF): 
Several assumptions used in the UPF's engineering models could result 
in a design subject to localized structural failure during an 
earthquake. Such failure could affect the operability of safety 
systems attached to the structure; 
Status of one safety concern where NNSA has completed corrective 
action: NNSA revised the document describing its approach to 
validating the assumptions used, and the Safety Board staff is 
reviewing NNSA's revisions. 

Status of one safety concern where the Safety Board and NNSA are not 
likely to agree on a path to resolution, and NNSA has conducted 
additional analyses to clarify its position: 

Safety concern number: 15; 
Safety concern identified by the Defense Nuclear Facilities Safety 
Board (Safety Board) with the Uranium Processing Facility (UPF): When 
calculating the rate at which radioactive material would settle out of 
the atmosphere onto the surrounding area in the event of an accidental 
release, NNSA concluded the material would settle more quickly, and 
thus pose less of a safety concern to the public, than could be the 
case using more conservative assumptions; 
Status of one safety concern where NNSA has completed corrective 
action: NNSA conducted a review that validated its analysis. Safety 
Board staff provided NNSA with a written explanation of their specific 
areas of disagreement, and NNSA is evaluating this explanation. 

Sources: GAO analysis of NNSA and Safety Board data. 

[A] For example, fires were assumed to be limited to a single process 
area instead of the full facility because it was assumed that fire 
barriers would prevent their spread. b A nuclear criticality accident 
occurs when enough fissile material, such as uranium, is brought 
together to cause a sustained nuclear chain reaction. The immediate 
result of a nuclear criticality accident is the production of an 
uncontrolled and unpredictable radiation source that can be lethal to 
people who are nearby. While the UPF will process the same types of 
materials that are currently being processed in other facilities at 
the Y-12 National Security Complex, the criticality analysis 
supporting existing operations assumes higher amounts of resulting 
radiation than are used in the analysis for the UPF. 

[C] According to the Safety Board, the accident of concern is 
categorized as being beyond the UPF's design requirement. However, DOE 
Standard 3009: Preparation Guide for U.S. Department of Energy 
Nonreactor Nuclear Facility Documented Safety Analyses directs that 
these types of accidents be analyzed to provide a perspective of the 
remaining risk associated with operating the facility. 

[D] According to the Safety Board, the use of the fire alarm does not 
adequately protect the UPF's workers because the appropriate responses 
for the two potential accident conditions are inherently different. 

[End of table] 

[End of section] 

Enclosure III: Twelve Additional Safety Concerns Identified by the 
Defense Nuclear Facilities Safety Board with the Uranium Processing 
Facility as of August 2013: 

On August 26, 2013, the Defense Nuclear Facilities Safety Board 
(Safety Board) sent the National Nuclear Security Administration 
(NNSA) a letter that acknowledged the agency's progress in addressing 
the Safety Board's previously identified concerns (i.e., the 15 
specific safety concerns identified by the Safety Board in enclosure 
II) with the design of the UPF. However, the letter stated that NNSA 
must continue to improve the effectiveness of the UPF's safety 
controls and strengthen oversight to ensure planned controls can 
reliably perform their safety functions. In addition, the Safety Board 
identified 12 additional specific safety concerns with the design of 
the UPF. According to NNSA officials, the agency is currently 
reviewing the Safety Board's letter and will provide a report and 
briefing to the Safety Board by November 22, 2013, describing NNSA's 
plan and schedule for addressing the issues. 

The 12 additional UPF-related safety concerns identified by the Safety 
Board are as follows: 

* Fires in certain process areas: For certain fire scenarios, the fire 
protection system would not actuate or actuation would be delayed and 
therefore may not prevent a significant release of toxicological 
material. 

* Glovebox fires: Under normal operating conditions, certain 
gloveboxes--a containment system of secured gloves attached to a box 
that allows workers to process nuclear material inside the box without 
risk of contamination--are provided with an inert gas atmosphere that 
does not allow combustion. However, if the inert environment is lost 
(e.g., due to an earthquake), oxygen intrusion into the glovebox could 
cause the material inside to ignite. Since fire protection sprinklers 
are located outside of the gloveboxes, they cannot be relied upon to 
protect against such fires. 

* Aircraft crashes: NNSA analyzed aircraft crash scenarios for the 
main UPF building but did not analyze the aircraft crash scenario for 
ancillary UPF structures, such as the loading dock and truck bay. 

* Natural disasters and man-made external events: The UPF structure is 
designed to provide protection against a specific set of natural 
disasters and man-made external events, such as vehicle impacts and 
wildfires. However, the UPF safety analysis does not clearly link the 
associated functional requirements and performance criteria for the 
UPF structure to the specific accidents. The Safety Board concluded 
that important structural attributes may not be effectively captured 
and incorporated into the UPF's design. 

* Concurrent releases of multiple hazardous materials: Some fire 
scenarios in the UPF can concurrently release multiple hazardous 
chemicals. However, the UPF's safety controls are designed to prevent 
or mitigate hazards based solely on the potential release of any 
single chemical exceeding the applicable thresholds. This could result 
in the need for additional safety controls when the cumulative effects 
of concurrently released chemicals are evaluated. 

* Dust explosions: Certain uranium processing activities in gloveboxes 
can generate dusts, which could produce explosions that could 
seriously injure facility workers. Under normal operating conditions, 
the affected gloveboxes are provided with an inert gas atmosphere to 
prevent dust explosions. However, the safety features that provide 
this inert atmosphere could be compromised under certain accident 
scenarios. 

* Violent chemical reactions: Certain chemical processing activities 
can result in violent chemical reactions that forcefully expel heated 
chemicals from process vessels. However, the UPF project has not 
identified any credited controls to protect facility workers from 
resulting chemical burns. 

* Combustible materials in certain processing equipment: During a 
specific uranium processing operation, potentially combustible 
materials might be present. When certain processing equipment is heated 
to its normal operating temperature (approximately 1400 degrees 
Celsius), the potentially combustible material could release enough 
energy to rupture the equipment and injure facility workers. The UPF 
project has not identified a control to prevent the introduction of 
potentially combustible material into certain processing equipment. 

* Steam overpressure in casting furnaces: Potential water intrusion 
into a furnace that casts highly enriched uranium during high-
temperature operations can cause a violent steam overpressure event 
that could seriously injure facility workers. 

* Hydrogen explosions (1): A hydrogen explosion could occur in the 
enriched uranium purification and metal production process under 
certain conditions. The current UPF safety strategy relies on operator 
action to prevent a hydrogen explosion but does not treat this 
operator action as a formal safety control, even though it is relied 
upon to prevent an event that could result in serious facility worker 
injuries. 

* Hydrogen explosions (2): Hydrogen would be released if water reacted 
with certain compounds used in the UPF assembly process area. The UPF 
safety analysis did not evaluate the potential for a hydrogen 
explosion. 

* Damage to enriched uranium in storage: For earthquake-induced fires, 
the UPF safety analysis assumes that 10 percent of enriched uranium 
located in the UPF's storage racks would be damaged. This 10 percent 
assumption is based on a series of experiments conducted at Los Alamos 
National Laboratory under controlled laboratory conditions. The Safety 
Board said that the unmitigated earthquake-induced UPF fire 
environment could exhibit conditions that are different than the 
conditions used in the Los Alamos experiments. As such, the Safety 
Board stated that the UPF project does not have adequate data to 
support its 10 percent damage ratio. 

[End of section] 

Enclosure IV: Comments from the Department of Energy: 

Department of Energy: 
National Nuclear Security Administration: 
Washington, DC 20585: 

October 3, 2013: 

Mr. David Trimble: 
Director: 
Natural Resources and Environment: 
Government Accountability Office: 
Washington, DC 20458: 

Dear Mr. Trimble: 

Thank you for the opportunity to review the Government Accountability Office 
(GAO) draft report titled "Safety Concerns on the Uranium Processing Facility 
Project", GAO-14-79R. I understand the GAO is required to report quarterly on 
the Uranium Processing Facility (UPF) in response to a request made by the 
Senate Appropriations Committee, Subcommittee on Energy and Water Development, 
and in accordance with the requirements contained in the National Defense 
Authorization Act for Fiscal Year 2013. This is the second quarterly report 
of the UPF report series. 

In response to the draft report, NNSA provides the following technical comments 
for GAO's consideration: 

1) Page 6, first full paragraph, third sentence: For accuracy, please revise the 
third sentence to read as follows: 

"However, in 2009, NNSA decided to expedite the UPF by combining the CD 2 and CD 3 
milestones, eliminating the development of the interim safety document for CD 2
(a Preliminary Safety Design Report) and focusing on the development of the 
Preliminary Documented Safety Analysis Reports to support the CD 3 deliverables." 

2) Page 6 footnote number 13: For consistency with current plans, please revise 
the footnote to read as follows: 

"UPF contractor representatives told us that they were going to develop 3 
Preliminary Documented Safety Analysis (PDSA) to support the CD 3 deliverables." 

If you have any questions regarding this response, please contact Dean Childs, 
Director, Office of Audit Coordination and Internal Affairs, at (301) 903-1341. 

Sincerely, 

Signed by: 

Cynthia A. Lersten: 
Associate Administrator for Management and Budget: 

[End of section] 

Footnotes: 

[1] NNSA owns the buildings, equipment, and the components produced at 
the Y-12 plant, but the site is operated under contract to NNSA by 
Babcock & Wilcox Technical Services Y-12, LLC (B&W), a partnership of 
the Babcock & Wilcox Company and Bechtel Corporation. 

[2] B&W is the contractor managing the UPF design and has 
subcontracted portions of the design work to four other contractors. 

[3] DOE's defense nuclear facilities are located at 13 sites, 
including 7 NNSA sites. 

[4] We have previously reported on challenges with DOE's safety 
oversight. See GAO, Hanford Waste Treatment Plant: DOE Needs to Take 
Action to Resolve Technical and Management Challenges, [hyperlink, 
http://www.gao.gov/products/GAO-13-38] (Washington, D.C.: Dec. 19, 
2012) and GAO, Modernizing the Nuclear Security Enterprise: 
Observations on DOE's and NNSA's Efforts to Enhance Oversight of 
Security, Safety, and Project and Contract Management, [hyperlink, 
http://www.gao.gov/products/GAO-13-482T] (Washington, D.C.: Mar. 13, 
2013). 

[5] The Safety Board consists of five members appointed by the 
President and confirmed by the Senate and is supported by 
approximately 100 technical, legal, and administrative staff. 

[6] The National Defense Authorization Act for Fiscal Year 2013 
renamed UPF as the Uranium Capabilities Replacement Project. NNSA uses 
the new nomenclature in its fiscal year 2014 budget request. 

[7] GAO, Nuclear Weapons: Factors Leading to Cost Increases with the 
Uranium Processing Facility, [hyperlink, 
http://www.gao.gov/products/GAO-13-686R] (Washington, D.C.: July 12, 
2013). 

[8] GAO, Government Financial Vulnerability: 14 Areas Needing Special 
Review, [hyperlink, http://www.gao.gov/products/GAO/OCG-90-1] 
(Washington, D.C.: Jan. 23, 1990). We update our high-risk list every 
2 years. 

[9] GAO, High-Risk Series: An Update, [hyperlink, 
http://www.gao.gov/products/GAO-09-271] (Washington, D.C.: January 
2009). 

[10] GAO, High-Risk Series: An Update, [hyperlink, 
http://www.gao.gov/products/GAO-13-283] (Washington, D.C.: February 
2013). 

[11] U.S. Department of Energy, Program and Project Management for the 
Acquisition of Capital Assets, DOE O 413.3B (Washington, D.C.: Nov. 
29, 2010). 

[12] A nuclear criticality accident occurs when enough fissile 
material, such as uranium, is brought together to cause a sustained 
nuclear chain reaction. The immediate result of a nuclear criticality 
accident is the production of an uncontrolled and unpredictable 
radiation source that can be lethal to people who are nearby. 

[13] UPF contractor representatives told us that they were going to 
develop two alternate safety-related documents--a preliminary hazard 
analysis and a preliminary documented safety analysis --as these 
documents were DOE's safety requirements prior to the issuance of DOE 
Standard 1189. 

[14] Of the 15 concerns identified by the Safety Board, NNSA officials 
said that the agency identified 8 similar concerns during an internal 
review of UPF safety that concluded in January 2012. In addition, NNSA 
officials told us that the agency required the UPF contractor to take 
corrective action to address 6 of these concerns. 

[15] For example, the Safety Board raised concerns about NNSA's 
methodology for analyzing fires resulting from an earthquake, and in 
response, NNSA conducted a new analysis providing additional details 
on its methodology. 

[16] For example, the Safety Board raised concerns that NNSA's project 
office is understaffed to perform effective oversight, with many 
officials sharing project management and technical oversight 
responsibilities. In response, NNSA developed a staffing plan and the 
project has recently been approved to fill an additional 10 specialist 
positions, such as fire safety engineers and criticality engineers. 

[17] According to NNSA's Associate Administrator for Acquisition and 
Project Management, the agency's approach to executing the UPF project 
is distinctly different than any other project within DOE, and is 
specifically designed to reduce the problems experienced with the 
Hanford Waste Treatment Plant and other DOE and NNSA projects. For 
example, agency officials said that the UPF is the first major project 
that is implementing DOE Standard 1189 to help ensure safety is 
adequately integrated into design. 

[18] [hyperlink, http://www.gao.gov/products/GAO-13-686R]. 

[19] U.S. Department of Energy, Program and Project Management for the 
Acquisition of Capital Assets, DOE O 413.3B (Washington, D.C.: Nov. 
29, 2010) 

[20] UPF contractor representatives told us that they were going to 
develop two alternate safety-related documents--a preliminary hazard 
analysis and a preliminary documented safety analysis--as these 
documents were DOE's prior safety requirements. 

[End of section] 

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