Over the last two years, DOE and Nuclear Waste Partnership (NWP, the prime contractor) have made efforts to strengthen the SC at the WIPP. Following are two data points we can use to infer how much progress they’ve made.
Incentive Payment to NWP
In FY2015 NWP earned a performance fee* based on both objective and subjective criteria. Overall, NWP received 85.7% of the total potential fee ($11,714K out of $13,665K.)
The objective portion comprised 75% of the total potential fee and NWP was awarded 89.7% of that amount ($9,194K). Only one objective criterion appears related to SC, viz., “reducing preventive and corrective maintenance backlogs” and NWP received the full fee possible, $550K out of $550K.
The subjective portion comprised 25% of the total potential fee and NWP was awarded 73.7% of that amount ($2,520K). There is more information about SC in this portion of the award fee determination document. DOE said NWP’s performance on improving its safety programs reflected “a maturing nuclear safety culture with continuous improvements.” However, there were signs of SC weakness in the Areas for Improvement including “The contractor did not provide sufficient objective evidence of closure of all of the corrective actions it submitted as complete in FY2015”; “The small number of self-assessments by the contractor in FY2015 was inadequate to measure performance” and “Recent improvements in the nuclear safety culture are slowly being realized in the safe execution of work . . .”
DNFSB Critique of WIPP's Upgraded Documented Safety Analysis
A recent Defense Nuclear Facilities Safety Board (DNFSB) staff report** reviews the WIPP Documented Safety Analysis (DSA) currently being updated by NWP under the oversight of DOE. The DNFSB report identifies one significant issue for DOE management attention, summarized below:
The Feb. 2014 explosion occurred because Los Alamos National Laboratory (LANL) shipped ignitable waste to WIPP even though the existing Waste Acceptance Criteria (WAC) prohibited such action. Currently, other LANL-generated drums containing potentially ignitable waste are securely stored at WIPP.
The draft DSA does not analyze the possibility that some similar accident could occur involving a container arriving at WIPP in the future. Instead, DOE and NWP argue that improvements to the WIPP WAC and/or WAC compliance program will reliably prevent problems in future waste receipts. In other words, something that happened before will not happen again because WIPP will be watching for it. For this approach to work, WAC compliance by the waste generators and WIPP inspectors must be completely effective and 100% reliable. DNFSB recommends that DOE and NWP management “explore defense-in-depth measures that enhance WIPP’s capability to detect and respond to problems caused by unexpected failures in the WAC compliance program.”
The performance fee awards indicate that NWP needs to keep working to strengthen its SC to an acceptable level.
The DSA issue is more troublesome. What kind of effective SC would blow off (pun intended) its responsibility to consider the possibility of recurrence of exactly the kind of problem that occurred before and caused the WIPP to be shut down for over two years? We criticize other organizations for over-analyzing the specifics of individual accidents while ignoring other possibilities, especially systemic issues, but in this case, NWP and DOE are not even reaching the lowest perceptible bar of repeat incident prevention.
We’ll give the DNFSB points for raising the DSA issue but take away some points because they didn’t make a straightforward recommendation that NWP and DOE complete a more thorough analysis of the specific hazard of another drum of prohibited waste slipping through the system and into the underground.
At best, we can say the SC at the WIPP is incrementally improved. DOE has always taken a half-hearted approach to SC and their lack of commitment is visible here.
* T. Shrader (DOE) to P. Breidenbach (NWP), "Contract DE-EM0001971 Nuclear Waste Partnership LLC - Award Fee Determination for the Period October 1, 2014 through September 30, 2015, and FY2015 Fee Determination Scorecard for Total Earned Award Fee and Performance Based Incentives" (April 12, 2016).
** J.L. Connery (DNFSB) to E.J. Moniz (DOE), letter with DNFSB Staff Issue Report “Waste Isolation Pilot Plant Documented Safety Analysis” dated Jan. 13, 2016 attached (Mar. 28, 2016).