“The DOE-issued Preliminary Notice of Violation (PNOV) describes examples of the numerous violations of DOE nuclear safety requirements [by Fluor Hanford Inc. (FHI)] that occurred during the design and construction of the [Sludge and Water System (SWS)]. Specifically, violations were identified in the following areas: (1) management processes/personnel training and qualification—the failure by FHI management to establish integrated schedules and ensure adequately trained and qualified personnel were assigned to supervise and perform the work; (2) quality improvement—the failure to ensure that corrective actions from a prior enforcement action and Compliance Order were effective in preventing the recurrence of quality problems, and the failure to identify and correct deficiencies at SWS that occurred over a long period of time; (3) design—significant design deficiencies with the as-built SWS that, in some cases, would have rendered safety-significant equipment and instrumentation incapable of performing their safety function