June 12, 2003
The Honorable Spencer Abraham
Secretary of Energy
1000 Independence Avenue, SW
Washington, DC 20585-1000
Dear Secretary Abraham:
On March 8, 2000, the Defense Nuclear Facilities Safety Board (Board) issued Recommendation 2000-2, Configuration Management, Vital Safety Systems. This recommendation called for the Department of Energy (DOE) to take steps to ensure that safety systems for defense nuclear facilities will remain reliable and effective. In particular, the Board stressed the actions required to ensure the reliability of confinement ventilation systems. The Board approved DOE’s Implementation Plan for Recommendation 2000-2 on December 14, 2000. This plan consists of 29 specific actions designed to meet the intent of the recommendation. Two of the key actions required by the plan are the performance of initial reviews of vital safety systems (Phase I assessments), followed by more detailed reviews of selected vital safety systems (Phase II assessments).
The Board’s staff observed several Phase II assessments and reviewed the reports on all completed assessments, as well as the implementation of the requirements for providing qualified federal and contractor employees cognizant of the vital safety systems. A report summarizing these reviews is enclosed for your use in assessing the progress at several DOE sites.
The Board is particularly interested in DOE’s efforts to institutionalize these assessments. In a letter dated April 7, 2003, the National Nuclear Security Administration (NNSA) provided a discussion of the processes the NNSA sites are using to institutionalize the Phase II assessments and stated that NNSA expected each site office manager to appraise the implementation of these processes. The Office of Environmental Management provided the Board with a similar discussion in a letter dated May 2, 2003. In this letter it was noted that institutionalizing these assessments would not be completed at the Rocky Flats Environmental Technology Site (RFETS). This is acceptable for RFETS; however, a systematic study should be completed before curtailing similar assessments at other closure sites.
The Board has directed its staff to continue to work with DOE on resolving the remaining issues associated with the implementation of Recommendation 2000-2 identified in the Board’s letter of September l8, 2002. Specific items that remain to be completed include:
The Board considers that implementation of Recommendation 2000-2 should result in improved configuration management and reliability of vital safety systems at defense nuclear facilities. Further, the Board believes that both DOE and NNSA must vigorously pursue the completion of this important activity. Therefore, pursuant to 42 U.S.C. § 2286b(d), the Board requests to be briefed within 6 months of receipt of this letter on the status of the following: (1) site activities to institutionalize the Phase II assessments, (2) the staffing of federal and contractor subject matter expert/systems engineer positions, (3) changes to DOE’s engineering-related functional area qualification standards, (4) issuance of the revised Nuclear Air Cleaning Handbook, and (5) actions being taken to address the common weaknesses and lessons learned identified in the enclosed report.
John T. Conway
c: The Honorable Linton Brooks
The Honorable Robert Gordon Card
The Honorable Everet H. Beckner
The Honorable Beverly Ann Cook
The Honorable Jessie Hill Roberson
Mr. Mark B. Whitaker, Jr.
DEFENSE NUCLEAR FACILITIES SAFETY BOARD
Staff Issue Report
April 24, 2003
MEMORANDUM FOR: J. K. Fortenberry, Technical Director
COPIES: Board Members
FROM: D. L. Burnfield
SUBJECT: Summary of Site Visits to Review Progress in Implementing Recommendation 2000-2, Configuration Management, Vital Safety Systems
This report documents observations resulting from visits made to four sites in the Department of Energy’s (DOE) weapons complex by members of the staff of the Defense Nuclear Facilities Safety Board (Board). The purpose of these visits was to evaluate progress made in implementing the Board’s Recommendation 2000-2, Configuration Management, Vital Safety Systems. Reviews were conducted at the Y-12 National Security Complex (Y-12), the Pantex Plant, the Hanford Site (Fluor Hanford, CH2M Hill, and Pacific Northwest National Laboratory), and Lawrence Liver-more National Laboratory (LLNL). The visits, led by D. Burnfield with J. DeLoach and outside expert D. Volgenau, were conducted during a 6-month period from July 2002 to January 2003, with follow-up discussions and documentation reviews being performed through March 2003.
Background. The Implementation Plan for Recommendation 2000-2 includes commitments to improve the competence of DOE and contractor engineering personnel, as well as to perform summary (Phase I) and detailed (Phase II) assessments of the material condition and operability of vital safety systems, including the programs that support them (e.g., maintenance and engineering). The reviews at the five DOE site offices (two at Hanford) emphasized these commitments. Specific areas evaluated included the following: (1) DOE’s subject matter expert (SME)/systems engineer programs; (2) Site contractor systems engineering programs; and (3) Phase II assessments, which included a walkdown by the staff of one or more vital safety systems at each site.
Summary. Although it appeared that, for the four sites visited, the managers of the DOE site offices and of the site contractors were actively supporting the intent of Recommendation 2000-2 and were working to implement its principles, there was a wide disparity in the effectiveness of their actions:
Detailed Observations. The following observations support the above summary comments.
DOE’s SME/Systems Engineer Programs―As noted, this area remains weak at all of the site offices visited, and the intended benefits in terms of contractor oversight remain to be fully realized. All of the DOE site offices had established SME/system engineer organizations; however, a program had been developed, recently promulgated, and implemented only at the Y-12 and LLNL site offices. The Pantex Site Office (PXSO), DOE-Richland Operations Office (DOE-RL), and the Office of River Protection had yet to fully establish effective SME/systems engineer programs. Common weaknesses noted in the existing programs included the following:
Contractors’ Systems Engineering Programs―As noted, the Board’s staff observed a wide disparity in the effectiveness of the site contractors’ systems engineering programs. Both BWXT at Y-12 and CH2M Hill at the Hanford tank farms had implemented well-founded and robust systems engineering programs. These programs are maturing. The contractors appeared to be cognizant of the areas requiring further emphasis and enhancement and were working aggressively to improve their programs and to increase the staffing to allow adequate coverage of all vital safety systems. The programs at the remaining sites suffered from a number of shortcomings and were much less effective; several required increased staffing. Each could benefit from the lessons learned at Y-12 and the Hanford tank farms. The staff observed that the contractors for the other Hanford Site projects and the environmental management facilities at LLNL had particularly weak systems engineer programs. The following are examples of common weaknesses noted in these contractors’ systems engineer programs:
The two contractors with strong systems engineer programs demonstrated some common strengths, such as the following:
The best of the material assessments included specific requirements to note conditions, ensure that deficiencies were corrected, and trend important parameters to identify degradation.
Phase II Assessments―Each of the visited sites has scheduled or completed its Phase II assessments. All of the site contractors believed they were making progress toward institutionalizing the principles of Recommendation 2000-2; however, some were found to be doing better than others in this regard. The contractors for Y-12 and the Hanford tank farms had been the most aggressive in accepting and working to correct the areas for improvement noted in the Phase II assessments. None of the sites had fully institutionalized a process for conducting Phase II-like assessments. The contractors for some of the sites, such as Hanford, were examining how such a process might be incorporated into existing assessment processes. Other sites, such as LLNL, had not yet given this area much consideration.
The Board’s staff reviewed system drawings and then conducted a walkdown of one or more vital safety systems together with representatives of DOE and the contractors during each of the site visits. In general, both the federal and contractor systems engineers demonstrated good knowledge of their systems, and each system’s material condition appeared to indicate that it was being maintained adequately. A common weakness noted was a lack of understanding on the part of systems engineers of how to properly assess the material condition of their system(s).
A review of the Phase II assessments completed at Y-12 and subsequent discussions with site personnel revealed some lessons learned that ought to be considered for applicability across the DOE weapons complex: