[DNFSB
LETTERHEAD]
November 3, 2004
The Honorable Spencer Abraham
Secretary of Energy
1000 Independence Avenue, SW
Washington, DC 20585-1000
Dear Secretary Abraham:
In Recommendation 2000-2, Configuration Management,
Vital Safety Systems, the
Defense Nuclear Facilities Safety Board (Board) recommended a number of
measures necessary to ensure the reliable performance of safety systems. Many of these measures could be considered
part of the configuration management program for safety systems recognized by
the Department of Energy (DOE) as being essential to the safety of its nuclear
facilities. Title 10, U.S. Code of
Federal Regulations, Part 830.122 (10 CFR 830.122), Nuclear Safety
Management, Quality Assurance Criteria, and several DOE orders specifically
require various aspects of a configuration management program to ensure the
continued reliable performance of safety systems.
As
part of its
response to Recommendation 2000-2, DOE committed to having Lawrence Livermore
National Laboratory (LLNL) perform an assessment of its configuration
management program for vital safety systems. This assessment was completed in May 2003. According to the assessment report, however,
“as the estimated implementation dates for the directorate [configuration
management] programs are about 15 months to almost 6 and one-half years away, a
rigorous assessment to measure effectiveness was premature.” The report provides a cursory assessment of
the Nuclear Materials Technology Program (NMTP), the LLNL organization responsible
for the operation of the Plutonium Facility. The report states, “Because of the detailed
NMTP gap analyses, and since the NMTP [configuration management] plan and procedures
have not yet been written or revised to reflect the [Configuration Management Program
Description] requirements, the preparation of numerous detailed Opportunities
for Improvement was not warranted.”
It is not clear how the National
Nuclear Security Administration’s (NNSA) Livermore Site Office (LSO) has
reconciled the absence of an implemented configuration management program with
specific requirements such as those in 10 CFR 830.122; DOE Order 420.1A,
Facility
Safety; and
DOE Order 433.1, Maintenance
Management Program for Nuclear Facilities. Seven
months after receiving the assessment report from LLNL, LSO responded by issuing
a letter noting that LSO was “extremely concerned about the health of the
configuration management program at LLNL....” LSO
noted that the assessment report was “not as candid as it could be.” Two months after receiving LSO’s letter, LLNL
responded by making changes to the program description and identifying further
slips in the implementation of a configuration management program for LLNL’s
defense nuclear facilities.
The Board is concerned about the
apparent lack of an adequate configuration management program for the
highest-hazard nuclear facilities at LLNL. During the past few months, LLNL has reported
several occurrences involving the inadequate condition of safety systems. These include inadequate covers (tape) for
safety-class ventilation duct penetrations, potential cracking in
safety-significant ventilation duct welds, and inadequate seismic restraints for
safety-significant gloveboxes. The
failure to implement an adequate configuration management program would appear
to increase the likelihood of future occurrences involving the operation of
safety systems.
The apparent lack of urgency on
the part of both LLNL and LSO in addressing this issue concerns the Board. Therefore, pursuant to 42 U.S.C. § 2286b(d), the Board requests a report from
DOE within 60 days of receipt of this letter that addresses:
In addition, the Board would
discourage DOE from proposing closure of Recommendation 2000-2 until DOE can
demonstrate that adequate configuration management programs exist for vital
safety systems at all of its defense nuclear facilities.
Sincerely,
John T. Conway
Chairman
c: The Honorable Linton Brooks
The
Honorable Everet H. Beckner
Mr.
John Shaw
Mrs.
Camille Yuan-Soo Hoo
Mr.
Mark B. Whitaker, Jr.