[DOE LETTERHEAD]
National
Nuclear Security Administration
January 4, 2005
The Honorable John T. Conway
Chairman
Defense Nuclear Facilities
Safety Board
625 Indiana Avenue, N.W.
Suite 700
Washington, D.C. 20004
Dear Mr. Chairman:
The Secretary has requested that
I forward this interim response to your November 3, 2004, letter regarding the
implementation status of Recommendation 2000-2, Configuration Management,
Vital Safety Systems, at
the Lawrence Livermore National Laboratory (LLNL). Your letter noted several occurrences
involving the inadequate condition of safety systems, including covers (tape)
for safety-class ventilation duct penetrations, potential cracking in
safety-significant ventilation duct welds, and inadequate seismic restraints
for safety-significant gloveboxes. Specifically, you requested from DOE a report
within 60 days that addresses:
The Livermore Site Office (LSO)
chartered a review team to evaluate the institutional application of
configuration management within Building 332, including specific vital safety
system reviews. The review team
performed document reviews, walkdowns of specific Building 332 vital safety
systems, and held discussions with systems engineers, facility and operations
personnel, and safety basis personnel.
The review team’s enclosed
report addresses the specific actions taken or compensatory measures
implemented to address the condition of the safety systems noted in your letter.
In addition, the report identifies or
confirms serious vulnerabilities in the configuration management program at the
institutional level and in the majority of the reviewed vital safety systems
within Building 332. The enclosed LSO
report concludes that configuration management is not complete or effective
within Building 332. In addition, the
team noted that the commitment to institutionalize the DOE Phase II assessments
in response to DNFSB Recommendation 2000-2 has not been satisfied, and there
are no institutional assessments of vital safety systems being performed in
LLNL’s defense nuclear facilities.
Regarding the potentially
cracked ducting in Building 332, LSO will direct LLNL to perform
non-destructive testing as necessary to verify the existence of cracks. If testing confirms the presence of cracks in
the ducting, LLNL will follow the unreviewed safety question determination
process.
Based on the team’s findings, NNSA
accepts LSO’s
recommendation to expedite performance of comprehensive Phase II assessments
for all vital safety systems in Building 332, with first priority on the fire
suppression system and gloveboxes. In addition,
NNSA agrees that LSO will work jointly with LLNL to reassess LLNL’s institutional
configuration management program, consistent with relevant Phase II assessment
guidance.
LSO will provide its Building
332 assessment results to LLNL by January 3, 2005. LLNL has been directed to submit a
resource-loaded corrective action plan for Building 332 to LSO by March 3, 2005.
NNSA has directed LSO to complete the
remaining vital safety system reviews no later than March 2005. Subsequently, LLNL corrective action plans
will be submitted to LSO within 60 days after receipt of subject assessments. Upon completion of all LSO assessments and
LLNL corrective action plans, LSO will direct LLNL to develop a comprehensive
resource loaded schedule for a fully implemented configuration management
program for the defense nuclear facilities.
I share your concern regarding
the adequacy of the configuration management program in Building 332. A full response to your letter, including the resource loaded
schedule for implementing a configuration management program for vital safety
systems at LLNL’s defense nuclear facilities, will be provided to the Board
following LSO’s completion of their assessments and LLNL’s identification of
all necessary corrective actions.
Sincerely,
Linton F. Brooks
Administrator
cc: M. Whitaker, DR-1