National Nuclear Security Administration
January 4, 2005
The Honorable John T. Conway
Defense Nuclear Facilities Safety Board
625 Indiana Avenue, N.W.
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 teamís 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 LLNLís 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 teamís findings, NNSA accepts LSOís 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 LLNLís 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 LLNLís defense nuclear facilities, will be provided to the Board following LSOís completion of their assessments and LLNLís identification of all necessary corrective actions.
Linton F. Brooks
cc: †M. Whitaker, DR-1