July 30, 2007
The Honorable Samuel W. Bodman
Secretary of Energy
1000 Independence Avenue, SW
Washington, DC 20585-1000
Dear Secretary Bodman:
The prevention and mitigation of potential accidents inherent in the mission activities at defense nuclear facilities is a fundamental objective that requires the Department of Energy (DOE) and its contractors to identify accident scenarios and then establish effective and reliable safety controls to address them. Engineered controls are preferred over administrative controls because, in general, engineered controls are considered to be more reliable and effective than administrative controls. At times, administrative controls will be required to perform specific safety functions. Examples of administrative controls include discrete operator actions, or programmatic controls such as combustible loading programs (associated with fire protection programs), operator training programs, and inservice inspection programs.
Observations relevant to the development and implementation of administrative controls in the DOE defense nuclear complex were the basis for the Defense Nuclear Facilities Safety Board’s (Board) Recommendation 2002-3, Requirements for the Design, Implementation, and Maintenance of Administrative Controls. On January 3, 2007, DOE informed the Board that all of its actions and commitments associated with the Implementation Plan for Recommendation 2002-3 had been completed and proposed that the Recommendation be closed. In a letter dated January 22, 2007, the Board acknowledged the progress made by DOE in response to the Recommendation, and indicated that the Board’s staff would conduct field reviews of a representative sample of defense nuclear facilities to independently assess the adequacy and effectiveness of DOE’s efforts in implementing the Recommendation before reaching a decision on closure. Based on those field reviews, the Board has determined that Recommendation 2002-3 must remain open.
The results of the staff’s reviews, which is enclosed with this letter, indicate that a number of systemic weaknesses exist in the Recommendation implementation across the defense nuclear complex. Examples of these include, but are not limited to, deficiencies in developing programs to ensure (1) the long-term effectiveness of specific administrative controls and (2) the appropriate classification of critical supports systems for specific administrative controls. Further, it appears that a number of major defense nuclear facilities have not yet fully implemented the Recommendation. Moreover, the Board is concerned that DOE audits and self-assessments, as specified in Commitment 4.7 of the Implementation Plan to assess the overall effectiveness of the program, were ineffective in identifying the implementation issues cited in the enclosed report.
Therefore, pursuant to 42 U.S.C. § 2286b(d), the Board requests a briefing within 45 days of receipt of this letter describing the specific actions DOE will take to further ensure the implementation of Recommendation 2002-3 in the field.
A. J. Eggenberger
c: The Honorable J. Clay Sell
The Honorable James A. Rispoli
The Honorable Thomas P. D'Agostino
Mr. Mark B. Whitaker, Jr.
DEFENSE NUCLEAR FACILITIES SAFETY BOARD
Staff Issue Report
June 22, 2007
MEMORANDUM FOR: J. K. Fortenberry
COPIES: Board Members
FROM: J. L. Shackelford
SUBJECT: Review of the Implementation of Recommendation 2002-3, Requirements for the Design, Implementation, and Maintenance of Administrative Controls
This report documents a series of reviews of the Department of Energy’s (DOE) implementation of the Defense Nuclear Facilities Safety Board’s (Board) Recommendation 2002-3, Requirements for the Design, Implementation, and Maintenance of Administrative Controls, at selected facilities in the defense nuclear complex.
Background. On December 11, 2002, the Board issued Recommendation 2002-3 to DOE, which DOE accepted on January 31, 2003. On June 26, 2003, DOE issued an Implementation Plan for the Recommendation. Subsequently, DOE issued a letter, dated January 4, 2007, informing the Board that all of the commitments in the Implementation Plan had been completed and proposing that the Recommendation be closed. On January 22, 2007, the Board responded to DOE’s request for closure. The Board acknowledged that progress had been made in response to the issues addressed by the Recommendation. However, the Board indicated that its staff would conduct field reviews of a representative sample of defense nuclear facilities to independently assess the adequacy and effectiveness of DOE’s efforts in implementing the Recommendation before reaching a decision on closure. The results of the staff’s reviews are summarized below.
Review of the Implementation of Recommendation 2002-3 at Selected Defense Nuclear Facilities. The central element of DOE’s response to the Board’s Recommendation dealing with administrative controls was the development of the concept of a specific administrative control (SAC). In general terms, a SAC is an administrative control that would be categorized as either safety-significant or safety-class if the function it served were implemented through an engineered structure, system, or component. The staff reviewed the policies, programs, and processes for the development and implementation of SACs at the Pantex Plant, Savannah River Site (SRS), and Y-12 National Security Complex. These reviews encompassed an assessment of the general process for developing SACs, including how the hazard and accident analysis processes flowed into the development of SACs. The reviews also focused on the activities associated with procedure development, training and qualification, assessment of the adequacy of SACs, implementation of SACs, and root-cause assessments and lessons-learned efforts associated with identified weaknesses in SACs. The staff selected a number of SACs for detailed evaluation and assessment to determine whether all of the expectations and requirements embodied in the Board’s Recommendation were being met. The staff also assessed the respective DOE Site Office’s oversight of SACs.
At each of the sites reviewed, the staff found that the contractor had formulated and implemented a systematic process for the development of safety bases that addressed the guidance and requirements associated with SACs as defined in DOE Standard 3009, Preparation Guide for U.S. Department of Energy Nonreactor Nuclear Facility Documented Safety Analyses, Change Notice 3, and DOE Standard 1186, Specific Administrative Controls. At the same time, however, the staff noted a number of weaknesses in the implementation of the Recommendation. Examples of these weaknesses are summarized below.
Savannah River Site
Y-12 National Security Complex
Summary. Although considerable progress had been made toward addressing the issues outlined in Recommendation 2002-3, the staff’s review found that significant and apparently systemic weaknesses existed in the implementation of Recommendation 2002-3 across the defense nuclear complex. While each of the facilities reviewed had developed a systematic process for the development of safety bases that addressed the guidance and requirements defined in DOE Standard 3009 and DOE Standard 1186 for SACs, the Board’s staff observed numerous weaknesses in the Recommendation’s implementation suggesting additional efforts would be necessary to fully realize the benefits envisioned by the Board. These included weaknesses in developing programs to ensure the long-term effectiveness of SACs, providing the specificity and level of detail necessary to accomplish the desired safety objectives of SACs, ensuring that critical support systems for SACs are appropriately classified, specifying the need for independent or concurrent verification, and inappropriately crediting safety management programs in lieu of SACs or engineered controls. Further, the Board’s staff observed that a number of major defense nuclear facilities had not yet fully implemented the Recommendation.
In response to the staff’s observations and findings, a number of corrective actions have been taken at the facilities that were reviewed to address many of the identified deficiencies. The staff is concerned that DOE and contractor audits and self-assessments had not identified the deficiencies observed by the Board’s staff.
Commitment 4.7 of the Implementation Plan indicated that DOE would evaluate the overall success of the effectiveness of the implementation of the Recommendation. In its letter of January 4, 2007, DOE informed the Board that all of the commitments in the Implementation Plan had been completed and proposed that the Recommendation be closed. The staff’s observations show that DOE’s review was not effective in identifying the weaknesses, deficiencies, and incompleteness of the Recommendation’s implementation, and that additional effort and attention in this area is warranted before the Recommendation can be closed.