[DNFSB
LETTERHEAD]
October 23, 2007
The Honorable Thomas P. D'Agostino
Administrator
National Nuclear Security Administration
Dear Mr. D'Agostino:
The
National Nuclear Security Administration's (NNSA) current plan for sustained
manufacturing of plutonium pits, essential to national security, relies on
continued operation of the 55-year-old Chemistry and Metallurgy Research (CMR)
facility at Los Alamos National Laboratory (LANL). The Defense Nuclear
Facilities Safety Board (Board) believes that continued operation of the CMR
facility in its current condition poses significant risks to workers and the
public. Given the age, material condition, nuclear material inventory, and
seismic capacity of CMR, it is important that NNSA fully understand these risks
in its continued use of the facility.
The CMR
facility is known to have serious vulnerabilities,
such as the lack of robust building confinement to prevent a release of
radioactivity during an accident. In the late 1990s, the Department of Energy
(DOE) decided to scale down a planned CMR facility upgrade project and focus on
safety system upgrades required to support safe operation until the CMR
Replacement Project was completed in 2010. This decision to abandon a complete
facility upgrade was due primarily to the identification of a seismic fault
under two wings and the susceptibility of all the wings to structural collapse
due to ground motion from a 500-year return period earthquake. While subsequent
actions were taken to reduce combustibles and
material-at-risk in the CMR facility, the safety of the facility has not been
reassessed since the governing safety basis was approved in 1998.
In a letter to the Board dated February 16, 1999, the DOE
Office of Defense Programs enclosed a copy of the "Strategy for Managing
Risks at the CMR Facility at LANL." In that document, DOE outlined
near-term and long-term actions to manage the risk at the CMR facility and continue
safe operations until 2010. It was envisioned that the
CMR Replacement Project would be completed by 2010; however, the Replacement
Project has experienced significant delays, is now nominally projected for
completion in 2016, and faces continued susceptibility to year-to-year
budgetary uncertainty. Consequently, the CMR facility will likely be required
to support pit production activities to 2016 and beyond.
The Board
understands that LANL plans to develop a CMR facility safety basis for post-2010 operations, with approval and implementation of this new safety basis in
2009. It is unlikely that this effort will eliminate or mitigate the safety
risks of operating the CMR facility beyond 2010 without significant facility
upgrades or mission changes. This timetable leaves little time for NNSA to
complete any necessary safety system upgrades or identify alternative
strategies for meeting national security priorities. As noted above, the
situation is further exacerbated by delays and
continued budgetary uncertainty afflicting the CMR Replacement Project.
Therefore,
pursuant to 42 U.S.C. 2286b(d), the Board requests
that NNSA submit within 60 days of
receipt of this letter a report and briefing providing (1) a safety rationale
for continuing the operation of CMR, and (2) a detailed schedule of NNSA's actions to assure safe operation of this facility.
Sincerely,
A. J. Eggenberger
Chairman
c: The
Honorable J. Clay Sell
Mr. Donald L. Winchell, Jr.
Mr. Mark B. Whitaker, Jr.