[DOE LETTERHEAD]
March 11, 2008
The Honorable A. J. Eggenberger
Chairman
Defense Nuclear Facilities Safety Board
Dear Mr. Chairman:
This is in response to your October 16, 2007, letter that provided a 60-day reporting
requirement to address your concerns about the safety of nuclear operations at the Los
Alamos National Laboratory (LANL). Specifically, your letter requested a report on the
actions the National Nuclear Security Administration (NNSA) has taken to (1) facilitate
timely and effective implementation of ongoing safety improvement initiatives for
nuclear operations; (2) rapidly increase confidence in safety systems currently relied
upon in operating nuclear facilities; and, (3) improve the Federal oversight of safety
systems at LANL. On December 21, 2007, I requested additional time to respond to your
letter in order to provide a more comprehensive and informative description of the status
of safety improvements at LANL, and to ensure appropriate actions throughout the chain
of command to improve Federal oversight.
Ongoing Safety Improvements. NNSA has taken a number of steps to facilitate the
timely and effective implementation of ongoing safety improvement initiatives for
nuclear operations at LANL. On January 23-24, 2008, the Principal Deputy
Administrator convened a meeting of senior managers from LANL, Los Alamos Site
Office (LASO), the Office of the Deputy Administrator for Defense Programs (NA-10),
and the Office of the Chief, Defense Nuclear Safety (CDNS). During this meeting,
NNSA and LANL senior managers reviewed the status of a wide range of safety
improvements in progress at LANL and identified near-term priority actions for safety
improvements. LANL management committed to complete Nuclear Facility
Documented Safety Analyses (DSA) per the schedules established with LASO and to
implement aggressively the approved DSA and Technical Safety Requirements (TSR).
LANL senior managers also committed to complete improvements in Formality of
Operations including increasing Cognizant System Engineer staffing. The LASO Deputy
Manager committed to conduct a detailed review of Material at Risk at the Chemistry and
Metallurgy Research (CMR) facility, oversee Formality of Operations improvements, and
work closely with LANL to quickly review and approve updated TSR for CMR. NNSA
Headquarters has prioritized the support of LASO resource requirements necessary for
improvement of Federal oversight and implementation of safety improvement initiatives.
Confidence in Safety Systems. Following receipt of your October 16, 2007, letter,
LASO directed LANL to evaluate specific safety system issues identified by the Defense
Nuclear Facilities Safety Board (DNFSB) staff and to make an initial operability
determination for the affected systems. In response, LANL determined that, in the near
term, the affected systems identified in your October 16, 2007, letter meet their
operability requirements for normal and abnormal conditions. LASO has reviewed
LANL’s evaluation and agrees that the issues identified by the DNFSB staff do not
indicate immediate concerns with system performance. The issues raised in your letter
do have the potential to impact future operability of these systems, however, and LANL
has initiated specific actions to address these issues. In addition, as part of its Fiscal Year
(FY) 2009 oversight plan, NA-10, with support from the CDNS and the NNSA Service
Center, will conduct an on-site assessment for a sample of the vital safety systems at
LANL. This assessment will allow NNSA to validate the effectiveness of the LANL
vital safety system assessment program, the efficacy of actions taken to address the
specific issues raised in your letter, and the effectiveness of LASO safety system
oversight programs.
NNSA continues to agree with the DNFSB that multiyear improvement initiatives are
necessary to provide long-term solutions to safety issues at LANL. As you noted in your
letter, NNSA and LANL have initiated a number of long-term programs to increase
confidence in safety systems currently relied upon in operating nuclear facilities at
LANL. NNSA continues to place strong emphasis on these actions, particularly the
implementation of the Safety Basis Improvement Plan and the Formality of Operations
Program developed by LANL. Although much work remains, LANL has made
substantial progress in their Formality of Operations implementation plans, reporting
completion for 411 of 766 milestones at the end of 2007, with all milestones under
formal change control and status reported quarterly.
NA- 10 has also taken action this Fiscal Year (FY) to incentivize improved safety
performance at LANL. NA-10 worked closely with LASO to approve specific contractor
performance incentives in FY 2008 for completion of safety system assessments for all
Safety Class systems, with a stretch goal for operational awareness oversight of
Formality of Operations implementation. During the January 23-24 meeting, the
Principal Deputy Administrator and NA-10 conveyed senior leadership's sense of
urgency for achieving safety improvements as soon as practicable.
Improvements in Federal Oversight. Regarding Federal oversight improvements, one
of my six Special Focus Areas for NNSA regards improving Federal oversight of nuclear
safety, physical security, and cyber security. I have tasked the CDNS to ensure the
overall effectiveness of the interface between Federal oversight and contractor assurance
for nuclear safety. The CDNS is working with other NNSA organizations to finalize
specific requirements for nuclear safety oversight, including assessment programs by Site
Offices and Headquarters. These requirements, including expectations for how oversight
may be tailored based on validated contractor assurance system information, will be
reflected in an NNSA supplemental directive on Line Oversight and Contractor
Assurance.
In addition, a recent CDNS review of NA-10 nuclear safety management performance
noted several management concerns, including a lack of well-defined and documented
Headquarters roles and responsibilities for nuclear safety and resource gaps in nuclear
safety oversight. To address identified Headquarters nuclear safety issues, NA-10 is
undergoing a detailed functional analysis of all offices and considering options to realign
existing NNSA technical capabilities to strengthen line management capability in nuclear
safety oversight.
Recent LASO Federal oversight improvements include authorization for two additional
positions to perform safety system oversight functions. In FY 2008, LASO will improve
oversight of conduct of maintenance at the activity level, with focus on evaluating the
system operability and integration and involvement of LANL system engineers. In
addition, LASO is developing formal expectations for improved Federal oversight of the
Formality of Operations Program, with plans to evaluate operability of safety systems
through routine operational awareness activities and surveillances. The scheduling and
performance of formal assessments will be documented in the LASO FY 2008 integrated
assessment schedule. Updates on LASO corrective actions will be promulgated quarterly
to NNSA senior management.
As you know, LASO has experienced difficulty in acquiring and assigning the necessary
resources to improve LASO oversight programs. To ensure adequate technical support
while
these resource issues are being resolved, the
provide
dedicated support to LASO. In 2007, the
Technical Services dedicated over 40 percent of available environmental, safety and
health staff to support LASO safety capabilities, and that level of support is expected to
continue until LASO is fully staffed to execute assigned safety functions.
Summary. NNSA agrees that the findings and observations of the DNFSB staff indicate
the need to focus senior management and available technical resources at Headquarters,
LASO, and LANL on implementation of programs that result in safety system
performance improvements at the floor level in LANL nuclear facilities. NNSA believes
that efforts underway by LANL, coupled with the actions summarized above and
complimented by Federal oversight process improvements and priority resource
allocations, will result in near-term measurable improvements in nuclear facility
operations needed to build the foundation for continuous improvements in the long term.
I have asked the Deputy Administrator for Defense Programs to work with you to
schedule a briefing per your request. If you have any questions, please contact me or
Michael Thompson at (202) 586-6058.
Sincerely,
Thomas
P. D'Agostino
Administrator