March 25, 2008
The Honorable A. J. Eggenberger
Defense Nuclear Facilities Safety Board
625 Indiana Avenue, NW, Suite 700
Washington, D.C. 20004-2901
Dear Mr. Chairman:
On December 21, 2007, I requested a 90-day extension to respond to your October 23, 2007, letter that included a 60-day reporting requirement to provide a safety rationale for continuing the operation of the Chemistry and Metallurgy Research (CMR) Building at the Los Alamos National Laboratory (LANL), as well as a detailed schedule of the National Nuclear Security Administration (NNSA) actions to assure safe operation of this facility. This letter provides a summary of actions to date and planned actions that support the safe operation of the CMR Building. The enclosure to this letter provides further details on the completed and planned actions.
The safety rationale for continued operation of the CMR Building will be included in the new CMK Documented Safety Analysis (DSA), currently planned to be submitted to the NNSA Los Alamos Site Office (LASO) for approval in February 2009. In the interim, LASO has completed an assessment of the location, quantity, and condition of all special nuclear material (SNM) within the CMR Building with the objective of validating the reduced SNM levels in the facility. LASO formally requested LANL to address the recommendations from the assessment report. Also, LANL submitted revised Interim Technical Safety Requirements (ITSRs) for the CMR Building in February 2008. Following LASO approval and implementation by LANL, LASO will validate the implementation of these ITSRs. LANL has also started several initiatives reviewing the condition of CMR safety systems that will provide input to the CMR Life Extension Program.
With regard to the schedule for NNSA actions to assure safe operation, LASO is planning on approval of the ITSRs by April 2008. As stated previously, the CMR DSA will be submitted to LASO in February 2009. LANL will conduct safety system assessments for safety class systems identified in the ITSRs in 2008 with completion in 2010 of the assessments for all safety systems identified in the CMR DSA. LASO is developing an oversight plan for CMR that will include oversight of ITSR implementation and LANL safety system assessments, as well as LASO safety system reviews. This LASO CMR oversight plan will be issued shortly after the development by LANL of the validation schedule for the ITSRs. As described in my March 11, 2008, letter to you about the safety of nuclear operations at LANL, NNSA Headquarters will conduct an on-site assessment of LANL safety systems as part of its Fiscal Year 2009 oversight plan, including a sample of safety systems at CMR.
In May 2008, LASO and LANL will hold an Integrated Nuclear Planning (INP) Workshop to discuss programmatic needs, associated material at risk, and operations and alternative analyses for the CMR Building. Information from ongoing LANL activities and assessments and the results of the INP Workshop will enable NNSA to better address the concerns of the Defense Nuclear Facilities Safety Board (DNFSB). NNSA will provide to the DNFSB by September 1, 2008, a long-term schedule of actions related to the continued operation of the CMR Building, including submittal of the DSA for the CMR Building, which will complete NNSA's response to the DNFSB on this subject.
As requested in your letter, a briefing on the issues associated with the continued operation of the CMR Building has been scheduled for April 10, 2008. If you have any questions, please contact me or Michael Thompson at (202) 586-6058.
Thomas P. D'Agostino
cc: M. Whitaker, HS-1.1