May 6, 2008
The Honorable A. J. Eggenberger
Defense Nuclear Facilities Safety Board
This is in response to your letter to me dated March 5, 2008. I appreciate the Defense Nuclear Facilities Safety Board's (DNFSB) comments regarding the Radioactive Liquid Waste Treatment Facility (RLWTF) Upgrade Project at Los Alamos National Laboratory (LANL). I am committed to the development of a more robust preliminary design and safety basis for this project, and I intend to use your recent review to help guide the needed improvements. I will also be relying on the resolution of comments from the integrated project teams (IPT) on the preliminary design to correct and improve the preliminary design for the project. Over half of the issues raised in the report enclosed with your letter were previously identified by the Los Alamos Site Office (LASO) and LANL IPTs.
Your letter noted that the integration of safety with design is weak for the RLWTF Upgrade Project. During the revised Preliminary Design for this project, expected to be completed in Fiscal Year 2008, a gap analysis will be performed between the recently approved DOE-STD-1189, Integration of Safety into the Design Process, and current project plans. The results of this gap analysis will be used to determine which portions of DOE-STD-1189 will be adopted for the project. In addition, appropriate LANL procedures will be revised to address: 1) change control of design inputs during the design life cycle of a project; and 2) traceability of functional and operational requirements and design criteria to approved design documents. The proper application of these new requirements to the RLWTF Upgrade Project will be validated through the design review process, as well as LANL and NNSA Readiness to Execute Reviews and the DOE External Independent Review.
Your second major item of concern is that Federal oversight of the project through the IPT is weak. LASO recently created two new job positions for subject matter experts (SMEs) that, when filled, will be assigned to the Project Management Team as IPT members for the RLWTF Upgrade Project. One will be assigned to focus on commissioning, startup, and transition to operations for the project and the other will be dedicated to safety system oversight for design activities. In addition, LASO is providing immediate additional support to the RLWTF Upgrade Project Federal Project Director (FPD) by assigning two LASO FPDs on a part-time basis, with one providing oversight of the integration of safety in design, and the other providing oversight of the Zero Liquid Discharge Subproject and development and implementation of NQA-I, Quality Assurance Requirements for Nuclear Facility Applications. Also, LASO will revise the Monthly Project Watchlist process to include IPT member participation and strengthen senior management attention. I have directed Jim McConnell from the Office of Nuclear Safety and Operations to provide technical support to LASO as needed to strengthen Federal oversight of the revised preliminary design and corresponding safety basis.
Regarding the seismic design requirements for the RLWTF Upgrade Project, a preliminary Natural Phenomena Hazard (NPH) Performance Category (PC) of PC-2 has been determined for the project. This determination was made in accordance with the requirements of DOE Order 420.lB, Facility Safety, its implementation guides, and the accompanying DOE-STD-1021, Natural Phenomena Hazards Performance Categorization Guidelines for Structures, Systems, and Components. The NPH Performance Category for the project and safety structures, systems, and components will be revalidated during the revised Preliminary Design.
LASO and LANL reviewed the issues in the enclosure to your letter to identify the direct and contributing factors that led to the issues and identified actions to correct these factors. The enclosure to this letter describes further actions that LASO and LANL will take to address the root causes of the issues. Following the completion of the revised Preliminary Design for the RLWTF Upgrade Project, a report will be issued that will document lessons learned to be applied to other design and construction projects at LANL. Several of the actions in the enclosure are broadly applicable to design and construction projects at LANL.
I value the DNFSB's ongoing participation in the review of the RLWTF Upgrade Project. As requested in your letter, a briefing on the issues associated with the RLWTF Upgrade Project will be scheduled shortly. If you have any questions, please contact me or Mr. Donald Winchell, Jr., the LASO Revitalization Manager.
Robert L. Smolen
for Defense Programs
cc: Mr. Donald L. Winchell, Jr., LASO
Mr. Mark B. Whitaker, Jr., HS-1.1