[DNFSB LETTERHEAD]
March 18, 2003
The Honorable Linton Brooks
Acting Administrator
of the National Nuclear Security
Administration
U.S. Department of Energy
1000 Independence Avenue, SW
Washington, DC 20585-0701
Dear Ambassador Brooks:
The Defense Nuclear Facilities Safety Board
(Board) recently observed the National Nuclear Security Administration’s (NNSA)
readiness assessment of the implementation of controls from the Fire
Protection Basis for Interim Operation (FP BIO) at the Pantex Plant. A report on the staff’s observations is
enclosed for your information and use, as appropriate. The FP BIO and its implementation are
commitments to the Board under the Department of Energy’s (DOE) Implementation
Plan for Recommendation 98-2, Safety Management at the Pantex Plant. If implemented properly, the controls in the
FP BIO represent a significant enhancement to the safety of Pantex
operations. However, the NNSA
assessment team concluded that the FP BIO controls had not been implemented
properly.
NNSA’s contractor, BWXT Pantex, took
immediate action to address the ineffective implementation of combustible
loading controls for the W79 and W87 programs.
Recent observations by the Board’s staff verified improvement in the
implementation of these controls. Much
of this improvement resulted from a change in implementation philosophy to a
simpler, more conservative approach.
The Board is encouraged by this
improvement. However, the findings from
the readiness assessment highlight the problems that accrue from the
ever-increasing use of administrative controls. The Board continues to be concerned about the effectiveness and
reliability of administrative control programs within the DOE’s defense nuclear
complex. The generation of new safety
bases in the near future is expected to complicate the set of administrative
controls still further. Board
Recommendation 2002-3, Requirements for the Design, Implementation and
Maintenance of Administrative Controls state that, as a minimum,
administrative controls should have attributes that ensure effectiveness and
reliability. The Board understands BWXT
has a program underway to simplify and integrate controls for the current
safety basis and planned safety basis upgrades. As one aspect of the implementation of Recommendation 2002-3, the
Board encourages BWXT to pursue this effort vigorously. Other DOE defense nuclear sites might
benefit from a similar program.
NNSA’s readiness assessment of the
implementation of fire protection controls was essential to identifying significant
safety issues and improving the implementation of important safety
controls. NNSA’s Pantex Site Office is
to be commended for its decision to perform an independent validation of the
implementation of new safety basis documents at the Pantex Plant. As DOE sites continue to develop new safety
basis documents in compliance with 10 Code of Federal Regulations 830, Nuclear
Safety Management, it might be appropriate to require similar,
appropriately tailored assessments to independently validate the implementation
of controls identified in those documents, particularly where those controls
differ significantly from the controls currently in place. Even when ongoing operations do not change,
the controls relied upon to ensure the safety of those operations are often
modified, expanded, or relied upon to perform new safety functions.
Despite the ability of the Pantex Site
Office team to identify significant problems with the implementation of fire
protection safety controls, as noted in the enclosed report, the Board’s staff
noted several issues with regard to the performance of this review. The ability to conduct thorough readiness
reviews takes on added importance in view of the recent reorganization in which
the site offices have been given more responsibility for conducting readiness
assessments without additional resources with which to conduct those
reviews. In order to maintain the rigor
of readiness reviews at an appropriate level, NNSA should reevaluate its
readiness process, especially with regard to the pertinent expertise,
experience and availability of readiness assessment team members. The findings of the NNSA readiness
assessment team also indicate deficiencies in the BWXT process.
Sincerely,
John T. Conway
Chairman
c:
The Honorable Beverly Ann Cook
The Honorable Everet H. Beckner
Mr. Daniel E. Glenn
Mr. Mark B. Whitaker, Jr.
Enclosure
DEFENSE
NUCLEAR FACILITIES SAFETY BOARD
Staff Issue Report
March 3,
2003
MEMORANDUM FOR: J.
K. Fortenberry, Technical Director
COPIES: Board
Members
FROM: R.
Rauch
SUBJECT: Implementation
of Fire Protection Controls at the Pantex Plant
This report documents observations made by
the staff of the Defense Nuclear Facilities Safety Board (Board) of the National Nuclear
Security Administration’s (NNSA) readiness assessment (RA) of the
implementation of controls from the Fire Protection Basis for Interim
Operation (FP BIO) for individual weapon programs and special-purpose
facilities. Staff member R. Rauch and
outside expert R. West observed the RA on December 9–13 and December 16–19, 2002.
Staff members J. Deplitch and A. Matteucci and outside experts L. McGrew
and R. West observed the implementation of combustible loading controls for W79
and W87 operations on January 7–9,2003.
Background. The
FP BIO evaluates fire-related accident scenarios for nuclear facilities at the
Pantex Plant and identifies the controls necessary to ensure the safety of
nuclear operations in those facilities.
These controls, as defined in the Technical Safety Requirements for
Pantex Facilities (TSRs); encompass fire detection and suppression systems
(including surveillance requirements), facility structural requirements and
other design features; and administrative controls in such areas as combustible
loading and fire department response.
These controls are supplemented by controls developed in a combustible
(material) loading disposition (CLD) document for each weapon program that
define the allowed material and required locations of combustibles to ensure
that timely operation of the deluge suppression systems can protect the
facility. The development,
implementation, and assessment of the FP BIO controls are commitments to the
Board under Recommendation 98-2, Safety Management at the Pantex Plant.
The Pantex Plant contractor (BWXT)
implemented controls in the FP BIO in three phases. Each phase was followed by a contractor RA to determine whether
the controls had been effectively implemented.
Phase I involved seven site-wide administrative controls. Phases II and III consisted of specific
engineered and administrative controls for weapon programs, transportation,
staging, and nuclear material operations.
The Pantex Site Office (PXSO) completed the NNSA RA for Phase I controls
in March 2002. PXSO conducted its RA
for Phases II and III in December 2002, after BWXT had made the controls
applicable in the TSRs.
Implementation of Fire Protection Controls. To
assess the implementation of fire protection controls, the PXSO RA team leader
elected to sample three weapon programs (W79, W87, and W88) and associated
special-purpose facilities. The team
identified 2 pre-start and 19 post-start findings. The RA report noted that the team “was unable to conclude that
BWXT had successfully implemented the [FP BIO] Phase II and III controls due to
the number and type of issues identified in the RA and the limited sampling of
active programs.” The RA team found the
fire protection controls on the W79 and W87 programs “to be poorly implemented,”
whereas the implementation of controls for the W88 program met
expectations. The RA team also
expressed concern regarding the accountability of line management for
readiness.
Complexity of Combustible Loading Controls―The deficiencies noted in implementation of the administrative controls
related to combustible loading appear, in part, to be due to the number of
controls and their promulgation by means of numerous directives. The TSR and CLD controls are incorporated
into plant standards, procedures, and general requirements documents for action
by operational and support personnel.
Questions about definitions of allowable combustible materials and the
multiplicity of directives used for issuing controls complicate the controls’
implementation. The following are
examples of problems noted with the flowdown and interpretation of controls:
Some weapon programs chose to interpret
these requirements in a conservative but simplified manner, and prohibited any
transient or not-in-use combustibles in a facility unless they were
containerized or in contact with personnel.
These programs (e.g., WSS) appear to have been successful at
implementation of controls. Other
weapon programs (e.g., W79 and W87) left interpretation of the controls in the
TSRs and various documents to the production technicians. While this approach allowed more flexibility
with regard to the types and locations of combustibles used in the facilities,
the result was ineffective implementation of controls.
This issue was addressed in letters from the
Board dated February 27 and June 21, 200l. The initial letter described some combustible loading controls as
burdensome. The June 21, 2001, letter
then pointed to the benefits of streamlining these controls, including reducing
training requirements, improving efficiency, and further improving overall
safety by decreasing the chances for human error. The Board’s Recommendation 2002-3, Requirements for the Design,
Implementation and Maintenance of Administrative
Controls, also discusses the importance of effective and reliable
administrative controls. The methods
chosen by some program managers to implement administrative combustible loading
controls ultimately compromised the effectiveness and reliability of these
controls.
Following the NNSA RA, BWXT took action to
address the implementation of combustible loading controls for the W79 and W87
programs. On a subsequent visit, the Board’s
staff noted marked improvement in the adherence of production technicians to
combustible loading controls, especially on the W87 program. This improvement resulted from a change in
the approach for implementing controls to the more restrictive yet simplified
approach used by the W88 program. This
rapid response to deficiencies identified during the FP BIO RA is
encouraging. As discussed in the
Board’s letters, additional action is needed to reduce the continuing and
potentially increasing burden of numerous administrative controls and improve
their implementation, thereby providing the necessary reliability and
effectiveness for these safety controls.
RA Processes―PXSO decided to validate implementation of
the FP BIO controls through the RA process, and intends to use this process to
verify the implementation of controls resulting from the safety documents being
developed under Title 10 of Code of Federal Regulations Part 830, Nuclear Safety Management. The number of problems
identified by the RAs indicates this approach is warranted any time significant
new or modified controls are implemented.
Despite the number of issues identified during the RA, deficiencies were
noted with the readiness process:
Conclusions. The
controls in the FP BIO are a significant enhancement to the safety of nuclear
operations at the Pantex Plant. The
effectiveness of the deluge systems in protecting against postulated accident
scenarios depends on administrative controls to limit the amounts and locations
of combustibles. As discussed in the
Board’s Recommendation 2002-3, it is important that these administrative
controls be effective and reliable.
This was not the case for the FP BIO controls in two of three programs
reviewed. Subsequently, BWXT improved
the control on combustible materials for these two programs in response to the
NNSA RA findings.
The generation of new safety bases in the
near future is expected to complicate the set of administrative controls still
further. An effort needs to be made to
simplify and integrate the controls for the current safety basis and planned
safety program upgrades to provide assurance of continued implementation of all
controls. It may be noted that BWXT has
initiated efforts to address the elimination of unnecessary, excessively
complex, or inadequate administrative controls and, where possible, to replace
them with appropriate engineered controls.
These efforts should be formalized and pursued vigorously.
Additionally, PXSO and BWXT should consider
making improvements in their readiness review processes. There is a need to improve the thoroughness
of the reviews, to improve the definition of their scope, to minimize work
distractions, and to reduce the effects of various personnel impacts.