[DNFSB
LETTERHEAD]
December 14, 2004
The Honorable Spencer Abraham
Secretary of Energy
1000 Independence Avenue, SW
Washington, DC 20585-1000
Dear Secretary Abraham:
In Recommendation 98-2, Accelerating Safety
Management Improvements at the Pantex Plant, the Defense Nuclear Facilities
Safety Board (Board) recommended that the Department of Energy (DOE) strengthen
and simplify the process by which DOE designs and develops nuclear explosive
work activities at the Pantex Plant. The
Board remains concerned with long delayed important commitments in DOE’s
Implementation Plan for Recommendation 98-2 related to accelerating key safety
improvements to nuclear explosive operations.
One delayed commitment is
implementation of the Seamless Safety for the 2lst Century (SS-21) process for B83
nuclear explosive operations. DOE
originally committed to implementing SS-21 for the B83 program by May 2002. In an October 28, 2002 letter, several changes
were proposed to the Implementation Plan for Recommendation 98-2, including a
two year delay in the delivery date for the B83 program to May 30, 2004. Despite reservations, the Board accepted this
change. In an April 28, 2004 letter, the
B83 commitment was extended again by the National Nuclear Security
Administration (NNSA) to October 29, 2004. In an August 6, 2004 letter, the B83
commitment was again extended to January 2005. The B83 Nuclear Explosive Safety Study was
extended to March 31, 2005, to accommodate this delay. The Board has now received a letter from NNSA
dated November 3, 2004, that indicates the implementation of SS-21 for the B83
program is once again being delayed, with a new target date of March 2005. In addition, BWXT has requested another
extension of the B83 Nuclear Explosive Safety Study. The B83 program is only now beginning the
startup reviews necessary to authorize operations.
The second late commitment is
the implementation of improved site-wide Technical Safety Requirement (TSR)
controls for on-site transportation of nuclear explosives. The implementation plan for the Transportation
Safety Analysis Report was integrated with plans to implement controls from
other new Safety Analysis Reports in an effort to consolidate and coordinate
available resources. In total, more than
200 new or revised TSR controls were scheduled to be implemented and verified.
During a recent review of the
safety basis and efforts to implement TSR controls for the Pantex Plant, the
Board’s staff found that the contractor’s schedule of interim milestones for
the implementation and verification of TSR controls has continued to slip. The contractor committed to achieve
implementation of 150 TSR controls by October 1, 2004. The contractor,
BWXT-Pantex, fell 94 controls short of this milestone. In the Quarterly Report for Recommendation
98-2, July 1 through September 30, 2003, the contractor committed to completing
a final contractor readiness assessment of the TSR controls by March 2005. In the latest revision to the TSR
implementation plan, dated November 17, 2004, the contractor has delayed the
TSR implementation project end date by four months to September 2005.
A third commitment of concern to
the Board is the development of a Technical Business Practice that establishes
guidance on expectations for the evaluation and documentation of weapon
response information. On January 31, 2001, DOE sent the Board a revision to
Chapter 11.8, “Integration of Weapon Response into Authorization Bases at the
Pantex Plant,” of the Development
and Production Manual in
lieu of the proposed Technical Business Practice. However, as has been discussed in several
interactions with NNSA, the scope of the revision fell short of establishing a
consistent approach for evaluating weapon responses, particularly with respect
to consensus expectations for an expert elicitation process and the supporting
technical basis for documenting expert opinions. Senior NNSA management agreed to have a
Technical Business Practice developed that would provide the needed guidance. However, the Board has not been informed of
any progress in this area.
Pursuant to 42 U.S.C. § 2286b(d), the Board hereby establishes
a monthly requirement from senior NNSA managers for a briefing on the status of
these commitments under the Recommendation 98-2 DOE Implementation Plan. These monthly briefings appear necessary to focus
attention within NNSA on the continuing delays in these important commitments. At a minimum, the briefings should provide the
following information: (1) the number of TSR controls that have been implemented,
verified, and made effective, (2) the current status of implementation of SS-21
for the B83 program, and (3) status of the Technical Business Practice that
establishes quality requirements for weapon responses. These monthly briefings are to begin following
receipt of this letter and continue until these commitments have been fulfilled.
Sincerely,
John T. Conway
Chairman
c: The Honorable Linton Brooks
The
Honorable Everet H. Beckner
Mr.
Marty Schoenbauer
Mr.
Daniel E. Glenn
Mr.
Mark B. Whitaker, Jr.