[DOE LETTERHEAD]
NATIONAL NUCLEAR SECURITY ADMINISTRATION
August 14, 2007
Dear Mr. Chairman:
This is in
response to your letter of July 16, 2007, regarding the safe startup
of weapon program activities at the Pantex Plant. Your letter discussed circumstances
surrounding the startup of
W76 Mod 1 operations
in particular, and requested a report
detailing answers to three questions.
National Nuclear Security
Administration senior management understands the concerns you express in your
letter, and we agree with the
conceptual basis of
the message. NNSA has not and does not
endorse an organizational policy or operational philosophy whereby production
goals or mission needs trump safety requirements, and we do not view granting
exemptions to safety requirements as a matter of convenience. In reference
to the case in point, NNSA made its decisions with careful consideration of
maintaining an appropriate balance between competing objectives, while ensuring
that operational safety would not be compromised
in any way before authorization to begin operations was granted. The following discussion provides the bases
for these assertions and responds to the specific issues and questions in your
letter:
▪ The requirement for having an approved
safety basis before start of the NESS is invoked in DOE Order
452.2C, Nuclear Explosive Safety, issued on June 12, 2006. The Order includes an explicit provision
for granting exemptions to its requirements. Therefore, this NNSA action should not be
interpreted as a circumvention of DOE requirements. The decision to approve the Pantex Site Office
(PXSO) request for this exemption was coordinated with the Central
Technical Authority (CTA), Chief of Defense Nuclear Safety (CDNS), NA-10, and
NA-12, all of whom concurred with the PXSO request.
▪ These documents support the safety
basis but are not part of the required documentation set, and were available to
the NESS Group (NESSG) as draft documents. The fact that
they were not final versions only impacted the
efficiency and duration of the NESS. It had no effect on the validity of the NESS, its
findings, or the final control set.
▪ The contractor RA (CRA) started
after the NNSA review of the DSA was complete and both conditions of
approval (COAs) were known and provided to the contractor. Formal approval of the DSA occurred
4 days
after the CRA started. While we agree with the basic premise that this action
can be viewed as a break with the tenets of best practices, it had no effect on
the safety of the operations (i.e., adequacy of
controls), as the preliminary
and final COAs did not impact the conduct or conclusions of the CRA.
·
“Furthermore,
despite line management’s declaration of readiness, the contractor RA
encountered procedures that contained numerous errors and discovered that some
procedures could not be performed as written.”
▪ NNSA concedes
that the number of identified procedural errors were atypical, suggesting a
lower state of readiness than that anticipated by the contractor or NNSA. However,
in another respect, the very discovery of all these errors is reassuring in
suggesting a robust process carried out by competent and independent contractor
staff as intended by process design and requirements.
▪ PXSO instituted
the same requirement in a local procedure (Pantex Procedure 115.1.0, Startup and Restart of Pantex
Plant Activities)
several years ago,
and that requirement is still in effect. PXSO carefully considered the specifics of
the situation before granting permission to the contractor to go forward with
the CRA before its formal approval of the safety basis. In addition, the NNSA CTA
plans to issue implementing guidance by September 30, 2007
alerting NNSA offices and contractors that it is
an NNSA expectation
that the safety basis and controls be finalized and approved before a CRA starts.
In the conclusion to your letter, you also
asked three specific questions:
1.
What
specific actions will be
taken by NNSA to verify that startup activities for the W76 Mod 1
project have been adequately performed?
This
action is complete.
The CRA,
NNSA RA, and NESS are all complete; all pre-start findings have been closed. Corrective
action plans have been established for post-start findings. No additional start-up or review-related
actions are required to authorize operations. The NESS was
conducted April 10 - 13,
17 - 20, 24 - 26, 2007. The NESSG identified one pre-start and two
post-start findings. The NESSG Chair
reviewed the final Documented Safety Analysis (DSA)/Safety Evaluation Report
(SER) and determined there was no impact on NESS results. The pre-start finding is closed. NA-12 approved the NESS report on May 22, 2007.
The CRA
was conducted May 4 - 21, 2007, and identified 20 pre-start
findings. All pre-start findings are closed.
The DSA
was approved on May 8, 2007.
The NNSA RA was conducted Jun 6 - 15,
2007, and identified
three pre-start and two post-start findings. The pre-start findings are closed.
2.
What
specific actions will be taken by NNSA to ensure compliance with, and minimize
exemptions to, DOE requirements and expectations during startup and restart of
nuclear explosive operations at Pantex?
NNSA
weapon program start-up activities have been performed in accordance with applicable
requirements. Exemption requests are
rare and are granted only after careful consideration of the maturity of the
related nuclear safety processes and the operation’s safety basis, as well as
the contractor’s past performance in regard to the affected requirement.
As mentioned earlier, PXSO Procedure
115.1.0
requires that contractors not start their CRA unless the associated documented safety
analysis is approved and any conditions of approval have been resolved. In the case of
W76-1 assembly operations,
a deviation to that local prerequisite was approved by PXSO based
on BWXT’s past improved start-up performance, the requirement that
all conditions from the approval of the safety analysis were closed prior to
completion of the CRA, the fact that the assembly process is essentially the reverse
of the disassembly and inspection process (the safety basis for which had already
been reviewed and approved by NNSA), and because the safety analysis had been
under change control (through the unreviewed safety question process) since it
was submitted to PXSO for approval on April 6,
2007. Additionally, it is noted that PXSO’s review
of the W76-1 assembly safety analysis was complete, comments had been discussed
with the contractor, and the PXSO approval documentation was in final
preparation at the start of the CRA.
Again,
complex-wide clarifying guidance on NNSA expectations regarding the sequencing of the approval of the safety basis and start of the CRA
will be issued by the CTA in the near future.
3.
When
will the above actions be
completed?
The first
action is complete. The issuance of the
CTA guidance describing NNSA expectations regarding the sequencing of safety
basis approval and CRA is expected by September 30, 2007.
If you have further questions, please
contact me or Steve Goodrum at (202) 586-4879.
Sincerely,
Martin J. Schoenbauer
Acting Deputy Administrator
for Defense Programs
cc:
W. Ostendorff,
NA-1
M. Whitaker,
HS-1.1
S. Erhart,
PXSO
D. Glenn, PXSO
J. McConnell, NA-2.1
T. D’Agostino,
NA-10
S. Goodrum, NA-12
R. Lewis, NA-12
E. Schmidt,
NA-121