[DNFSB
LETTERHEAD]
November 29, 2005
The Honorable Linton Brooks
Administrator
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) was briefed on November 21, 2005, by the National Nuclear
Security Administration’s (NNSA) Deputy Administrator for Defense Programs and
the manager of NNSA’s Los Alamos Site Office (LASO) on a 3-month “strategic pause”
that began that day at LASO. The Board
was informed that this pause is considered necessary for NNSA to reengineer
oversight policies and procedures in preparation for the transition to a new
prime contractor for management and operation of Los Alamos National Laboratory
(LANL). Approximately two-thirds of
LASO’s workforce is being devoted to the reengineering effort during the pause,
leaving the remaining third to oversee laboratory operations. No corresponding reduction in hazardous
activities at LANL is planned. As a compensatory
measure, LASO has tasked LANL to increase its own internal self-assessment for an
indefinite period of time.
The Board believes that LASO’s
retreat from its federal oversight responsibilities is inappropriate and gives
rise to safety vulnerabilities at LANL. Three fundamental issues lie at the heart of
the Board’s concern:
Timing
of Substantial
Reduction in Oversight―The
award of the recently competed contract for management and operation of LANL is
expected to be announced in early December 2005, and contract transition
activities are planned to take place during the following 6 months. Continued federal engagement is pivotal to
setting expectations for the new contractor management team and to ensuring
that the LANL workforce stays focused on continued safe operations during the
contract transition, a period when heightened attention to safety is needed. Also, the laboratory is currently pursuing the
resolution of a large number of corrective actions to address safety
deficiencies identified during the recent laboratory shutdown. This represents a significant effort that
requires continued support and oversight from NNSA, especially as the effort is
being transferred to a new contractor team.
Time-Urgent
Risk Reduction―The reduction in federal oversight
is likely to weaken the emphasis on accomplishing a number of key,
time-sensitive risk reduction activities at LANL. Without consistent federal emphasis, vital
activities such as the examples listed below may flounder as LANL enters the
planned 6-month contract transition period:
Recommendation
2004-1 Implications―Recommendation 2004-1 stressed the need to maintain
the capability for examining, assessing, and auditing by all levels of the
Department of Energy organization. The
strategic pause drastically reduces LASO’s capability to perform these essential
federal responsibilities. Specific
safety oversight activities affected by the pause include the monitoring of
LANL operations by facility representatives, safety basis review and approval
actions, safety system oversight functions, and project oversight for activities
such as the design of the Chemistry and Metallurgy Research Replacement
Facility.
LASO has directed LANL to
compensate for the reduction in federal presence by devoting additional
resources to self-assessment during the pause. The Board has previously objected to shifting
safety oversight to the contractor in Recommendation 2004-1, and in comments
provided in a January 5, 2005, letter on the draft Request for proposal for the
LANL contract. In both of these cases,
the Board was assured that NNSA would maintain robust oversight of nuclear
safety.
Furthermore, although its focus
remains on defense nuclear facilities, the Board notes that there will be
little or no federal safety oversight during the pause of lower hazard nuclear activities
or hazardous non-nuclear activities. There will also likely be no additional
contractor self-assessments of these activities. Lower hazard nuclear activities and hazardous
non-nuclear activities have been the source of several safety incidents at LANL
in the recent past.
It does not appear that NNSA
thoroughly considered the issues summarized above before authorizing the
strategic pause at LASO. In particular, NNSA
has not explicitly evaluated the safety risks of the pause. While the Board understands the need to
reengineer LASO’s oversight policies and procedures, it is not clear that the
benefits outweigh the risks of such a drastic reduction in oversight at this
time.
The Board does not agree that a
strategic pause of oversight by LASO as described above is consistent with the
safe operation of LANL. If NNSA believes
that this course of action must be pursued, the Board requires information
regarding how the issues described above will be addressed, as well as how
effective federal safety oversight will be maintained for the more significant
defense nuclear activities to be pursued during this period (listed in the
enclosure to this letter). In
particular, information is needed regarding the risk mitigation strategy during
the pause, assistance to be provided through external expertise, and details of
the additional self-assessments to be conducted by LANL. Pursuant to 42 U.S.C. § 2286b(d), the Board requests this
information be provided in the form of a briefing by senior NNSA officials
within 1 week of receipt of this letter.
Sincerely,
A.
J. Eggenberger
Chairman
c: Mr. Thomas P. D’Agostino
Mr.
Edwin L. Wilmot
Mr.
Mark B. Whitaker, Jr.
Enclosure
ENCLOSURE
Operations
Requiring a High Order of Federal Oversight
TA-55 Plutonium Facility
·
Plutonium-238
Full-scale Aqueous Scrap Processing line start up.
·
Bench-scale
scrap recovery line resumption.
·
Completion
of clean-up of plutonium-238 in Room 201B, and initiation of pyrolysis.
·
General
fissile materials operations.
·
The
building leak-path issue. (Although
compensatory measures are in place, satisfactory resolution in a timely manner
is required.)
Waste Operations at TA-54
Area G and TA-50
·
Quick-to-Waste
Isolation Pilot Plant operations.
·
Management,
operations, and procedures that are undergoing significant restructuring.
·
Safety
issues at the Radioactive Liquid Waste Treatment Facility involving leaking
tanks.
TA-18
·
Continuing
material moves.
·
Any
hand-stacking and/or criticality operations.
Issues Common to Various
Defense Nuclear Facilities
·
Establishing
expectations for the in-coming contractor management team and ensuring continued
focus on safe operation.
·
Disposition
of positive Unreviewed Safety Questions and Potentially Inadequate Safety Analyses.
·
Continuation
of initiative to improve Integrated Work Management.
·
Hazardous
work-for-others.
·
Ability
to respond to operational events/conditions/etc.