[DNFSB
LETTERHEAD]
July 30, 2007
The Honorable Samuel W. Bodman
Secretary of Energy
1000 Independence Avenue, SW
Washington, DC 20585-1000
Dear Secretary Bodman:
The prevention and mitigation of potential accidents
inherent in the mission activities at defense nuclear facilities is a fundamental
objective that requires the Department of Energy (DOE) and its contractors to
identify accident scenarios and then establish effective and reliable safety
controls to address them. Engineered
controls are preferred over administrative controls because, in general,
engineered controls are considered to be more reliable and effective than administrative
controls. At times, administrative
controls will be required to perform specific safety functions. Examples of administrative controls include
discrete operator actions, or programmatic controls such as combustible
loading programs (associated with fire protection programs), operator training
programs, and inservice inspection programs.
Observations relevant to the development and implementation of
administrative controls in
the DOE defense nuclear complex were the basis for the
Defense Nuclear Facilities Safety Board’s (Board) Recommendation 2002-3, Requirements for the Design, Implementation, and Maintenance
of Administrative Controls. On January 3, 2007, DOE informed the Board that all of its actions
and commitments associated with the Implementation Plan for
Recommendation 2002-3 had been completed and proposed that the Recommendation
be closed. In a letter dated
January 22, 2007, the Board acknowledged the progress made by DOE in response
to the Recommendation, and indicated that the Board’s staff would conduct field
reviews of a representative sample of defense nuclear facilities to
independently assess the adequacy and effectiveness of DOE’s efforts in
implementing the Recommendation before reaching a decision on closure. Based on those field reviews, the Board has
determined that Recommendation 2002-3 must remain open.
The results of the staff’s reviews, which is enclosed
with this letter, indicate that
a number of
systemic weaknesses exist in the Recommendation implementation
across the defense nuclear complex. Examples of these include, but are not limited
to, deficiencies in developing programs to ensure
(1) the long-term effectiveness of specific administrative controls and (2) the
appropriate classification of critical supports systems for
specific administrative controls. Further, it appears that a number of
major defense nuclear facilities have not yet fully implemented the Recommendation.
Moreover, the Board is concerned
that DOE audits and self-assessments, as specified in Commitment 4.7 of the
Implementation Plan to assess the overall effectiveness of the program,
were ineffective in identifying the implementation issues cited in the enclosed
report.
Therefore, pursuant to 42 U.S.C. § 2286b(d),
the Board requests a briefing within 45 days of receipt of this letter
describing the specific actions DOE will take to further ensure the implementation
of Recommendation 2002-3 in the field.
Sincerely,
A. J. Eggenberger
Chairman
c: The Honorable J. Clay
Sell
The Honorable James A. Rispoli
The
Honorable Thomas P. D'Agostino
Mr. Mark B. Whitaker, Jr.
Enclosure
DEFENSE NUCLEAR FACILITIES
SAFETY BOARD
Staff Issue Report
June 22, 2007
MEMORANDUM FOR: J. K. Fortenberry
COPIES: Board Members
FROM: J. L.
Shackelford
SUBJECT: Review of the Implementation of Recommendation 2002-3, Requirements
for the Design, Implementation, and Maintenance of Administrative
Controls
This report documents a series of reviews of the Department
of Energy’s (DOE) implementation of the Defense Nuclear Facilities Safety
Board’s (Board) Recommendation 2002-3, Requirements for the Design, Implementation, and Maintenance of Administrative Controls, at selected
facilities in the defense nuclear complex.
Background. On
December 11, 2002, the Board issued Recommendation 2002-3 to DOE, which DOE
accepted on January 31, 2003. On June
26, 2003, DOE issued an Implementation Plan for the Recommendation. Subsequently, DOE issued a letter, dated January
4, 2007, informing the Board that all of the commitments in the Implementation
Plan had been completed and proposing that the Recommendation be closed. On January 22, 2007, the Board responded to
DOE’s request for closure. The Board
acknowledged that progress had been made in response to the issues addressed by
the Recommendation. However, the Board indicated
that its staff would conduct field reviews of a representative sample of
defense nuclear facilities to
independently assess the adequacy and effectiveness of
DOE’s efforts in implementing the Recommendation before reaching a
decision on closure. The results of the staff’s
reviews are summarized below.
Review of the Implementation of
Recommendation 2002-3 at Selected Defense Nuclear Facilities. The
central element of DOE’s
response to the Board’s Recommendation dealing with
administrative controls was the development of the concept of a specific administrative
control (SAC). In general terms, a SAC
is an administrative control that would be categorized as either
safety-significant or safety-class if the function it served were implemented through
an engineered structure, system, or component. The staff reviewed the policies, programs, and
processes for the development and implementation of SACs at
the Pantex Plant, Savannah River Site (SRS), and Y-12 National Security Complex.
These reviews encompassed an assessment of the
general process for developing SACs, including how the hazard and accident
analysis processes flowed into the development of SACs. The reviews also focused on the activities
associated with procedure development, training and qualification, assessment
of the adequacy of SACs, implementation of SACs, and root-cause assessments
and lessons-learned efforts associated with identified weaknesses in SACs. The staff selected a number of SACs for detailed
evaluation and assessment to determine whether all of the expectations and
requirements embodied in the Board’s Recommendation were being met. The staff also assessed the respective DOE
Site Office’s oversight of SACs.
At each of the sites reviewed, the staff found that the
contractor had formulated and implemented a systematic process for the
development of safety bases that addressed the guidance and requirements
associated with SACs as defined in DOE Standard 3009, Preparation Guide for
U.S. Department of Energy Nonreactor Nuclear Facility Documented Safety
Analyses, Change Notice 3, and DOE Standard 1186, Specific
Administrative Controls. At
the same time, however, the staff noted a number of weaknesses in the
implementation of the Recommendation. Examples
of these weaknesses are summarized below.
Pantex Plant
Savannah River Site
Y-12
National Security Complex
Summary. Although
considerable progress had been made toward addressing the issues outlined in
Recommendation 2002-3, the staff’s review found that significant and apparently
systemic weaknesses existed in the implementation of Recommendation 2002-3
across the defense nuclear complex. While each of the facilities reviewed had
developed a systematic process for the development of safety bases that
addressed the guidance and requirements defined in DOE Standard 3009 and DOE
Standard 1186 for SACs, the Board’s staff observed numerous weaknesses in the
Recommendation’s implementation suggesting additional efforts would be
necessary to fully realize the benefits envisioned by the Board. These included weaknesses in developing programs
to ensure the long-term effectiveness of SACs, providing the specificity and
level of detail necessary to accomplish the desired safety objectives of SACs, ensuring
that critical support systems for SACs are appropriately classified, specifying
the need for independent or concurrent verification, and inappropriately
crediting safety management programs in lieu of SACs or engineered controls. Further, the Board’s staff observed that a number
of major defense nuclear facilities had not yet fully implemented the
Recommendation.
In response to the staff’s observations and findings, a
number of corrective actions have been taken at the facilities that were
reviewed to address many of the identified deficiencies. The staff is concerned that DOE and contractor
audits and self-assessments had not identified the deficiencies observed by the
Board’s staff.
Commitment 4.7 of the Implementation Plan indicated that
DOE would evaluate the overall success of the effectiveness of the
implementation of the Recommendation. In
its letter of January 4, 2007, DOE informed the Board that all of the
commitments in the Implementation Plan had been completed and proposed that the
Recommendation be closed. The staff’s observations
show that DOE’s review was not effective in identifying the weaknesses, deficiencies,
and incompleteness of the Recommendation’s implementation, and that additional effort
and attention in this area is warranted before the Recommendation can be closed.