[DNFSB
LETTERHEAD]
February 24, 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) is reviewing the design of the Chemistry and Metallurgy
Research Facility Replacement (CMR-R) Project at Los Alamos National Laboratory
(LANL). To expedite the schedule, the
National Nuclear Security Administration (NNSA) is planning to combine Critical
Decision (CD)-2 (approval of performance baseline) and CD-3 (approval to start
construction) for this project. After completion
of the preliminary design, a design-build contract will be awarded to an architecture/engineering
firm to finalize the design and construct the facility. This approach will essentially eliminate
NNSA’s formal review of the final design prior to construction.
The Board recognizes that from a
safety perspective, completing CMR-R earlier is attractive because it would
reduce nuclear hazards in the existing CMR facility and its aging safety
systems. The Board also understands that
in order to lower project uncertainty at CD-2 approval, NNSA expects the
preliminary design package to be more developed than is usual, including an
approved Preliminary Documented Safety Analysis. However, expediting the schedule by
eliminating one of the design reviews and utilizing a design-build contract has
the potential for the government to lose control of the design and construction
of safety systems unless they have been meticulously defined in the
design-build contract.
Department of Energy Manual 413.3,
Project
Management for the Acquisition of Capital Assets, cautions that “design-build can
be used most successfully with projects that have well-defined requirements,
are not complex, and have limited risks”. The magnitude, complexity, and mission
importance of CMR-R do not satisfy this caution.
The Board believes that for a
design-build approach to be successful, intense oversight by NNSA and LANL will
be required, using personnel experienced in the management and oversight of
large, complex projects, in areas such as project management, cost estimating,
safety analysis, process design, construction, and scheduling. However, the number of NNSA and LANL personnel
experienced in these areas is limited.
The Board believes that without
appropriate technical oversight of the design the success of the CMR-R project
could be jeopardized. Experience to-date
with the Hanford Waste Treatment Plant should be a cautionary example regarding
use of non traditional approaches to large, complex nuclear construction
projects. Therefore, pursuant to 42 U.S.C.
§ 2286b(d), the Board
requests a briefing within 30 days of CD-1 approval to provide NNSA’s rationale
for the use of a design-build approach for the CMR-R Project and its plan to
ensure that adequate staff will be assigned to this project between now and
CD-2 approval. The NNSA briefing should specifically
address those technical issues in which direct NNSA involvement will be
necessary during the preliminary design and expectations for the level of
direct federal involvement and the technical individuals or positions
performing those functions.
Sincerely,
John T. Conway
Chairman
c: Mr. Edwin L. Wilmot
Mr.
Mark B. Whitaker, Jr.