[DNFSB
LETTERHEAD]
November 28, 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:
In a letter dated November 3, 2004,
the Defense Nuclear Facilities Safety Board (Board) requested a report on the
actions to be taken to identify and correct deficiencies in the Device Assembly
Facility (DAF) at the Nevada Test Site. The Board’s request resulted primarily from observations
by the Board’s staff of significant deficiencies at that facility, combined
with the Department of Energy’s plans to increase both the scope and tempo of
the facility’s nuclear operations.
The Board was pleased to receive
the response of the National Nuclear Security Administration (NNSA), dated
February 8, 2005. That response outlines
a strategy consisting of four elements: (1)
DAF management’s commitment to safety; (2) planned improvements in NNSA’s
oversight activities; (3) conduct of Operational Readiness Reviews prior to the
startup of new activities; and (4) a Safety Basis Implementation Plan (SBIP).
The Board acknowledges the
commitment of NNSA and DAF management to safety, and also encourages an
increased level of federal oversight. Given the unique situation at DAF, the Board
believes additional focused review and assessment activities are necessary to
ensure that the facility will be ready to carry out new high-hazard activities
safely. However, the federal oversight
assessment program of the Nevada Site Office has not developed as indicated in NNSA’s
response. It appears there is no plan to
conduct broad-scope, detailed, and specific reviews of the adequacy and
reliability of the important safety management programs and vital safety systems
required to support long-term safe operation of DAF.
The SBIP appears to be a
valuable resource in identifying and tracking certain elements of the
implementation of the safety basis. The
SBIP appears to identify those programs that are required to be implemented
prior to new activity startup and to establish a requirements crosswalk between
the required programs and the applicable standards. However, the process embodied in the plan, in itself, would not accomplish broad-based, comprehensive programmatic
reviews of vital safety management programs. Further, as noted in the Board’s letter of November
3, 2004, the Operational Readiness Review process is generally focused on
verifying, through a sampling review, the operational attributes of the activity
being performed. Consequently, the
readiness review process alone would not provide the scope and depth of review
warranted at DAF before the facility is declared ready to perform new
operations.
The inadequacy of the strategy
of relying on the SBIP and the readiness review process is illustrated by the
following examples. Prior to NNSA’s
September 2004 review of the training and qualification program, which was
conducted at the Board’s request, the SBIP indicated that the program had been
implemented as of May 2004 for glovebox operations and would be implemented “as
required” for other activities. However,
as noted in NNSA’s assessment, the training and qualification program exhibited
significant deficiencies not previously identified by the SBIP and other
oversight processes. Similarly, a review
of the safety basis conducted by the Board’s staff in July 2004 identified
issues related to the reliability of the fire suppression system not identified
previously, More recently, as noted in the Board’s letter of March 18, 2005,
the Board’s staff identified that the extent and safety impact of cracks and
water infiltration in the DAF structure required further assessment. The SBIP does not specifically address these
and other issues.
The Board believes NNSA needs to
reconsider the current strategy and adopt a more proactive and comprehensive
approach to the review and assessment of important safety management programs
and vital safety systems at DAF. Although the current scope of work at the
facility does not include activities related to interim criticality
experiments, the Criticality Experiments Facility is relocating to DAF, and
other activities have been considered for inclusion in the overall DAF mission.
Assurance of a robust suite of safety management
programs and a reliable infrastructure of safety systems is necessary to
support DAF’s safe and efficient operation,
regardless of the specific operations and activities to be performed at the facility.
The Board will continue to closely
follow NNSA’s efforts toward ensuring that DAF can fulfill its important
national security mission safely.
Pursuant to 42 U.S.C. § 2286b(d), the Board requests that NNSA provide a report and briefing
within 60 days of receipt of this letter addressing what additional actions
will be taken to address the issues outlined above.
Sincerely,
A. J. Eggenberger
Chairman
c: Mr. Thomas P. D’Agostino
Ms.
Kathleen A. Carlson
Mr.
Mark B. Whitaker, Jr.