[DNFSB
LETTERHEAD]
December 14, 2005
The Honorable Samuel W. Bodman
Secretary of Energy
1000 Independence Avenue, SW
Washington, DC 20585-1000
Dear Secretary Bodman:
In the Implementation Plan for
the Defense Nuclear Facilities Safety Board’s (Board) Recommendation 98-2, Accelerating Safety
Management Improvements at the Pantex Plant, the Department of Energy (DOE)
committed to develop a technical business practice (TBP) to establish guidance
on expectations for the evaluation and documentation of weapon response to potential
accident environments and stimuli. In
this Implementation Plan, DOE stated that “there is great variability in the
degree of supporting documentation that serves as the technical basis for
conclusions drawn by laboratory experts”. A well documented technical basis is particularly
important for evaluating changes, as with the unreviewed safety question
process.
In a letter dated December 14, 2004,
the Board noted that previous efforts to satisfy this Implementation Plan
commitment “fell short of establishing a consistent approach for evaluating weapon
responses, particularly with respect to consensus expectations for an expert
elicitation process and the supporting technical basis for documenting expert
opinions”.
On October 31, 2005, the Board
received a draft TBP, Hazard
Analysis and Weapon Response, for
review and comment. The National Nuclear
Security Administration (NNSA) letter forwarding the standard noted that NNSA
now plans to develop a standard set of weapon response rules to cover many
situations, which “reduced the necessity to explicitly define expectations for
the evaluation and documentation of weapon response”. Soon
after, in a briefing on December 8, 2005, NNSA officials informed the Board
that a TBP was no longer considered the appropriate vehicle for requirements on
weapon response development. NNSA now
intends to revise the Development and Production (D&P) Manual, Chapter 11.8,
Integration
of Weapon Response into Authorization Bases at the Pantex Plant,
and the DOE Limited
Standard DOE-DP-STD-3016, Hazard
Analysis Reports for Nuclear Explosive Operations,
instead of using a
TBP to implement requirements for development of weapon responses. No date was offered for completing this
overdue commitment.
The Board agrees that revising
the D&P Manual and DOE-DP-STD-3016 would be a satisfactory means for
implementing the needed requirements for evaluation and documentation of weapon
responses. However, based on the
December 8, 2005, briefing, it is unclear when such revisions would be
developed and implemented. Furthermore,
based on review of the draft TBP and its October 31, 2005, forwarding letter,
it does not appear that NNSA is moving toward defining requirements that meet
the commitment in the Recommendation 98-2 Implementation Plan. Examples of specific deficiencies are listed
below:
The guidance in the draft TBP is
vague and does not establish effective criteria for evaluating and documenting
weapon responses as is required by 10 CFR 830 Subpart A,
Quality Assurance
Requirements. The lack of criteria allows each
design laboratory to develop its internal processes without consistent
standards for approach, quality assurance, and documentation. In light of the fundamental deficiencies noted
above and the uncertain schedule for completing this effort, the Board
requests, pursuant to 42 U.S.C. §
2286b(d), a report
within 30 days of receipt of this letter that provides a clear path forward for
developing the required guidance.
Sincerely,
A.
J. Eggenberger
Chairman
c: The
Honorable Linton Brooks
Mr.
Thomas P. D’Agostino
Mr.
Mark B. Whitaker, Jr.