[DNFSB LETTERHEAD]
April l0, 2003
The Honorable Linton Brooks
Acting Administrator
of the National Nuclear Security
Administration
U. S.
Department of Energy
1000 Independence Avenue, SW
Washington, DC 20585-0701
Dear Ambassador Brooks:
The staff of the Defense Nuclear Facilities
Safety Board (Board) recently observed significant deficiencies in the current
safety bases for some of Lawrence Liver-more National Laboratory’s (LLNL)
defense nuclear facilities (most notably the Plutonium Facility, Building
332). The Department of Energy (DOE)
has also identified many of these weaknesses and has directed LLNL to correct
them. In some cases, however, lack of
vigorous DOE oversight has allowed these deficiencies to exist for years. As such, DOE should ensure that these
identified weaknesses are adequately addressed in a timely manner or establish
appropriate compensatory measures until deficiencies are adequately addressed.
Additionally, the Board’s staff observed
deficiencies related to maintaining mass limits for hazardous chemicals in
non-nuclear facilities and the ability of nuclear facilities to accurately and
effectively assess the potential adverse impacts posed by external hazards from
non-nuclear facilities. One non-nuclear
facility was found to have more than twice its prescribed limit of a hazardous
chemical. This lack of vigilance in
maintaining inventory limits and coordinating site-wide hazard assessments
could result in higher than expected consequences or the existence of
unanalyzed hazards.
The enclosed issue report provides
additional details regarding these observations. Given the significance and persistence of the identified
deficiencies, it appears that further attention is necessary to ensure the
complete and timely remediation of these weaknesses and the development of
rigorous and comprehensive Documented Safety Analyses that fully comply with
the requirements of Part 830 to Title 10 of the Code of Federal Regulations, Nuclear
Safety Management. Therefore,
pursuant to 42 U.S.C. § 2286b(d),
the Board requests a report within 60 days of receipt of this letter that
documents how DOE will resolve issues identified in the enclosed report.
Sincerely,
John T. Conway
Chairman
c:
The Honorable Jessie Hill Roberson
Mrs. Camille Yuan-Soo Hoo
Mr. Mark B. Whitaker, Jr.
Enclosure
DEFENSE
NUCLEAR FACILITIES SAFETY BOARD
March 25,
2003
MEMORANDUM FOR: J. K.
Fortenberry, Technical Director
COPIES: Board
Members
FROM: B.
Broderick
SUBJECT: Hazard
Assessment and Control at Lawrence Livermore National Laboratory
This report documents a review of hazard
assessment and control at Lawrence Livermore National Laboratory (LLNL),
conducted by members of the staff of the Defense Nuclear Facilities Safety
Board (Board). Staff members W.
Andrews, F. Bamdad, B. Broderick, and J. Shackelford met with representatives
of the National Nuclear Security Administration’s (NNSA) Livermore Site Office
(LSO) and LLNL to discuss the content of safety basis documentation and
implementation of controls at several defense nuclear facilities and selected
non-nuclear facilities whose operations could potentially impact nuclear
facilities.
Background.
Documented Safety Analyses (DSAs) that comply with the mandates of Part
830 to Title 10 Code of Federal Regulations, Nuclear Safety Management,
are required to be submitted for applicable LLNL defense nuclear facilities by
April l0, 2003 (October 10, 2003, for the Plutonium Facility, per NNSA
extension). In many cases, these DSAs
will contain updated or revised hazard and accident analyses and associated
modifications to the set of safety controls identified to address facility
hazards. With preparation of these
documents being in various stages of development, the Board’s staff conducted a
review of current safety basis documentation to serve as a baseline for the
assessment of future DSAs, and to provide comments and observations relative to
existing Safety Analysis Reports (SAR) (under which facilities are currently
operated) that could prove beneficial in the generation of DSAs and subsequent
annual updates. The staff focused
special attention on evaluating the following areas to support this
objective: existing hazard and accident
analyses as they pertain to the derivation of hazard controls; the
configuration, capabilities, and adequacy of structures, systems, and
components (SSC) that figure prominently in the control schemes designed to
prevent or mitigate postulated accident scenarios; and potential impacts on
defense nuclear facilities that could result from hazards associated with the
operation of LLNL’s non-nuclear facilities.
Potential Inadequacies in Existing Safety
Bases at Nuclear Facilities. The Board’s staff reviewed the current SARs
for the Plutonium Facility (Building 332), the Hardened Engineering Test
Facility (Building 334), and the Material Management Source Vault (Building
23lV), in addition to conducting walkdown assessments of safety-related SSCs
employed in these facilities to prevent or mitigate accident scenarios. Relevant observations are discussed below.
Building 332―The Board’s staff reviewed the current
facility SAR and Technical Safety Requirements (TSRs), dated August 2002, and
noted a number of inadequacies and weaknesses.
These inadequacies included postulated accident scenarios for which
unmitigated consequences had been evaluated to exceed the off-site evaluation
guidelines, but for which no safety-class controls had been identified. Additionally, it was observed that in some
cases, SSCs had been implicitly credited with performing a safety function, but
had not been assigned a formal functional classification. The staff also observed that support systems
for some safety-class and safety-significant SSCs did not carry a functional
classification commensurate with the classification of the SSCs they
supported. The following specific
examples illustrate the issues identified by the staff:
These specific issues, as well as the staffs
overall concerns regarding the safety basis, were communicated to NNSA and the
contractor. In many cases, the general
concerns articulated by the staff had been identified by NNSA as weak or
problematic areas in Building 332 safety bases dating as far back as January
1995. However, many previously
identified deficiencies continue to exist in the September 2002 SAR. These deficiencies were numerous enough to
prompt NNSA to establish 33 conditions of approval in its Safety Evaluation
Report (SER), some as significant as directing the contractor to “completely
redo the hazards analysis” to ensure that all hazards had been appropriately
described and analyzed. The SER sets
the expectation that these conditions of approval are to be met in the
forthcoming rule-compliant DSA.
However, the significance and persistence of these deficiencies suggest
that increased vigilance may be warranted on the part of NNSA and the
contractor to ensure that these weaknesses are corrected in a timely manner or
that appropriate compensatory measures are established.
Building 231V―The staff reviewed the facility SAR dated
November 2001, which designated Building 231V as a Hazard Category 3 nuclear
facility, but identified no safety-significant SSCs to control facility
hazards. In its April 2002 SER, NNSA
had approved the facility’s SAR with 10 conditions of approval, one of which
directed the contractor to functionally classify the building’s structure,
vault ventilation system (including fume hood exhaust and high-efficiency
particulate air [HEPA] filters), and vault continuous air monitors as
safety-significant SSCs. In May 2002,
the facility submitted and subsequently withdrew a nominally rule-compliant DSA
that did not address important NNSA conditions of approval, including the
functional reclassification of SSCs and the development of TSRs to protect
these controls. It appeared that NNSA
had not adequately followed up to ensure that these required modifications were
being implemented. As a result, more
than 10 months had elapsed without the necessary conditions of approval having
been met and without reasonably assertive oversight having been exercised by
NNSA.
Building 334―The staff reviewed the current Building 334
SAR, dated January 2000. Given the existing limitations on operations and
material forms and quantities allowed in this facility, as mandated by the
January 2000 SAR, it appeared that the current safety basis was adequate. The staff noted, however, that thermal
testing conducted in two specially engineered thermal chambers, one of the
facility’s most hazardous operations, had ceased because of prohibitive
budgetary and security constraints, yet the safety basis still allowed these
operations to take place. The
contractor committed to formally precluding the use of thermal testing chambers
while special nuclear material was present in the facility by instituting a
TSR-controlled lockout-tagout administrative control in the forthcoming DSA.
Cognizance and Control of External Hazards. The
Board’s staff reviewed identified external hazards to nuclear facilities and
walked down a number of non-nuclear facilities. These included the Chemical and Material Science Isotope
Laboratories (Building 151), the Microfabrication Laboratory (Building 153),
and the Materials Fabrication Shop (Building 321). The intent was to understand and evaluate the external hazards
posed by accidents in these facilities to nuclear facilities. The staff also reviewed the controls and
protocols in place in these non-nuclear facilities to prevent or mitigate
accidents that could affect nuclear facilities.
Inventory Control in Non-Nuclear Facilities―Hazard Analysis Reports (HARs) comprise the
safety bases for non-nuclear facilities.
HARs set inventory limits for materials that could cause adverse
chemical and toxicological impacts on nuclear facilities and codify processes
designed to ensure that these inventory limits are satisfied.
The HAR for Building 153, dated January
2001, identified a mass limit of 15.87 lb for the amount of chlorine that could
be stored in the facility. In February
2003, it was discovered that the actual mass of chlorine in Building 153 was
approximately 33 lb, and that this condition had existed even prior to the
approval of the 2001 HAR. Not only had
the amount of chlorine exceeded the approved mass limit since the HAR’s
inception, but nearly 40 separate inventory checks and continuous facility use
of the laboratory-wide chemical inventory and tracking system, ChemTrack, had
failed to identify this situation.
The prolonged chlorine over-mass condition
in Building 153, as well as other recent inventory control-related occurrences,
suggests that increased vigilance is required in non-nuclear facilities to
ensure that consequences associated with an accident in one of these facilities
would not exceed the expected severity and invalidate carefully developed
emergency preparedness plans and procedures aimed at mitigating such adverse
effects, including impacts on nuclear facilities. The Building 153 event also demonstrates potential safety
benefits that could be associated with the development or identification of a
system better suited to the safety-related role of chemical inventory control
and management than the currently employed ChemTrack system, which was not
designed to serve this purpose.
Integration of Hazard Assessments―The Building 332 SAR identifies a chlorine
release from the local Zone 7 water treatment plant as the most significant
off-site, external chemical hazard to this facility. The staff inquired as to whether a memorandum of agreement had
been established with the owners of the treatment plant to ensure that
personnel from LLNL and Building 332 would be notified in a timely manner
should a chlorine release event occur.
However, managers and authorization basis personnel for Building 332
were unable to provide details relevant to this situation. Upon further inquiry by the staff, the site
fire chief indicated that the Zone 7 plant had altered its treatment process
more than a year ago such that the facility no longer posed a threat to
Building 332 or any other nuclear facility for which this external hazard may
have been identified. The lack of coordination
and integration between hazard assessments in this example had resulted in an
inefficient expenditure of resources to analyze and address a hazard that no
longer existed. In this instance, the
lack of coordination had not degraded the completeness or conservatism of the
existing analysis. However, the staff
noted that the lack of overall coordination at the site could result in
undesirable consequences if a new hazard were introduced, and a similar lack of
coordination and integration resulted in a failure to address the issue.