**\[DOE LETTERHEAD\]**

**National Nuclear Security Administration**

January 4, 2005

The Honorable John T. Conway

Chairman

Defense Nuclear Facilities Safety Board

625 Indiana Avenue, N.W.

Suite 700

Washington, D.C. 20004

Dear Mr. Chairman:

The Secretary has requested that I forward this interim response to your
November 3, 2004, letter regarding the implementation status of
Recommendation 2000-2, *Configuration Management, Vital Safety Systems,*
at the Lawrence Livermore National Laboratory (LLNL). Your letter noted
several occurrences involving the inadequate condition of safety
systems, including covers (tape) for safety-class ventilation duct
penetrations, potential cracking in safety-significant ventilation duct
welds, and inadequate seismic restraints for safety-significant
gloveboxes. Specifically, you requested from DOE a report within 60 days
that addresses:

-   NNSA's assessment of the configuration management program as it now
    exists for vital safety systems at LLNL's defense nuclear
    facilities.

-   A resource-loaded schedule for implementing a configuration
    management program for vital safety systems at LLNL's defense
    nuclear facilities.

The Livermore Site Office (LSO) chartered a review team to evaluate the
institutional application of configuration management within Building
332, including specific vital safety system reviews. The review team
performed document reviews, walkdowns of specific Building 332 vital
safety systems, and held discussions with systems engineers, facility
and operations personnel, and safety basis personnel.

The review team's enclosed report addresses the specific actions taken
or compensatory measures implemented to address the condition of the
safety systems noted in your letter.

In addition, the report identifies or confirms serious vulnerabilities
in the configuration management program at the institutional level and
in the majority of the reviewed vital safety systems within Building
332. The enclosed LSO report concludes that configuration management is
not complete or effective within Building 332. In addition, the team
noted that the commitment to institutionalize the DOE Phase II
assessments in response to DNFSB Recommendation 2000-2 has not been
satisfied, and there are no institutional assessments of vital safety
systems being performed in LLNL's defense nuclear facilities.

Regarding the potentially cracked ducting in Building 332, LSO will
direct LLNL to perform non-destructive testing as necessary to verify
the existence of cracks. If testing confirms the presence of cracks in
the ducting, LLNL will follow the unreviewed safety question
determination process.

Based on the team's findings, NNSA accepts LSO's recommendation to
expedite performance of comprehensive Phase II assessments for all vital
safety systems in Building 332, with first priority on the fire
suppression system and gloveboxes. In addition, NNSA agrees that LSO
will work jointly with LLNL to reassess LLNL's institutional
configuration management program, consistent with relevant Phase II
assessment guidance.

LSO will provide its Building 332 assessment results to LLNL by January
3, 2005.

LLNL has been directed to submit a resource-loaded corrective action
plan for Building 332 to LSO by March 3, 2005. NNSA has directed LSO to
complete the remaining vital safety system reviews no later than March
2005. Subsequently, LLNL corrective action plans will be submitted to
LSO within 60 days after receipt of subject assessments. Upon completion
of all LSO assessments and LLNL corrective action plans, LSO will direct
LLNL to develop a comprehensive resource loaded schedule for a fully
implemented configuration management program for the defense nuclear
facilities.

I share your concern regarding the adequacy of the configuration
management program in Building 332. A full response to your letter,
including the resource loaded schedule for implementing a configuration
management program for vital safety systems at LLNL's defense nuclear
facilities, will be provided to the Board following LSO's completion of
their assessments and LLNL's identification of all necessary corrective
actions.

Sincerely,

***Linton F. Brooks***

***Administrator***

cc: M. Whitaker, DR-1

[Enclosure](../tb05j04b.pdf)