December 21, 1994


The Honorable Victor H. Reis
Assistant Secretary for Defense Programs
Department of Energy
Washington, D.C.  20585

Dear Dr. Reis:

From October 5 through 7, 1994, members of the Defense Nuclear Facilities Safety
Board (DNFSB) staff visited the Lawrence Livermore National Laboratory (LLNL). 
The DNFSB is pleased to note that the LLNL radiological control program has been
generally successful and that LLNL is making progress toward compliance with
Department of Energy (DOE) Order 5480.19, Conduct of Operations Requirements for
DOE Facilities.  

However, based on DNFSB staff observations documented in the enclosed trip
report, it appears that additional work needs to be done.  A number of
deficiencies were identified; most troubling is the fact that the Plutonium
Facility still lacks equipment operating procedures for its safety systems.  In
addition, DOE has succeeded in getting only three Training Implementation
Matrices (TIMs) approved for the six nuclear facilities planned for long-term
operation at LLNL.  The TIM has been fully implemented at only one of these
facilities, the Tritium Facility.  

Our staff will continue to monitor implementation of DOE requirements for these
programs with emphasis on the follow-up actions taken by DOE with respect to the
deficiencies noted in the report.  Mr. Steve Krahn of the DNFSB staff will be
available to provide any assistance in addressing the issues in this letter.

                                                Sincerely,



                                                John T. Conway
                                                Chairman

c:     The Honorable Tara O'Toole, EH-1
       Mr. Mark Whitaker, EH-6
       Mr. James Turner, Acting Manager, DOE-OAK

Enclosure
















DEFENSE NUCLEAR FACILITIES SAFETY BOARD

November 9, 1994

MEMORANDUM FOR:      G.W. Cunningham, Technical Director

COPIES:              Board Members

FROM:                C. R. Martin, LLNL Program Manager

SUBJECT:             Status of Implementation of Department of Energy (DOE)
                     Requirements for Radiological Protection, Formality of
                     Operations and Training at Lawrence Livermore National
                     Laboratory (LLNL)

1.  Purpose:  This trip report documents a review by the Defense Nuclear
    Facilities Safety Board (DNFSB) technical staff (Charles Martin and Wayne
    Andrews) of LLNL from October 6-7, 1994.  This report also incorporates
    comments by Steve Krahn from his September 28, visit to LLNL and incorporates
    and updates findings from two previous DNFSB staff reviews at LLNL. 

2.  Summary:  

    a. The LLNL radiological control program has been generally successful.  The
       Laboratory has been implementing DOE Notice 5480.6, Radiological Control
       Manual (RCM), since December of 1993, and states that they currently
       comply with most of the requirements; full compliance is expected by
       October 1, 1996.  At present, the weakest area of compliance is in meeting
       requirements for training and recordkeeping.  In addition, the lack of a
       robust radiological performance indicator program hampers the ability of
       management to monitor the effectiveness of the radiological control
       program.  

    b. LLNL is making progress toward compliance with DOE Order 5480.19, Conduct
       of Operations Requirements for DOE Facilities.  Most of the nuclear
       facilities are currently in compliance with nearly all of the
       requirements; however, the Plutonium Facility is still out of compliance
       with about a third of them.  One of the most serious deficiencies is the
       lack of equipment operating procedures for safety systems.

    c. Despite the fact that DOE Order 5480.20, Personnel Selection,
       Qualification, Training, and Staffing Requirements at DOE Reactor and Non-
       Reactor Nuclear Facilities, was accepted into the DOE-UC contract in
       November 1992, DOE has succeeded in getting only three Training
       Implementation Matrices (TIMs) approved for the six nuclear facilities
       planned for long-term operation at LLNL.  The TIM has been fully
       implemented at only one of these facilities, the Tritium Facility
       (Building 331).  

3.  Discussion/Observations:    

    a. Radiological Protection:

       (1)    General:  The LLNL radiological control program has a highly-
              experienced and highly- qualified staff.  Evidence for a generally
              successful program includes the fact that external doses have been
              steadily declining over the years.  In addition, in the last five
              years, only three individuals have had committed effective dose
              equivalents of greater than 100 mrem.

       (2)    Implementation Plan:  LLNL was not contractually obligated to
              implement the RCM until December 2, 1993, when DOE Order 5480.11A,
              Change 3 was added to the DOE-University of California contract. 
              Currently, the Laboratory claims compliance with 85% of the
              requirements in the RCM.  The weakest area is in meeting
              requirements for training and recordkeeping.  The implementation
              plan calls for full compliance by October 1, 1996.  

       (3)    ALARA Program:  Individual operations are reviewed by facility
              operations and health physics personnel to identify potential ALARA
              improvements and in some cases significant exposure reductions have
              been realized.  There is room for improvement, however.  The RCM
              suggests 22 radiological performance indicators that could be used
              as metrics in a performance goals program; however, LLNL has only
              one radiological performance goal, to reduce the collective
              occupational radiation dose to 95% of the previous five year running
              average.  The lack of a robust radiological performance indicator
              program hampers the ability of management to monitor the
              effectiveness of the ALARA program.  Further, review of radiological
              data is the responsibility of first line supervision who, at LLNL,
              are not provided any formal, documented guidance.  

       (4)    Documentation Controls:  Discipline Action Plans (DAP) define
              radiological control requirements for each facility.  There is
              currently no formal change control system for these documents.  In
              the future, LLNL plans to develop electronic, on-line versions to
              provide document control.

    b. Conduct of Operations:

       (1)    General:  The staff was briefed that the Laboratory Executive
              Officer has the responsibility for independent oversight while the
              Associate Director for Plant Operations has line responsibility.  In
              February of 1995, a new organizational structure will be in place
              with two Deputy Directors:  one for Operations and one for Programs. 
              The Deputy Director for Operations will assume overall
              responsibility for implementing a satisfactory style and level of
              conduct of operations. 

       (2)    Implementation Plan:  DOE Order 5480.19 was added to the DOE-UC
              contract on December 2, 1993.  At the present time, according to the
              Facility Manager, the Plutonium Facility is in compliance with only
              69% of the requirements.  The elements not yet in compliance include
              the following:  conduct of operations training needs to be developed
              for managers and supervisors and policies and procedures need to be
              developed for independent verification, recordkeeping, equipment
              operating procedures, equipment and piping labeling, indirect
              monitoring of operating parameters, the required reading program and
              operator-aid postings. 

       (3)    Off-Shift Staffing in the Plutonium Facility:  The Plutonium
              Facility is not manned during off-shifts and weekends.  While the
              facility is toured about every two hours by a maintenance mechanic,
              this individual is not necessarily qualified to operate or perform
              maintenance on the building safety systems.  This practice is not
              consistent with that of other plutonium facilities in the weapons
              complex.  According to the facility engineer, the response times
              used by LLNL to justify their off-shift staffing policy have not
              been validated. 

    c. Training and Qualification:  DOE Order 5480.20 was accepted into the DOE-
       UC contract on November 20, 1992.  Of the 11 nuclear facilities at LLNL,
       TIMs have been submitted for six.  As of mid August 1994, DOE has approved
       three including the TIM for the Plutonium Facility.  Two of the 11 nuclear
       facilities have been downgraded to non-nuclear and no longer require TIMs;
       three more may get downgraded in the near future.  For the Plutonium
       Facility, the DNFSB staff was briefed that the TIM will be fully
       implemented by April 1, 1995; however, briefing charts presented to the
       staff do not show firm commitments for initial and continuing training
       development.  

5.  Future Actions:  The staff will follow the progress of implementation of the
    DOE RCM and DOE Orders 5480.19 and 5480.20 at LLNL and DOE/OAK.