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Inspection Report 

Fire Suppression and Related Services 

at Los Alamos National Laboratory 

DOE/IG-0821 September 2009 

U.S. Department of Energy 

Office of Inspector General 

Office of Inspections 
Department of Energy 

Washington, DC 20585 

September 11, 2009 

MEMORANDUM FOR THE SECRETARY 

 FROM: Gregory H. Friedman 

 Inspector General 

SUBJECT: INFORMATION: Inspection Report on “Fire Suppression and 

Related Services at Los Alamos National Laboratory” 

BACKGROUND

The Department of Energy’s (DOE’s) Los Alamos National Laboratory (LANL) is a 

multidisciplinary research institution engaged in strategic science on behalf of national 

security. LANL operates in “unique” hazard environments, to include special nuclear 

materials, explosives, and hazardous chemicals, that create special fire suppression and 

emergency management challenges. To address these challenges, LANL must have a 

comprehensive approach to the protection of personnel, facilities, physical assets, and 

programmatic activities from fire and related dangers. LANL is managed for DOE’s 

National Nuclear Security Administration (NNSA) by Los Alamos National Security, 

LLC, which assumed responsibility for the management and operation of LANL on 

June 1, 2006. 

In December 1992, DOE directly acquired fire suppression and related services under a 

5-year contract with the Incorporated County of Los Alamos (County). The Los Alamos 

County Fire Department (LAFD) provided fire suppression and related services to LANL 

and to the County. The contract expired in December 1997, but the Terms and 

Conditions and the Statement of Work of this contract were continued through a series of 

Pre-Contract Cost Agreements (PCCAs) between LANL and the County over 

approximately the next 11 years. During this period, DOE paid 100 percent of the cost of 

LAFD operations, totaling approximately $135 million. 

Information was provided to the Office of Inspector General (OIG) that problems existed 

with regard to fire suppression and related services at LANL. As a result, we initiated an 

inspection to determine if fire suppression and related services at LANL are assured 

through contractual arrangements with the County. On September 30, 2008, subsequent 

to the initiation of our inspection, the NNSA entered into a Cooperative Agreement with 

the County to provide fire department and related services to LANL. 

RESULTS OF INSPECTION

We concluded that fire suppression and related services had not been assured through 

contractual arrangements with the County. Specifically, we found that: 

 Fire fighters had not been properly trained to confidently and effectively fight fires in 

the unique operational environments they may encounter at LANL facilities; 
 Required pre-incident plans developed by the LAFD lacked the information necessary 

for fire fighters to effectively respond to incidents at LANL; 

 Fire fighters did not have the knowledge of LANL facilities necessary to effectively 

respond in the event of an emergency, and their access to these facilities was 

sometimes precluded; 

 The LAFD’s fire fighting capabilities have not been sufficiently demonstrated 

through exercises with documented assessments of their performance; and, 

 The LAFD did not address a number of the long standing recommendations made in 

the 1995 and 2004 LANL Baseline Needs Assessments (BNAs), and DOE, including 

NNSA, failed to contractually require that they do so. 

In addition, we determined that a number of these issues and concerns were previously 

identified by the Defense Nuclear Facilities Safety Board (DNFSB) and the NNSA over 

the past decade without resolution. 

We concluded that the above conditions were caused by significant problems with the 

administration of the contracting arrangements by DOE, NNSA, LANL, and the County. 

We did not find evidence that anyone actively managed the fire suppression services 

contract for a number of years. In addition, the PCCAs were inappropriately used in 

place of a comprehensive contract over the nearly 11 year period from December 1997 to 

September 2008. 

After years of unsuccessful attempts to negotiate a contract with the County, on 

September 30, 2008, the NNSA entered into a Cooperative Agreement that replaced the 

11 year use of the PCCAs. Since February 2009, the Cooperative Agreement has 

prompted actual and planned initiatives to address some of the conditions identified in 

this report. However, the challenges facing NNSA, LANL, and the County are 

significant, especially given the history of failed attempts to secure the appropriate level 

of fire suppression services for LANL. We believe that the recent initiatives taken by the 

NNSA under the Cooperative Agreement are good first steps, but additional actions are 

needed. NNSA’s efforts must continue into the future with planned improvements being 

realized in order to meet the special fire suppression and emergency management needs 

of LANL. We made several recommendations to the Administrator of the NNSA to 

address our findings. 

MANAGEMENT REACTION

In responding to a draft of this report, NNSA agreed with the recommendations and 

provided information on corrective actions taken or planned. In addition, NNSA stated 

that they understood and agreed that there have been issues related to fire services 

between the County of Los Alamos and NNSA. However, NNSA stated that the report, 

as written, does not appear to take into consideration recent improvements to the 

conditions identified in this report and focuses too much on the problems of the preceding 

11 years. NNSA stated that they believe this has resulted in some mischaracterizations in 

the report. 
We consider management’s agreement with the report recommendations to be generally 

responsive to our report findings. However, we take exception to NNSA’s assertion that 

the report, as written, does not appear to take into consideration recent improvements to 

the conditions identified. Our report specifically identifies areas where NNSA made or 

has planned improvements in the areas of training, pre-incident planning, drills and 

exercises, firefighter knowledge of facilities, disposition and tracking of BNA 

recommendations, and performance based incentives. 

We also take exception to NNSA’s assertion that the report focuses too much on the 

problems of the preceding 11 years, resulting in some mischaracterizations in the report. 

As stated in the report, since February 2009, the Cooperative Agreement has prompted 

actual and planned initiatives to address some of the conditions identified in this report. 

However, the challenges facing NNSA, LANL, and the County are significant, especially 

given the history of failed attempts to secure the appropriate level of fire suppression 

services for LANL. We believe that the recent initiatives taken by the NNSA under the 

Cooperative Agreement are good first steps, but additional actions are needed. 

Contrary to NNSA’s statement that these issues have resulted in some 

mischaracterizations in the report, the report accurately characterizes the weaknesses in 

fire suppression services that have existed at this Laboratory for many years. Continued 

corrective actions are required in order to ensure that the risks to LANL’s facilities, 

personnel, and operations are eliminated. Management’s comments are provided in their 

entirety in Appendix B of the report. 

Attachment 

cc: Deputy Secretary 

 Administrator, National Nuclear Security Administration 

 Chief of Staff 

 Manager, Los Alamos Site Office 

 Director, Office of Internal Review (CF-1.2) 
FIRE SUPPRESSION AND RELATED SERVICES AT 

LOS ALAMOS NATIONAL LABORATORY 

TABLE OF 

CONTENTS 

OVERVIEW 

Introduction and Objective '..................................................... 1 


Observations and Conclusions 1 


DETAILS OF FINDINGS 

Fire Fighter Training ................................................................ 4 


Pre-I ncident Plans .................................................................... 5 


Knowledge of Facilities and Access ..................................... 7 


Exercises and Performance Evaluations 9 


Baseline Needs Assessment ................................................. 11 


DNFSB and NNSA Findings .................................................. 12 


Contract Administration ........................................................... 13 


Use of Cooperative Agreement ............................................. 15 


Government Performance and Results Act ........................ 17 


Summary .................................................................................... 18 


RECOMMENDATIONS .......................................................... 19 


MANAGEMENT COMMENTS .............................................. 20 


INSPECTOR COMMENTS .................................................... 20 


APPENDICES 

A. Scope and Methodology ................................................... 21 


B. Management Comments ' 22 ..........................................................-.............. _.. _-...... _-- .. .. 

Overview 


INTRODUCTION 


AND OBJECTIVE 


OBSERVATIONS AND 

CONCLUSIONS 

The Department of Energy's (DOE's) Los Alamos National 

Laboratory (LANL) is a multidisciplinary research institution 

engaged in strategic science on behalf ofnational security. LANL 

operates in "unique" hazard environments, to include special 

nuclear materials, explosives, and hazardous chemicals, that create 

special fire suppression and emergency management challenges. 

To address these challenges, LANL must have a comprehensive 

approach to the protection ofpersonnel, facilities, physical assets, 

and programmatic activities from fire and related dangers. LANL 

is managed for DOE's National Nuclear Security Administration 

(NNSA) by Los Alamos National Security, LLC, which assumed 

responsibility for the management and operation ofLANL on 

June 1, 2006. 

In December 1992, DOE directly acquired fire suppression and 

related services under a 5-year contract with the Incorporated 

County of Los Alamos (County), The Los Alamos County Fire 

Department (LAFD) provided fire suppression and related services 

to LANL and to the County. The contract expired in December 

1997, but the Terms and Conditions and the Statement of Work of 

this contract were continued through a series of Pre-Contract Cost 

Agreements (PC CAs) between LANL and the County over 

approximately the next 11 years. During this period, DOE paid 

100 percent ofthe cost ofLAFD operations, totaling 

approximately $135 million. 

Information was provided to the Office of Inspector General (OIG) 

that problems existed with regard to fire suppression and related 

services at LANL. As a result, we initiated an inspection to 

determine iffire suppression and related services at LANL are 

assured through contractual arrangements with the County. On 

September 30, 2008, subsequent to the initiation of our inspection, 

the NNSA entered into a Cooperative Agreement with the County 

to provide fire department and related services to LANL. 

We concluded that fire suppression and related services had not 

been assured through contractual arrangements with the County, 

Specifically, we found that: 

• 	 Fire fighters had not been properly trained to confidently and 

effectively fight fires in the unique operational environments 

they may encounter at LANL facilities; 

Page 1 	 Fire Suppression and Related 

Services at Los Alamos 

National Laboratory 
• 	 Required pre-incident plans developed by the LAFD lacked the 

information necessary for fire fighters to effectively respond to 

incidents at LANL; 

• 	 Fire fighters did not have the knowledge ofLANL facilities 

necessary to effectively respond in the event of an emergency, 

and their access to these facilities was sometimes precluded; 

• 	 The LAFD's fire fighting capabilities had not been sufficiently 

demonstrated through exercises with documented assessments 

oftheir performance; and, 

• 	 The LAFD did not address a number ofthe long standing 

recommendations made in the 1995 and 2004 LANL Baseline 

Needs Assessments (BNAs)l, and DOE, including NNSA, 

failed to contractually require that they do so. 

In addition, we determined that a number ofthese issues and 

concerns were previously identified by the Defense Nuclear 

Facilities Safety Board (DNFSB) and the NNSA over the past 

decade without resolution. 

We concluded that the above conditions were caused by significant 

problems with the administration ofthe contracting arrangements 

by DOE, NNSA, LANL, and the County. We did not find 

evidence that anyone actively managed the fire suppression 

services contract for a number of years. In addition, the PCCAs 

were inappropriately used in place of a comprehensive contract 

over the nearly 11 year period from December 1997 to September 

2008. 

After years of unsuccessful attempts to negotiate a contract with 

the County, on September 30,2008, the NNSA entered into a 

Cooperative Agreement that replaced the 11 year use ofthe 

PCCAs. Since February 2009, the Cooperative Agreement has 

prompted actual and planned initiatives to address some ofthe 

conditions identified in this report. However, the challenges facing 

NNSA, LANL, and the County are significant, especially given the 

history offailed attempts to secure the appropriate level offire 

suppression services for LANL. We believe that the recent 

initiatives taken by the NNSA under the Cooperative Agreement 

are good first steps, but additional actions are needed. NNSA's 

A Baseline Needs Assessment is an assessment ofthe fIre protection emergency response organization that 

establishes the site fife fIghting capabilities. 

Page 2 	 Observations and Conclusions 

I 
efforts must continue into the future with planned improvements 

being realized in order to meet the special fire suppression and 

emergency management needs ofLANL. 

We note that an October 1995 OIG Audit Report, "Audit of Fire 

and Emergency Medical Services Cost Sharing Between the 

Department ofEnergy and Los Alamos County," determined DOE 

was paying about 99 percent ofthe cost ofthe LAFD while using 

about 47 percent ofthe services. This 1995 Audit recommended 

alternative methods for sharing costs or separating responsibility 

for these services. In addition, on June 23, 2009, the OIG issued 

an Audit Report on "Fire Protection Deficiencies at Los Alamos 

National Laboratory." This audit disclosed that many ofthe fire 

protection "pre-existing conditions" identified during the June 1, 

2006, LANL contract transition to Los Alamos National Security, 

LLC, had not been resolved. 

Page 3 Observations and Conclusions 
Details of Findings 


FIRE FIGHTER 

TRAINING 

Training Weaknesses 

Site Specific Training 

We found that fire fighters had not been properly trained to 

confidently and effectively fight fires in the unique operational 

environments they may encounter at LANL facilities. 

Under DOE's December 1992 contract with the County, the LAFD 

was required to develop a training program to maintain a minimum 

level offire suppression service. Under this program, training for 

fire fighters was required to meet National Fire Protection 

Association (NFP A) 1001, "Standard for Fire Fighter Professional 

Qualifications." In addition, the contract required pre-incident 

training that provided a comprehensive working knowledge of 

building protection, including technical indoctrination in nuclear 

criticality, radiation protection, explosives, large electrical 

installations, and LANL experimental facilities. The contract 

stated that DOE was to provide training, as required, that involved 

specific types ofhazardous material that were unique to LANL 

operations. The 1992 contract terms were carried forward under 

the PCCAs until September 30,2008. (Training under the 

Cooperative Agreement is discussed later in this report.) 

Contrary to these requirements, fire fighters had not received the 

necessary and required training for fighting fires at LANL. 

Specifically, we determined that LAFD fire fighters had not been 

trained in: 

• Nuclear criticality safety; 

• Glove box and special nuclear material fire fighting; 

• Explosives fire fighting; 

• Chemical and biological agent fire fighting; and, 

• Fighting fires involving gases. 

The LAFD Annual Training Plan for 2008 only included 16 total 

hours of LANL site specific training on an "as needed" basis, 

without identifying detailed training requirements. During 

interviews ofLAFD fire fighters, the majority told us that they did 

not feel prepared and trained to fight all types of fire incidents at 

LANL. 

In an effort to address these training shortfalls, LANL personnel 

at Technical Area (TA)-16 and TA-55 recently developed site 

specific training and guidance for emergency responders. Site 

Page 4 Details of Findings 
PRE-INCIDENT PLANS 

Plan Elements 

officials recognized that, to adequately respond to incidents at 

these highly sensitive facilities, the fire fighters needed additional 

infonnation that was not provided in LAFD fire fighter training or 

pre-incident plans. 

The new site specific training and guidance included details 

regarding facility fire scenarios, staging of LAFD equipment and 

personnel, and fire fighting techniques. For example, at T A -16, 

specific infonnation was provided to the LAFD on fire incidents 

involving buildings with explosives. At T A-55, specific 

infonnation was provided to the LAFD on extinguishing fires in 

glove boxes involving nuclear material. 

The efforts at TA-16 and TA-55 to develop site specific training 

and guidance for emergency responders represent a proactive effort 

on the part of LANL to improve fire suppression services. 

However, other LANL facilities have special operational 

environments that need to be similarly addressed. 

We found that required pre-incident plans (also referred to as prefire plans) developed by the LAFD lacked the infonnation 

necessary for fire fighters to effectively respond to incidents at 

LANL. 

Under the December 1992 contract with the County, the LAFD 

was required to implement a Pre-Fire Planning Program "to 

develop and maintain [pre-incident] plans for incidents which the 

Fire Department responds to." The contract required pre-incident 

plans to be developed by the County, with infonnation obtained 

primarily by on-site surveys, and reviewed at least annually or as 

conditions warranted. 

According to NFPA Standard 1620, "Recommended Practice for 

Pre-Incident Planning," the pre-incident plan should be the 

foundation for decision-making during an emergency situation and 

should provide important data that will assist the incident 

commander in developing appropriate strategies and tactics for 

managing the incident. The principles identified in NFP A 

standards were incorporated into DOE Order 420.1B, "Facility 

Safety," and the DOE "Model" Fire Protection Program, which 

demonstrates acceptable methods and examples to assist each DOE 

site in meeting the fire protection program's objectives. 

Pre-incident plans are required for every facility at LANL. We 

reviewed the pre-incident plans for two critical facilities at LANL, 

the plutonium facility at T A-55 and the Chemistry Metallurgy 

Page 5 Details of Findings 
Radioactive Materials 

Criticality Safety 

Research (CMR) facility. We found that these pre-incident plans 

lacked critical information necessary for fire fighters to effectively 

respond to fire incidents in these facilities and did not include 

information recommended by NFPA Standard 1620 and DOE's 

"Model" Fire Protection Program document. Specifically, the 

plans did not contain: 

• 	 Scenarios: Information used to anticipate likely scenarios; 

• 	 Extinguishment: Any unusual materials or methods 


required for extinguishing fires; 


• 	 Exposures: A list of any buildings and/or other features 

that might possibly be affected in an emergency situation; 

• 	 Equipment response: The equipment that would normally 

respond to alarms in each facility, as well as any special 

equipment that might be needed, including backup 

equipment for second alarm responses; 

• 	 Plan of attack: Positioning of each fire engine and any 

special information necessary for attacking fires in the 

building; and, 

• 	 Entry: A list of all entrances to the building. 

We also determined that, although the pre-incident plans for TA-55 

and the CMR facility acknowledged the presence ofradioactive 

materials inside the buildings, neither plan identified: (1) 

radioactive materials as a fire hazard; (2) the exact locations ofthe 

radioactive materials; or (3) guidelines for extinguishing specific 

radioactive materials. For example, plutonium, especially finely 

divided material, is a radioactive fire hazard, and magnesium oxide 

sand is the most effective material for extinguishing plutonium 

fires. However. the pre-incident plan for the plutonium facility 

failed to identify radioactive materials as a "Fire" hazard. only 

showing radioactive material as an "Acute Health" and a "Chronic 

Health" hazard. In addition. the plan did not identify the locations 

of plutonium or that magnesium oxide sand is the most effective 

method to extinguish a fire involving plutonium. 

In addition. we determined that the pre-incident plans for the 

plutonium and CMR facilities did not incorporate criticality safety 

controls for fire fighting in areas within or adjacent to "moderatorcontrolled areas." DOE Order 420.1B establishes requirements for 

Page 6 	 Details of Findings 
Authority Havi ng 

Jurisdiction 

KNOWLEDGE OF 

FACILITIES AND 

ACCESS 

a criticality safety program applicable to DOE nuclear facilities and 

activities that involve, or potentially involve, nuclear materials in 

quantities beyond certain specifications. The Order specifies that 

guidelines for fire fighting must be established for areas within or 

adjacent to moderator-controlled areas, which are areas where 

appropriate precautions must be taken when using water as a fire 

fighting agent. DOE Standard 1158-2002, "Self-Assessment 

Standard for DOE Contractor Criticality Safety Programs," requires 

that pre-incident plans incorporate criticality safety controls. 

Further, for nearly the past 11 years, we did not find any evidence 

that DOE, including NNSA, provided the LAFD with guidance on 

the level of planning appropriate for: (1) the hazard environments 

at LANL; and (2) the property being "pre-planned." NFPA 1620 

states that the "authority having jurisdiction" has the responsibility 

to determine the level ofplanning appropriate for the jurisdiction 

and the property being pre-planned. DOE Order 420.1B identifies 

the "Head of Field Element" as the "authority having jurisdiction," 

in this case the Los Alamos Site Office (Site Office). 

In order to compensate for the lack of guidance from the "authority 

having jurisdiction," we found that site personnel at the TA-55 

plutonium facility recently took the initiative to address 

deficiencies and weaknesses in the LAFD pre-fire plan through the 

development of a TA-55 Facility Emergency Response Guide. 

This Guide was intended to provide LAFD personnel with 

information not found in the LAFD pre-fire plan. Consistent with 

NFPA 1620, the Guide, which became effective on January 29, 

2009, provided specific information on various types of 

emergencies that were unique to specific areas ofthe plutonium 

facility, as well as information on materials or methods required 

for extinguishing fires at the facility. While the Guide for TA-55 

is useful, it does not address the larger issue that the pre-incident 

plans developed by the LAFD lack the information necessary for 

fire fighters to effectively respond to incidents at LANL. 

We found that fire fighters did not have the knowledge ofLANL 

facilities necessary to effectively respond in the event of an 

emergency, and their access to these facilities was sometimes 

precluded. 

During our inspection, several LAFD fire fighters expressed 

concern that their lack of knowledge ofLANL facilities could 

impact their ability to effectively respond to an incident. 

Specifically, fire fighters said that: 

Page 7 Details of Findings 
• 	 It can be several years between site visits or tours of 


LANL's highly sensitive facilities; 


• 	 Facility modifications or changes are not identified to the 

LAFD in a timely manner; 

• 	 Changes in facility hazards are not provided to the LAFD 

in a timely manner; and, 

• 	 Fire fighters are frequently rotated from station to station, 

which negatively affects their ability to develop sufficient 

knowledge ofthe facilities they need to respond to in their 

assigned districts. 

Fire fighters also informed us of: 

• 	 Incidents in which badge readers denied LAFD personnel 

access to facilities or did not work; 

• 	 Incidents where keys that should have allowed LAFD 

personnel access to facilities did not work; 

• 	 Coordination problems with the scheduling of access to 

LANL facilities during updates to pre-incident fire plans; 

• 	 Instances where they were denied access to areas inside 

some facilities because of a lack of a "need-to-know;" and, 

• 	 Instances where computers onboard emergency vehicles 

were not operational, so pre-incident plans could not be 

viewed. 

We contacted LANL officials to discuss the issues listed above. 

LANL officials agreed that there have been some problems with 

badge readers and that some keys have not worked because locks 

have been changed without notifying the LANL key custodian. 

LANL officials also told us that electronic notifications are 

provided quarterly (or sooner ifrequired) from LANL to the LAFD 

concerning physical modifications or changes to facilities as well 

as changes in facility hazards. 

An LAFD official confirmed that they do receive communications 

from LANL on these types ofmodifications and changes. We 

were told that this information is provided to the fire fighters 

through computer updates on a weekly basis (or sooner if 

Page 8 	 Details of Findings 
EXERCISES AND 

PERFORMANCE 

EVALUATIONS 

Exercises 

required). However, the LAFD official acknowledged that this 

process has .not been totally effective in ensuring that fire fighters 

are fully aware of such modifications and changes. The LAFD 

official told us that the fire department is taking steps to improve 

the process by verbally informing fire fighters of updates that 

affect their knowledge of facilities. 

Finally, we confirmed the condition involving computers onboard 

emergency vehicles by witnessing unsuccessful attempts by LAFD 

personnel to operate the onboard computer located on a primary 

response fire engine for LANL. 

We found that the LAFD' s fire fighting capabilities had not 

been sufficiently demonstrated through exercises with documented 

assessments oftheir performance. 

According to DOE Order ISI.IC, "Comprehensive Emergency 

Management System," emergency planning must include 

identification of hazards and threats; hazard mitigation; 

development and preparation of emergency plans and procedures; 

identification of personnel and resources needed for an effective 

response; and practicing response through training, drills, and 

exercises. We were told by LANL officials that LANL schedules, 

plans, coordinates, conducts, and evaluates exercises on a 

continuous basis at its nuclear and high and medium hazard 

facilities in accordance with direction in DOE Order 151.1 C. 

Drills and exercises are conducted as designated by LANL' s 

Emergency Operations Division. Development of exercises is 

based upon the facility/site hazards and types of scenarios 

identified in LANL' s Emergency Planning Hazard Assessment, 

which is used in preparation ofLANL emergency plans and 

procedures. 

LANL officials told us that during the initial exercise planning 

phase, ifit is determined that the exercise scenario warrants 

participation by the LAFD, LANL requests that a LAFD 

representative participates on the exercise design team. The LAFD 

representative would provide technical knowledge regarding 

LAFD operations and input for scenario development; develop 

guidelines and/or limitations regarding LAFD participation in the 

exercise; and, develop objectives specific for their organization. 

LANL officials said that the expectation for an effective exercise is 

that the LAFD would participate with a "real time response2

," 

2 "Real time response" is other than a staged or simulated response. The term is used to describe a typical response 

as ifthe event were an actual emergency. 

Page 9 Details of Findings 
Assessments and 

Documentation 

including a full complement offire department personnel and 

equipment. 

However, we were told that when LANL contacts the LAFD to 

request its participation in the LANL exercise planning phase and 

the actual exercise, the common response from the LAFD is that it 

is unable to participate due to a lack of available manpower and 

resources. LANL officials also told us that on those occasions 

when the LAFD agreed to participate in an exercise, it would only 

send a Battalion Chief and his driver in one LAFD vehicle, an 

SUV. This limited response by LAFD to exercises results in the 

Battalion Chief simulating LAFD participation in the scenario 

rather than a "real time response." Thus, LAFD fire fighters have 

not sufficiently participated in exercises to validate their response 

capabilities. 

A LAFD official told us that they participate in the LANL 

exercises "as available." Further, we were told that the LAFD 

feels that the exercises are geared more towards testing LANL's 

capabilities and responses; not the fire department's, and they do 

not feel they always need to be there. We were told that the 

exercises tie them up, sometimes for up to four hours, where they 

are considered "out of service" and they would be unable to 

respond to other calls at LANL and the City ofLos Alamos, which 

is their first priority. The LAFD official said that when they 

participate in a LANL exercise, they are unable to respond "real 

time" using resources already on duty because it depletes their 

manpower and resources, and "ifthe Lab wants us to be there, they 

will need to pay us overtime." 

According to DOE Order 151.1 C, LANL' s readiness assurance 

must include assessments and documentation to ensure that 

stated emergency capabilities are sufficient to implement 

emergency plans. However, a LANL official told us that when 

"outside entities3

," including the LAFD, participate in LANL 

exercises and drills, the "outside entities" develop their own 

objectives for inclusion in exercise planning, and those objectives 

are not evaluated by LANL. The official said that offsite response 

organizations, such as the LAFD, evaluate their own performance 

in an exercise against their own objectives. The official further 

said that other subcontractors to LANL have a more robust 

program tied to DOE requirements to evaluate and assess 

3 "Outside entities" is a tenn used by LANL to identify outside governmental authorities such as the Los Alamos 

Police Department, U.S. Forest Service, U.S. Park Service, the Federal Bureau ofInvestigation, the State ofNew 

Mexico, and the LAFD. 

Page 10 Details of Findings 
BASELINE NEEDS 

ASSESSMENT 

perfonnance during participation in LANL exercises, but the 

LAFD has never been held to the same level of accountability due 

to the lack of a fonnal contract for many years. As a result, LANL 

was not able to evaluate the perfonnance and capabilities of the 

LAFD to timely and effectively respond to site emergencies. 

The December 1992 contract between DOE and the County stated 

in Part III, Statement of Work, Section XIV, Self Assessment 

Program, that the Contractor (the County) shall develop and 

implement a self-assessment program to provide means to assess 

the perfonnance ofthe fire department. The Contractor shall 

perfonn and document perfonnance evaluations and shall 

document and perfonn corrective actions. 

However, a LAFD official told us that they had never conducted 

and documented perfonnance evaluations in any kind of selfassessment that established and identified lessons learned or 

corrective actions. This official also said that they did not evaluate 

LAFD perfonnance in LANL exercises and that no one (i.e., 

NNSA, DOE, or LANL) had ever infonned them that they had to 

conduct an evaluation oftheir exercise perfonnance. Another 

official said that, if they identify any issues of concern at a LANL 

exercise, their internal process is to handle it at that time in the 

field, in the fonn of a brief discussion. This official also said that 

if an issue of concern warranted any further discussion or review 

"we may put it into an [LAFD] annual training plan." 

We believe that (1) the LAFD's failure to fully participate in 

planned LANL exercises and (2) LANL's, the LAFD's, and the 

Site Office's failure to ensure that appropriate evaluations were 

conducted ofthe LAFD's perfonnance prevents LANL and NNSA 

from having the necessary assurances that the LAFD could provide 

an appropriate level ofresponse to an incident at LANL's unique 

facilities. 

We found that the LAFD did not address a number of the long 

standing recommendations made in the 1995 and 2004 LANL 

BNAs, and DOE, including NNSA, failed to contractually require 

that they do so. This resulted in continuing weaknesses in the 

capability of the LAFD to respond to a fire or other emergency 

event at LANL since several ofthe outstanding recommendations 

addressed training, staffmg, and pre-incident plans. 

DOE Order 420.1B states that a fire protection program requires a 

BNA of the fire protection emergency response organization that 

establishes the site fire fighting capabilities. The BNA is expected 

Page 11 Details of Findings 
DNFSBAND 

NNSA FINDINGS 

to reflect applicable NFP A codes and standards and be updated at 

least every three years or whenever a significant new hazard is 

introduced that is not covered in the current BNA. 

LANL's 1995 BNA found a series of conditions and trends that 

indicated a significantly increased risk offire at LANL. The BNA 

concluded that this situation was "a severe threat to the institution, 

its mission and its surroundings." The 1995 BNA contained 32 

recommendations, many ofwhich addressed weaknesses in LAFD 

performance. These recommendations ranged from having fire 

department services provided by a single, highly professional 

entity to having better pre-fire plans that are site-specific and 

address the conditions found at LANL. The next BNA, conducted 

in 2004, contained 17 recommendations, including 6 from the 1995 

BNA that had not been addressed. We note that this approximately 

9-year lapse oftime between BNAs was not consistent with the 3­

year update requirement of DOE Order 420.1B. 

We determined that a number ofthese issues and concerns 

were previously identified by the DNFSB and the NNSA over the 

past decade without resolution. For example: 

• 	 In August 1999, the DNFSB found that neither LANL nor the 

LAFD presented data addressing important program features 

such as pre-fire plans; LAFD staffing, training, and equipment; 

and the use of a BNA; 

• 	 In June 2002, the NNSA concluded thatthe consequence of 

several years ofdelay in negotiating a contract between LANL 

and the LAFD was that minimum expectations regarding the 

capability ofthe LAFD to respond to emergencies in a timely 

and effective manner were not clearly defined, documented, 

and agreed upon; and, therefore, they may not be met; 

• 	 In April 2005, the DNFSB found that there was no corrective 


action plan in place to address the recommendations ofthe 


2004 BNA, which had been intended to address staffing, 


training, and equipment needs for the LAFD; and, 


• 	 In December 2008, the DNFSB indicated that there were 


weaknesses in the capability ofthe LAFD to respond to a fire 


or other emergency event in the unique hazard environment 


associated with defense nuclear facilities at LANL, citing 


minimal progress in closing the recommendations from the 


Page 12 	 Details of Findings 
CONTRACT 

ADMINISTRATION 

Administration 

2004 BNA, which corresponded to weaknesses in staffmg, 

training, and planning observed during recent exercises. 

The DNFSB also concluded that observations regarding recent 

site exercises suggested significant weaknesses in the ability of 

the LAFD to provide an appropriate level of emergency 

response to LANL's defense nuclear facilities and indicated a 

lack of comprehensive training and hazard awareness, 

insufficient staifmg, and a lack of individual facility response 

planning. The DNFSB stated that these observations required 

near-term actions to improve emergency responders' training, 

pre-planning, and familiarity with the defense nuclear facilities 

at LANL. The DNFSB also noted the need to refine exercise 

objectives of emergency responders, including the LAFD, in 

order to assess the effectiveness oftraining and planning more 

rigorously. 

We concluded that the preceding conditions were caused by 

significant problems with the administration ofthe contracting 

arrangements between DOE, NNSA, LANL, and the County. 

We did not find evidence that anyone actively administered or 

managed the fire suppression services contract for a number of 

years. As early as March 1994, DOE proposed transferring the 

administration ofthe fire suppression contract with the County to 

LANL. At that time, LANL raised several questions regarding the 

proposed transfer, including what was the defmition of 

"administration" and what were the roles, responsibilities, duties, 

authorities, and requirements of the contract administrator. We did 

not find evidence that these questions were addressed. 

When the 1992 contract ended in December 1997, it was continued 

through the use of PC CAs that incorporated by reference the 

Terms and Conditions and the Statement of Work ofthe 1992 

contract. LANL and the County were the signatories on the 

PCCAs, creating the appearance that LANL would administer the 

agreements. However, based on our interviews of DOE and LANL 

personnel, there apparently remained considerable confusion over 

the roles, responsibilities, and authorities under the PCCAs. 

Current LANL officials were under the impression that DOE 

directed LANL to enter into the PCCAs with the County. 

Given that the Terms and Conditions and the Statement of Work of 

DOE's 1992 contract with the County carried forward in the 

PCCAs, it is unclear to us how DOE could assign LANL 

responsibility for administering a Federal contract, which is an 

Page 13 Details of Findings 
Use of the PCCA 

inherently governmental function. We were told by one NNSA 

contracting official that the transfer of a DOE prime contract to 

LANL was "illegal." We were told by another NNSA contracting 

official that there was no known mechanism for effecting this 

transfer. We did not identify any evidence showing how this 

transfer took place or under what authority. 

A contracting official for Los Alamos National Security, LLC, told 

us that they viewed their role as a "transfer agent" in relation to the 

fire suppression and emergency services being provided by the 

County. As a transfer agent, they ensured the County was funded 

to provide the fire suppression and emergency services, but they 

did not issue direction to the County, nor did they evaluate the 

level ofservice to ensure that the services provided met the 

requirements ofthe PCCA. We were told that in instances where 

there were issues with the services being provided by the County 

or with the PC CAs, LANL viewed these issues as being the 

responsibility ofNNSA and referred them to the Site Office. 

In contrast, no official that we spoke to accepted responsibility for 

management ofthe PCCAs between December 1997 and 

September 2008. A Site Office official told us that, to the best of 

his recollection, the responsibility for providing day-to-day 

direction to the fire department and administration ofthe 

contracting arrangement belonged to LANL. This official said that 

ifLANL encountered any difficulties in performing those 

functions, the Site Office would intervene, as necessary. 

We also determined that the PCCAs were inappropriately used in 

place of a comprehensive contract over the nearly 11 year period 

from December 1997 to September 2008. As the name states, PreContract Cost Agreements are supposed to be used when there is a 

need to allow a subcontractor to begin work before a subcontract 

can be issued. As such, PCCAs are not intended to be used for 

such an extended period oftime. In fact, LANL's own internal 

policy states that the period covered by a PCCA shall not exceed 

45 working days. Extensions beyond 45 days can be authorized, 

but the use ofthis authority for nearly 11 years clearly goes beyond 

the intent ofthe agreements. 

We note that when Los Alamos National Security, LLC, took over 

management ofLANL in 2006, it identified the use ofthe PCCAs 

as a "preexisting condition" that needed to be addressed. 

However, NNSA directed Los Alamos National Security, LLC, to 

continue using the PCCAs until a new agreement was reached with 

the County. Therefore, the misuse ofthis instrument continued 

Page 14 Details of Findings 
USE OF COOPERATIVE 

AGREEMENT 

Reaching an 

Agreement 

until September 2008. As a result, problems with the 

administration ofthis agreement persisted for more than a decade 

without resolution, and weaknesses in the areas of fire fighter 

training, knowledge of facilities, pre-incident plans, and exercises 

went unabated. 

After years of unsuccessful attempts to negotiate a contract with 

the County, on September 30, 2008, the NNSA entered into 

a Cooperative Agreement that replaced the nearly 11 year use of 

the PCCAs. Since February 2009, the Cooperative Agreement has 

prompted actual and planned initiatives to address some ofthe 

conditions identified in this report. 

In December 1997, DOE directed the University ofCalifornia, 

which was the LANL management and operating contractor at the 

time, to negotiate a new contract with the County. Between 1997 

and April 2005, the University engaged in negotiations that only 

resulted in the development of a draft Request for Proposal (RFP). 

The Site Office did not accept the draft RFP and directed LANL to 

stop any future work. In June 2005, Site Office officials took over 

responsibility for negotiating a new contract with the County. 

However, the Site Office officials found that the County was not 

willing to sign a contract because the County took exception to the 

"flow-down" terms and conditions ofFederal and DOE 

Acquisition Regulations. Subsequently, NNSA officials at the 

Albuquerque Service Center took over responsibility for 

negotiating a new contract with the County, but these officials 

were met with similar objections by negotiators for the County. 

In an effort to accommodate the County, NNSA decided to pursue 

a Cooperative Agreement in lieu of a comprehensive contract. In 

deciding to use a Cooperative Agreement to acquire fire 

suppression services for LANL, NNSA said it reasoned that the 

primary purpose was to carry out a public purpose ofsupport for 

the County and NNSA. 

Since the principal purpose ofthis agreement was to acquire 

services for the direct benefit ofthe Government, a contract 

between NNSA and the County would have been the more optimal 

instrument to use under DOE policy. DOE's "Guide to Financial 

Assistance" states that Cooperative Agreements are used when the 

principal purpose of a transaction is the transfer anything of value 

to accomplish a public purpose of support, but it also states that 

project benefits or uses should only be indirect or incidental in 

nature. The Guide states that a contract should be used when the 

principal purpose ofthe instrument is to acquire (by purchase, 

Page 15 Details of Findings 
Improvements to 

Conditions Identified 

lease, or barter) property or services for the direct benefit or use of 

the Govetnment. 

However, since February 2009, the Cooperative Agreement has 

prompted actual and planned initiatives to address some ofthe 

conditions identified in this report. 

Specifically, the Cooperative Agreement requires the County, 

NNSA, and LANL to collaboratively develop exercises, drills, and 

site specific training commensurate with the various hazards at 

LANL, with particular emphasis on nuclear and industrial hazards. 

The Cooperative Agreement also requires that the County 

participate in these exercises, drills, and site specific training. In 

addition, NNSA is to ensure that the exercises, drills, and site 

specific training are provided to the County without additional cost 

to the Cooperative Agreement. 

The NNSA designated LANL as the Technical Monitor for the 

administration ofthe Cooperative Agreement in a memorandum 

dated December 10,2008. LANL was required to provide 

specialized and site-specific training for all LAFD uniformed 

responders and command personnel ofthe LAFD. Initially LANL 

had questions about the sufficiency ofthe Cooperative Agreement. 

In a letter dated January 12,2009, to the NNSA Site Office 

Manager, LANL responded to the December 10, 2008, 

memorandum, stating that while the Cooperative Agreement 

represented a major improvement in the formal relationship 

between the County and DOE, some wording in the Cooperative 

Agreement provided for potential gaps in LAFD services. One 

area specifically addressed was training, stating that "there is 

currently no capability, funding, or planning in place to conduct 

this training." However, we were told by a LANL official that this 

concern has been resolved and that a number of actual and planned 

initiatives are under way. These include: 

• 	 A 2009 LAFD Training Plan has been developed and was 

approved in March 2009. 

• 	 117 LAFD fire fighters have been provided with 

Emergency Responder Radiological Training (ERRT) 

between February and April 2009. 

• 	 119 LAFD fire fighters have been provided Pyrophoric 

Material Glove Box Firefighting Training between April 

and the end of June 2009. 

Page 16 	 Details of Findings 
GOVERMENT 

PERFORMANCE AND 

RESULTS ACT 

• 	 Additional LAFD fire fighter training is planned for 

calendar year 2009 to include the use ofContaminated 

Personnel Protection Equipment and Unique Hazardous 

Materials Emergency Response, including high explosives, 

beryllium, biological agents, and tritium. 

• 	 Establishment of a 3-party (LANL, LAFD, and the Site 

Office) Fire Fighter Training Advisory Board which met 

for the first time on April 9,2009. 

• 	 LANL Facility Tours have been scheduled for 2009 and 

2010. Tours ofTA-55 and TA-50 were in progress as of 

February 2009. Additional Tours for TA-3, TA-54, and 

TA-16 are scheduled for 2009 and 2010. 

• 	 A new BNA was approved by NNSA on May 19,2009, 

and NNSA has directed LANL to ensure that the 2009 

BNA recommendations are formally disposed of and 

tracked to closure. 

In addition, the 2009 LAFD Training Plan makes limited reference 

to pre-incidents plans and indicates that Tour/Training information 

will "translate" to LAFD pre-incident plans. Also, the 2009 LAFD 

Training Plan makes limited reference to LANL drills and 

exercises, stating that "LAFD may participate in some ofthe 

various facility drills and exercises as requested by LANL" 

according to a schedule identified in the plan. However, it is not 

clear how these references will address the pre-incident planning 

and exercise issues identified in this report. 

We determined that the Los Alamos National Security, LLC, 

Performance Evaluation Plan does not address LANL fire 

suppression services, nor does it or the Cooperative Agreement 

contain associated performance measures, consistent with the 

intent ofthe Government Performance and Results Act (GPRA) of 

1993. Since 1997, approximately $135 million of taxpayer dollars 

have been spent for fire suppression and related services at LANL 

without any accountability for achieving program results. 

Performance measurement is mandated by GPRA in order to hold 

Federal agencies accountable for achieving program results, as well 

as, to promote a focus on service quality and customer satisfaction. 

The Cooperative Agreement does not clearly create or establish a set 

of performance measures for the LAFD. The Cooperative 

Agreement includes a requirement for the County to provide a yearly 

Page 17 	 Details of Findings 
SUMMARY 


Progress Report assessing the status of work and a comparison of 

actual accomplishments with the established goals and objectives, 

but it does not address how the information will be used to achieve 

program results or promote service quality. The Cooperative 

Agreement does include broad objectives, such as providing an 

enhanced level of fire department services, and requirements in areas 

such as minimum staffing, response times, and training, which are a 

good starting point for establishing performance measures. 

We believe that NNSA needs to develop specific performance 

measures with associated incentives for the LAFD so that: (1) 

progress toward meeting the goals and objectives ofthe 

Cooperative Agreement can be demonstrated; (2) opportunities for 

improvement can be identified; and (3) past problems with the 

provision offire suppression and related services are corrected. 

We note that the NNSA is in the process of establishing a 

Performance Based Incentive for FY 2010 to continue the effort to 

provide for enhanced fire department service training in 2010. 

Specifically, a draft document titled "LANL Enhanced Training of 

Fire Department Personnel" states that LANL shall collaboratively 

define, establish, and provide training for the delivery of enhanced 

fire department services at LANL in FY 2010. 

For nearly the past 11 years, fire suppression services have not 

been assured at LANL, placing LANL in a position of 

unacceptable risk to its facilities, personnel, and operations. In 

addition to critical breakdowns in the contractual relationships 

between DOE, NNSA, LANL, and the County, fire fighters did not 

have the tools they needed to effectively respond to an incident at 

LANL. In addition, DOEINNSA did not have an effective means 

of evaluating fire department performance during exercise and 

drills, and did not have the means to assure that appropriate 

corrective actions were identified and implemented. 

The conditions described in this report not only have the potential 

to severely disrupt the activities of a critical national asset, they 

also have the potential to severely disrupt LANL's critical national 

security missions. The challenges facing NNSA, LANL, and the 

County are significant, especially given the history offailed 

attempts to secure the appropriate level offire suppression services 

for the unique hazard environments at LANL. We believe that the 

recent initiatives taken by the NNSA under the Cooperative 

Agreement are good first steps. However, additional actions are 

needed and NNSA's efforts must continue into the future with 

planned improvements being realized. 

Page 18 Details of Findings 
RECOMMENDATIONS 	 We recommend that the Administrator ofNNSA take immediate 

action to ensure that: 

1. 	 NNSA and LANL continue to develop site specific training 

and guidance for emergency responders under a LANL-wide 

initiative to improve the ability ofthe LAFD to respond to 

incidents involving the unique hazard environments ofLANL. 

2. 	 Fire fighters continue to receive specialized training necessary 

for the specific types ofhazards and hazardous materials at 

LANL, and that fire fighters are made aware of physical 

modifications or changes to facilities as well as changes in 

facility hazards in a timely manner. 

3. 	 Pre-incident plans contain sufficient detail to provide an 

effective response to incidents at LANL facilities, and that preincident plans incorporate criticality safety controls consistent 

with DOE Standard 1158-2002. 

4. 	 Fire fighters are provided with routine tours ofLANL facilities 

in order to gain the familiarity necessary to effectively respond 

in the event of an emergency. 

5. 	 Issues with fire fighters' access to facilities, to include issues 

relating to badge readers and keys, are appropriately addressed. 

6. 	 Computers onboard emergency response vehicles are effective 

as the means of accessing and utilizing pre-incident plans. 

7. 	 The LAFD fully participates in required exercises and drills 

conducted at LANL where a real time response is expected, 

and, consistent with DOE Order 151.1C, NNSA and LANL 

have the capability to assess the fire department's emergency 

response capabilities and address weaknesses while ensuring 

corrective actions. 

8. 	 All recommendations from Baseline Needs Assessments are 

disposed of and tracked to closure. 

9. 	 Appropriate performance measures are developed and 

implemented in order to hold the LAFD and LANL 

accountable for achieving program results as well as to 

promote a focus on service quality and customer satisfaction. 

Page 19 	 Recommendations 
MANAGEMENT 

COMMENTS 

INSPECTOR 

COMMENTS 

10. The entity responsible for administering the Cooperative 

Agreement has the necessary capabilities, resources, and 

authorities for effective administration. 

In comments on a draft ofthis report, NNSA agreed with the 

recommendations and provided information on corrective actions 

taken or planned. In addition, NNSA stated that they understood 

and agreed that there have been issues related to fire services 

between the County ofLos Alamos'and NNSA. However, NNSA 

stated that the report, as written, does not appear to take into 

consideration recent improvements to the conditions identified in 

this report and focuses too much on the problems ofthe preceding 

11 years. NNSA stated that they believe this has resulted in some 

mischaracterizations in the report. 

We consider management's agreement with the report 

recommendations to be generally responsive to our report findings. 

However" we take exception to NNSA's assertion that the report, 

as written, does not appear to take into consideration recent 

improvements to the conditions identified. Our report specifically 

identifies areas where NNSA made or has planned improvements 

in the areas oftraining, pre-incident planning, drills and exercises, 

firefighter knowledge offacilities, disposition and tracking of 

BNA recommendations, and performance based incentives. 

We also take exception to NNSA's assertion that the report focuses 

too much on the problems ofthe preceding 11 years, resulting in 

some mischaracterizations in the report. As stated in the report, 

since February 2009, the Cooperative Agreement has prompted 

actual and planned initiatives to address some ofthe conditions 

identified in this report. However, the challenges facing NNSA, 

LANL, and the County are significant, especially given the history 

offailed attempts to secure the appropriate level offire suppression 

services for LANL. We believe that the recent initiatives taken by 

the NNSA under the Cooperative Agreement are good first steps, 

but additional actions are needed. 

Contrary to NNSA's statement that these issues have resulted in 

some mischaracterizations in the report, the report accurately 

characterizes the weaknesses in fire suppression services that have 

existed at this Laboratory for many years. Continued corrective 

actions are required in order to ensure that the risks to LANL' s 

facilities, personnel, and operations are eliminated. 

Page 20 Recommendations 

Management and Inspector Comments 
Appendix A 


SCOPE AND 

METHODOLOGY 

We conducted the majority ofour inspection fieldwork between 

August 2008 and February 2009. We reviewed applicable policies 

and procedures for facility safety, nuclear criticality safety, and a 

comprehensive emergency management program. These reviews 

also included applicable NFP A standards. 

In addition to reviewing applicable criteria, we also conducted 

extensive interviews with individuals within the affected entities, 

including DOE, NNSA, the LAFD, and Los Alamos National 

Security, LLC. 

Pursuant to the "Government Performance and Results Act of 

1993," we reviewed the LANL 2009 Performance Evaluation Plan. 

We determined that this plan did not contain performance 

measures and expectations for fire suppression services; however, 

providing fire suppression services is not a requirement under the 

LANS contract. In addition, we found no specific performance 

measures and expectations, consistent with the intent of GPRA that 

have been developed by the NNSA for the services provid~d by the 

County under the Cooperative Agreement. We have addressed the 

lack of performance measures and expectations in the body ofthis 

report. 

This inspection was conducted in accordance with the "Quality 

Standards for Inspections" issued by the President's Council on 

Integrity and Efficiency. 

Page 21 Scope and Methodology 
Appendix B 


Department of Energy 


National Hueleer Security AdmInistration 


Washington, DC 20585 


AUG 2 1 2::.:9 

MEMORANDUM FOR Herbert Richardson 

Principal Deputy Inspecto~GP.L-J 

FROM: Michael C. KAneX .;-jYr-----­

Associate Administrato 

for Management and Administration 

SUBJECf: 	 Comments to the IG Draft Report, LANL Fire Suppression, 

Proj. No. S081S013; IDRMS No. 2008-02869 

The National Nuclear Security Administration (NNSA) appreciates the opportunity to 

review the Inspector General's (IG) report, Fire Suppression tmd Related Services at Los 

Alamos National Laboratory. I understand that the 10 initiated this inspection to 

determine iffire suppression and related services at the Los Alamos National Laboratory 

(LANL) are assured through contractual arrangements with the County. 

NNSA understands and aarees that there have been issues related to fire services between 

the County of Los Alamos and NNSA. However, the statement the IG made that LANL 

provides unacceptable risk to its facilities, personnel, and the County of Los, Alamos is 

misleading and an unfortunate statement. 

In the past year, the exhaustive, comprehensive, and collaborative efforts of LANL, the 

Los Alamos Fire Department (LAFD), and the Los Alamos Site Office (LASO) have lead 

to more open communication, a better trained firefighting force, and the improved 

confidcDl:e offirefiahtin& personnel to provide for an effective and safe response for fire, 

medical, or hazardous material emergencies at LANL. The report disregards these recent 

aainI and focuses too much on the problems ofthe preceding nine years. LANL, LASO, 

and LAFD are moving past these issues and the report as written does not appear to take 

into c:onsideration the progress that we have taken and, therefore, we believe that there 

are some miiICharacterizatioDl in the report. Attached are comments from the Site Office 

for your consideration. 

NNSA agrees with the recommendations and corrective actions that have been taken or 

Will be taken. 

1. 	 Continued dew.lopment of sit. spedlie traiaiDl: Corrective actions for this 

recommendation have been previously identified via the LASO approved LAFD 

Training Plan and the FY 20 I 0 Performance Based Incentive designed by the Site 

Office. A training process is already well underway and future· efforts are 

Page 22 	 Management Comments 
Appendix B 


2 

already captured in LASO planning efforts for FY 2010. NNSA believes the 

intent ofthe recommendation has been met and considers this closed. 

2. 	 Fireflgbter specialized traioiDg, updates to haards: Corrective actions for 

thb recommendation have been previously identified via the LASO approved 

LAFD Training Plan, current training activities, and the FY 2010 Performance 

Based Incentive designed by the Site Office. A training process is already well 

underway and future efforts are already captured in LASO planning efforts for FY 

2010. NNSA believes the intent ofthe recommendation has been met and 

considers this closed. 

3. 	 Pre-Ineident Planning Improvemeats: Corrective actions for this 

m:ommendation have been previously identified via the LASO approved FY 

2009 Baseline Needs Assessment recommendation (Rce 14), for which corrective 

actions are already underway. Concerns have already been identified and 

corrective actions are pending. Actions win be completed by the end ofFY 2010. 

4. 	 Fi.refi&bter Tours: Corrective actions for this recommendation have been 

previously identified via the LASO approved LAFD Training Plan, current 

fiv;ility tour activities, and the FY 2010 Performance Based Incentive designed by 

the Site Office. A tour program is already well underway and future efforts are 

alIeady captured in LASO planning efforts for FY 2010. NNSA believes the 

intent ofthe recommendation has been met and considers this closed. 

S. 	 Improvement to Firefighter Aeeess to Faeilitiea: Corrective actions for this 

recommendation have been previously identified via the LASO approved FY 

2009 Baseline Needs Assessment recommendation (Rec 6), for which corrective 

actions are already underway. Concerns have already been identified and 

corrective actions are pending. Actions will be completed by the end ofFY 2010. 

6. 	 V chiele Computer UtDbation: LASO will evaluate this concern as part ofthe 

FY 2009 LASO Fire Department Assessment. Actions will be completed by the 

. end ofFY 2010. 

7. 	 LAFD Esereise Partieipatioa, LASO Aucum.ent: The Cooperative 

A&reement, signed by NNSA and Los Alamos County on September 30, 2008, 

requires LAFD exercise participation and an annual assessment ofLAFD 

activities by the Site Office Program Manaser. As noted earlier in this docUDlalt, 

these actions are underway. The office ofNNSA Emergency Management 

Implementation. NA-43. supported LASO in the annual assessment ofthe LAFD 

during July 2009. NA-43 will continue to provide support for these and other 

emergency-management related activities as requested by the Site Office 

Emergency Management Program Manager. These activities are documented via 

the Cooperative Agreement and are being completed in FY 2009. NNSA believes 

the intent of the recommendation has been met and considers this closed. 

8. 	 BNA RecommeadatioD, Disposition and elolun: LASO directed this action to 

be accomplished when it approved the FY 2009 BNA on May 19,2009. NNSA 

considers this recommendation closed. 

Page 23 	 Management Comments 
Appendix B 


3 

9. 	 Perform.ace Measures Developed: As noted earlier, LASO has designed a FY 

2010 Performance Based Incentive to improve training, tours, and hazard 

identification by LANL to the LAFD. NA-43 participates in the corporate 

process for fonnulating performance measures and objectives to improve 

emergency management performance as well as monitors and evaluates 

performance ofthe Emergency Management Programs against performance 

measures and targets in their PEP. Additionally, the Cooperative AgreeIl1C!lt 

allows LASO to terminate the agreement with the County, as desired. As such, 

performance measures are already in place. NNSA considers this 

teCOmmendation closed. 

10. Cooperative Agreemeat Effective AdmiDistratioa: The NNSA Service Center 

and LASO have the capabilities, resources, and authorities for effective 

Cooperative Agreement administration. There are no further actions for NNSA to 

take on this teCOmmendation and considers it closed. 

Should you have any questions related to this response, please contact JoAnne Parker, 

Acting Director. Policy and Internal Controls Management, 202·586-1913. 

cc: 	 Revitalization Manager, Loa Alamos Site Office 

Senior Procurement Executive 

Director, Service Center 

Page 24 	 Management Comments 
Appendix B 


4 

LASO's Commeats to the Draft IG Iaspeetioa Report: 


Fin Suppreuio& ad Related Services at Los Alamos N.tioaal Laboratory 


A review of the above document continues to identify discrepancies regarding the status 

ofthe services provided by the L05 Alamos Fire Department (LAFD) to the Los Alamos 

National Laboratory (LANL). The current overarching problem with the report is that it 

does not integrate within the report the many numerous beneficial activities that have 

been completed by LAFD, LANL, and the Los Alamos Site Office {LASO) since the 

signina of the Cooperative Agreement {CAl on September 30, 2008. Although the report 

cites problems with this program over the past decade, it is LASO's belief that the 

progress in firefighter training, facility and hazard knowledge and exercise performance 

mIde in the last nine months is reflective ofthe commitment ofthe three parties to 

correct these long-standing issues. The report incorrectly cites the following deficiencies 

(in boJ.dfilce) whereas the current state ofthe program is not addressed. 

lDadequate Training to LAFD 0& Uniq_ LANL ad Site Specifie Hazards: The IG 

Report incorrectly notes that LAFD firefighters had not been trained in criticality safety, 

glovebox and special nuclear material firefighting, explosives fireflghting, chemical and 

biological agent firefighting. Despite LASO and LANL providing details on the training 

performed and planned for Los Alamos County firefighters, through the Site Office 

approveC 2009 LAFD Training Plan, the report does not identify. in this section, the 

training activities regarding the: 

• 	 Emergency Responder Radiological Training (ERRT). 

• 	 Pyrophoric Material Glovebox Firefighting Training. 

• 	 Upcoming activities related to training plan commitments for additional training 

courses, including in calendar year 2009: 

o 	 Unique hazardous materials emergency response, including high 

explosives. beryllium, biological agents. and tritium. 

o 	 Contaminated personal protection equipment donning and dof'fing 

o 	 Annual ERRT Training. 

• 	 Establislunent ofa three-party (LANL, LAFD. and LASO) Firefighter Training 

Advisory Board. 

• 	 Establishment ofa performance baled incentive for FY 2010 to continue the 

effort to provide for enhanced fire department service training next year. 

Althouah these activities are noted in the "Improvements to Conditions Identified" 

section in the rear ofthe report, many of these actions clearly contradict statements in the 

Il:lCR alannin& "Training Weaknesses" section. Additionally. the report continues to cite 

interviews with Los Alamos County firefighters that were performed before the rollout of 

these specific actions, and thus do not reflect what LASO believes is a better trained and 

more toofident fIrefighting force. 

Finally, the report incorrectly mentions this training as specific to TA-16 and TA-55, 

whc'eu such training is applicable to other explosive and nuclear facilities across the 

laboratory. This is a misinterpretation ofthe training approach and applicability of 

response techniques. The report does not reflect the amount ofeffort and success ofthe 

Page 25 	 Management Comments 
Appendix B 


S 

'I'.bre& parties to provide this newly developed training to LAFD and the commitment of 

USO to continuing the effort. 

Pre-IDdcilDt PlaDs LaekiDg Required IDformation: The CA provided the vehicle to 

address this solf-identified (see 2009 BNA, Recommendation 14) deficiency through the 

requirement for the collaborative establishment ofa LAFD Training Plan. The LASoapproved 2009 UFD Training Plan notes that the facility tours and training provided to 

firefi&bfers in 2009 will trIn5I.ate to a LAFD pre-incident plan capturing: 

• 	 Incident response elements or scene factors particular to LANL facilities or 

operations 

• 	 Ventilation system and filter plenum tactical fire fighting considerations 

• Control offirewater runoff. 


Through tours and ttaining provided in 2009, pre-incident plans for these facilities will 


be revised, as necessary. As tours continue to be completed (the LAFD Training Plan 


calls for upcoming tours at CMR [started June 19], WETF, and the NNSB building), 


these pre-incident plans will be updated to capture this important information. 


Lack of ladlity bowled. aDd aceeu: The CA provided the vehicle to address this 

previously identified deficiency through the requirement for the collaborative 

atabJisbment of a LAFD Training Plan. The LASo-approved 2009 LAFD Training Plan 

notes that the facility tours are to be coordinated with LAFD and scheduled thIoughout 

2009 and 2010. LANL and LAFD have coordinated to accomplish the following tours, to 

date, for the followina LANL hazardous material facilities: 

• 	 TA-SS, RLUOB [110 firefighters] 

• 	 TA-SS, PF-4 and surrounding buildings [90 firefighters] 

• 	 TA-SO, RLWTF [12 officers] 

• 	 TA-3, SIGMA and BTF [6S firefighters] 

Thcae are extensive tours, typically 2-4 hours in duration depending on the size ofthe 

facility. LAFD personnel learn about facility operations, hazardous materials, access 

points, ventilation controls, fire suppression capabilities, and expected facility support. 

The thnIe parties made the early determination to attempt to tour ALL firefighters on 

these tours due to shift rotations and the potential for multi-alarm response for a 

si&nificant event. Due to LAFO coverage concerns, such tours typical.ly consist of small 

teImI offirefighters and thus, many tours need to be provided. 

Additionally, the Cooperative Aareement requires LAFD participation for LANL 

hIzardous material facility exercises. LAFD, since FY2008, has been providing support 

for these exerciles (15-20 each year) which require their response to hazardous material 

release events (typical.ly due to flrCS or explosions) and have been raising their awareness 

ofpotential facility events, hazards, access requirements, fire suppression needs and 

capebilities, and LANL emeraency response support. The report incorrectly cites that 

LAFD commonly does not participate in such exercises. The report of a minimal 

participation may have been accurate for previous years, but with the CA stipulations, 

LAFD participation has been much improved in 2009. 

Page 26 	 Management Comments 
Appendix B 


6 

Oataide EDtitia Do Not Aslell LAFD: As mentioned, a previous conference call with 

OOE la, per the CA, LASO has a new requirement to accomplish an annual assessment 

ofLAFD activities. This first assessment is in progress. LASO, through support 

provided by the Office of Emergency Management Implementation (NA-43). contracted 

with a.retired Fire Chief with 3S years of experience, to assess LAFD perfonnance during 

the July 23n1 Full Scale Exercise. This exercise scenario involved an explosion with 

several casualties at the Beryllium Test Facility. LASO will issue this LAFD evaluation 

report prior to the end ofthis Fiscal Year. 

LAFD lack of.dioD OD previous BNA neommeDdatiD...: The draft 10 report does 

not address that the CA provided the impetus for a more rigorous and updated 2009 

BNA, which was approved by LASO on May 19. 2009. It fails to mention that LASO 

required that the 2009 BNA included a review ofthe status ofthe pmrious BNA (2004) 

1WC'MUD.f,!!')dltions, as these were not formally tracked by LANL or LASO. The 2009 

BNA concluded that, ofthe IS recommendations cited in the 2004 RNA (two oftbese 

were identified as out ofscope ofthe 2009 BNA review), 12 had been fully or partially 

implemented. This 2009 RNA conclusion is in direct opposition to the concern ofnot 

addressing previously recommendations cited in the draft IO report. LASO has already 

directed LANL to ensure the 2009 RNA recommendations are formally disposed. ofand 

tmck.ed to closure via the Laboratory's Issue Management Tracking System and resolved 

via an implementation plan. The success of LANL to complete these necessary 

eort'Cdive actions will be addreaed through performance based incentive measures in FY 

2010. 

Page 27 Management Comments 
IG Report No. DOE/IG-0821 

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