[DNFSB LETTERHEAD]
April 4, 2003
The Honorable Jessie Hill Roberson
Assistant Secretary for Environmental
Management
U.S. Department of Energy
1000 Independence Avenue, SW
Washington, DC 20585-0113
Dear Ms. Roberson:
The Hanford Spent Nuclear Fuel Project
(SNFP) is preparing to place K-Basin sludge in interim storage at the 221-T
building (T Plant), where it will be maintained in a retrievable condition
pending final treatment and disposal.
As part of the documented safety analysis (DSA) for this activity, the
contractor performed a seismic evaluation―Seismic Evaluation of the T Plant 221-T
Building for Interim Storage of K-Basin Sludge, 200 West Area, Hanford Site, HNF-6033, Rev. l―to determine potential earthquake effects on
the T Plant structure. Although the
analysis did not conform to the methodology prescribed in the Department of
Energy (DOE) Standard, DOE-STD-1020-94, Natural Phenomena Hazards Design and
Evaluation Criteria for Department of Energy Facilities, or its 2002
revision, the alternative methodology used in HNF-6033, and a limited
independent analysis conducted by the Defense Nuclear Facilities Safety Board’s
(Board) staff, showed that the building’s ultimate seismic capacity
demonstrates an acceptable margin to failure for an existing Performance
Category-2 facility. As such, the Board
believes the building is satisfactory for sludge storage in order to reduce the
risk of leaving the sludge in the K-Basins.
However, portions of the T Plant structure
do not meet minimum reinforcement requirements of the American Concrete
Institute (ACI), ACI 318, Building Code Requirements for Structural Concrete,
and given that the building was constructed more than 50 years ago, the Board
is concerned about the structure’s suitability for any mission other than
sludge storage. The Board understands
that the SNFP is considering processing sludge and other remote-handled
transuranic waste at T Plant, a new mission that may increase the quantity of
materials at risk and invalidate the existing evaluation criteria.
In view of the issues outlined above, the
Board would like to be informed of the K-Basin sludge disposition plans, and of
any proposed changes to the building’s mission.
Sincerely,
John T. Conway
Chairman
c:
Mr. Keith A. Klein
Mr. Mark B. Whitaker, Jr.