[DOE LETTERHEAD]
NATIONAL NUCLEAR
SECURITY ADMINISTRATION
April 1, 2003
The Honorable John T. Conway
Chairman
Defense Nuclear Facilities Safety Board
625 Indiana Avenue, NW.
Suite 700
Washington, DC. 20004-2901
Dear Mr. Chairman:
The Defense Nuclear Facilities Safety Board
(Board) letter of December 27, 2002, noted that, despite improvements to the
design criteria document and the process for identification of safety control,
persistent weaknesses need to be addressed to ensure an adequate safety basis for
the operation of the Highly Enriched Uranium Materials Facility (HEUMF). I am committed to ensuring that the HEUMF is
designed with an appropriate safety basis.
My letter dated February 20, 2003, reported that the HEUMF Preliminary
Documented Safety Analysis (PDSA) process has resulted in a change in the
control set and that the isolation holdup approach, which was identified in the
staff report as a concern, is no longer being considered. The interim response also reported the
establishment by BWXT Y-12 of a project team that will develop a plan to
address concerns with the types and physical characteristics of materials and
the technical standard and criteria for their storage in the HEUMF.
The preparation of the draft HEUMF PDSA has
reached the point where we have a more mature preliminary determination of
credited controls for Design Basis events.
The safety analysis indicates that adequate protection to the workers
and the public can be ensured by the identification of credited controls
(Safety Class building and storage racks and Safety Significant fire sprinkler
system) other than a Safety Class secondary confinement system. The secondary confinement system will be
identified in the draft HEUMF PDSA as a Safety Significant system providing
significant defense in depth. Specific
details on the requirements for the secondary confinement system as it performs
this function, such as equipment classification and power supply requirements
for the confinement system fans, will be resolved as part of the PDSA review
and approval process. Additional
information on the HEUMF secondary confinement system and other staff report
issues with the HEUMF Preliminary Hazard Analysis are attached as Enclosure 1,
Confinement System for the HEUMF.
The draft PDSA is scheduled for submittal to
NNSA for formal review in May 2003. NNSA
Site Office and Headquarters staffs continue to coordinate with the contractor
to maintain awareness of the PDSA progress and content. We will maintain an ongoing dialogue with
your staff on our progress in resolving their issues and are planning a staff
review of the HEUMF PDSA after its formal submittal to NNSA; at that time, we
will be prepared to address the resolution of issues in the staff report not
covered in the enclosure.
The Y-12 storage criteria that applies to
all enriched uranium material forms, storage containers, and duration are
specified in the “Criteria for the Safe Storage of Enriched Uranium at the Y-12
National Security Complex,” Y/ES-015/Rl, and “Criteria for Acceptance and
Technical Assessment for Acceptance of Enriched Uranium at the Y-12 National
Security Complex,” Y/LB-15, 920/R2. The
HEUMF must be in compliance with the storage criteria in these documents. As part of the activities committed in the January
31, 2003, NNSA “Report to the DNFSB on the Management of Inactive Actinide Material
at NNSA Sites, Strategy for FY 2003-04 Activities,” Y-12 will revise and update
these documents in FY 2003 with specific focus on HEUMF storage requirements.
Since it will be several years before the
HEUMF is ready to receive material, planning for stored material in the HEUMF
will be based on a strategy that integrates all pertinent ongoing HEU storage
and disposition initiatives. In
addressing issues at Y-12 that resulted in part from the fact that multiple
types of storage containers complicate criticality safety requirements and
affect operator conduct of operation performance, BWXT Y-12 is developing a
plan to evaluate current facility container storage and determine a minimum set
of storage containers that meet facility safety and operational needs, while
simplifying criticality safety and operator handling requirements. In addition, as part of the Material Recycle
and Recovery program, actions are ongoing to develop and execute a project plan
that will evaluate currently stored in-process HEU materials at Y-12 awaiting
further processing with an end goal to establish and execute a path forward for
recovery or discard.
BWXT Y-12 managers are integrating the
actions from these initiatives into a Y-12 Comprehensive Ten-Year HEU Storage
Material Management Project Plan. This
plan will not only form the basis for the HEU that will be stored in the HEUMF
but also will include the planning to move materials to the HEUMF. The Y-12 Site Office and BWXT Y-12 staffs
have had preliminary discussions with your staff on the proposed path
forward. Enclosure 2, “Development of
Comprehensive HEU Storage and Material Management Plan,” includes the current
status and details of our planning.
We will continue to work closely wit11 your
staff to exchange updates on issue resolution as the draft PDSA for HEUMF is
finalized and the project plan for HEU storage at Y-12 is finalized and
executed. As your staff is aware, the
HEUMF project team maintains a log of issues/questions raised by the Board and
staff as a result of their site visits and document reviews. The team uses this log to track resolution
of issues. Several of the comments
included in the Staff Issue Report that are not directly addressed in the
enclosures will be tracked via this log.
If you have any questions concerning our
response to your letter, please contact me or have your staff contact Mr. David
E. Beck at (202) 586-4879 or Mr. Bill Brumley at (865) 576-0752.
Sincerely,
Everet H. Beckner
Deputy Administrator
for Defense Programs