The Honorable John T. Conway
Defense Nuclear Facilities Safety Board
625 Indiana Ave, NW, Suite 700
Washington, DC 20004
Dear Mr. Chairman:
The purpose of this letter is to provide the
status of commitments from the Office of Environmental Management (EM) to the
Defense Nuclear Facility Safety Board (DNFSB) that are currently past due.
Three commitments on Sludge Removal at
Hanford as delineated in (a) Commitment 119 of the Implementation Plan (IP) for
Recommendation 2000-1 “Stabilization and Storage of Nuclear Material”, (b) your
April 10, 2003, requirement to report on K-Basins path forward and (c) my June
10, 2003, commitment to provide an update on K-Basins sludge removal:
- The Department is evaluating alternate direct disposition
strategies to process sludge that would eliminate interim storage at the
T-Plant and reprocessing to prepare it for disposal.
- Until such time that EM has an alternate credible path for direct
disposal, the site will continue along the path to remove sludge from the
basins and package it in large diameter containers (LDC).
- The start of removal of sludge from the K-Basins (Commitment 119)
will not start in 2003. The
schedule does not support a Department of Energy Operational Readiness
Review (ORR) before January 2004.
Three commitments (2.9, 2.11, and 2.12) on
the low curie salt-waste process as delineated in the IP for 2001-01 “High-Level
Waste Management at the Savannah River Site”:
- Due to litigation related to waste incidental to reprocessing (WIR)
provisions of DOE Order 435.1, our detailed response to address these DNFSB
2001-01 commitments continues to be worked. I expect to have these response issues
resolved by December 15, 2003.
- The programmatic risk assessment with mitigation strategy
(Commitment 2.12) and the low curie salt processing evaluation (Commitment
2.11) are currently undergoing internal review and will be provided as
soon as the review is complete.
- The South Carolina Department of Health and Environmental Control
has notified the Department that they would take no official action on the
permit applications pending resolution of the ongoing litigation. The Saltstone Facility permit
modifications are required for processing low curie salt feed and disposal
of the resulting grouted waste.
- The transfer of first batch of low curie salt cake from Tank 50 (Commitment
2.9) is thus impacted and will not be completed this calendar year.
There are two actions from the Secretary’s November
22, 2002 letter on
the “Quality Assurance Improvement Plan for Defense Nuclear Facilities”. Past due deliverables include (a) issuing EM
requirements for Functions, Responsibilities and Authorities (FRA) and Quality
Assurance documents and (b) updating the EM Headquarters and Field FRA
documents. EM will revise its FRA
document after the corporate FRA is reworked and issued. A reissued EM FRA document is not expected
before February 2004, with the EM Field FRAs to follow, provided the corporate
FRA is issued by the end of December 2003.
I will provide the Board an update on these
issues by January 31, 2004, and will brief your senior staff next
month. If you have any questions, please
call me at (202) 586-0738.
Paul M. Golan
Chief Operating Officer
Office of Environmental Management