[DNFSB
LETTEHEAD]
March 24, 2004
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:
In March 2001, the Defense Nuclear Facilities
Safety Board (Board) issued Recommendation 2001-1, High-Level Waste Management at the Savannah River Site. The focus of this Recommendation was on
ensuring that the high-level waste (HLW) system at the Savannah River Site
(SRS) would remain capable of safely supporting vital waste stabilization and
disposition programs through completion. At that time, it was recognized that
maintaining adequate working space in compliant waste tanks would be the
primary challenge in ensuring that the HLW system would remain viable to
support the site’s cleanup activities.
The Department of Energy (DOE) accepted
Recommendation 200l-l and provided the Board with an Implementation Plan with
several deliverables relating to the removal and disposition of salt waste. As part of its accelerated cleanup plan for
SRS, DOE developed a baseline strategy for salt disposition that allowed
decontamination techniques to be tailored to actual radiological
characteristics. Initial estimates of
levels of cesium and actinide contamination indicated that two-thirds of the
salt waste originally slated for processing through the planned Salt Waste
Processing Facility could be disposed of safely and more quickly on site in
near-surface grout monoliths after undergoing more-modest decontamination
processes in existing facilities. This
tailored approach to decontamination is often referred to as the Low-Curie Salt
(LCS) initiative. In a letter dated
March 4, 2002, the Board cautioned DOE not to over-rely on LCS given the large
uncertainty associated with the initial contamination estimates, as well as
regulatory issues. Continued pursuit of
full-scale decontamination facilities has been, and continues to be, encouraged
by the Board.
The waste characterization data obtained
from sampling performed to date indicate that the cesium and actinide
contamination levels in the salt waste are higher than originally estimated. Thus, a much larger fraction of salt waste
than predicted may require processing through the Salt Waste Processing Facility.
Further, a July 2003 federal court
decision that eliminated the waste-incidental-to-reprocessing provisions of DOE
Order 435.1, Radioactive Waste Management,
has invalidated the administrative process used by DOE to establish its basis
for the LCS initiative. In addition,
DOE’s budget request to Congress for fiscal year 2005 includes no funding for
salt processing activities at SRS. These
events may seriously impair the salt processing efforts at SRS.
On March 2, 2004, DOE submitted to the Board
a key deliverable for Recommendation 2001-l—a programmatic risk assessment with mitigation strategies for the salt
disposition program. This risk
assessment identified at least seven high risks (i.e., probabilities of occurrence
ranging from likely to very likely and severity of consequences ranging from significant
to crisis). The risk assessment
deliverable was intended to encourage the development of a robust program plan
for salt disposition that was not over-reliant on the success of the LCS program.
However, the identified risks instead
illustrate an approach that is heavily reliant on the success of LCS.
The programmatic risk assessment was
performed almost a year ago, in March 2003, and events since then have created
risks in the salt processing program not considered in DOE’s report. Of particular interest to the Board, the
programmatic risk assessment does not identify insufficient usable tank space
as a risk to the salt disposition program, nor does it discuss mitigation
strategies to reduce or treat tank farm liquid receipts. The risk assessment did conclude that
insufficient funding represented a high risk with significant schedule impact
and economic consequence, but the only mitigation strategy was to work to
obtain funding, as opposed to a plan to minimize the impact of a perturbation
in funding.
There is now less usable space in the SRS
HLW system than at the time Recommendation 2001-l was issued. Without an effective strategy for dealing with
the aforementioned programmatic risks, the tank space situation will continue
to degrade, which will in turn create safety concerns by increasing operational
risk and jeopardizing vital cleanup activities at the site, including the
retrieval and pretreatment of HLW sludges from old-style tanks, sludge
vitrification at the Defense Waste Processing Facility, and stabilization of
nuclear materials at H-Canyon and HB-Line.
Therefore, pursuant to 42 U.S.C. § 2286b(d), the Board requests a briefing
within 30 days of receipt of this letter addressing the following topics:
1.
DOE’s plan for
management, processing, and stabilization of the HLW at SRS, given the LCS
performance issues discussed above.
2.
DOE’s
contingency plan for accomplishing HLW stabilization at SRS within the funding
contained in the DOE budget request to Congress for fiscal year 2005.
Sincerely,
John T. Conway
Chairman
c: Mr.
Jeffrey M. Allison
Mr. Mark B.
Whitaker, Jr.