May 3, 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:
On November 18, 2003, the Department of Energy (DOE) approved a Basis for Interim Operation (BIO) for the Mobile Waste Characterization and Loading Units for the Central Characterization Project at the Waste Isolation Pilot Plant, and authorized use of this BIO at more than 28 sites without further analysis. This safety basis was intended to comply with the requirements of the Nuclear Safety Management rule (10 Code of Federal Regulations Part 830). It authorizes activities that include waste handling and staging, characterization, nondestructive assay and examination, head-space gas sampling, visual examination and repackaging, and TRUPACT-II loading activities.
The staff of the Defense Nuclear Facilities Safety Board (Board) reviewed this BIO and some of its supporting documents and identified significant technical deficiencies. The issues identified include quality assurance-related issues, such as technical errors; incorrect modeling of accident scenarios; lack of proper documentation of accident analyses; and potentially inadequate identification and classification of controls for protection of the public and workers. These issues, as documented in the enclosed report, were discussed with some of the authors of the BIO during a meeting held on March 5, 2004, at Lawrence Livermore National Laboratory.
The Board is concerned that waste operations using the controls in this safety basis, as authorized in your November 18, 2003 letter, may not adequately protect the public and workers. Therefore, pursuant to 42 U.S.C. § 2286b(d), the Board requests a report within 45 days of receipt of this letter that documents (1) an independent assessment of the adequacy of the BIO, documented in a Safety Evaluation Report; (2) a plan and schedule for correcting the deficiencies and shortcomings identified in the enclosed report; (3) an assessment of ongoing activities that may have used a similar safety basis; and (4) actions that will be taken to identify an adequate set of controls for the ongoing activities until a technically justifiable safety basis has been prepared and approved.
John T. Conway
c: Mr. Mark B. Whitaker, Jr.
DEFENSE NUCLEAR FACILITIES SAFETY BOARD
Staff Issue Report
March 25, 2004
MEMORANDUM FOR: J. K. Fortenberry, Technical Director
COPIES: Board Members
FROM: F. Bamdad, D. Ogg
SUBJECT: Authorization Basis for the Waste Isolation Pilot Plant Mobile Characterization Units
This report documents observations made by the staff of the Defense Nuclear Facilities Safety Board (Board) during a review of a safety basis document approved by the Department of Energy’s (DOE) Office of Environmental Management (EM). This safety basis was prepared for the Mobile Waste Characterization and Loading Units (Mobile Units) for the Central Characterization Project at the Waste Isolation Pilot Plant (WIPP). Staff members F. Bamdad, D. Kupferer, C. March, M. Merritt, D. Ogg, R. Robinson, and W. Von Holle participated in this review. On March 5, 2004, the staff attended a meeting at Lawrence Livermore National Laboratory to discuss the technical contents of the supporting documents for the safety basis with the responsible analysts.
Background. On November 18, 2003, EM approved a Basis for Interim Operation (BIO) for the WIPP Mobile Units and authorized its use as the safety basis at more than 28 sites throughout the defense nuclear complex without performing any additional analyses. The BIO applies to the retrieval, staging, handling, characterization, and repackaging of transuranic (TRU) waste, and is intended to comply with the requirements of the Nuclear Safety Management rule (10 Code of Federal Regulations [CFR] Part 830, [10 CFR Part 830]). The BIO is augmented by an Application Guide that identifies the site-specific conditions to be met prior to implementation of the BIO and operation of the Mobile Units.
DOE’s approval relies on many years of experience with such activities and assumes that operation of the units would not constitute an initial startup. DOE instead categorizes operation of the WIPP Mobile Units as a restart of an approved operation/activity which represents a facility modification. Accordingly, DOE concludes that a Readiness Assessment could be used to approve the activities instead of an Operational Readiness Review (ORR). The Application Guide contains a checklist for the performance of such a Readiness Assessment.
Preparing a generic safety basis for similar activities at different sites may be a valuable tool for achieving consistency and may save resources, but the Board’s staff has identified several deficiencies that raise concern regarding the technical quality of this document.
Basis for Interim Operation. The BIO identifies and evaluates the hazards associated with operations involving waste handling, staging, characterization, nondestructive assay and examination, head-space gas sampling, visual examination, repackaging, and TRUPACT-II loading activities. Some hazardous events are carried forward for quantitative accident analyses and potential identification of safety-related systems. Although no safety-class systems are identified in the BIO, some design features are designated as safety-significant to protect workers from significant consequences of potential events. Additionally, the BIO takes credit for several administrative control programs.
The staff noted several deficiencies in the BIO. Some of these deficiencies are general, while others relate specifically to a drum deflagration accident.
Deficiencies in the Hydrogen Deflagration Analysis
The BIO considers hydrogen generation and accumulation in the drums to be a credible event and analyzes hydrogen deflagration as a potential event. Treatment of the hydrogen deflagration event in the BIO, however, is technically deficient and may have resulted in an inadequate set of controls:
Operational Readiness. DOE Order 425.lC, Startup and Restart of Nuclear Facilities,
mandates that the initial startup of a new hazard category 1, 2, or 3 nuclear facility, or restart of a hazard category 1 or 2 nuclear facility, requires an ORR. The WIPP Mobile Unit operations are categorized as a hazard category 2 nuclear facility because of the substantial amount of radioactive materials involved in the activities. EM, however, authorized the sites to perform a Readiness Assessment once the common elements of the safety basis have been implemented and verified. It should be noted that the activities involved in use of the WIPP Mobile Units may never have been performed at some of these 28 sites; moreover, the systems and equipment involved in the activities need to be set up at each site, and TSR implementation must be verified independently for each operation. Therefore, performance of a Readiness Assessment may not meet the requirements of DOE Order 425.1C or be adequate to ensure safety.
Of note, workers at Lawrence Livermore National Laboratory are using the WIPP Mobile Units at the Decontamination and Waste Treatment Facility. Personnel from the National Nuclear Security Administration’s Livermore Site Office performed an ORR to authorize the startup of operations, as required by DOE Order 425.1C. This ORR identified several pre-start findings, thus demonstrating the necessity of a thorough review before startup of similar operations at other sites.