August 6, 2004
The Honorable John T. Conway
Defense Nuclear Facilities Safety Board
625 Indiana Avenue, NW, Suite 700
Washington, D.C. 20004-2941
Dear Mr. Chairman:
The purpose of this letter is to provide the response to your letter dated May 3, 2004, regarding the Defense Nuclear Facilities Safety Board observations on the Waste Isolation Pilot Plant Mobile Characterization Unit Generic Documented Safety Analysis. You transmitted a letter with concerns on the Department of Energy (DOE) approved Basis for Interim Operation (BIO) for the Mobile Waste Characterization and Loading Units (MCU). Your letter requested a report that documents: 1) an independent assessment of the adequacy of the BIO; 2) a plan and schedule for correcting deficiencies identified in the “Staff Issue Report,” dated March 25, 2004; 3) an assessment of ongoing activities that may have used a similar safety basis; and 4) actions that will be taken to ensure an adequate set of controls until a technically justifiable safety basis has been prepared and approved.
With respect to item 1), an independent peer review was commissioned on the draft version of the BIO and technical comments were addressed before the document was finalized. Attachment 1 to my letter provides the independent reviewer’s comments and the BIO development team’s responses. The independent reviewer has also reviewed and concurred with the team’s resolution of issues identified by your letter. Additionally, the host sites will document the acceptance of the BIO along with any deviations in accordance with the “licensing criteria” contained in the BIO companion document, Application Guide for Mobile Waste Characterization System Components in Support of the Mobile Operations Authorization Basis.
Regarding item 2) in your letter, several improvements are planned for the BIO, Technical Safety Requirements and Application Guide that will resolve concerns identified in the “Staff Issue Report.” A summary of proposed changes to these documents are discussed in Attachment 2 and are linked to various issues identified by your staff. These changes and other recent lessons learned will be incorporated in the next annual update of the MCU safety basis documents that will be issued in November 2004. A copy will be provided to the Board staff. The BIO development team is currently working with the Carlsbad Field Office to implement proposed changes.
In response to items 3) and 4) of your letter, no site has implemented the BIO. Any site-specific implementation will be in accordance with the annual update. Based on the attached response, the revised safety basis and associated control set will be further improved for transuranic waste characterization activities.
We appreciate your input and will continue to work with your staff as the annual update process proceeds. If you have any further questions, please call me at (202) 586-7709 or Mr. Dae Y. Chung, Director, Licensing Office, at (301) 903-3968.
Paul M. Golan
Acting Assistant Secretary for