February 2, 2005
Mr. Robert F. Warther
U.S. Department of Energy
Ohio Field Office
175 Tri County Parkway
Springdale, Ohio 45246-3222
Dear Mr. Warther:
The Defense Nuclear Facilities Safety Board (Board) continues to closely monitor the efforts of the Department of Energy’s (DOE) Fernald Closure Project and its contractor, Fluor Fernald, Inc., to retrieve, treat, and package for disposal the radioactive wastes in the silos at Fernald. The Board notes that Fluor Fernald personnel completed readiness reviews for the first two of three phases of the silos remediation effort, including the Silo 3 Retrieval and Disposition Project and the Silos 1 and 2 Accelerated Waste Retrieval Project. Recently, a member of the Board’s staff observed efforts to complete a contractor Standard Startup Review and a DOE Readiness Assessment for the third phase of the silos remediation effort, the Silos 1 and 2 Remediation Facility. This review was stopped when it became apparent that the Fluor Fernald line organization was not adequately prepared to operate the facility safely.
The Board notes that DOE mandated that a DOE Readiness Assessment be completed for each of these activities even though it was not required by DOE directives. The Board also commends those involved in the readiness review process for recognizing the above shortcomings and halting the reviews.
However, the two previous readiness reviews for the silos remediation effort also identified a large number of significant deficiencies. Written comments from both contractor and DOE review teams noted that line management had not been thorough in its readiness preparations. Furthermore, the second DOE Readiness Assessment found that not only had the project’s readiness self-assessment been less than thorough, but the project’s independent assessments, added as corrective actions following the first readiness review, had also been inadequate.
The Board is troubled by the repeated lack of readiness on the part of the Fluor Fernald line organization and the apparent failure of earlier corrective actions to address this problem. A well-prepared organization relies on a readiness review only for validation of its preparations to operate safely and usually passes the review with but a few corrective actions needed to improve operations.
The Board would like to understand what efforts are being made by DOE and Fluor Fernald to address these recurring deficiencies. Therefore, pursuant to 42 U.S.C. § 2286b(d), the Board requests that DOE and Fluor Fernald inform the Board on actions taken to ensure that the Silos 1 and 2 Remediation Facility is fully ready to operate safely. This report should be provided prior to startup authorization from DOE.
John T. Conway
c: Mr. Paul M. Golan
Mr. Mark B. Whitaker, Jr.