[DOE LETTERHEAD]

 

NATIONAL NUCLEAR SECURITY ADMINISTRATION

 

November 2, 2007

The Honorable A. J. Eggenberger

Chairman

Defense Facilities Nuclear Safety Board

625 Indiana Avenue, NW, Suite 700

Washington, D.C. 20004-2901

 

Dear Mr. Chairman:

 

The purpose of this letter is to report the results of the review of National Nuclear

Security Administration (NNSA) site office and contractor procedures and mechanisms

for using the 25 rem evaluation guideline (EG) as required under Deliverable 8.9.1 of the

Department of Energy's (DOE) Implementation Plan (IP) for Defense Nuclear Facilities

Safety Board (DNFSB) recommendation 2004-2, Active Confinement Systems.

 

Recommendation 2004-2, the Department's 2004-2 IP, and DNFSB/TECH-34,

Confinement of Radioactive Materials at Defense Nuclear Facilities, document concerns

that the 25 rem site boundary exposure EG is not being solely used for classification of

safety controls as described in Appendix A, Evaluation Guideline, of the DOE's

Standard 3009, Preparation Guide for U.S. Department of Energy Nonreactor Nuclear

Facility Documented Safety Analyses, but instead is being used 1) as a design acceptance

criterion for confinement system performance, and 2) as an allowable public dose.

 

By memorandum dated May 18, 2007, (enclosed) the NNSA requested that a review of

site office and contractor mechanisms or procedures for using the 25 rem offsite dose EG

and application to approved safety bases be performed to verify that, consistent with

Appendix A, it is only being used for classification of safety controls, and not for

designing or operating defense nuclear facilities, or as an allowable dose to the public.

Further, NNSA sites were directed to clearly describe any instances where mechanisms

or procedures are found deficient, and the actions that will be taken to correct the

deficiencies.

 

Our review of the NNSA site responses to the May 18, 2007, memorandum and

subsequent discussions with NNSA site office lead safety basis subject matter experts

confirms that, with the following exceptions, site office and contractor processes and

procedures only allow use of the 25 rem offsite dose EG for classification of safety

controls consistent with the guidance of Appendix A to DOE Standard 3009, and not for

designing or operating defense nuclear facilities or as an allowable dose to the public.

 

• Los Alamos Site Office (LASO) Management Procedure (MP) 01.01, Safety Basis
  Review Procedure and Operations Plan, contained the following statement:
  "Evaluation Guidelines (EG) refers to the hazardous material dose/exposure values
  that the safety analysis evaluates against. The intention is that theoretical individual
  doses/exposures exceeding the Evaluation Guidelines should not occur at a given
  point, unlike other values, such as emergency planning thresholds. Offsite Evaluation
  Guidelines are established for the purpose of identifying and evaluating safety-class
  structures, systems, and components." This could be interpreted to mean that doses
  to the public of less than or equal to the EG are acceptable. This procedure has been
  replaced by new procedures that have replaced discussions of the EG with references
  to Appendix A of DOE-STD-3009. LASO has recently implemented the new
  procedures, and is confident that the 25 rem EG has been used appropriately during
  the Los Alamos National Laboratory (LANL)/LASO safety basis reviews despite the
  language in MP 01.01.

 

• The NNSA Nuclear Safety Specialist Qualification Standard Reference Guide, dated

September 2005, contains two sections of text that need to be revised. The first is

section 4.a which states: The evaluation guidelines establish the hazardous material

doses/exposure values that the safety analysis is evaluated against. Theoretically,

individual doses/exposures exceeding the evaluation guideline should not occur at a

given point inside the evaluation area. Offsite evaluation guidelines are established

for the purpose of identifying and evaluating safety-class structures, systems, and

components. This could also be interpreted to mean that doses less than or equal to

the EG are acceptable. The second is section 30.d which states: The accident

analysis is used to quantify the hazard analysis and to bin accidents by order of

magnitude. This is done to have relative values to compare to the evaluation

guidelines that define limits allowable for both workers and the public. This

statement is wrong and must be corrected. The Office of Facility and Infrastructure

Acquisition and Operation (NA-17) is working with the NNSA Service Center to

have these statements corrected in the next revision to the guide which is scheduled to

be issued by December 2007.

 

Based on our review, we do not believe that either of the above situations has resulted in

misapplication of the EG in the development or review and approval of the safety basis

for NNSA defense nuclear facilities.

 

In summary, our review has determined that NNSA site offices and contractors

understand proper use of the 25 rem EG and that it is being used correctly.

 

If you have any questions, please contact me or have your staff contact Rick Kendall,

NA-173 by phone at (301) 903-3102 or by e-mail at Rick.Kendall@nnsa.doe.gov.

 

Sincerely,

 

Martin J. Schoenbauer

Principal Assistant Deputy Administrator

  for Operations

 

Enclosure