[DOE LETTERHEAD]

July 1, 2002

The Honorable John T. Conway
Chairman
Defense Nuclear Facilities Safety Board
625 Indiana Avenue, NW
Suite 700
Washington, D.C. 20004-2901

Dear Mr. Chairman:

This letter is in response to your letter of April 23, 2002, concerning start up of the Los Alamos National Laboratory (LANL) Aqueous Recovery Line for Plutonium-238 (Pu-238) scrap. Your letter identifies concerns related to hazard identification and analysis, and the use of administrative controls. Specific examples of incomplete hazards analyses, and improper safety controls are cited in a Staff Issue Report, dated April 9, 2002. The Board suggested that further evaluation of the safety basis and safety-related controls for the Pu-238 aqueous recovery line is warranted.

Based upon a thorough review of the concerns raised in the Staff Issue Report, LANL and the National Nuclear Security Administration (NNSA) have concluded that: 1) the hazard identification and analysis for Pu-238 aqueous recovery meet applicable standards and guidelines; 2) the application of controls to mitigate risk are consistent with applicable requirements and guidelines; and 3) Technical Safety Requirements established for these activities adequately capture relevant safety controls, in accordance with applicable requirements and guidelines.

In a letter dated June 3, 2002 (Enclosure l), LANL addresses the specific concerns identified in the Staff Issue Report. Specifically, LANL provides clarifying discussion and analyses related to deflagration, resin accidents, mechanical hazard, chemical hazard, reliance on administrative safety controls, and additional observations made by the Defense Nuclear Facilities Safety Board (DNFSB) staff. The Office of Los Alamos Site Operations (OLASO) provides additional discussion (Enclosure 2) related to other issues raised in the Staff Issue Report and in subsequent discussion with the DNFSB Site Representative.

The NNSA has determined that the Process Hazard Analysis for the Pu-238 scrap line and the safety controls identified in the authorization basis documentation are adequate to support safe operations. However, the NNSA and LANL are committed to continuous improvement in the development of authorization basis documents and would welcome additional discussion with the DNFSB to identify opportunities for improvement.

Everet H. Beckner
Deputy Administrator
for Defense Programs

Enclosures

cc w/ enclosures:
M. Whitaker, S.3-1