[DNFSB
LETTERHEAD]
November 28, 2005
The Honorable Linton Brooks
Administrator
National Nuclear Security
Administration
U.S. Department of Energy
1000 Independence Avenue, SW
Washington, DC 20585-0701
Dear Ambassador Brooks:
The Defense Nuclear Facilities
Safety Board (Board) was briefed on October 5, 2005, in response to a reporting
requirement contained in the Board’s letter of April 20, 2005, regarding structural
deficiencies in the 9212 complex at the Y-12 National Security Complex (Y-12),
and the need to eliminate the backlog of nuclear materials placed at risk by
these deficiencies. The Board notes that
the 9212 complex is more than 50 years old and is continuing to deteriorate. The 9212 complex is constructed of metal
frame and hollow clay tile walls. This
facility does not meet safety requirements for Hazard Category 2 nuclear
facilities, and the current path forward does not identify upgrades needed for
the facility to meet these requirements.
In summary, the National Nuclear
Security Administration (NNSA) presented to the Board a plan for a phased
approach to repair maintenance-related deficiencies, followed by an evaluation
of the facility to identify potential modifications to improve its resistance
to earthquakes or other natural phenomena hazards. These improvements would then be prioritized using
a risk-based methodology. NNSA proposed
that an annual review be conducted to determine which modifications will be
implemented. In parallel, an effort to
eliminate the backlog of nuclear materials stored in the 9212 complex is being
undertaken to reduce the material-at-risk. The annual decision on implementing the
additional structural improvements would depend on the operations planned for
the 9212 complex, progress toward the goal of completing construction of the
planned replacement facility, the Uranium Processing Facility (UPF), by 2013,
and progress in reducing the backlog of nuclear materials.
The Board agrees that reduction
of material-at-risk and maintenance-related repairs should be pursued
immediately and aggressively as planned. However, the Board does not agree with the
plan to assess the need for further structural improvements annually unless
decisions on upgrades are directly linked to the achievement of specific
milestones on a specified schedule in the UPF project. Otherwise, the annual assessments could result
in a continuing series of short-term decisions to accept deficiencies in the
9212 complex. Absent a direct link to
progress on UPF, it is not clear what would cause a string of such incremental
decisions to come to an end, or what would drive the difficult decision to
invest heavily in the 9212 complex or shut down its operations should UPF not
be developed as planned.
Although appropriate to support
near-term operations, incremental improvements to the 9212 complex structure
will not be sufficient to allow long-term operations given the continuing structural
and process equipment deterioration. Construction of UPF or a major systemic upgrade
of 9212 to meet Hazard Category 2 safety requirements (if such upgrades are
even practical) is necessary to support long-term performance of the national
security mission at Y-12. Any decision
to upgrade 9212 for long-term operation would require a timely and thorough condition
assessment of the 9212 complex. Absent
that, consideration should be given to closing the facility at a point where
the health and safety of the workers can no longer be objectively assured.
Therefore, pursuant to 42 U.S.C.
§ 2286b(d), the Board requests
that a report be submitted within 60 days of completion of the risk
prioritization activity (scheduled for April 2006), clearly setting forth the
facility modifications that would be implemented should each Critical Decision
milestone for the UPF project be delayed.
Sincerely,
A.
J. Eggenberger
Chairman
c: Mr. William J. Brumley
Mr.
Thomas P. D’Agostino
Mr.
Mark B. Whitaker, Jr.