[DOE
LETTERHEAD]
August 6, 2004
The Honorable John T. Conway
Chairman
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.
Sincerely,
Paul M. Golan
Acting Assistant Secretary for
Environmental Management