[DNFSB
LETTERHEAD]
January 5, 2006
The Honorable Samuel W. Bodman
Secretary of Energy
1000 Independence Avenue, SW
Washington, DC 20585-1000
Dear Secretary Bodman:
The Defense Nuclear Facilities
Safety Board (Board) received your letter dated November 28, 2005, enclosing
the Department of Energy’s (DOE) revised Implementation Plan for the Board’s
Recommendation 2000-1, Prioritization
for Stabilizing Nuclear Materials. This
revision makes changes to your commitments regarding the removal and treatment
of sludge from the K-Basins at the Hanford site. In formulating this newest revision to the
Implementation Plan, DOE and its contractor appear to have applied improved
project management techniques and to have conducted a detailed project risk
assessment. The Board accepts this
revision to the Implementation Plan. However, the Board remains concerned about
several aspects of this project.
The Board has long emphasized
the urgency of removing spent nuclear fuel and sludge from the K-Basins to
mitigate the hazard to workers, the public, and the environment posed by these
materials. In attempting to complete
this effort, the K-Basins Closure Project and its predecessor projects have
suffered several setbacks due to deficiencies in design, engineering, and project
management, including poorly managed project risks. The recent project risk assessment provides a
good foundation for improved performance within the project. As mentioned
in your letter, however, the risk assessment is incomplete.
Since the design of the sludge
stabilization and packaging system is not complete, there is insufficient
project information to support the completion of an adequate risk assessment.
This uncertainty has been
addressed in the risk assessment by the inclusion of a large delay (282 days)
in the schedule to account for potential contingencies in the stabilization and
packaging subproject. The Board looks
forward to completion of the system design and risk assessment, and a
subsequent adjustment of the project schedule.
Additionally, the risk assessment―and
the success of the project―are predicated on more than 20 specific
assumptions that themselves represent significant risks. These appear to be treated as “enabling
assumptions,” have not been factored into the risk assessment, and do not have
corresponding risk mitigation strategies identified in the risk assessment
report. It is very important that DOE
and the contractor manage these assumptions carefully, and where appropriate
pursue risk mitigation strategies to ensure the success of the project.
The Board remains concerned that
difficulties with design, engineering, and project management may continue to
delay the project. Although a number of
corrective actions have been taken in the past year to address these problematic
areas, little substantial evidence exists to indicate that the project is now
healthy in these areas. The Board plans
to continue its close observation of the project. A particular milestone of interest is the
startup and operation of the hose-in-hose transfer line. The startup of this system, planned for late
next year, should serve as an indicator of the health of the design,
engineering, and readiness preparation processes within the project.
The Board believes DOE can do
more to demand from the contractor quality products and services that will lead
to timely risk reduction at the K-Basins. Therefore, pursuant to 42 U.S.C. § 2286b(d), the Board requests that DOE
provide a briefing to the Board within 90 days of receipt of this letter that presents
(1) the status of the design of the sludge stabilization and packaging
subproject and provides an estimate for the completion of the corresponding project
risk assessment; (2) DOE’s strategy for managing the assumptions upon which the
project’s success rests; and (3) any
additional actions DOE plans to take (e.g., use of additional oversight or
contractual mechanisms) to ensure successful and timely startup of the
hose-in-hose transfer line in particular, and completion of the K-Basins
Closure Project in general.
Sincerely,
A.
J. Eggenberger
Chairman
c: The Honorable James A. Rispoli
Mr.
Keith A. Kline
Mr.
Mark B. Whitaker, Jr.