[DNFSB
LETTERHEAD]
The Honorable Spencer Abraham
Secretary of Energy
Dear Secretary Abraham:
It has been 4 years since the Defense
Nuclear Facilities Safety Board (Board) submitted Recommendation 2000-1, Prioritization for Stabilizing Nuclear
Materials, to the Department of Energy (DOE). At that time, the Board noted that large
quantities of plutonium metals, oxides, and residues at Los Alamos National
Laboratory (LANL) were still awaiting stabilization, packaging, or disposal. Since then, DOE has issued several revisions
to its Implementation Plan for Recommendations 94-1, Improved Schedule for Remediation in the Defense Nuclear Facilities
Complex, and 2000-1, yet LANL is the only DOE site without an
Implementation Plan accepted by the Board.
The Board noted in its
The Board recently conducted a review of
stabilization and storage of nuclear materials at LANL. Although LANL has completed a project
execution plan for stabilization and disposition
activities, the schedule to complete work on legacy materials remains
essentially unchanged from the protracted dates of the July 2002 Implementation
Plan. In past letters, the Board has suggested
specific stabilization plans that warrant acceleration. Examples include repackaging of materials
stored in vulnerable containers, processing of non-weapons-grade plutonium, and
direct discard of residues. The Board
notes that LANL is now directly discarding certain lean residues as previously
suggested by the Board, but is still unnecessarily processing some residues to
meet an outdated economic discard limit for plutonium. A summary of the correspondence on
Recommendations 94-1/2000-l at LANL and a report summarizing issues noted
during the Board’s review are enclosed.
Last week the Board was briefed on the
results of DOE’s Type B investigation of the
Therefore, pursuant to 42 U.S.C. § 2286b(d), the Board requests that, within
120 days of receipt of this letter, DOE provide a revised Implementation Plan
for Recommendation 2000-l for accelerated stabilization, repackaging, or
disposition of nuclear materials at LANL reflecting these considerations and
the issues noted in the enclosed report.
Sincerely,
John T. Conway
Chairman
c: The
Honorable Linton Brooks
The Honorable
Jessie Hill Roberson
The Honorable
Everet H. Beckner
Mr. Ralph E. Erickson
Mr. Mark B. Whitaker,
Jr.
Enclosure
Correspondence on Recommendations
94-1/2000-l at
1998
December 28, 1998, Department of Energy (DOE) 94-l Implementation
Plan (IP) commits to complete stabilization of LANL excess plutonium inventory
by fiscal year (FY) 2005.
1999
December 14, 1999, Board letter to DOE urges LANL to give
priority to the processing of high-priority legacy residues which are much more
likely to have vulnerabilities in the condition of packaging or material than
newly generated residues.
2000
January 14, 2000, Board Recommendation 2000-l notes LANL
94-l IP is behind schedule in repackaging and/or stabilization of metals,
oxides, and residues.
2001
March 23, 2001, Board letter to DOE raises objections to
LANL 5-year delay specifically citing risks of maintaining legacy residues in
slip-lid cans for too long.
November 21, 2001, Board letter to DOE reiterates its
suggestion that LANL prioritize older residues ahead of newly generated ones
due to packaging degradation concerns.
2002
July 22, 2002, DOE 2000-2 IP Rev 2 adds programmatic
(non-excess) items to schedule which still extends out to FY10.
August 9, 2002, Board letter to DOE again raises
objections to LANL 5-year delay and again cites risks of maintaining legacy
residues (suggests direct discard). Reporting requirement asks for DOE to provide
date for improved schedule for LANL.
2003
2004
February 2, 2004, National Nuclear Security
Administration/LASO/LANL Type B Accident Investigation presentation to Board. Commitment to repackage items in Room 201B and
complete Comprehensive Nuclear Materials Packaging and Storage Plan by FY 10
(no acceleration of 94-1/2000-l activities).
DEFENSE NUCLEAR FACILITIES SAFETY BOARD
Staff Issue Report
MEMORANDUM
FOR: J. K. Fortenberry, Technical Director
COPIES: Board
Members
FROM: R.
Rosen
SUBJECT: Nuclear
Materials Stabilization and Storage at
This report documents a review by the staff
of the Defense Nuclear Facilities Safety Board (Board) of nuclear materials
stabilization and storage at Los Alamos National Laboratory (LANL). The purpose of the review was to assess the
progress of LANL’s activities in response to Recommendations 94-1, Improved
Schedule for Remediation in the Defense Nuclear Facilities Complex, and 2000-1,
Prioritization for Stabilizing Nuclear Materials. The review was performed during
Background. The
goal of the materials stabilization activities at LANL is to stabilize and package
all nuclear materials into containers that meet Department of Energy (DOE)
standard DOE-STD-3013, Stabilization, Packaging, and Storage of
Plutonium-Bearing Materials; Technical Area (TA)-55 Site Standard Pack
containers; or transuranic waste containers certified for disposal at the Waste
Isolation Pilot Plant. LANL has
developed a project execution plan to achieve this goal in accordance with the
laboratory’s portion of the DOE’s July 2002 Implementation Plan for Recommendations
94-1/2000-l. Although the project
execution plan elaborates on the stabilization, packaging, and disposition
activities at LANL, the schedule remains essentially unchanged from the July
2002 Implementation Plan that was rejected by the Board in its August 9, 2002,
letter to DOE. On
Materials Stabilization Schedule. LANL has made progress toward stabilizing, packaging,
and disposing of plutonium-bearing items in nonstandard containers. During fiscal years 2001 through 2003, LANL
completed work on nearly 20 percent more items than was planned. However, LANL’s stabilization schedule is
still based upon the unsatisfactory commitment dates of DOE’s July 2002
Implementation Plan for Recommendations 94-l/2000-1. Approximately 2,900 excess items and 1,400
programmatic items remain to be stabilized, repackaged in approved containers,
or disposed. This schedule does not
reflect an appropriate sense of urgency on the part of LANL or the National
Nuclear Security Administration (NNSA) with regard to removing materials from
nonstandard packages that pose a higher risk of failure, such as slip-lid cans.
The Board’s staff has reminded LANL and
NNSA’s Office of Los Alamos Site Operations that the Board still expects NNSA
to provide an improved schedule for LANL’s stabilization activities, consistent
with the request in the Board’s
|
LANL Inventory Stabilization Schedule by Fiscal Year (Item Count) |
|||||||||
|
Process Line |
2001 – 2003 |
2004 |
2005 |
2006 |
2007 |
2008 |
2009 |
2010 |
Total Planned |
|
Vessels |
0 |
3 |
3 |
3 |
4 |
0 |
0 |
0 |
13 |
|
Roasting and Blending |
316 |
150 |
150 |
150 |
150 |
125 |
0 |
0 |
1041 |
|
Non-Weapons- Grade (Exposure Reduction Line) |
15 |
0 |
0 |
0 |
280 |
280 |
280 |
233 |
1088 |
|
Nitrate Operations |
139 |
45 |
45 |
45 |
45 |
45 |
45 |
43 |
452 |
|
Chloride Operations |
314 |
130 |
130 |
130 |
130 |
130 |
130 |
133 |
1227 |
|
Unique Items |
45 |
20 |
20 |
20 |
17 |
0 |
0 |
0 |
122 |
|
Programmatic Repackaging |
357 |
175 |
280 |
280 |
280 |
210 |
100 |
93 |
1775 |
|
Total Planned |
1186 |
523 |
628 |
628 |
906 |
790 |
555 |
502 |
5718 |
|
Total Completed |
1403 |
N/A |
N/A |
N/A |
N/A |
N/A |
N/A |
N/A |
N/A |
The project execution plan does not address
all nuclear materials stored in unsatisfactory conditions at LANL, or even
within TA-55. For example, the packages
of 238Pu-contaminated cellulose rags responsible for the August 2003
worker contamination event are not included in the above table. Likewise, NNSA’s
LANL has been generating contaminated
cellulose rags from 238Pu operations and has continued to package
and store these residues in nonstandard containers for future recovery. Approximately 155 such containers have been
generated and stored on the floor space of Room 201B in the TA-55 238Pu
laboratory since 1996. LANL does not
have formalized controls governing the package configuration or length of time
that items can be stored on laboratory floor space. The staff learned that only 12 of these
containers had been stabilized during the 2 years of pyrolysis operations, even
though it takes only a few days to process each container. The staff is unaware of any compelling reason
why more timely processing of these residues could not have been accomplished.
LANL’s
Response to 238Pu Contamination Release. As a
result of the 238Pu release, LANL committed to reconfiguring and
repackaging all of the 238Pu residue items stored on the floor space
of Room 201B after completing an assessment that prioritizes these items based
on a risk assessment. LANL also
described to the Board’s staff a plan for a comprehensive review of nuclear materials
packaging and storage. This plan would initially
involve a review of all items in TA-55 and the Chemistry and Metallurgy
Research (CMR) Facility to identify items not stored in a safety-significant
confinement system. These items would
then be prioritized for repackaging based on a risk assessment. Eventually, this repackaging effort would be
extended to all nuclear materials at LANL not stored in a safety-significant
confinement system.
The staff learned that LANL’s risk
assessment will be based principally on isotopic content (material-at-risk),
with little consideration of the chemical reactivity or age (length of time
since packaging) of the materials. In
earlier letters to DOE, the Board has suggested that the age of residues should
be considered when establishing priorities for processing because older items
are more likely to have vulnerabilities in material condition and packaging. Nonetheless, LANL’s surveillance and
repackaging plans for all nuclear materials stored in nonstandard containers is
a positive effort that should be implemented without further delay. The Implementation Plan should be revised to
include new milestones for all of the items not previously included in the
project execution plan. The staff also
believes it would be appropriate for LANL to immediately issue a Laboratory
Implementing Requirement for compulsory storage of nuclear materials in
containers that provide safety-significant confinement.
Areas
for Accelerated Stabilization. The staff believes all areas of
LANL’s inventory stabilization schedule should be considered for accelerated
stabilization, repackaging, and disposition. The following areas are of particular concern.
Programmatic
Repackaging—This category
includes items in the TA-55 storage vault and CMR Facility that are not defined
as excess and are packaged in nonstandard containers, such as slip-lid cans. Any programmatic items not included in the
project execution plan, such as those in Room 201B, need to be added to the
schedule. The items in this category
will be reprocessed or repackaged into TA-55 Site Standard Pack containers for
future use. These standard containers
are robust and well suited for safe interim storage. The staff believes the current schedule, which
does not eliminate nonstandard containers from LANL’s inventory until 2010,
should be accelerated based on a risk assessment that prioritizes items
according to the age of the package and form of material as well as the
material-at-risk. The Implementation
Plan should be revised to include accelerated milestones for all programmatic
repackaging.
Non-Weapons-Grade
Materials—This category of
items includes reactor-grade plutonium oxide and other higher-dose-rate items (>100 mrem/hr). LANL plans to construct a new Exposure Reduction
Line in TA-55 to process these items for packaging into DOE-STD-3013 containers
or disposal. The precise configuration
and capabilities of the Exposure Reduction Line have not yet been defined, but
this process line will serve to reduce the dose to operators and avoid contamination
of equipment used to process weapons-grade plutonium. LANL has delayed work on designing and
installing this equipment because of funding constraints and limited numbers of
personnel. However, some
non-weapons-grade materials are being stabilized using existing process lines.
The staff noted that the schedule for
stabilizing these items, which does not begin until 2007, was too protracted
considering that these isotopes pose a higher hazard than the weapons-grade plutonium
materials. LANL stated that limited
processing of the higher-dose isotopes could be done each year in the weeks
immediately before TA-55’s annual cleanup and inventory. The staff encouraged LANL to define and
schedule this activity to show how much progress could be made in the interim
through such an approach. The staff
believes LANL should expedite the design, installation, and startup of a
dedicated line for processing non-weapons-grade plutonium to accelerate
stabilization of these items. The
Implementation Plan should be revised to include accelerated milestones for
stabilization of non-weapons-grade materials.
Direct
Discard of Residues—In its
Building
164 Drums—Approximately 34
packages containing excess uranium materials are stored in Building 164 at
TA-18. Most of these packages are
55-gallon steel drums. LANL plans to process
these materials in the CMR Facility, but the schedule for this activity has
been delayed because of competing processing requirements. These drums present an unknown hazard because the
contents and condition of the packages are not entirely known. The staff believes these drums should be
characterized and processed or repackaged, as appropriate, as soon as possible.
Non
TA-55 Excess Items—LANL’s
project execution plan includes a discussion of excess materials stored in
facilities outside of TA-55. The plan
characterizes these items as generally low risk, but requiring inspection in
order to verify that the materials are in a safe storage form. It is not clear when these inspections would
be performed, but the project execution plans states that disposition is not
likely to be scheduled until after 2010. The staff believes these excess items should
be inspected to verify safe storage conditions sooner, rather than later, and
that disposition should be completed well before 2010.