[DOE
LETTERHEAD]
July 29, 2005
The Honorable A. J. Eggenberger
Chairman
Defense Nuclear Facilities
Safety Board
625 Indiana Avenue, NW, Suite
700
Washington, D.C. 20004
Dear Mr. Chairman:
This letter is to inform you
that Commitment 120E of Revision 2 to the Implementation Plan (IP) for Stabilization and Storage of
Nuclear Material for the Defense Nuclear Facilities Safety Board (DNFSB)
Recommendation 2000-1, July 2002 IP, calling for the transfer of sludge from
the K East Basin to the K West Basin will not be completed by July 31, 2005, as
previously committed. Commitment 119E,
calling for the completion of sludge containerization in K East Basin by
December 31, 2004, has continued to be delayed, and that has impacted the
ability to transfer the sludge.
Commitment 119E requires the
consolidation and containerization of K East Basin sludge, except that in the
North Load Out Pit (NLOP), into interim storage tanks
within the Basin by December 31, 2004. Nearly 80 percent of the material in the K
East Basin is containerized and the transfer system is designed, fabricated, is
being installed and tested to validate the performance of the integrated
components. Multiple factors have
contributed to this delay; however, the principle cause was inadequate project
characterization and execution.
Technical factors also
contributed to these delays including-the work to grout the K East discharge
chute impacted the pH of the Basin water, which had the unintended effect of
clouding the water. Water clarity is
also affected by the sludge collection and debris removal activities. The reduced water clarity has significantly
impacted the sludge containerization activities and is compounded by the
physical nature of the sludge (degrees of compaction) and the amount and types
of debris interspersed with the sludge.
To address the project
deficiencies, the Department of Energy (DOE) commissioned the Sludge Review
Board (SRB) to examine the information available on sludge characteristics and
determine if sufficient information was available to safely containerize,
transfer, and treat the sludge. The SRB concluded
that the proposed design and processes for collection, transfer, and treatment
of K East Basin and K West Basin sludge can be safely implemented and that
sufficient characterization data existed to proceed with the project.
The SRB report has been provided
to you and the site is currently evaluating the recommendations. Pending completion of
those evaluations,
additional changes to the sludge transfer
and treatment systems will be incorporated into project plans.
In the interim, DOE is taking
actions to minimize future schedule slippage and to improve project performance.
The project continues to identify
further work efficiencies and activities that can be performed in parallel
rather than sequentially. For example,
as preparations for containerization continue in the K West Basin, some sludge
is being consolidated into the K West South Load Out Pit
to accelerate subsequent containerization. We are also reviewing the technical basis for
Basin water chemistry to determine whether new control parameters might minimize
water clarity issues during the upcoming K West Basin discharge chute grouting
and sludge containerization. When
beneficial to project progress, K
East Basin staff
work overtime to support sludge collection. However, these actions may not be sufficient
to recover schedule lost to date.
The Richland Operations Office
is also pursuing other paths concurrent with working with Flour Hanford, Inc. to
address the performance issues including; increased oversight of sludge
activities, pursuing additional contract remedies due to the schedule impacts
and the missing of additional DNFSB and Tri-Party Agreement milestones, and
evaluating the technical basis and schedule for the remaining work at the K
Basins. The results of evaluating the
sludge schedule and the associated technical basis will be factored into a
revision to the IP, that is currently being prepared.
If you have any further
questions, please call me at (202) 586-0738 or have your staff call Dr. Robert
Goldsmith, Acting Deputy Assistant Secretary for Integrated Safety Management
and Operations Oversight, at (301)
903-4954.
Sincerely,
Dr. Inés Triay
Chief Operating Officer
Environmental Management
cc: Keith Klein, RL
Mark
Whitaker, DR-1