[DNFSB
LETTERHEAD]
The Honorable Jessie Hill Roberson
Assistant Secretary for Environmental
Management
Washington, DC 20585-o 113
Dear Ms. Roberson:
The Defense Nuclear Facilities Safety Board
(Board) received a letter from the Department of Energy (DOE) in response to
the Board’s letter of
The Board has reviewed DOE’s letter from the
Chief Operating Officer, Office of Environmental Management, dated
Resolution of these comments does not reduce
the need for DOE to expedite a decision on disposal of excess plutonium or to
determine if there are better options (such as a new plutonium storage
facility) for extended storage of plutonium at SRS.
Sincerely,
John T. Conway
Chairman
c: Mr.
Jeffrey M. Allison
Mr. Mark B.
Whitaker, Jr.
Enclosure
ENCLOSURE
The Defense Nuclear Facilities Safety
Board’s
Detailed Comments on Department of Energy’s
Letter of January 5, 2004
1.
The current
lightning protection system in Building 235-F (235-F) does not comply with National
Fire Protection Association Standard 780, Standard
for the Installation of Lightning Protection Systems. Department of Energy (DOE) responds that it
will review the results of a new Fire Hazards Analysis (FHA) currently in
preparation to determine what action is required for the lightning protection
system. The need for a viable lightning
protection system must be based on more than the FHA. The Documented Safety Analysis and hazards analysis
must also be considered. Additionally, a
lightning-induced fire in non-safety-related electrical cables is undesirable
and could lead to a fire that could be a safety concern.
2.
The majority
of electrical cables in 235-F are approximately 50 years old and have exceeded their
estimated design life. DOE responds that
monitoring of the electrical cables in other facilities of similar age at
Savannah River Site has not shown a pattern of cable degradation. DOE notes that a large portion of the
electrical cable was replaced in the 1980s during replacement of a portion of
the ventilation system. DOE plans to
perform a megger test of a sample of the remaining electrical cables and to
conduct routine thermography testing on electrical equipment in the facility.
While a large portion
of electrical cable for the ventilation system was replaced, this is not the
case for electrical cable for other safety systems. Furthermore, the electrical cable for the ventilation
system is now more than 20 years old and will exceed its estimated design life before
the facility has been decommissioned. A
viable preventive maintenance test to monitor the condition of electrical cable
is essential to ensure continued reliability of the electrical systems. The proposed megger test and thermography test
do not adequately monitor for damaged and deteriorating cables. A time-domain reflectivity test, such as that in
the Electronic Characterization and Diagnostics system, is needed to monitor
the condition of the electrical cables.
3.
The electrical
distribution system in 235-F was installed in accordance with the 1957 version of
the National Electrical Code (NEC). An
assessment of the existing electrical systems against current code requirements
could help identify potential fire hazards and reveal latent system
vulnerabilities. DOE responds that site
standards require that the specifications listed in the code of record govern
the design associated with existing facilities. DOE also notes that the NEC does not have a
requirement to assess existing equipment against the current NEC or to update
equipment.
Building 235-F
and K-Area Material Storage (KAMS) are being given a new, extended-term storage
mission that could continue more than 20 years. An NEC-qualified inspector specifically
trained to evaluate older systems may have insight into safety vulnerabilities
that would not be apparent to facility engineers, even though they are familiar
with the code requirements. The result
of such an inspection could be used to help enhance the reliability of the
electrical systems in 235-F.
4.
The
short-circuit analysis for KAMS is based on the short-circuit currents from the
original electrical calculations for K-Reactor. These currents do not reflect the existing
electrical equipment configuration. DOE
responds that a new analysis is being completed for the 480-volt systems.
The new
short-circuit analysis should encompass an evaluation of the 120-volt systems
up to the distribution panels. These
systems include the majority of the electrical equipment in the working areas. Additionally, these panels have historically
been responsible for the majority of failures because of their inability to
handle short-circuits.