[USOE LETTERHEAD]
June 10, 1999
The Honorable John T. Conway
Chairman
Defense Nuclear Facilities Safety Board
625 Indiana Avenue N. W.
Suite 700
Washington, D.C. 20004
Dear Mr. Chairman:
This is in response to your April 29, 1999, letter. I share your interest in ensuring appropriate radiation protection measures for detecting, controlling, and monitoring metal tritides and organically-bound tritium across the defense nuclear complex. Our ongoing efforts have been focused on resolving this issue at the Mound site to support work scheduled to begin in July 1999. Enclosure 1 provides the requested Department strategy on this matter, as it relates to Mound.
In parallel to ongoing efforts at Mound, the Department is evaluating radiation protection needs beyond Mound. Communications with the Radiological Control Coordinating Committee and the Tritium Focus Group indicate that no other site is conducting tritide operations on par with those at Mound. We plan to validate this information, and also identify the potential future need to work with stable metal tritides or organically bound tritium.
By September 30, 1999, the Department will provide an updated policy approach on radiation protection measures for metal tritides and organically-bound tritium. This approach will identify and describe any new requirements, guidance, or radiological control technical positions determined to be necessary, and provide a schedule for their publication. In addition, we will base this approach on a systematic determination of the extent of past, current, and planned Department of Energy operations involving metal tritides and organically-bound tritium compounds.
Enclosure 2 provides the Department's path forward for evaluating this issue throughout the complex and developing an updated technical approach. By July 1, 1999, we will take compensatory measures to remind Department of Energy sites of the possible presence of metal tritides, organically-bound tritium, and to inform the Department's sites of the current technical information available about these tritium compounds.
If you have any questions, please contact me or have your staff contact Mr. Rick Jones at (301) 903-6061 or Mr. Jay Thompson at (301) 903-2198.
Sincerely,
Ernest J. Moniz
Enclosures
Enclosure 1
Path Forward For Work With Stable Metal Tritides at Mound
Stable metal tritides (SMTs) have been handled, stored, and processed at Mound over the past thirty years, as a result of research and production campaigns that evaluated many exotic materials. Today's challenge is the Decontamination and Decommissioning (D&D) of the areas, gloveboxes, fumehoods, and ventilation systems potentially contaminated with legacy SMTs. Work in these areas is planned to start in July 1999. The D&D of tritium facilities is on the critical path for Mound closure.
The Department will focus on the following three areas: 1. Review of preparations by the Mound contractor, Babcock and Wilcox of Ohio (BWO), to carry on the work with SMTs, 2. DOE technical support to Mound in formulating the approach for work with SMTs, and 3. Oversight of readiness for work and of work progress at Mound.
Enclosure 2
Evaluation of a DOE Corporate Need for Additional Guidance and/or
Regulatory Changes to Address SMTs
The DOE will formally request information to identify if there are facilities, other than Mound, at which the potential exists for worker exposure to SMTs and organically-bound tritium. The DOE has already informally received feedback from the Radiological Control Coordinating Committee, Tritium Focus Group, and from the 1998 Bioassay Workshop that the Mound facility is the only facility with a current and time critical need to work with either SMTs or organically-bound tritium. To validate the information DOE has received to date, EM and DP will collect information on current and potential future need to work with either SMTs or organically-bound tritium. This information will be coordinated via Site/Project Managers. As a compensatory measure, the request for information will include a discussion of the radiation protection issues and provide guidance on the need to evaluate the radiation protection measures for individuals working with SMTs and organically-bound tritium. The letter will include a reference to information on dose conversion factors for SMTs and organically-bound tritium provided in International Commission on Radiological Protection Publication 71--Age Dependent Doses to Members of the Public from Intake of Radionuclides.
EM will also obtain input from the Tritium Focus Group. EH will assist with a similar request to the Radiological Control Coordinating Committee. EM will summarize the results from all these inputs by July 31, 1999.
The request for information will also request input concerning approaches taken at other sites (e.g., Los Amos National Laboratory and Savannah River Site) in working with SMTs and organically-bound tritium. This information will also be compiled by EM and DP and will then be evaluated by EM, DP and EH to determine its applicability in developing guidance, technical positions or regulatory changes. This evaluation will be completed by August 31, 1999.
All of the information gained above, along with the lessons learned developed during the Mound work will be evaluated to determine if additional guidance, a technical position, or regulatory changes are needed. By September 30, 1999, the Department will provide an updated policy approach on radiation protection measures for metal tritides and organically-bound tritium. This approach will identify and describe any new requirements, guidance, radiological control technical positions determined to be necessary, and provide a schedule for their publication.