[DNFSB
LETTERHEAD]
December 14, 2004
Mr. Paul M. Golan
Acting Assistant Secretary for
Environmental Management
U.S. Department of Energy
1000 Independence Avenue, SW
Washington, DC 20585-0113
Dear Mr. Golan:
The Defense Nuclear Facilities
Safety Board (Board) recently learned of a developing issue at the Savannah
River Site (SRS) that requires your prompt attention. During a review of the transuranic (TRU) waste
retrieval operations at SRS conducted on November 9, 2004, the Board’s staff
informed representatives of the Department of Energy (DOE) Savannah River Operations
Office and Westinghouse Savannah River Company (WSRC) about safety issues regarding
unvented TRU waste drums. DOE’s
complex-wide experience has shown that unvented TRU waste drums can and do
contain flammable and explosive mixtures of hydrogen and oxygen gases, and that
controls are needed to protect workers from this hazard. This observation is well documented in the
Fluor Hanford report Revised
Hydrogen Deflagration Analysis (HNF-19492, Revision 0-A, March
2004), and was identified as a safety issue in the Board’s letters of November
7, 2003, and May 3, 2004, to the Assistant Secretary for Environmental
Management. The issue of the safety of
the workers at SRS is magnified by the fact that ongoing TRU waste disposal
activities involve the handling and storage of as many as 400 unvented drums at
a time on open storage pads.
Despite these observations by
the Board’s staff, WSRC personnel strongly maintained that this safety issue
was not credible because there had been no evidence of flammable or explosive
gas mixtures during their extensive experience in handling and venting unvented
drums. On November 11, 2004, however, a
DOE Facility Representative observed a TRU waste drum venting operation and
discovered that the drum contained 16.4 percent hydrogen and 13.8 percent oxygen, a mixture of gases capable of an energetic
deflagration. This situation led to the declaration
of a Potential Inadequacy in the Safety Analysis and the issuance of an
occurrence report (SR--WSRC-SW&I-2004-0015). In a subsequent review of records for
previously vented drums, WSRC personnel identified more than 100 drums that had
contained flammable mixtures of hydrogen and oxygen prior to venting, of which
29 had contained at least 15 percent hydrogen.
The Board recognizes the many
years of experience WSRC has in the matter of safe storage of waste drums, but
is disturbed and concerned that complacency and incaution seem to have led WSRC
not to consider all the relevant data before taking a strong position that a
safety issue is not credible. It is also
disturbing that, despite the fact that WSRC possessed data showing that this
hazard existed, inquiries from both the Board’s staff
and DOE’s Facility Representative were required before WSRC ultimately
acknowledged the safety issue.
Furthermore, the Board is
concerned about the inaccurate information provided to members of the Board’s
staff who identified this safety issue. Given that records have now been produced
showing that more than 100 drums contained flammable mixtures of hydrogen and oxygen
prior to venting, it is clear that WSRC possessed data contradicting the claim
that no such drums had been found in WSRC’s experience. The Board depends on obtaining accurate and
complete information from DOE to carry out its statutory oversight
responsibilities. It is essential for
DOE and its contractors to ensure that information provided to the Board and
its staff is accurate and complete, and that positions adopted in response to
issues raised by the Board and its staff are likewise based upon accurate and
complete information.
In light of these observations
and pursuant to 42 U.S.C. 2286b(d), the Board requests
a briefing within 30 days of receipt of this letter that provides a factual
review of the issues discussed above as well as a corrective action plan with
milestones and dates.
Sincerely,
John T. Conway
Chairman
c: Mr. Mark B. Whitaker, Jr.
Mr.
Jeffrey M. Allison