[DOE LETTERHEAD]
December 30, 2002
The Honorable John T. Conway
Chairman
Defense Nuclear Facilities Safety Board
625 Indiana Avenue, NW.
Suite 700
Washington, D.C. 20004-2901
Dear Mr. Chairman:
This letter is provided in response to your
letter of November 13, 2002, on criticality safety practices at Y-12. Your letter noted concerns with the general
neglect of criticality controls in the storage and handling of fissile material
at Y-12. While the National Nuclear
Security Administration shares the Defense Nuclear Facilities Safety Board’s
(Board) concern with the circumstances that led to the specific occurrence at
Y-12, internal and external criticality safety reviews conducted at Y-12 have
concluded that the contractor’s Nuclear Criticality Safety (NCS) program is
well designed, thoroughly documented, and implemented; the Y-12 Site Office has
been active in monitoring and evaluating contractor performance.
The number of NCS noncompliance issues
identified at Y-12 over the last 3 years has shown a steady decrease, while the
workload has doubled, and the expected standard of performance has become more
stringent. In February 2002, Y-12
broadened the scope of nuclear criticality issues that were classified as deficiencies
to increase the level of evaluation of previously considered minor NCS issues
to ensure the further maturing of
Y-12’s NCS Program. In accomplishing these improvements, actions
have been taken and are being planned to reduce the complexity of NCS posting
instructions, the number of containers in use in specific areas, and to improve
the standardization of NCS requirements.
However, actions to simplify and standardize fissile material handling
operations are dependent on reducing the inventory of stored nuclear material
and storing remaining materials in a smaller set of standard containers. These actions have not been fully
implemented, which were determined to be a contributing cause to the occurrence
in Building 9212.
Major resources at Y-12 over the last year
have been focused on restarting Wet Chemistry Processes. Once running, these processes will reduce
the inventory of stored materials, which will facilitate the standardization of
fissile material handling operations.
In parallel with the Wet Chemistry Restart as resources become
available, plans are also being developed to create a long-term strategic plan
to further reduce the inventory of stored nuclear materials and the storage of
remaining materials in a smaller set of standard containers. The long-term strategic plan needs to
incorporate complex-wide actions on nuclear material disposition paths and
nuclear material container shipping, receiving, and storage standards.
We are planning to brief the Board in
January 2003 on improvements that have been made to the Y-12 NCS Program, and
the status of development of Y-12’s implementation plans to reduce the amount
of stored nuclear materials and to standardize fissile material storage
containers.
If there are any questions concerning our
approach to address the criticality safety concerns at Y-12, please contact me
or have your staff contact Rodney Lehman at (301) 903-6104.
Sincerely,
Everet H. Beckner
Deputy Administrator
for Defense Programs
cc:
M. Whitaker, EH-9