Kenneth Fletcher
NS&D Monitor
1/10/2014

The Department of Energy appears to be making progress on closing still-pending recommendations from the Defense Nuclear Facilities Safety Board, with the DNFSB recently agreeing to close one recommendation and the Department seeking to have another one also closed. Last month, the DNFSB closed a recommendation from 2000 called “Prioritization for Stabilizing Nuclear Materials.” The Board first delivered the recommendation in early 2000, and approved DOE’s implementation plan in 2006. “The Department of Energy (DOE) has adequately addressed the safety-related concerns that warranted issuing Recommendation 2000-1,” states a Dec. 19 Board letter to DOE closing out the recommendation. “Forty-seven of the fifty commitments contained in DOE’s implementation plan are complete, and the three remaining commitments are either part of an established project or part of a formal consent agreement.”

The 2000 recommendation was designed to complement a recommendation from 1994 outlining a schedule for remediation of facilities in the DOE complex, noting numerous challenges still remained and outlined a plan for a prioritization of stabilization efforts. “Material remaining in liquids generally poses the greatest hazard, because of higher possibility of dispersal and because of potential criticality,” states the original recommendation. “Among these liquids the highly enriched uranium solutions stored in tanks outside the H-Canyon at the Savannah River Site require the most attention because of criticality concerns. Following the solutions in importance are unstabilized plutonium oxides and plutonium metal remaining in containers with normal atmosphere, especially at locations in moist climates. Closely following in importance are various plutonium-bearing residues which are not as well isolated or packaged as they should be.”

DOE has completed nearly all of its 50 commitments developed in response to the recommendation, leaving just three—Vessel disposition, materials at Los Alamos National Laboratory and K-Basin sludge. The vessel disposition and LANL commitments will be completed under LANL’s Confinement Vessel Disposition Project. Completion of K-Basin sludge removal is required by the Hanford Federal Facility Agreement and Consent Order.    

DOE Wants to Close Risk Assessment Rec.

DOE has also said it has completed all actions in its implementation plan for a 2009 Defense Nuclear Facilities Safety Board recommendation on “Risk Assessment Methodologies at Defense Nuclear Facilities.” The DNFSB’s recommendation called for policies and standards and guidance for use of quantitative risk assessment methodologies at nuclear facilities in the DOE complex. “DOE accepted Recommendation 2009-1 and took the requisite action to improve its infrastructure for ensuring the appropriate use and control of quantitative risk assessments in nuclear safety applications,” states a Dec. 23 letter from DOE to the Board. “This included revising DOE’s Nuclear Safety Policy and developing a new technical standard to provide Departmental policy, criteria and guidance on the development and use of quantitative risk assessments.”

The original DNFSB recommendation noted the need for DOE to develop a policy on the use of quantitative risk assessments for nuclear safety. “Without such a policy, DOE has little basis to accept the validity of existing risk management tools that use quantitative risk assessment,” the Board said, adding, “The continued pursuit of ad hoc applications of risk assessment in the absence of adequate DOE policy and guidance is contrary to the standards-based approach to nuclear safety espoused by DOE and endorsed by the Board.” It included four sub-recommendations calling for a policy on the use of quantitative risk assessment for nuclear safety applications, establishment of requirements and guidance in accordance with the policy, an evaluation of ongoing uses of risk assessment methodologies and a requirement to identify efficiencies and gaps in those processes.

The Department has completed all of the actions in its implementation plan, such as establishing the Risk Assessment Technical Experts Working Group, revising DOE Nuclear Safety Policy to address quantitative risk assessment, and issuing a complex-wide notice providing interim advice on existing risk assessment policies. DOE also took additional steps, including completing a study on the use of quantitative risk assessment, and developing supplemental training and a new course on the topic. Additionally, in 2010 DOE did a risk assessment study that found that DOE’s nuclear safety policy should be revised with regards to risk assessment. Revisions were completed in 2013.