![[logo] US EPA](http://www.epa.gov/epafiles/images/logo_epaseal.gif){kind=logo}
DOE Response to Recommendation 2001-1 of the Defense Nuclear Facilities Safety Board, High-Level Waste Management at the Savannah River Site.
Note: EPA no longer updates this information, but it may be useful as a reference or resource.
[Federal Register: June 18, 2001 (Volume 66, Number 117)]
[Notices]
[Page 32797-32801]
From the Federal Register Online via GPO Access [wais.access.gpo.gov]
[DOCID:fr18jn01-50]
=======================================================================
-----------------------------------------------------------------------
DEPARTMENT OF ENERGY
DOE Response to Recommendation 2001-1 of the Defense Nuclear
Facilities Safety Board, High-Level Waste Management at the Savannah
River Site.
AGENCY: Department of Energy.
ACTION: Notice.
-----------------------------------------------------------------------
SUMMARY: The Defense Nuclear Facilities Safety Board Recommendation
2001-1, concerning high-level waste management at the Savannah River
Site, was published in the Federal Register on April 3, 2001 (66 FR
17689). In accordance with section 315(b) of the Atomic Energy Act of
1954, as amended, 42 U.S.C. 2286d(b), the Secretary transmitted the
following response to the Defense Nuclear Facilities Safety Board on
May 18, 2001.
DATES: Comments, data, views, or arguments concerning the Secretary's
response are due on or before July 18, 2001.
ADDRESSES: Send comments, data, views, or arguments concerning the
Secretary's response to: Defense Nuclear Facilities Safety Board, 625
Indiana Avenue NW, Suite 700, Washington, DC 20004.
FOR FURTHER INFORMATION CONTACT: Mr. Mark Frei, Deputy Assistant
Secretary for Project Completion, Office of Environmental Management,
Department of Energy, 1000 Independence Avenue SW, Washington, DC
20585.
Issued in Washington, DC on May 18, 2001.
Mark B. Whitaker, Jr.,
Departmental Representative to the Defense Nuclear Facilities Safety
Board.
[[Page 32798]]
[GRAPHIC]
[TIFF OMITTED] TN18JN01.000
[[Page 32799]]
Current Status of High Level Waste System Relative to DNFSB
Recommendation 2001-1
General
The Department shares the Board's concern about reliance on older
equipment for long-term operations. The Department, however, believes
that due attention is being afforded these areas. Furthermore, the
Department believes that, because an adequate safety margin is in
place, it is more prudent to pursue activities that result in waste
stabilization than to focus on activities that may improve short-term
storage conditions while delaying ultimate stabilization. The
Department believes careful consideration was given to the technical
safety issues and the risks and benefits were properly balanced prior
to the re-use of old style tanks.
While the Department shares the Board's concerns about the
decreasing operational flexibility in the Tank Farms due to increasing
material backlogs as a result of equipment and process problems, the
Department does not agree that the margin of safety has been reduced by
recent events and actions. Authorization Basis and environmental
regulatory requirements have all been met without using reserve storage
space.
Finally, the Department recognizes and shares the Board's desire to
move forward expeditiously with efforts toward long-term solutions. The
Department is committed to ensuring the best solutions are chosen after
careful identification and consideration of safety and programmatic
risks. As the Board is aware, the early identification and resolution
of technical issues significantly reduces project delays, redesign, and
compensatory measures during the construction and operational phases of
a project. As discussed below in response to the specific
subrecommendation related to salt disposition, progress in this area is
being made on schedule, and the time spent resolving issues is proving
worthwhile.
In summary, the Department is aware of the loss of operational
flexibility currently being experienced in the Tank Farms as a result
of process and equipment failures. The Department and its contractors
are committed to restoring operational flexibility in a safe and timely
manner. In developing this implementation plan all actions are assumed
to be fully funded.
Specific Recommended Actions
1. Initiate actions to remove transferable HLW liquid from Tank 6 to a
level below all known leak sites.
The Department accepts this subrecommendation. An initial transfer
of 40,000 gallons of liquid from Tank 6 into Tank 8 was completed on
March 27, 2001. As committed to in our video conference call with the
Board on March 22, 2001, the Department has continued to evaluate the
Tank 6 condition and the overall HLW system. Based on our evaluation
the Department has concluded that additional lowering of the waste in
the tank to below the lowest known leak site is appropriate and this
direction was given to the site contractor on May 1, 2001.
DOE recognizes that situations compromising the integrity of the
primary containment are undesirable. The Department has determined that
the Tank 6 waste can be lowered below the lowest known leak site
without significantly compromising the primary mission objective of HLW
retrieval and vitrification. This will allow a reduction in Tank 6
surveillance activities related to the status of identified leak sites.
The Department implementation milestone for this subrecommendation
is:
Commitment 1.1 Pump tank to below the lowest known leak site.
Lead Responsibility: Deputy Assistant Secretary, Office of Project
Completion.
Due Date: May 31, 2001.
2. Reassess the schedule and priority for selecting a technology for a
salt processing capability, and vigorously accelerate the schedule
leading to operation of a salt processing facility.
The Department accepts this subrecommendation and will assess the
schedule for salt processing once the preferred technology decision is
made and will accelerate this critical activity where possible. The
Department will then provide a briefing to the Board.
The selection of a salt processing technology is a critical
priority of the Department and the process remains on schedule for a
July 2001 decision date. Radioactive waste test demonstrations
currently in progress are a key element of the selection process.
Acceleration of this date at this time is not considered feasible.
Since March 2000, the Department has been working towards identify a
preferred technology in June in accordance with the Action Plan
defining the Savannah River Site Salt processing Project Roles and
Responsibilities. Under this Plan, a joint Headquarters/Savannah River
site Technical Working Group (TWG) was established to lead the effort
for technology selection. Key activities selection include the
development of selection criteria and conduct of extensive research and
development testing that will address high technical risks for each of
the technologies under consideration. These activities have been
completed or they are on schedule to identifying a preferred technology
in June. The Salt Processing Alternatives Draft Supplemental
Environmental Impact Statement (SEIS) has been issued for public
comment and the final SEIS is on schedule to support the decision-
making process. The Department currently plans to have the Record of
Decision for this SEIS embody the DOE selection, with issuance by July
2001. Once this decision is made, the Request for Proposals (RFP) will
be issued to seek up to two Engineering, Procurement, and Construction
(EPC) contractors to perform conceptual design of the full-scale
facility.
Planning for the Salt Waste Processing Facility (SWPF) includes a
pilot plant for the technology selected. A pilot plant is viewed as
critical to further mitigate technical risks prior to final design and
construction of the SWPF and will improve confidence in project
execution. To this end, pilot-plant design, construction, and operation
are being planned to provide meaningful input to the conceptual and
preliminary design.
Efforts are being made to ensure that the decision date will be met
and that follow-on design, construction and startup activities can
begin on schedule. It should be noted that part of the overall strategy
for this effort is one of continually identifying and implementing
actions to ensure that an effective salt-processing technology is
selected and constructed on or ahead of schedule. This project is
managed in accordance with DOE Order 413.3 and has incorporated
``lessons learned'' from other projects.
The Department is committed to ensuring that the best technology is
chosen after careful identification and consideration of safety and
programmatic risks. Given the long-term nature of this program, and
consistent with DOE Order 413.3, the Department believes that the
establishment of program/project milestones beyond technology selection
is counterproductive until a firm baseline is established (35% design
completion). However, DOE commits to continue to assess the schedule in
an effort to accelerate this critical activity, and therefore accepts
this subrecommendation.
[[Page 32800]]
The Department implementation milestone for this subrecommendation
is:
Commitment 2.1: Make a preferred technology selection and issue
ROD.
Lead Responsibility: Deputy Assistant Secretary, Office of Project
Completion.
Due Date: July 2001.
Commitment 2.2: Brief the Board on the preferred salt processing
technology selection, schedule, and opportunities for acceleration.
Lead Responsibility: Deputy Assistant Secretary, Office of Project
Completion.
Due Date: July 2001.
3. Develop and implement an integrated plan for HLW tank space
management that emphasizes continued safe operation of the Tank Farms
throughout its life cycle. This plan should include enough margin to
accommodate contingencies and reduce overall programmatic risk. The
plan should also restore operating margin to the Tank Farms by
including action to:
The Department accepts this subrecommendation and the HLW system
Plan update will be provided to the Board. The Tank Farm space
management strategy is based on a set of key assumptions involving
canister production rates, influent stream volumes, Tank Farm
evaporator performance, and space gain initiative implementation. Tank
space management is a sub-set of the overall integrated HLW System Plan
and as such is a life-cycle look at the space available to accommodate
contingencies and support site missions. The HLW System Plan is updated
annually and considers the latest data available as well as the current
conditions, challenges and potential impacts to Tank Farm operations.
The next revision to the HLW System Plan, scheduled for issue in May
2001, will provide enhance coverage of areas not previously highlighted
and will include management of type I, II, and Type IV tanks.
Each of the specific actions in the Board's Recommendation is
addressed below.
a. Reduce or eliminate the DWPF recycle stream. Several proposals
already have been made to reduce the volume of DWPF recycle waste sent
to the Tank Farm. A major reduction effort was implemented in January
2000 to isolate the steam atomized scrubber system from the melter off-
gas system. This resulted in an annual 700,000-gallon reduction in
recycle being sent to the Tank Farm. Proposals associated with the frit
transfer system and reductions in sample line flushes resulted in
additional water generation reductions. It is anticipated that the
annual recycle being sent to the Tank Farm will be reduced from
approximately 2,200,000 gallons for a 250 can-per-year production rate
to approximately 1,400,000 gallons or less. Additional DWPF recycle
reduction proposals, such as the installation of a DWPF acid
evaporator, will be evaluated
b. Recover former ITP tanks for Tank Farm operations. A schedule
has been implemented to return Tank 49 (previously an ITP salt
processing tank) to waste concentrate storage. A briefing for the Board
on August 2,2000, provided the Department's plans relative to Tank 49.
Tank 49 currently contains approximately 200,000 gallons of benzene-
bearing solution from ITP demonstration runs that must be removed prior
to its return to waste storage service. The decomposition of benzene
producing phenylborate compounds will be performed in two phases. The
first phase was completed in March 2001 when the material in Tank 49
has heated to 40 degrees Celsius. The second phase involves the
introduction of copper catalyst to Tank 49. The first copper addition
occurred in March 2001 and subsequent additions are scheduled to be
completed by May 2001. Once the decomposition of the phenylborates is
complete, the material in Tank 49 will be transferred to Tank 50.
Modifications required to tie Tank 49 into the H-Tank Farm transfer
system already have been completed. Tank 49 is expected to be available
to receive concentrated waste later this year.
Tank 50, currently being used as a receipt tank for Effluent
Treatment Facility (ETF) bottoms, is scheduled for return to waste
concentrate storage in late 2002. The associated construction/project
work has been initiated to support this effort. A Baseline Change
Package authorizing the start of this work was approved April 23, 2001.
Additionally, Tank 48, which already is addressed in the
Recommendation 96-1 Implementation Plan, is an option and will be
considered for future revisions of the HLW System Plan. Lessons learned
from returning Tank 49 to service will be incorporated into the future
Tank 48 plans and factored into future revisions of the HLW System
Plan.
c. Assess the desirability of adding an additional HLW evaporator
to support Tank Farm operations. Construction of an additional
evaporator is not a viable alternative for the near-term. The current
issues impacting evaporator operations are not associated with
evaporator capacity. The current issues are process and equipment
related which, would also exist with a new evaporator system. These
problems are specifically addressed in paragraph (e) below. The
Department considers that a more prudent and cost-effective approach to
resolve the problem is by optimizing existing evaporator operations by
means of resolving waste compatibility and equipment degradation
problems.
Previous studies have shown that the three evaporator systems
currently available have sufficient capacity to handle the expected
demands of the HLW system once the process and equipment issues
associated with the 2H and 3H Evaporator systems are overcome. These
studies also show that the three evaporator systems operating at
planned capacity will provide margin to accommodate future system
upsets and allow the option to shutdown the 2F Evaporator system at
some point in the future. The 2F Evaporator system could potentially be
used as a ``contingency'' when this margin is achieved.
The Department concludes that a new evaporator is not a feasible
near-term solution, and it projects that an excess evaporation capacity
will exist in the long-term.
d. Assess the feasibility of constructing new HLW tanks. Previous
consideration of this option indicates that it is a costly approach
that has many regulatory, stakeholder, and permitting issues. In
addition, constructing and operating new HLW tanks would add to the
ultimate environmental management and restoration cleanup mission. This
option is not considered feasible as a short-term remedy to gain
operating safety margin in the Tank Farms. It has been estimated that
the permitting and construction period required to have tanks suitable
for storage of HLW would take from seven to ten years.
The Department concludes that new HLW storage tanks are not a near-
term solution, but it will evaluate them as a longer-term solution if
salt processing capability is not achieved as planned.
e. Resolve waste compatibility and equipment degradation problems
to allow unconstrained operation of the three existing evaporators.
Improvements made to the 2F Evaporator system during FY 2000 have made
that system more reliable and current performance is better than
expected. This system is operational and a new vessel is currently on
hand should it be necessary to replace the existing vessel.
The 2H Evaporator experienced erratic lift rates and was shut down
in
[[Page 32801]]
January 2000 when attempts to correct the lift rate were unsuccessful.
Sample results from solids previously found in the evaporator pot
revealed that the material consisted of sodium aluminosilicate and
sodium diuranate. Initial analysis indicated that these solids form in
the presence of high silica and high aluminum feed. The Savannah River
Technology Center (SRTC) continues to analyze methods of preventing the
aluminisilicate formation in the evaporator pot. Until this work is
completed, appropriate controls have been put in place to limit the
amount of silica content in the feed to the 3H and 2F Evaporators.
Operations are now underway to the 2H Evaporator to remove the
solids. The 2H Evaporator cleaning and recovery efforts are behind
schedule but this system is expected back into operations in FY 2001.
The 3H Evaporator system is operating in a limited mode due to
cooling coil problems in Tank 30 (the 3H Evaporator drop tank). A
project to convert Tank 37 to drop tank service, by installing a drop
line from the evaporator to the tank, has been initiated and the
Baseline Change Proposal (BCP) authorizing funding was approved on
April 23, 2001. The schedule to have the 3H system functioning at full
capacity is late 2002.
The revised HLW System Plan accounts for these difficulties and the
resolutions described above are underway.
The Department implementation milestone for this subrecommendation
is:
Commitment 3.1: Issue Revision 12 of the HLW System Plan.
Lead Responsibility: Deputy Assistant Secretary, Office of Project
Completion.
Due Date: May 2001.
4. Reassess contractor incentives to ensure that near--term production
at DWPF is not overemphasized at the expense of safety margin in the
Tank Farms
The DOE accepts this subrecommendation. The Department has re-
assessed the contractor incentive package to identify whether
additional incentives are needed to promote near term improvements in
Tank Farm operations.
The current incentive package is based upon significant amounts of
fee at risk if the safety and long-term reliability of the system is
allowed to deteriorate in order to meet short term DWPF production. In
trying to minimize the potential that the contractor would pursue
short-term gain at the expense of longer-term system reliability,
several features were incorporated into the final set of incentives
currently being used:
1. The number of canisters produced in the later years of the
contract period earn larger fees than those produced earlier. This
feature was incorporated to ensure that work on the preparation of
sludge batch 3 was maintained and that this batch of feed would be
ready to support the overall canister production goals.
2. Specific evaporation and tank farm space goals were allotted
separate incentives to ensure that the tank farm health at the end of
the period was sufficient to support continued operations after the
contract period.
3. Separate incentives were identified for specific safety
documentation goals.
4. Minimum levels of performance were established. Failure to
attain these levels could result in application of the Conditional
Payment of Fee clause. Under this clause significant reductions in
previously earned fees could result from a failure to meet the minimum
levels of performance specified.
5. Unallocated fee was set aside for emergent activities/situations
that may warrant incentivization. This is a continually ongoing process
and will be the basis for the Department's current re-assessment.
The Department plans to assess the appropriateness of these
incentives annually throughout the term of the existing contract.
Commitment 4.1: The Department will provide a briefing to the Board
on specific elements of the current incentive package at Savannah River
Site.
Lead Responsibility: Deputy Assistant Secretary, Office of Project
Completion.
Due Date: July 2001.
[FR Doc. 01-15281 Filed 6-15-01; 8:45 am]
BILLING CODE 6450-01-P