12 November 2010

Plutonium Safety for Public-Workers Protection

http://www.ofr.gov/OFRUpload/OFRData/2010-28683_PI.pdf

[FR Doc. 2010-28683 Filed 11/12/2010 at 8:45 am; Publication Date: 11/15/2010]

3670-01

DEFENSE NUCLEAR FACILITIES SAFETY BOARD

[Recommendation 2010-1]

Safety Analysis Requirements for Defining Adequate Protection for the Public and the Workers

AGENCY: Defense Nuclear Facilities Safety Board.

ACTION: Notice, recommendation.

SUMMARY: Pursuant to 42 U.S.C. 2286a(a)(5), the Defense Nuclear Facilities Safety Board has made a recommendation to the Secretary of Energy requesting an amendment to the Department of Energy’s nuclear safety rule, 10 CFR Part 830.

DATES: Comments, data, views, or arguments concerning the recommendation are due on or before [insert date 30 days from the date of Federal Register publication].

ADDRESS: Send comments, data, views, or arguments concerning this recommendation to:

Defense Nuclear Faculties Safety Board, 625 Indiana Avenue, NW, Suite 700, Washington, D.C. 20004-2001.

FOR FURTHER INFORMATION CONTACT: Brian Grosner or Andrew L. Thibadeau at the address above or telephone number (202-694-7000).

Date: November 9, 2010

Peter S. Winokur,

Chairman

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RECOMMENDATION 2010-1 TO THE SECRETARY OF ENERGY

Safety Analysis Requirements for Defining Adequate Protection
for the Public and the Workers

Pursuant to 42 U.S.C. § 2286a(a)(5)
Atomic Energy Act of 1954, As Amended

Dated: October 29, 2010

Background

The Department of Energy’s (DOE) nuclear safety regulations were developed as a result of a mandate by Congress in the Price Anderson Act Amendments of 1988. These regulations now appear in Parts 820, 830, and 835 of Title 10 in the Code of Federal Regulations (CFR). In this Recommendation, the Defense Nuclear Facilities Safety Board (Board) addresses recent changes in DOE’s “interpretation” of certain critical provisions of Title 10 CFR Part 830, Nuclear Safety Management (10 CFR Part 830), provisions which are intended to provide adequate protection of the public health and safety. As explained below, in the Board’s view this revised interpretative posture weakens the safety structure the rule is designed to hold firmly in place.

10 CFR Part 830 imposes a requirement that a documented safety analysis, or DSA, is to be prepared for every DOE nuclear facility. This DSA, once approved by DOE, forms the regulatory basis for safety of the facility or operation. 10 CFR Part 830 does more, however: its Appendix A provides “safe harbors” for the preparation and approval of DSAs. These safe harbors are, in the main, references to detailed guidance issued by DOE. A DSA that is prepared following applicable guidance found in “safe harbors” should be found acceptable, meaning that the facility’s safety systems are adequate to protect public health and safety from nuclear hazards.

One of the key safe harbor guides for the preparation of DSAs is DOE Standard 3009-94, Preparation Guide for U.S. Department of Energy Nonreactor Nuclear Facility Safety Analysis Reports.¹ First issued in July of 1994, this Standard was intended to provide guidance on meeting the requirements imposed by DOE Order 5480.23, Nuclear Safety Analysis Reports, a set of nuclear safety requirements that preceded and were supplanted by 10 CFR Part 830. The Standard stated that “Technical Standards, such as this document, support the guides by providing additional guidance into how the requirements [of Orders and Rules] should be met.” As such, it did not contain any nuclear safety requirements. Five years after its initial issuance, DOE amended Standard 3009-94 by the addition of Appendix A, entitled “Evaluation Guidelines.” These guidelines apply dose criteria to the results of accident calculations found in DSAs. Stated broadly, the Evaluation Guidelines mandate that safety class systems be installed if, as a result of a potential accident, the unmitigated dose consequences at the site boundary approach or exceed 25 rem Total Effective Dose Equivalent (TEDE).

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1 When DOE issued Change Notice 2, the title of this Standard was revised to Preparation Guide for U.S. Department of Energy Nonreactor Nuclear Facility Documented Safety Analyses.

When 10 CFR Part 830 was promulgated in final form in early 2001, the version of DOE Standard 3009-94 incorporated into Appendix A of the rule as a safe harbor included the Evaluation Guidelines. This combination of the rule’s requirement for an approved DSA and the application of the Evaluation Guidelines of DOE Standard 3009-94 formed the basis upon which adequate protection of the public health and safety would be gauged. Whenever dose consequence calculations showed that an accident scenario would result in offsite doses approaching or exceeding 25 rem TEDE, safety class systems would have to be chosen and installed to reduce this dose to a small fraction of the Evaluation Guidelines.

Developments Since 2001

As a safe harbor for 10 CFR Part 830, the Evaluation Guidelines described in DOE Standard 3009-94 have been enforced and met for the majority of DOE’s defense nuclear facilities, assuring adequate protection to the public, workers, and the environment. However, in December 2008, the National Nuclear Security Administration (NNSA) approved a DSA for the Plutonium Facility at Los Alamos National Laboratory that represented a significant departure from the accepted methodology, as discussed in the Board’s Recommendation 2009-2, Los Alamos National Laboratory Plutonium Facility Seismic Safety. The Board followed up its Recommendation with a letter to the Deputy Secretary of Energy on March 15, 2010, that sought to determine whether DOE’s current interpretation of 10 CFR Part 830 and DOE Standard 3009-94 still supports the principles of providing adequate protection of the public, workers, and the environment from the hazards of operating DOE’s defense nuclear facilities. The Board’s letter particularly expressed concern regarding the appearance that DOE’s present interpretation is that nuclear safety Evaluation Guidelines established in DOE Standard 3009-94 do not have to be met.

DOE’s June 10, 2010, response to the Board’s letter states that DOE’s utilization and implementation of DOE Standard 3009-94 has not changed since issuance of 10 CFR Part 830. DOE’s response observes that DOE Standard 3009-94 “was not written as a prescriptive item-by-item requirements document; rather it provides an overall approach and guidance for preparing a DSA.” DOE’s response states that the Standard describes steps that the contractor may take if the postulated accident consequences cannot be mitigated below the Evaluation Guideline. DOE’s response also cites guidance for DOE approval authorities contained in DOE Standard 1104-2009, Review and Approval of Nuclear Facility Safety Basis and Safety Design Basis Documents, and notes that the Safety Basis Approval Authority may prescribe interim controls and planned improvements if the Evaluation Guideline is exceeded. DOE’s response closes by stating that its managers “are expected to carefully evaluate situations that fall short of expectations and only provide their approval of documented safety analyses when they are satisfied that operations can be conducted safely…, that options to meet DOE expectations have been evaluated, and that adequate commitments to achieve an appropriate safety posture in a timely manner have been made.”

The lack of definitive statements in DOE’s June 10, 2010, response illustrates the difficulties inherent in applying a guidance document as a safe harbor for implementing the requirements of a regulation. Furthermore, NNSA’s approval of the DSA for the Los Alamos National Laboratory’s Plutonium Facility in December 2008 demonstrates that, despite DOE’s stated expectations, it is not always true that DOE’s managers will ensure safety by imposing conditions of approval that address inadequacies in the safety basis. This is illustrated to a lesser extent at the other NNSA facilities—described in follow-up correspondence NNSA issued to the Board on June 30, 2010—which have not implemented controls or compensatory measures sufficient to reduce accident consequences below the Evaluation Guideline. DOE Standard 1104-2009 serves as a source of guidance for DOE Safety Basis Approval Authorities, but it, too, is a guidance document, unequivocally stating, “This Standard does not add any new requirements for DOE or its contractors.”

DOE’s standards-based regulatory system needs a clear and unambiguous set of nuclear safety requirements to ensure that adequate protection of the public, workers, and the environment is provided. Further, it is imperative that DOE provide clear direction to its Safety Basis Approval Authorities to ensure that, if nuclear safety requirements cannot be met prior to approval of a DSA, DOE imposes clear conditions of approval for compensatory measures for the short term and facility modifications for the longer term to achieve the required safety posture. This acceptance of risk and commitment to future upgrades must be approved at a level of authority within DOE that is high enough to control both the resources needed to accomplish the upgrades as well as the programmatic decision-making involved in determining that the risk of continuing operations is offset by sufficiently compelling programmatic needs.

Item 4 of the Recommendation below deserves a further word of explanation. The Board does not recommend lightly a change to DOE’s nuclear safety regulations. But as explained above, DOE has chosen over the past several years to drift away from the principles that underlay the rule as originally intended. The Board has chosen to recommend a rule change because this action would tend, in the long run, to prevent future shifts in DOE safety policy that would once again have to be challenged and argued against. For these reasons, the Board recommends that the nuclear safety rule, 10 CFR Part 830, be amended as stated below.

Recommendation

Therefore, the Board recommends that DOE:

1. Immediately affirm the previously understood requirement that unmitigated, bounding-type accident scenarios will be used at DOE’s defense nuclear facilities to estimate dose consequences at the site boundary, and that a sufficient combination of structures, systems, or components must be designated safety class to prevent exposures at the site boundary from approaching or exceeding 25 rem TEDE.

2. For those defense nuclear facilities that have not implemented compensatory measures sufficient to reduce exposures at the site boundary below 25 rem TEDE, direct the responsible program secretarial officer to develop a plan to meet this requirement within a reasonable timeframe.

3. Revise DOE Standard 3009-94 to identify clearly and unambiguously the requirements that must be met to demonstrate that an adequate level of protection for the public and workers is provided through a DSA. This should be accomplished, at a minimum, by:

a. Clearly defining methodologies and providing acceptability criteria for controls, parameters, processes, analytical tools, and other data that should be used in preparation of a DSA.

b. Delineating the criteria to be met for identification and analyses of an adequate set of Design Basis Accidents (for new facilities), or Evaluation Basis Accidents (for existing facilities).

c. Providing criteria that must be met by the safety-class structures, systems, and components to (i) mitigate the consequences to a fraction of the Evaluation Guideline, or (ii) prevent the events by demonstrating an acceptable reliability for the preventive features.

d. Establishing a process and path forward to meeting (a) through (c) above through compensatory measures and planned improvements if the DSA cannot demonstrate compliance.

4. Amend 10 CFR Part 830 by incorporating the revised version of DOE Standard 3009-94 into the text as a requirement, instead of as a safe harbor cited in Table 2.

5. Formally establish the minimum criteria and requirements that govern federal approval of a DSA, by revision to DOE Standard 1104-2009 and other appropriate documents. The criteria and requirements should include:

a. The authorities that can be delegated, the required training and qualification of the approval authority, and the boundaries and limitations of the approval authority’s responsibilities,

b. Actions to be taken if conditions are beyond the specified boundaries and limitations of the approval authority,

c. The organization or the individual who can approve a DSA that is beyond the delegated approval authority’s boundaries and limitations,

d. The regulatory process that must be followed if condition are beyond the specified boundaries and limitations of the approval authority, and any compensatory actions to be taken, and

e. The criteria the approval authority must use to quantify the acceptance of risk for continued operations when offsite dose consequences have not been reduced to a small fraction of the Evaluation Guideline.

6. Formally designate the responsible organization and identify the processes for performing oversight to ensure that the responsibilities identified in Item 5 above are fully implemented.

 
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Peter S. Winokur, Chairman

Added by Cryptome

Los Alamos TA-55 Plutonium Facility

Above and below source

Images and text below from: http://cryptome.org/eyeball/lanl/lanl-eyeball.htm

4.32.1 Site Description

The Plutonium Facility Site at TA-55 [Table 4-28, Figure 4-32 (index map of TA-55)] is located on 40 acres (16.18 ha) about 1 mi (1.6 km) southeast of the central technical area (TA-3). Most of TA-55 is situated inside a restricted area surrounded by a double security fence. The main complex has five connected buildings: the Administration Building (Building 1), the Support Office Building (Building 2), the Support Building (Building 3), the Plutonium Facility (Building 4), and the Warehouse (Building 5). The Nuclear Materials Storage Facility (Building 41) is separate from the main complex but shares an underground transfer tunnel with Building 4. Various support, storage, security, and training structures are located throughout the main complex.

4.32.2 Facilities Description

To meet the varied needs of research and development and plutonium-processing programs at the Laboratory, TA-55 provides chemical and metallurgical processes for recovering, purifying, and converting plutonium and other actinides into many compounds and forms. Additional capabilities include the means to safely and securely ship, receive, handle, and store nuclear materials, as well as manage the wastes and residues produced by TA-55 operations. A core capability is basic and applied research in plutonium and actinide chemistry.

Core competencies are maintained in the Plutonium Facility for each type of plutonium-processing activity. Extensive plutonium recovery processes are maintained, as well as the ability to convert the recovered material to plutonium metal. A separate portion of the facility is dedicated to fabricating ceramic-based reactor fuels and to processing 238Pu used to produce radioisotope heat sources. In addition, analytical capabilities, materials control and accountability techniques, and a substantial R&D base are available to support these core capabilities.

A sophisticated nuclear materials measurement and accountability system is used at TA-55. The system includes nuclear materials accounting, nuclear materials management and modeling, a measurement support operation, operation of a nondestructive assay laboratory, nuclear materials packaging and transfer, and nuclear materials storage. All nuclear materials that are in process or are stored onsite are monitored to ensure that material balances are properly maintained and inventoried on a real-time basis. The nuclear-materials-packaging and transfer operation receives nuclear material into the facility and transfers shipments out of the facility. The nuclear materials storage operation provides a safe storage location for the actinide materials at the Plutonium Facility.

The Plutonium Facility has extensive capabilities for treating, packaging, storing, and transporting the radioactive waste produced by TA-55 operations. Liquid wastes are converted to solids or are piped to the RLWTF at TA-50. Some solid TRU wastes are immobilized in cement in 55-gal. (208-L) drums. Other TRU waste is consolidated in 15-gal. (57-L) or 30-gal. (114-L) drums or is packaged in waste boxes. Low-level wastes are also packaged at this facility. Solid wastes of all types are stored at TA-55 until they are shipped to Laboratory waste storage or disposal locations, primarily at TA-54.

4.32.2.1 Facility Hazard Categories

Table 4-28 identifies the facilities at TA-55 that fall into a facility hazard category because of the type of operations performed in the facility.

4.32.2.1.1 Nuclear Facility Hazard Categories

The Plutonium Building (Building 4) is categorized as a Hazard Category 2 nuclear facility. Although not currently operational, the Nuclear Materials Storage Facility will also be a Hazard Category 2 nuclear facility and is shown as such on the accompanying maps.

4.32.2.1.1.1 Plutonium Building

Plutonium processing is performed in the Plutonium Building (Building 4, Figure 4-32, Sheet 1), which is a two-story laboratory of approximately 151,000 ft2 (46,025 m2). The exterior walls and roof are of reinforced concrete. A concrete fire wall divides the building into two halves, each of which contains its own ventilation systems and electrical substations. One half of the process floor is divided by a central corridor into Areas 100 and 200. This half contains the plutonium research and development laboratories, the 238Pu operations, and the personnel decontamination area. The other half is divided into Areas 300 and 400 by another corridor. This half houses plutonium recovery, metal preparation and fabrication, and nondestructive analysis laboratories.

Each of the processing areas is further divided into a number of rooms that contain the gloveboxes for plutonium work. The ventilation systems that service the gloveboxes and all other utilities are located in the basement of the facility. The basement also houses critical support equipment, including all other ventilation equipment, the packing/unpacking room, waste-handling areas, the isopress laboratory, and the plutonium storage vault.

Three levels of containment are provided for plutonium processing. The primary confinement system includes gloveboxes, hoods, vessels, tanks, piping, and the glovebox ventilation exhaust system. The secondary confinement system includes the walls, floors, ceiling, and doors of the laboratories containing the gloveboxes, as well as the laboratory recirculation and bleed-off exhaust system. The exterior walls, floor, roof, and doors of the structure, along with the basement exhaust system, provide the tertiary confinement system.

The ventilation system in the facility has four zones, all of which are maintained at a lower pressure than that of the outside air. Air enters the two halves of the facility through an intake stack that has four ducts. Two ducts supply air to each half of the building. The ventilation system is designed so that each zone operates as a separate building with its own filtered exhaust stack. Exhaust from each confinement area is sent through at least two stages of HEPA filtration to prevent radioactive particles from being discharged to the environment.

The conveyor system in the facility transports contaminated material and equipment to almost any point on the first floor. Elevated stainless steel tunnels equipped with a trolley hoist system connect the gloveboxes. The vertical portions of the tunnels connect the overhead system to the gloveboxes at drop boxes located on the first floor. These drop boxes are the transfer points in which items are hoisted up to the trolley in the overhead tunnel system for eventual offsite waste disposal.

The criticality detection system monitors operations on the main processing floor of the Plutonium Facility and in the basement vault to detect gamma energy released from fission of SNM. The system is designed to detect conditions that could lead to a criticality accident in this facility and to sound an audible alarm. The alarm initiates immediate evacuation to minimize personnel exposure. This system consists of 20 Geiger-Mueller detector heads and associated circuitry located throughout the first-floor process areas and basement vault.

A continuous air-monitoring system is used to sample and analyze air from multiple points throughout the laboratory areas, basement, ductwork, and exhaust stacks. A continuous stream of sample air is drawn to a solid-state alpha detector, whose data are used for man/machine interface (lights, meter, squealer) and for monitoring by the operations center.

Other supporting systems include fire detection and suppression systems, a chilled-water system, an instrument air system, electrical power, water distribution systems, and a vacuum system. Voice communication is provided by a paging system and a telephone system. The emergency system provides paging throughout the TA-55 area and sounds the criticality and fire alarms.

4.32.2.1.1.2 Nuclear Materials Storage Facility

The Nuclear Materials Storage Facility (Building 41, Figure 4-32, Sheet 1) will eventually contain a significant amount of stored nuclear material. This facility is primarily intended for intermediate and long-term storage of SNM. Although completed in 1987, the Nuclear Materials Storage Facility has never operated because of design and construction deficiencies. A major renovation project is being planned to correct those deficiencies so that the facility can operate. The renovation project is expected to be completed by 2001.

4.32.2.1.2 Non-Nuclear Facility Hazard Categories

Two facilities, Buildings 3 and 5, are categorized L/CHEM, and one facility, Building 7, is L/ENS. Building 3 (the Support Building) contains some laboratories that use chemicals. Building 5 (the Warehouse) is used to store chemicals. Building 7 (the Calcium Building) is used to store calcium (Figure 4-32, Sheet 1).

4.32.2.2 Nonhazardous Facilities

Approximately 55 other facilities exist at TA-55, all of which have been categorized nonhazardous. These buildings are administrative, technical, and general storage buildings; passageways; and pump stations.