DOE Response to Recommendation 2019-2 of the Defense Nuclear Facilities Safety Board, Safety of the Savannah River Site Tritium Facilities, 52494-52496 [2019-21438]
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Federal Register / Vol. 84, No. 191 / Wednesday, October 2, 2019 / Notices
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Wednesday, October 30, 2019, 9:00
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Tuesday, October 29, 2019
• EM Program Update
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Signed in Washington, DC, on September
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LaTanya Butler,
Deputy Committee Management Officer.
[FR Doc. 2019–21366 Filed 10–1–19; 8:45 am]
BILLING CODE 6450–01–P
DEPARTMENT OF ENERGY
DOE Response to Recommendation
2019–2 of the Defense Nuclear
Facilities Safety Board, Safety of the
Savannah River Site Tritium Facilities
Office of Environment, Health,
Safety and Security, Department of
Energy.
ACTION: Notice.
On June 11, 2019, the Defense
Nuclear Facilities Safety Board issued
Recommendation 2019–2, Safety of the
Savannah River Site Tritium Facilities,
to the Department of Energy. In
accordance with the Atomic Energy Act
of 1954, the Secretary of Energy’s
response to the Recommendation is
provided in this notice.
DATES: Comments, data, views, or
arguments concerning the Secretary’s
response are due on or before November
1, 2019.
ADDRESSES: Please send to: Defense
Nuclear Facilities Safety Board, 625
Indiana Avenue NW, Suite 700,
Washington, DC 20004.
FOR FURTHER INFORMATION CONTACT: Mr.
Christopher Chaves, Office of the
Departmental Representative to the
Defense Nuclear Facilities Safety Board,
Office of Environment, Health, Safety
and Security, U.S. Department of
Energy, 1000 Independence Avenue
SW, Washington, DC 20585, or
telephone number (301) 903–5999, or
email Christopher.Chaves@hq.doe.gov.
SUPPLEMENTARY INFORMATION: On June
11, 2019, the Defense Nuclear Facilities
Safety Board issued Recommendation
2019–2, Safety of the Savannah River
Site Tritium Facilities, to the
Department of Energy. Recommendation
2019–2 was published in the Federal
Register on June 19, 2019 (84 FR 28517).
In accordance with section 315(c) of the
Atomic Energy Act of 1954 (42 U.S.C.
2286d(c)), the Secretary of Energy’s
response to the Recommendation is
printed in full at the conclusion of this
notice.
SUMMARY:
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Signed in Washington, DC on
September 24, 2019.
Joe Olencz,
Departmental Representative to the Defense
Nuclear Facilities Safety Board, Office of
Environment, Health, Safety and Security.
September 10, 2019
The Honorable Bruce Hamilton
Defense Nuclear Facilities Safety
Board
625 Indiana Avenue NW, Suite 700
Washington, DC 20004
Dear Mr. Chairman:
I appreciate the Defense Nuclear
Facilities Safety Board’s (DNFSB)
continued support to the Department of
Energy’s National Nuclear Security
Administration (DOE/NNSA) in the safe
operation of our facilities. I am
committed to ensuring DOE/NNSA
continues to remain fully compliant in
the safe operations of our defense
nuclear facilities in a manner that
provides adequate protection to the
public, our workforce, and the
environment. Secretary Perry has
requested that I respond to DNFSB
Recommendation 2019–2, Safety of the
Savannah River Site Tritium Facilities,
dated June 11, 2019. In responding, I
first want to assure you that DOE/NNSA
remains fully compliant and committed
in our duties to the American public in
the safe operation of these facilities as
outlined in the enclosure to this letter.
These actions address the concerns of
the DNFSB and reflect how DOE/NNSA
is providing adequate protection of the
public’s health and safety at the Tritium
Facilities at the Savannah River Site
(SRS). Therefore, I do not accept
Recommendation 2019–2.
DOE/NNSA’s safety programs and
policies, and their effective
implementation by our well-trained
workforce, provide reasonable assurance
that adequate protection of public
health and safety is provided. Focused
ongoing actions at the Tritium Facilities
at SRS adequately address DNFSB
concerns outlined in Recommendation
2019–2 and make the need for
additional actions in response to a
DNFSB Recommendation unnecessarily
duplicative of that effort, and would,
therefore, detract from our continued
progress. Our commitment to safety in
the Tritium Facilities remains unwavering, and there has been no change
in the conservative safety philosophy in
the operation of the Tritium Facilities.
The Department believes that the
current Tritium Facilities’ documented
safety analysis contains appropriate
safety significant controls and the new
analysis, which is nearing completion,
will strengthen that safety posture. The
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Federal Register / Vol. 84, No. 191 / Wednesday, October 2, 2019 / Notices
planned Tritium Finishing Facility
(TFF), included in the President’s FY
2020 Budget Request, will
fundamentally improve safety at SRS, as
DOE/NNSA moves from the aging HArea Old Manufacturing Facility to this
new seismically-qualified facility.
Furthermore, the SRS Emergency
Management Program has demonstrated
steady and significant improvement
over the past several years and
continues to provide adequate
protection to the workforce and the
public surrounding SRS. A
comprehensive explanation of our safety
improvement activities is detailed in the
enclosure.
DOE/NNSA would be willing to brief
DNFSB on our actions outlined in the
enclosure and keep the Board updated
over time. We appreciate the Board’s
perspectives and look forward to the
continued positive interactions with
you and your staff.
If you have any questions, please
contact Ms. Nicole Nelson-Jean,
Manager of the Savannah River Field
Office, at (803) 208–3689.
Sincerely,
Lisa E. Gordon-Hagerty
Enclosure
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Enclosure
Department of Energy (DOE) Secretary
Response to the June 11, 2019, DNFSB
Recommendation 2019–2, Safety of the
Savannah River Site Tritium Facilities
Sub-recommendation 1—Identify and
implement near-term compensatory
measures at SRS to mitigate the
potential for high radiological
consequences to individuals who would
be impacted by a release from the
Tritium Facilities.
Procedural reductions in the Material
At Risk (MAR) have been completed in
the Tritium Facilities. Each operating
facility that makes up the Tritium
Facilities has an associated MAR listed
in the Documented Safety Analysis
(DSA). When it was understood that the
new analysis would increase the dose
consequences, Savannah River Nuclear
Solutions (SRNS) reduced tritium
quantities in such facility through the
Automated Reservoir Management
System. These reductions are reflected
in the DSA currently advancing through
the approval process by the
Department’s approval process.
Over the past several years, the
Department of Energy’s National
Nuclear Security Administration (DOE/
NNSA) and the Savannah River Site
(SRS) Management and Operating
partner, SRNS, have taken actions to
continue improving the Tritium
Facilities safety posture. A new hazards
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analysis has been conducted along with
a revision to the DSA. This new analysis
has further emphasized identifying
engineered controls over administrative
controls. The Board’s technical staff was
recently provided a draft of the new
DSA. The Department notes that even
with the extreme conservatism in the
analytical parameters, including a
postulated simultaneous release of all
tritium, from all the multiple facilities
within 20 minutes; the postulated
consequences to the public remain
below the Evaluation Guideline of DOE–
STD–3009–94, Preparation Guide for
U.S. Department of Energy Nonreactor
Nuclear Facility Documented Safety
Analyses.
In addition, hypothetical, worst-case
modeling does not account for any
Emergency Response exposure
reduction actions, personnel selfprotection actions, nor any subsequent
response actions to mitigate the
potential consequences. Based on the
current DSA, and the new DSA in
review, reasonable assurance of
adequate protection is ensured and the
risk to the public remains very low. It
is anticipated that the new DSA will be
approved in 2019. The actions taken in
completing the DSA aligns with
addressing the concerns raised in
Recommendation 2019–2.
DOE/NNSA actions and plans that
would have responded to this Subrecommendation are complete or
underway and therefore are considered
to have met the objectives of this Subrecommendation. DOE/NNSA is willing
to brief the DNFSB on these actions on
a recurring basis.
Sub-recommendation 2—Identify and
implement long-term actions and
controls to prevent or mitigate the
hazards and pose significant
radiological consequences to acceptably
low values consistent with the
requirements of DOE directives.
As noted in the Recommendation,
DOE/NNSA committed in 2011 to
develop a new analytical model for dose
consequences for SRS. In 2011, DOE/
NNSA outlined a plan to update the
atmospheric dispersion model, which
was completed in 2014. Implementation
of that new analysis began shortly
thereafter and included a review of the
safety controls selection and hierarchy.
DOE/NNSA decided to combine all the
Tritium Facilities’ safety bases and to
conduct a holistic revision to the DSA.
The new analysis placed additional
emphasis on engineered controls over
administrative controls. After an
extensive review, DOE/NNSA directed
changes and updates to the draft DSA,
including development of a formal
strategy that will continue to strengthen
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52495
the controls to protect co-located
workers (CWs) from large energetic
events postulated by the safety analysis.
The revised DSA was delivered to DOE/
NNSA in November 2018. Subject
matter experts from across DOE/NNSA
have completed a review of the
resubmitted DSA and have generated a
number of additional items requiring
further action. The actions taken in
completing the DSA aligns with
addressing the concerns raised in
Recommendation 2019–2.
The new DSA includes a number of
new credited features, including the
217–H Vault walls and fire damper, new
Specific Administrative Controls (SACs)
for fire water tank, and other new Fire
Suppression Surveillances have been
added. In addition, all current
Programmatic Controls have been
replaced by at least one SAC.
In 2018, recognizing the desire to
reduce worker consequences, DOE/
NNSA requested and received from
SRNS a strategy for risk reduction to
CWs (U–ESR–H–00163, Rev.0). This
strategy describes the SRNS plans for
additional structural analyses and
control development, if required for the
remaining facilities during a potential
seismic event. This analysis will be
used to determine suitability for
upgrading the functional classification
of additional controls. It also includes
analysis for dose reduction (e.g. tritium
oxidation conversion rates, plume rise
phenomena, etc.). In the aggregate, the
plan includes 19 commitments that are
being pursued and managed (SRNS–
T0000–2018–00227, Transmittal of the
Schedule for Implementing the Strategy
for Risk Reduction to the Co-Located
Worker in Tritium Facilities).
Longer term plans include the
construction of the Tritium Finishing
Facility (TFF) capital line item project,
to replace the aging HAOM 234–H
facility with a seismically-qualified
facility with a dedicated fire
suppression system. The TFF project
will mitigate potential risks to DOE/
NNSA’s Stockpile Stewardship Program
stemming from housing operations in
outdated facilities.
A formal Analysis of Alternatives
(AoA) was performed and documented
for the TFF project. The results of the
AoA recommended the construction of
new buildings instead of upgrading
existing buildings that involve tritium
operations. This will promulgate safety
in design integration and the new TFF
facilities will meet current DOE
requirements. It is anticipated the TFF
project will meet the Critical Decision1 project milestone in early FY 2020.
The current confinement strategy for
TFF is based on the use of multiple
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Federal Register / Vol. 84, No. 191 / Wednesday, October 2, 2019 / Notices
physical barriers and active controls to
include:
• Robust containers storing the MAR.
• Robust Natural Phenomena Hazard
Design Category-3 (NDC–3) structures
preventing building collapse and
impacts to containers.
• Robust NDC–3 fire suppression
systems preventing the spread of a fire
and mitigating the consequences of a
release.
• Exhaust Ventilation with elevated
release to mitigate consequences to the
CWs. Based on application of passive
barriers and active controls, the
mitigated consequence to both the
public and CW from a release of
radiological materials is either
prevented or maintained at levels well
below the Evaluation Guidelines.
As described above, DOE/NNSA is
committed to improving the safety
posture of the Tritium Facilities. The
actions already taken and those in
progress meet the requirements of our
Directives. No additional actions are
required at this time.
DOE/NNSA actions and plans that
would have responded to this Subrecommendation are complete or
underway and therefore are considered
to have met the issues highlighted and
meet the intent of the recommendation.
DOE/NNSA would be willing to brief
the DNFSB on these actions on a
recurring basis.
Sub-recommendation 3—Evaluate the
adequacy of the following safety
management programs and upgrade
them as necessary to ensure that SRS
can effectively respond to energetic
accidents at the Tritium Facilities, and
that it can quickly identify and properly
treat potential victims.
Sub-Recommendation #3 discusses
the Site’s capability to respond to a
Tritium event. The SRS and Tritium
Facilities Emergency Management
programs have made significant
improvements over the past several
years. The Emergency Preparedness (EP)
program meets DOE Directives and is
adequate to continue protecting the SRS
workers and the surrounding public. We
have recently evaluated the SRS safety
management programs and found them
to be adequate.
The current Emergency Management
program provides the appropriate
training required for individuals to
respond to alarms, abnormal operations,
and emergencies across SRS. The
Tritium Facilities EP program maintains
a fully qualified team which performs
approximately 50 drills per year to train
and validate the organizations ability to
respond to various scenarios, from
weather induced incidents to large
energetic events. SRS EP support
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organizations, like the SRS Fire
Department (FD), are trained and
routinely evaluated to ensure that they
can properly respond to an event in any
facility across the site. For example,
during the 2018 Site Exercise, the SRS
emergency response team responded to
a hypothetical complex multi-facility
and multi-contractor event that
included H-Area, Tritium, and H-Tank
Farm. Site level evaluated exercise
responses routinely involve multiple
local, county, state, and federal agencies
in the response efforts. In a trend to
further challenge all response
organizations, this latest exercise tested
the Site’s Emergency Response
Organization (ERO) to manage a
complex event with potential off-site
consequences. There were issues
identified in the exercise that SRS has
addressed and continues to address to
improve the program, including
identifying logistical challenges in the
movement of people from impacted
areas and then conducting appropriately
scoped drills to validate the
effectiveness.
DOE–SR, as the landlord at SRS, has
overall responsibility of the Emergency
Management Program for the site. As a
continuous improvement item, DOE–
SR, in conjunction with DOE/NNSA,
will perform an evaluation of the items
listed in the Sub-recommendation 3.
This evaluation will assess among other
things the ability and preparedness of
community emergency and medical
resources. Results of this evaluation will
be shared with the Board. Additionally,
DOE–SR will reassess the program if
Tritium source documents were to
substantially change in the future.
DOE/NNSA actions and plans that
would have responded to this
recommendation are complete,
underway, or planned and therefore are
considered to have met the objectives of
this Sub-recommendation. DOE/NNSA
is willing to brief the DNFSB on these
actions and keep the Board updated on
a reoccurring basis.
In summary, DOE/NNSA has already
initiated, and in some cases completed,
the actions the DNFSB recommends and
SRS tritium operations are providing
adequate protection of public safety.
Many significant long-term projects to
enhance safety in SRS tritium
operations are nearing completion.
Notably, the ongoing major construction
project to replace the HOAM Tritium
Facilities with new, modern, and robust
facilities is underway and is being
supported by the Department and
Congress.
These activities are significant and are
the proper implementation of DOE/
NNSA safety improvements at SRS.
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Therefore, DOE/NNSA concludes that
the most efficient, effective, and
quickest way to improve safety at the
SRS Tritium Facilities is to continue
with the current approach and path
forward. As previously noted, DOE/
NNSA actions and plans that would
have responded to this recommendation
are complete or underway and therefore
are considered to have met the issues
highlighted and meet the intent of the
recommendation.
[FR Doc. 2019–21438 Filed 10–1–19; 8:45 am]
BILLING CODE 6450–01–P
DEPARTMENT OF ENERGY
DOE/NSF High Energy Physics
Advisory Panel
Office of Science, Department
of Energy.
ACTION: Notice of open meeting.
AGENCY:
This notice announces a
meeting of the DOE/NSF High Energy
Physics Advisory Panel (HEPAP). The
Federal Advisory Committee Act
requires that public notice of these
meetings be announced in the Federal
Register.
DATES: Thursday, November 21, 2019;
9:00 a.m. to 6:00 p.m., Friday,
November 22, 2019; 8:30 a.m. to 4:00
p.m.
ADDRESSES: Bethesda Doubletree, 8120
Wisconsin Avenue, Bethesda, Maryland
20814.
FOR FURTHER INFORMATION CONTACT:
Michael Cooke, Executive Secretary;
High Energy Physics Advisory Panel
(HEPAP); U.S. Department of Energy;
Office of Science; SC–25/Germantown
Building, 1000 Independence Avenue
SW, Washington, DC 20585; Telephone:
(301) 903–4140; email: Michael.Cooke@
science.doe.gov.
SUPPLEMENTARY INFORMATION:
Purpose of Meeting: To provide
advice and guidance on a continuing
basis to the Department of Energy and
the National Science Foundation on
scientific priorities within the field of
high energy physics research.
Tentative Agenda: Agenda will
include discussions of the following:
November 21–22, 2019
• Discussion of Department of Energy
High Energy Physics Program
• Discussion of National Science
Foundation Elementary Particle
Physics Program
• Reports on and Discussions of
Topics of General Interest in High
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• Public Comment (10-minute rule)
Public Participation: The meeting is
open to the public. A webcast of this
SUMMARY:
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]]>Agencies
[Federal Register Volume 84, Number 191 (Wednesday, October 2, 2019)]
[Notices]
[Pages 52494-52496]
From the Federal Register Online via the Government Publishing Office [www.gpo.gov]
[FR Doc No: 2019-21438]
-----------------------------------------------------------------------
DEPARTMENT OF ENERGY
DOE Response to Recommendation 2019-2 of the Defense Nuclear
Facilities Safety Board, Safety of the Savannah River Site Tritium
Facilities
AGENCY: Office of Environment, Health, Safety and Security, Department
of Energy.
ACTION: Notice.
-----------------------------------------------------------------------
SUMMARY: On June 11, 2019, the Defense Nuclear Facilities Safety Board
issued Recommendation 2019-2, Safety of the Savannah River Site Tritium
Facilities, to the Department of Energy. In accordance with the Atomic
Energy Act of 1954, the Secretary of Energy's response to the
Recommendation is provided in this notice.
DATES: Comments, data, views, or arguments concerning the Secretary's
response are due on or before November 1, 2019.
ADDRESSES: Please send to: Defense Nuclear Facilities Safety Board, 625
Indiana Avenue NW, Suite 700, Washington, DC 20004.
FOR FURTHER INFORMATION CONTACT: Mr. Christopher Chaves, Office of the
Departmental Representative to the Defense Nuclear Facilities Safety
Board, Office of Environment, Health, Safety and Security, U.S.
Department of Energy, 1000 Independence Avenue SW, Washington, DC
20585, or telephone number (301) 903-5999, or email
[email protected].
SUPPLEMENTARY INFORMATION: On June 11, 2019, the Defense Nuclear
Facilities Safety Board issued Recommendation 2019-2, Safety of the
Savannah River Site Tritium Facilities, to the Department of Energy.
Recommendation 2019-2 was published in the Federal Register on June 19,
2019 (84 FR 28517). In accordance with section 315(c) of the Atomic
Energy Act of 1954 (42 U.S.C. 2286d(c)), the Secretary of Energy's
response to the Recommendation is printed in full at the conclusion of
this notice.
Signed in Washington, DC on September 24, 2019.
Joe Olencz,
Departmental Representative to the Defense Nuclear Facilities Safety
Board, Office of Environment, Health, Safety and Security.
September 10, 2019
The Honorable Bruce Hamilton
Defense Nuclear Facilities Safety Board
625 Indiana Avenue NW, Suite 700
Washington, DC 20004
Dear Mr. Chairman:
I appreciate the Defense Nuclear Facilities Safety Board's (DNFSB)
continued support to the Department of Energy's National Nuclear
Security Administration (DOE/NNSA) in the safe operation of our
facilities. I am committed to ensuring DOE/NNSA continues to remain
fully compliant in the safe operations of our defense nuclear
facilities in a manner that provides adequate protection to the public,
our workforce, and the environment. Secretary Perry has requested that
I respond to DNFSB Recommendation 2019-2, Safety of the Savannah River
Site Tritium Facilities, dated June 11, 2019. In responding, I first
want to assure you that DOE/NNSA remains fully compliant and committed
in our duties to the American public in the safe operation of these
facilities as outlined in the enclosure to this letter. These actions
address the concerns of the DNFSB and reflect how DOE/NNSA is providing
adequate protection of the public's health and safety at the Tritium
Facilities at the Savannah River Site (SRS). Therefore, I do not accept
Recommendation 2019-2.
DOE/NNSA's safety programs and policies, and their effective
implementation by our well-trained workforce, provide reasonable
assurance that adequate protection of public health and safety is
provided. Focused ongoing actions at the Tritium Facilities at SRS
adequately address DNFSB concerns outlined in Recommendation 2019-2 and
make the need for additional actions in response to a DNFSB
Recommendation unnecessarily duplicative of that effort, and would,
therefore, detract from our continued progress. Our commitment to
safety in the Tritium Facilities remains un-wavering, and there has
been no change in the conservative safety philosophy in the operation
of the Tritium Facilities.
The Department believes that the current Tritium Facilities'
documented safety analysis contains appropriate safety significant
controls and the new analysis, which is nearing completion, will
strengthen that safety posture. The
[[Page 52495]]
planned Tritium Finishing Facility (TFF), included in the President's
FY 2020 Budget Request, will fundamentally improve safety at SRS, as
DOE/NNSA moves from the aging H-Area Old Manufacturing Facility to this
new seismically-qualified facility. Furthermore, the SRS Emergency
Management Program has demonstrated steady and significant improvement
over the past several years and continues to provide adequate
protection to the workforce and the public surrounding SRS. A
comprehensive explanation of our safety improvement activities is
detailed in the enclosure.
DOE/NNSA would be willing to brief DNFSB on our actions outlined in
the enclosure and keep the Board updated over time. We appreciate the
Board's perspectives and look forward to the continued positive
interactions with you and your staff.
If you have any questions, please contact Ms. Nicole Nelson-Jean,
Manager of the Savannah River Field Office, at (803) 208-3689.
Sincerely,
Lisa E. Gordon-Hagerty
Enclosure
Enclosure
Department of Energy (DOE) Secretary Response to the June 11, 2019,
DNFSB Recommendation 2019-2, Safety of the Savannah River Site Tritium
Facilities
Sub-recommendation 1--Identify and implement near-term compensatory
measures at SRS to mitigate the potential for high radiological
consequences to individuals who would be impacted by a release from the
Tritium Facilities.
Procedural reductions in the Material At Risk (MAR) have been
completed in the Tritium Facilities. Each operating facility that makes
up the Tritium Facilities has an associated MAR listed in the
Documented Safety Analysis (DSA). When it was understood that the new
analysis would increase the dose consequences, Savannah River Nuclear
Solutions (SRNS) reduced tritium quantities in such facility through
the Automated Reservoir Management System. These reductions are
reflected in the DSA currently advancing through the approval process
by the Department's approval process.
Over the past several years, the Department of Energy's National
Nuclear Security Administration (DOE/NNSA) and the Savannah River Site
(SRS) Management and Operating partner, SRNS, have taken actions to
continue improving the Tritium Facilities safety posture. A new hazards
analysis has been conducted along with a revision to the DSA. This new
analysis has further emphasized identifying engineered controls over
administrative controls. The Board's technical staff was recently
provided a draft of the new DSA. The Department notes that even with
the extreme conservatism in the analytical parameters, including a
postulated simultaneous release of all tritium, from all the multiple
facilities within 20 minutes; the postulated consequences to the public
remain below the Evaluation Guideline of DOE-STD-3009-94, Preparation
Guide for U.S. Department of Energy Nonreactor Nuclear Facility
Documented Safety Analyses.
In addition, hypothetical, worst-case modeling does not account for
any Emergency Response exposure reduction actions, personnel self-
protection actions, nor any subsequent response actions to mitigate the
potential consequences. Based on the current DSA, and the new DSA in
review, reasonable assurance of adequate protection is ensured and the
risk to the public remains very low. It is anticipated that the new DSA
will be approved in 2019. The actions taken in completing the DSA
aligns with addressing the concerns raised in Recommendation 2019-2.
DOE/NNSA actions and plans that would have responded to this Sub-
recommendation are complete or underway and therefore are considered to
have met the objectives of this Sub-recommendation. DOE/NNSA is willing
to brief the DNFSB on these actions on a recurring basis.
Sub-recommendation 2--Identify and implement long-term actions and
controls to prevent or mitigate the hazards and pose significant
radiological consequences to acceptably low values consistent with the
requirements of DOE directives.
As noted in the Recommendation, DOE/NNSA committed in 2011 to
develop a new analytical model for dose consequences for SRS. In 2011,
DOE/NNSA outlined a plan to update the atmospheric dispersion model,
which was completed in 2014. Implementation of that new analysis began
shortly thereafter and included a review of the safety controls
selection and hierarchy. DOE/NNSA decided to combine all the Tritium
Facilities' safety bases and to conduct a holistic revision to the DSA.
The new analysis placed additional emphasis on engineered controls over
administrative controls. After an extensive review, DOE/NNSA directed
changes and updates to the draft DSA, including development of a formal
strategy that will continue to strengthen the controls to protect co-
located workers (CWs) from large energetic events postulated by the
safety analysis. The revised DSA was delivered to DOE/NNSA in November
2018. Subject matter experts from across DOE/NNSA have completed a
review of the resubmitted DSA and have generated a number of additional
items requiring further action. The actions taken in completing the DSA
aligns with addressing the concerns raised in Recommendation 2019-2.
The new DSA includes a number of new credited features, including
the 217-H Vault walls and fire damper, new Specific Administrative
Controls (SACs) for fire water tank, and other new Fire Suppression
Surveillances have been added. In addition, all current Programmatic
Controls have been replaced by at least one SAC.
In 2018, recognizing the desire to reduce worker consequences, DOE/
NNSA requested and received from SRNS a strategy for risk reduction to
CWs (U-ESR-H-00163, Rev.0). This strategy describes the SRNS plans for
additional structural analyses and control development, if required for
the remaining facilities during a potential seismic event. This
analysis will be used to determine suitability for upgrading the
functional classification of additional controls. It also includes
analysis for dose reduction (e.g. tritium oxidation conversion rates,
plume rise phenomena, etc.). In the aggregate, the plan includes 19
commitments that are being pursued and managed (SRNS-T0000-2018-00227,
Transmittal of the Schedule for Implementing the Strategy for Risk
Reduction to the Co-Located Worker in Tritium Facilities).
Longer term plans include the construction of the Tritium Finishing
Facility (TFF) capital line item project, to replace the aging HAOM
234-H facility with a seismically-qualified facility with a dedicated
fire suppression system. The TFF project will mitigate potential risks
to DOE/NNSA's Stockpile Stewardship Program stemming from housing
operations in outdated facilities.
A formal Analysis of Alternatives (AoA) was performed and
documented for the TFF project. The results of the AoA recommended the
construction of new buildings instead of upgrading existing buildings
that involve tritium operations. This will promulgate safety in design
integration and the new TFF facilities will meet current DOE
requirements. It is anticipated the TFF project will meet the Critical
Decision-1 project milestone in early FY 2020. The current confinement
strategy for TFF is based on the use of multiple
[[Page 52496]]
physical barriers and active controls to include:
Robust containers storing the MAR.
Robust Natural Phenomena Hazard Design Category-3 (NDC-3)
structures preventing building collapse and impacts to containers.
Robust NDC-3 fire suppression systems preventing the
spread of a fire and mitigating the consequences of a release.
Exhaust Ventilation with elevated release to mitigate
consequences to the CWs. Based on application of passive barriers and
active controls, the mitigated consequence to both the public and CW
from a release of radiological materials is either prevented or
maintained at levels well below the Evaluation Guidelines.
As described above, DOE/NNSA is committed to improving the safety
posture of the Tritium Facilities. The actions already taken and those
in progress meet the requirements of our Directives. No additional
actions are required at this time.
DOE/NNSA actions and plans that would have responded to this Sub-
recommendation are complete or underway and therefore are considered to
have met the issues highlighted and meet the intent of the
recommendation. DOE/NNSA would be willing to brief the DNFSB on these
actions on a recurring basis.
Sub-recommendation 3--Evaluate the adequacy of the following safety
management programs and upgrade them as necessary to ensure that SRS
can effectively respond to energetic accidents at the Tritium
Facilities, and that it can quickly identify and properly treat
potential victims.
Sub-Recommendation #3 discusses the Site's capability to respond to
a Tritium event. The SRS and Tritium Facilities Emergency Management
programs have made significant improvements over the past several
years. The Emergency Preparedness (EP) program meets DOE Directives and
is adequate to continue protecting the SRS workers and the surrounding
public. We have recently evaluated the SRS safety management programs
and found them to be adequate.
The current Emergency Management program provides the appropriate
training required for individuals to respond to alarms, abnormal
operations, and emergencies across SRS. The Tritium Facilities EP
program maintains a fully qualified team which performs approximately
50 drills per year to train and validate the organizations ability to
respond to various scenarios, from weather induced incidents to large
energetic events. SRS EP support organizations, like the SRS Fire
Department (FD), are trained and routinely evaluated to ensure that
they can properly respond to an event in any facility across the site.
For example, during the 2018 Site Exercise, the SRS emergency response
team responded to a hypothetical complex multi-facility and multi-
contractor event that included H-Area, Tritium, and H-Tank Farm. Site
level evaluated exercise responses routinely involve multiple local,
county, state, and federal agencies in the response efforts. In a trend
to further challenge all response organizations, this latest exercise
tested the Site's Emergency Response Organization (ERO) to manage a
complex event with potential off-site consequences. There were issues
identified in the exercise that SRS has addressed and continues to
address to improve the program, including identifying logistical
challenges in the movement of people from impacted areas and then
conducting appropriately scoped drills to validate the effectiveness.
DOE-SR, as the landlord at SRS, has overall responsibility of the
Emergency Management Program for the site. As a continuous improvement
item, DOE-SR, in conjunction with DOE/NNSA, will perform an evaluation
of the items listed in the Sub-recommendation 3. This evaluation will
assess among other things the ability and preparedness of community
emergency and medical resources. Results of this evaluation will be
shared with the Board. Additionally, DOE-SR will reassess the program
if Tritium source documents were to substantially change in the future.
DOE/NNSA actions and plans that would have responded to this
recommendation are complete, underway, or planned and therefore are
considered to have met the objectives of this Sub-recommendation. DOE/
NNSA is willing to brief the DNFSB on these actions and keep the Board
updated on a reoccurring basis.
In summary, DOE/NNSA has already initiated, and in some cases
completed, the actions the DNFSB recommends and SRS tritium operations
are providing adequate protection of public safety. Many significant
long-term projects to enhance safety in SRS tritium operations are
nearing completion. Notably, the ongoing major construction project to
replace the HOAM Tritium Facilities with new, modern, and robust
facilities is underway and is being supported by the Department and
Congress.
These activities are significant and are the proper implementation
of DOE/NNSA safety improvements at SRS. Therefore, DOE/NNSA concludes
that the most efficient, effective, and quickest way to improve safety
at the SRS Tritium Facilities is to continue with the current approach
and path forward. As previously noted, DOE/NNSA actions and plans that
would have responded to this recommendation are complete or underway
and therefore are considered to have met the issues highlighted and
meet the intent of the recommendation.
[FR Doc. 2019-21438 Filed 10-1-19; 8:45 am]
BILLING CODE 6450-01-P
