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]

Download as PDF 52494 Federal Register / Vol. 84, No. 191 / Wednesday, October 2, 2019 / Notices Tuesday, October 29, 2019, 8:30 a.m.– 5:15 p.m. Wednesday, October 30, 2019, 9:00 a.m.–12:00 p.m. ADDRESSES: Sun Valley Inn, 2 Sun Valley Road, Sun Valley, Idaho 83353. FOR FURTHER INFORMATION CONTACT: David Borak, EM SSAB Designated Federal Officer, U.S. Department of Energy, 1000 Independence Avenue SW, Washington, DC 20585; Phone: (202) 586–9928, or email: david.borak@ em.doe.gov. SUPPLEMENTARY INFORMATION: Purpose of the Board: The purpose of the Board is to make recommendations to DOE–EM and site management in the areas of environmental restoration, waste management, and related activities. Minutes: Minutes will be available by writing or calling David Borak at the address or phone number listed above. Minutes will also be available at the following website: https://energy.gov/ em/listings/chairs-meetings. Tentative Agenda Topics AGENCY: khammond on DSKJM1Z7X2PROD with NOTICES Tuesday, October 29, 2019 • EM Program Update • EM SSAB Chairs’ Round Robin • EM Budget Update • Transportation in Environmental Cleanup • Working with DOE on Transportation Planning • Public Comment • Board Business Wednesday, October 30, 2019 • DOE Headquarters News and Views • Field Operations/Waste Disposition Update • Public Comment • Board Business Public Participation: The meeting is open to the public. The EM SSAB Chairs welcome the attendance of the public at their advisory committee meetings and will make every effort to accommodate persons with physical disabilities or special needs. If you require special accommodations due to a disability, please contact David Borak at least seven days in advance of the meeting at the phone number listed above. Written statements may be filed either before or after the meeting with the Designated Federal Officer, David Borak, at the address or telephone listed above. Individuals who wish to make oral statements pertaining to agenda items should also contact David Borak. Requests must be received five days prior to the meeting and reasonable provision will be made to include the presentation in the agenda. The Designated Federal Officer is empowered to conduct the meeting in a fashion that will facilitate the orderly conduct of business. Individuals wishing to make public comment will be provided a maximum of five minutes to present their comments. VerDate Sep<11>2014 16:42 Oct 01, 2019 Jkt 250001 Signed in Washington, DC, on September 26, 2019. 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: PO 00000 Frm 00041 Fmt 4703 Sfmt 4703 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 E:\FR\FM\02OCN1.SGM 02OCN1 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 khammond on DSKJM1Z7X2PROD with NOTICES 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 VerDate Sep<11>2014 16:42 Oct 01, 2019 Jkt 250001 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 PO 00000 Frm 00042 Fmt 4703 Sfmt 4703 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 E:\FR\FM\02OCN1.SGM 02OCN1 khammond on DSKJM1Z7X2PROD with NOTICES 52496 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 VerDate Sep<11>2014 16:42 Oct 01, 2019 Jkt 250001 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. PO 00000 Frm 00043 Fmt 4703 Sfmt 4703 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 Energy Physics • Public Comment (10-minute rule) Public Participation: The meeting is open to the public. A webcast of this SUMMARY: E:\FR\FM\02OCN1.SGM 02OCN1

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