In November 1999, the Deputy Secretary of the Department of Energy directed a series of actions to strengthen the Department's ongoing nuclear criticality safety programs. A Review Plan describing lines of inquiry for assessing contractor programs was included. The Office of River Protection completed their assessment of the Tank Farm Contractor program in May 2000. This document supports that assessment by providing a compliance statement for each line of inquiry.
This document provides a detailed matrix of specific Tank Farms nuclear criticality safety program elements indexed to primary requirements documents. These requirements are collected at a higher level in HNF-SO-MP-SRID-001, ''Tank Waste Remediation System Standards/Requirements Identification Document.'' The intended use of this document is to provide a roadmap for implementing procedures and assessments.
On July 19, 1993, the Defense Nuclear Facilities Safety Board transmitted Recommendation 93-5 on the Hanford Waste Tank Characterization Studies to the Department of Energy. The recommendation was accepted on September 9, 1993. Recommendation 93-5 noted that there was insufficient tank waste technical information to ensure that Hanford Site wastes could be safely stored, that associated operations could be conducted safely, and that future disposal data requirements could be met. As a result the Board recommended that the characterization effort be upgraded and expedited. The original Implementation Plan was accepted by the Board in March 1994. This Implementation Plan revision presents a modified approach to achieve the original Implementation Plan objectives. The approach concentrates on actions necessary to ensure that wastes can be safely stored, that operations can be safely conducted, and that timely characterization information for the tank waste Disposal Program can be obtained. Since Recommendation 93-5 was issued, significant progress has been achieved in understanding tank safety- related phenomena, resolving tank safety issues, and enhancing the capability and efficiency of tank characterization. Reviewing this progress led to the realization that tank safety issues could not be resolved solely by accelerating sampling and analysis to improve the characterization of tank contents. The key to expediting resolution was to better understand safety-related phenomena that cause the safety issues. A revised characterization and safety strategy evolved. The characterization and safety strategy presented in this Implementation Plan revision builds on the improved understanding and significant progress made to date. The revision is multifaceted and consists of the key elements listed: (1) Maintain tanks in an interim configuration using safety controls and, where necessary, mitigative actions. (2) Upgrade and complete the Authorization Basis for the Tank Farms. This includes producing a Basis for Interim Operation, Final Safety Analysis Report, Technical Safety Requirements, Compliance Implementation Plan, and Safety Evaluation Report. (3) Complete the ongoing programs to resolve the ferrocyanide, organic complexants, organic solvents, flammable gas, high heat, and criticality safety issues. (4) Analyze core samples from key tanks (referred to as the High Priority Tanks) to understand phenomena and resolve issues associated with groups of tanks. These tanks were selected by integrating the information needs of the Safety and Disposal Programs. Appendix F provides a summary of the High Priority Tanks identified and the basis for information requested.
With the implementation of DOE Order 420.1B, Facility Safety, and DOE-STD-3007-2007, 'Guidelines for Preparing Criticality Safety Evaluations at Department of Energy Non-Reactor Nuclear Facilities', a new requirement was imposed that all criticality safety controls be evaluated for inclusion in the facility Documented Safety Analysis (DSA) and that the evaluation process be documented in the site Criticality Safety Program Description Document (CSPDD). At the Hanford site in Washington State the CSPDD, HNF-31695, 'General Description of the FH Criticality Safety Program', requires each facility develop a linking document called a Criticality Control Review (CCR) to document performance of these evaluations. Chapter 5, Appendix 5B of HNF-7098, Criticality Safety Program, provided an example of a format for a CCR that could be used in lieu of each facility developing its own CCR. Since the Plutonium Finishing Plant (PFP) is presently undergoing Deactivation and Decommissioning (D & D), new procedures are being developed for cleanout of equipment and systems that have not been operated in years. Existing Criticality Safety Evaluations (CSE) are revised, or new ones written, to develop the controls required to support D & D activities. Other Hanford facilities, including PFP, had difficulty using the basic CCR out of HNF-7098 when first implemented. Interpretation of the new guidelines indicated that many of the controls needed to be elevated to TSR level controls. Criterion 2 of the standard, requiring that the consequence of a criticality be examined for establishing the classification of a control, was not addressed. Upon in-depth review by PFP Criticality Safety staff, it was not clear that the programmatic interpretation of criterion 8C could be applied at PFP. Therefore, the PFP Criticality Safety staff decided to write their own CCR. The PFP CCR provides additional guidance for the evaluation team to use by clarifying the evaluation criteria in DOE-STD-3007-2007. In reviewing documents used in classifying controls for Nuclear Safety, it was noted that DOE-HDBK-1188, 'Glossary of Environment, Health, and Safety Terms', defines an Administrative Control (AC) in terms that are different than typically used in Criticality Safety. As part of this CCR, a new term, Criticality Administrative Control (CAC) was defined to clarify the difference between an AC used for criticality safety and an AC used for nuclear safety. In Nuclear Safety terms, an AC is a provision relating to organization and management, procedures, recordkeeping, assessment, and reporting necessary to ensure safe operation of a facility. A CAC was defined as an administrative control derived in a criticality safety analysis that is implemented to ensure double contingency. According to criterion 2 of Section IV, 'Linkage to the Documented Safety Analysis', of DOESTD-3007-2007, the consequence of a criticality should be examined for the purposes of classifying the significance of a control or component. HNF-PRO-700, 'Safety Basis Development', provides control selection criteria based on consequence and risk that may be used in the development of a Criticality Safety Evaluation (CSE) to establish the classification of a component as a design feature, as safety class or safety significant, i.e., an Engineered Safety Feature (ESF), or as equipment important to safety; or merely provides defense-in-depth. Similar logic is applied to the CACs. Criterion 8C of DOE-STD-3007-2007, as written, added to the confusion of using the basic CCR from HNF-7098. The PFP CCR attempts to clarify this criterion by revising it to say 'Programmatic commitments or general references to control philosophy (e.g., mass control or spacing control or concentration control as an overall control strategy for the process without specific quantification of individual limits) is included in the PFP DSA'. Table 1 shows the PFP methodology for evaluating CACs. This evaluation process has been in use since February of 2008 and has proven to be simple and effective. Each control identified in the applicable new/revised CSE is evaluated via the table. The results of this evaluation are documented in tables attached to the CCR as an appendix, for each CSE, to the base document.
