**\[SOE LETTERHEAD\]**

June 16, 2004

The Honorable Richard B. Cheney

President of the Senate

Washington, D.C. 20510

Dear Mr. President:

We are pleased to submit to Congress the enclosed report concerning
plutonium storage at our Savannah River Site, located near Aiken, South
Carolina. This report was mandated by Congress in Section 3183 of the
Defense Authorization Act for Fiscal Year 2003 (Public Law 107-314).
Section 3183 directed that the Defense Nuclear Facilities Safety Board
(Board) conduct a study of the adequacy of facilities at the Savannah
River Site for the storage of plutonium, and that it submit to Congress
and the Secretary of Energy a report on that study. Congress further
mandated in Section 3183 that not later than six months after the
Board's report is submitted to Congress, and every year thereafter, the
Secretary and the Board each submit to Congress a report on the actions
taken by the Secretary in response to proposals in the report.

The Board submitted its report, *Plutonium Storage at the Department of
Energy's Savannah River Site*, both to Congress and the Secretary of
Energy by letters dated December 1, 2003. The enclosed report is the
first one being submitted to Congress by the Department of Energy on the
actions being taken in response to the eight proposals contained in the
Board's December 2003 report. As indicated in our report, we are
expediting our decisions on disposal of excess plutonium and
re-evaluating our plutonium storage plan to determine if there are
better options.

If you need additional information, please contact me or Mr. Rick A.
Dearborn, Assistant Secretary for Congressional and Intergovernmental
Affairs, at (202) 586-5450.

Sincerely,

***Spencer Abraham***

Enclosure

**\[SOE LETTERHEAD\]**

June 16, 2004

The Honorable J. Dennis Hastert

Speaker of the House of Representatives

Washington, D.C. 20515

Dear Mr. Speaker:

We are pleased to submit to Congress the enclosed report concerning
plutonium storage at our Savannah River Site, located near Aiken, South
Carolina. This report was mandated by Congress in Section 3183 of the
Defense Authorization Act for Fiscal Year 2003 (Public Law 107-314).
Section 3183 directed that the Defense Nuclear Facilities Safety Board
(Board) conduct a study of the adequacy of facilities at the Savannah
River Site for the storage of plutonium, and that it submit to Congress
and the Secretary of Energy a report on that study. Congress further
mandated in Section 3183 that not later than six months after the
Board's report is submitted to Congress, and every year thereafter, the
Secretary and the Board each submit to Congress a report on the actions
taken by the Secretary in response to proposals in the report.

The Board submitted its report, Plutonium Storage at the Department of
Energy's Savannah River Site, both to Congress and the Secretary of
Energy by letters dated December 1, 2003. The enclosed report is the
first one being submitted to Congress by the Department of Energy on the
actions being taken in response to the eight proposals contained in the
Board's December 2003 report. As indicated in our report, we are
expediting our decisions on disposal of excess plutonium and
re-evaluating our plutonium storage plan to determine if there are
better options.

If you need additional information, please contact me or Mr. Rick A.
Dearborn, Assistant Secretary for Congressional and Intergovernmental
Affairs, at (202) 586-5450.

Sincerely,

***Spencer Abraham***

Enclosure

**First Report to Congress**

**On Actions Taken by the Department of Energy**

**In Response to the Proposals in the**

**Defense Nuclear Facilities Safety Board's**

**December 2003 Report to Congress on**

**Plutonium Storage at the Savannah River Site**

![](media/image1.png){width="1.7222222222222223in"
height="1.6347222222222222in"}

**Department of Energy**

**June 2004**

**Report to Congress on Actions Taken by the Department of Energy in
Response to**

**the Proposals in the Defense Nuclear Facilities Safety Board's
December 2003**

**Report to Congress on Plutonium Storage at the Savannah River Site**

[Introduction]{.underline}

Section 3183 of the Defense Authorization Act for Fiscal Year 2003
(Public Law 107-314) directed that the Defense Nuclear Facilities Safety
Board (Board) conduct a study of the adequacy of the K-Area Materials
Storage (KAMS) facility and related support facilities at the Savannah
River Site (SRS), such as Building 235-F, for the storage of defense
plutonium and defense plutonium materials. That statute also required
that the Board submit to Congress and the Secretary of Energy a report
on that study, including any proposals the Board considers appropriate
to enhance the safety, reliability, and functionality of KAMS. Congress
further mandated in Section 3183 that not later than six months after
the Board's report is submitted to Congress, and every year thereafter,
the Secretary and the Board each submit to Congress a report on the
actions taken by the Secretary in response to the proposals, if any,
included in the report.

The Board submitted its report, "Plutonium Storage at the Department of
Energy's Savannah River Site," both to Congress and the Secretary by
letters dated December 1, 2003. That report presented conclusions of the
Board's study, and identified several proposals for enhancing the
safety, reliability, and functionality of plutonium storage facilities
at SRS.

This report is the first one submitted to Congress by the Secretary of
Energy on the actions being taken by the Department of Energy (DOE) in
response to the proposals contained in the Board's December 2003 report
on plutonium storage at SRS.

[Board's Proposals]{.underline}

The Board's December 2003 report contains eight proposals; two on the
plutonium disposition program, five on the suitability of facilities
(one on KAMS and four on Building 235-F), and one on remote monitoring
and retrieval of material. Those proposals are listed below.

*Plutonium Disposition Program*

-   Expedite the development of a complete, well-considered plan for the
    disposition of all excess plutonium to preclude unnecessary extended
    storage of plutonium at SRS.

-   Conduct a new study of available options for the storage of
    plutonium at SRS.

*Suitability of Facilities*

KAMS

-   Install fire protection systems and eliminate unnecessary
    combustibles in KAMS.

Building 235-F

-   Establish an acceptable safety basis for stabilization and packaging
    of plutonium and extended storage of plutonium in the facility.

-   Conduct a systematic evaluation of the safety systems to determine
    needed upgrades.

-   Perform a structural analysis assessing seismic adequacy measured by
    current acceptance criteria. Since the facility has a new extended
    mission, the structural analysis should be based on ground motion
    equivalent to that used in the analysis for a new facility at SRS.

-   Decontaminate unused process cells.

*Remote Monitoring and Retrieval of Material*

-   Develop and implement validated procedures for the handling and
    intrasite shipment of plutonium containers, including damaged
    containers.

[Discussion]{.underline}

This section provides some discussion/background in order to provide a
better understanding of actions being taken by the Department.

*Plutonium Disposition Program and Potential Consolidation of Surplus
Plutonium at SRS*

Over the past several years, DOE has made a series of decisions
involving the storage and disposition of approximately 50 metric tons of
surplus plutonium materials. Decisions have been made concerning the
method of disposition to meet nonproliferation agreements with the
Russian Federation (e.g., by fabrication of surplus plutonium into mixed
oxide (MOX) fuel).

In April 2002 DOE decided, in concert with a decision to cancel the
plutonium immobilization project, to select a plutonium storage
alternative evaluated in the "Storage and Disposition of Weapons-Usable
Fissile Materials Final Programmatic Environmental Impact Statement"
(Storage and Disposition PEIS), DOE/EIS-0229, dated December

1996\. As stated in the "Amended Record of Decision, Surplus Plutonium
Disposition Program," published in the Federal Register, Vol. 67, p.
19432, April 19, 2002, DOE decided to immediately implement
consolidation for long-term storage at the SRS of surplus non-pit
material stored separately at the Rocky Flats Environmental Technology
Site (RFETS). DOE stated specifically that the decision affected only
the non-pit surplus plutonium located at Rocky Flats.

The decision to cancel the immobilization program was based primarily on
an assessment that the agreement with Russia to further nonproliferation
objectives by eliminating 34 metric tons of surplus plutonium from each
nation could be met using only the mixed oxide fuel program. Subsequent
to the 2002 decision, DOE determined that some surplus plutonium
materials originally intended for immobilization could be processed and
used to manufacture mixed oxide fuel. DOE issued the "Amended Record of
Decision, Surplus Plutonium Disposition Program," published in the
Federal Register, Vol. 68, p.

20134, April 24, 2003, indicating that about six metric tons of
plutonium originally intended for immobilization could potentially be
used as an alternative feedstock for the manufacture of mixed oxide
fuel. Therefore, with 34 metric tons of surplus plutonium to be
dispositioned through the MOX fuel program, approximately 16 metrics
tons would be without a disposition path. However, about three metric
tons of this surplus plutonium has subsequently been reclassified as
programmatic need material, resulting in a total of up to approximately
13 metric tons of surplus plutonium that currently is without a
disposition path.

All of the plutonium currently at SRS, which now includes all the
surplus non-pit material once stored at the RFETS, is part of the 13
metric tons of surplus plutonium discussed above. The vast majority of
the remainder of those 13 metric tons is currently stored at Hanford,
with smaller amounts currently stored at the Los Alamos and Lawrence
Livermore National Laboratories. Although the Department is evaluating
the consolidation of the entire 13 metric tons at SRS, at the time of
this report no decision had yet been made concerning this matter, and
such a decision would be subject to appropriate National Environmental
Policy Act (NEPA) review.

*Suitability of Facilities*

All the plutonium at SRS has been, and will continue to be, stored in a
safe manner. The plutonium storage facilities at SRS, including KAMS and
Building 235-F, meet all applicable safety requirements for their
current limited storage missions, as documented in existing safety basis
documentation.

[Status of Actions Taken by DOE in Response to the Board's
Proposals]{.underline}

*Plutonium Disposition Program*

**Board Proposal:** Expedite the development of a complete,
well-considered plan for the disposition of all excess plutonium to
preclude unnecessary extended storage of plutonium at SRS.

**DOE Actions:** DOE is conducting a preliminary investigation into a
potential vitrification process that could be used at SRS to prepare
excess plutonium that cannot be fabricated into MOX fuel for potential
disposal in a deep geologic repository. This process would incorporate
plutonium in small cans of lanthanide borosilicate glass. These small
cans of plutonium-bearing glass would the n be placed in Defense Waste
Processing Facility canisters, surrounded with high-level waste glass.
DOE is investigating the use of an existing SRS facility that could be
adapted for installation of the vitrification capability. Any facility
chosen would undergo a complete evaluation for its intended mission, and
any required upgrades would be performed. The results of the feasibility
study are to be provided to the Assistant Secretary for Environmental
Management by the end of fiscal year 2004.

DOE is currently in the process of preparing a license application for a
spent fuel repository at Yucca Mountain. Although DOE has done
analytical work regarding disposal of plutonium immobilized in ceramic
at Yucca Mountain, it has not done analysis specific to disposal of
vitrified plutonium there. Accordingly, given the very preliminary
nature of the investigation DOE is conducting into the feasibility of
vitrifying plutonium in this fashion, the license application DOE is
currently developing does not analyze or assume disposal of vitrified
plutonium at Yucca Mountain. In conjunction with other aspects of its
investigative work into the vitrification process, DOE will also seek to
determine what kind of analytical work might be called for to support a
potential license amendment that could allow it to dispose of the
vitrified plutonium at Yucca Mountain, assuming DOE decides it is
seriously interested in pursuing this course of action. Any serious
planning by DOE concerning potential disposal of plutonium immobilized
in this fashion at Yucca Mountain would, of course, require DOE to
develop the necessary information to support such a license amendment
and to seek and obtain the U.S. Nuclear Regulatory Commission's approval
of such a license amendment.

Any plutonium vitrification capability would be established by
implementing a project in accordance with DOE Order 413.3, "Program and
Project Management for the Acquisition of Capital Assets". This Order
describes the normal process that DOE uses for managing capital
projects, and the appropriate NEPA review would be performed for this
project.

**Board Proposal:** Conduct a new study of available options for the
storage of plutonium at SRS.

**DOE Actions:** The Department is updating the November 2000 study
concerning the storage of plutonium at SRS. Assumptions used to update
the study will be consistent with the recently approved project
concerning plutonium storage and stabilization in Building 235-F. The
study update is expected to be completed by June 30, 2004.

*Suitability of Facilities*

KAMS

**Board Proposal:** Install fire protection systems and eliminate
unnecessary combustibles in KAMS.

**DOE Actions:** DOE will evaluate the results of pending revisions to
safety and fire hazards analyses to determine what actions are needed.
In April 2003, DOE directed the contractor to revise the current safety
basis documentation for KAMS to reflect a facility life that extends
beyond ten years. As part of this facility life extension evaluation, a
new Fire Hazards Analysis (FHA) for KAMS is also being performed. The
revised analyses are expected to be completed by September 2004.

The original design life for the KAMS facility was about 10 years. The
fire protection posture designed into KAMS was to minimize both
transient and fixed combustibles within the facility such that the
remaining worst possible fire could not cause a release of plutonium.
The walls separating the KAMS facility from the remainder of the
K-Reactor building were fabricated into a two hour fire boundary.
Combustibles outside the facility fire boundaries were minimized,
contained, or mitigated to ensure the KAMS facility fire boundaries were
rated longer than any credible fire would burn.

Building 235-F

**Board Proposal:** Establish an acceptable safety basis for
stabilization and packaging of plutonium and extended storage of
plutonium in the facility.

**DOE Actions:** A revised safety basis and FHA are currently scheduled
to be completed and submitted to DOE by no later than April 2005. In
conjunction with the decision last year to pursue a project to install a
DOE-STD-3013 container surveillance, packaging and storage capability in
Building 235-F, DOE directed the contractor in April 2003 to upgrade the
235-F safety basis for the remainder of the facility to be commensurate
with such an extended facility mission. The safety basis revisions will
result in one set of 10 CFR 830 (*Nuclear Safety Management*)-compliant
Documented Safety Analysis (DSA) and associated Technical Safety
Requirements (TSRs) for the 235-F facility.

**Board Proposal:** Conduct a systematic evaluation of the safety
systems to determine needed upgrades.

**DOE Actions:** A systematic evaluation of safety systems to determine
needed upgrades will be performed as part of the ongoing revision to the
safety basis. As part of the normal process of development of a 10 CFR
830-compliant safety basis, a systematic evaluation of the required
safety systems is conducted to ensure those systems can perform their
required functions. For existing facilities, the safety systems must be
evaluated to ensure they can perform the required safety function
identified by the accident analysis performed as part of the revision to
the safety basis. The process at SRS used to perform this evaluation is
called a backfit analysis, an engineering evaluation process controlled
by WSRC Manual E7, "Conduct of Engineering and Technical Support
Procedure Manual," Procedure 3.41, "Backfit Analysis Process". All
active safety systems identified by the new 235-F DSA will have a
backfit analysis performed to ensure they can perform their required
safety function. If any upgrades to safety systems are needed, they will
be identified based on the analysis. DOE will review the backfit
analysis as part of its DSA approval process.

**Board Proposal:** Perform a structural analysis assessing seismic
adequacy measured by current acceptance criteria. Since the facility has
a new extended mission, the structural analysis should be based on
ground motion equivalent to that used in the analysis for a new facility
at SRS.

**DOE Actions:** A structural analysis of Building 235-F and its
outlying buildings is being conducted to current acceptance criteria, as
part of the DSA upgrade discussed above. New soil settlement evaluations
are also being conducted to identify the maximum expected differential
settlement from a design basis seismic event. Building 235-F and
outlying structures will then be analyzed to determine the overall
effect of the seismic event on safety systems. Any modifications to
safety systems to ensure they can perform their required functions
during and after a seismic event would be made prior to extending the
current facility mission. Since 235-F is an existing facility, the
structural analysis is being conducted based on ground motion equivalent
to that used for an existing facility at SRS. However, a structural
analysis for Building 235-F and its outlying structures based on a
ground motion equivalent to that used in the analysis for a new facility
at SRS is also being performed. DOE will evaluate the results from these
facility structural analyses to determine what course of action will be
required to provide adequate protection to the public and workers from
postulated accidents.

**Board Proposal:** Decontaminate unused process cells.

**DOE Actions:** A feasibility study is being performed to determine
whether the cells can be decontaminated or whether the plutonium-238
within the cells can be immobilized such that it would not be released
during any design basis accidents in the facility. An assay of these
process cells is also currently in progress to provide a better
determination of the actual amount of plutonium remaining. Based on the
results of the feasibility study, expected to be completed by October
2004, DOE will determine what course of action will be appropriate. It
should be noted that the safety basis upgrade and systematic evaluation
of the resulting safety systems must be consistent with the path forward
from this feasibility study.

*Remote Monitoring and Retrieval of Material*

**Board Proposal:** Develop and implement validated procedures for the
handling and intrasite shipment of plutonium containers, including
damaged containers.

**DOE Actions:** WSRC-RP-99-01027, "Memorandum of Agreement Between the
Nuclear Materials Management Operations Business Unit and the FB-Line
Project Closure Business Unit," Revision 2, with an effective date of
April 13, 2004, describes the responsibilities and requirements for
shipment of containers with plutonium from KAMS to F-Area. The handling
and intrasite shipment of plutonium-bearing containers at SRS is an
ongoing process that utilizes DOE Orders and site procedures. The
ability to ship simulated damaged containers from KAMS to F-Area was
demonstrated during the Operational Readiness Review for KAMS. Prior to
any shipment, a detailed engineering review would be performed based on
the specific damage to the shipping container. A generic procedure for
F-Area to receive a damaged container has recently been approved.