DOE PLAN OF ACTION TO RE-ASSESS

SAVANNAH RIVER SITE'S HIGH LEVEL WASTE

MANAGEMENT STRATEGY

DNFSB RECOMMENDATION 2001-1

##### IMPLEMENTATION PLAN

REVISION 4

June 2006

# Executive Summary

On March 23, 2001, the Defense Nuclear Facilities Safety Board (DNFSB)
issued Recommendation 2001-1, *High-Level Waste Management at the
Savannah River Site.* The recommendation addressed the need for the
Department of Energy (DOE) to ensure that the margin of safety and
amount of tank space in the Savannah River Site (SRS) High Level Waste
(HLW) system is sufficiently maintained to enable timely stabilization
of nuclear materials at SRS.

The DOE accepted this recommendation and found that the DNFSB
recommendation appropriately highlighted the need to vigorously address
the significant management challenges that SRS faces in accomplishing
the strategic mission of waste stabilization in light of the failure of
the In-Tank Precipitation (ITP) process, tank leaks, and other equipment
problems. These events forced major changes in the overall system plans
and additional actions were warranted to identify ways to regain
operational flexibility, increase system margins to deal with potential
future system upsets, and proceed with an alternative salt disposition
process. DOE agreed with the DNFSB that addressing these issues should
ensure continued safe storage of wastes, as well as continued
stabilization of both high level waste and nuclear materials at SRS.

This original plan outlined the actions that DOE and its contractors
were going to take to ensure continued safe storage of waste while
maintaining operational flexibility and progress in the stabilization of
material currently held in waste storage tanks. Actions included pumping
down liquid levels to below the lowest leak sites in two tanks,
implementing an alternative salt disposition process, re-evaluating
waste treatment and storage options, and conducting an independent
assessment of the contractor incentives.

Revision 2 of this Implementation Plan (IP) was submitted to the Board
on May 10, 2002 as specified in Commitment 2.6 to provide additional
commitments related to the implementation of a revised salt processing
program. Six new commitments and the associated background discussion
were added to the end of the sub-recommendation 2 section.

Revision 3 of the IP, which was submitted to the Board on January 17,
2006, was generated as a result of delays in meeting Commitments 2.9,
Demonstrate the Viability of Low Curie Salt Disposition (LCS), and
Commitment 2.10, Demonstrate the Viability of the Actinide Removal
Process (ARP). Because of the delays in these activities, the changes in
facility conditions, and other changes impacting tank space management,
Revision 3 re-evaluated the DNFSB's original concerns and
recommendations in light of the circumstances in the early CY 2006
timeframe and set forth a modified strategy to address the issues.

This revision (Revision 4) has been generated to reflect continuing
delays in implementing Commitment 2.9, Demonstrate the Viability of the
Deliquification, Dissolution, and Adjustment (DDA) process. These delays
are the result of ongoing discussions with the State of South Carolina
regarding the DOE's January 2006 *Section 3116 Determination for Salt
Waste Disposal at the Savannah River Site*. DOE has refined the approach
described in DOE's January 2006 Section 3116 Determination for Salt
Waste Disposal for treating the SRS salt waste. Under the refined
approach, DOE plans to: 1) treat and dispose of less waste with DDA, the
least effective of the interim processes; 2) further process some waste
with ARP/MCU that was originally planned to be processed with DDA alone,
3) pursue the treatment and destruction of organic laden material in
Tank 48 (originally planned to be processed with DDA); and 4) construct
new lag storage vessels for the Saltstone Production Facility, subject
to compliance with the National Environmental Policy Act. This refined
approach is consistent with the recent NAS recommendation to limit the
use of DDA, will decrease the curies disposed of at SRS, and will not
affect the conclusions in the 3116 Determination.

The Plan identifies the responsible manager and provides a due date for
completion for each commitment. The responsible manager ensures the
activity is satisfactorily completed, including seeking necessary
funding, and formally closed. Dr. Inés Triay, Chief Operating Officer
for Environmental Management, is the overall Responsible Manager and Mr.
Jeffrey Allison, Manager, Savannah River Operations Office, is the
point-of-contact for site-specific activities.

##### Table of Contents

[Page]{.underline}

1\. Background 4

2\. Underlying Causes 4

3\. Summary of Completed and Near-Term Actions 4

4\. Recommendation Issue Resolution

Subrecommendation 1 -- Leaking Tanks 5

Subrecommendation 2 -- Salt Processing 6

Subrecommendation 3 -- Tank Space Management 10

Subrecommendation 4 -- Incentives 15

5\. Management and Organization 16

**1.** **Background**

On March 23, 2001, the Defense Nuclear Facilities Safety Board (DNFSB)
issued Recommendation 2001-1, *High-Level Waste Management at the
Savannah River Site.* The recommendation addresses the need for the
Department of Energy (DOE) to ensure that the margin of safety and
amount of tank space at SRS is sufficiently maintained to enable timely
stabilization of nuclear materials at SRS. The DOE accepted the
recommendation as addressed in the IP provided to the Board on May 18,
2001. On May 24, 2001, the DNFSB responded in a letter in which it found
the original IP was not responsive to all elements of the recommendation
and provided a suggested course of action for consideration by the DOE
during the formulation of a revised IP. The DOE evaluated the concerns
described in the DNFSB's May 24, 2001, letter and revision 1 to the
original plan incorporated and addressed the DNFSB's expected actions.
Revision 2 of this IP was generated as specified in Commitment 2.6 to
provide additional commitments related to the implementation of a
revised salt processing program. Six new commitments and the associated
background discussion were added to the end of the sub-recommendation 2
section. All commitments made in Revision 2 except two were completed.
Due to legal and technical issues, delays were experienced in meeting
Commitments 2.9, Demonstrate the Viability of Low Curie Salt Disposition
(LCS), and Commitment 2.10, Demonstrate the Viability of the Actinide
Removal Process (ARP). As a result of these delays, changes in facility
conditions, and adjustments in program directions, Revision 3 of this IP
was a complete re-evaluation of the original issues in light of
circumstances at that time. Neither the text nor the commitment
summaries retain all of the original responses and actions and review of
Revision 2 is required to understand actions already completed. This
revision (Revision 4) reflects the approach refinements associated with
DOE's January 2006 *Section 3116 Determination for Salt Waste Disposal
at the Savannah River Site* and provides minor updates as appropriate.

**2. Underlying Causes**

The underlying causes of the matters highlighted in Recommendation
2001-1 were the failure of the ITP process, tank leaks, and other
equipment problems within the waste system. These events, along with
litigation, have forced major changes in the overall system plans and
added a level of complexity to the already challenging mission
objectives. The actions identified in this Plan are intended to outline
the major objectives and milestones to ensure mission objectives are
safely achieved.

**3. Summary of Completed and Near-Term Actions**

All commitments in Revision 2 of the IP except two \[Commitment 2.9,
Demonstrate the Viability of Low Curie Salt Disposition (LCS), and
Commitment 2.10, Demonstrate the Viability of the Actinide Removal
Process (ARP)\] have been completed and are not repeated in this
revision.

**4. Recommendation Issue Resolution**

The Board's subrecommendations and the specific actions to address each
subrecommendation are discussed below.

**Subrecommendation 1. Initiate actions to remove transferable HLW
liquid from Tank 6 to a level below all known leak sites.**

[Background]{.underline}: After a January 2001 transfer of low activity
waste water into an older style (Type I) tank (Tank 6) that had been
essentially empty since 1973, alarms were received in the control room
indicating liquid in the annulus area (collection space between the tank
wall and the concrete vault that encases the tank). Visual inspections
confirmed liquid in the annulus and sampling identified the material as
radioactive waste (versus rainwater intrusion). Detailed inspections
using a remote crawler and video camera identified 6 leak sites. An
initial transfer of 40,000 gallons of liquid from Tank 6 into Tank 8 was
completed on March 27, 2001. The direction to lower Tank 6 further was
given to the site contractor on May 1, 2001, and the contractor
completed lowering the level in Tank 6 to below the lowest known leak
site on May 30, 2001.

[Re-evaluation]{.underline}: DOE continues to restrict additions into
the Type I and Type II style tanks to only those required to facilitate
waste removal activities. Typical additions for waste removal activities
include liquid needed to slurry/mix the sludge, liquid needed to
facilitate transfer of the waste from the tank, liquids required to keep
a "wet" sludge from "drying", liquids for heel removal, liquids for
flushing or cleaning equipment/tank structures, and chemicals for
corrosion control. Several of these activities may include the addition
of liquids above known leak sites. In these cases, precautions are
implemented to limit the amount of material at risk for leakage and
necessary equipment is available prior to liquid additions.

In addition, Type I and Type II style tanks may be used to facilitate
waste or residual heel removal from another older style tank.
Specifically, waste from Tanks 4, 5, and 6 is planned to be transferred
to Tank 7 before being transferred to Extended Sludge Processing (ESP)
due to the existing transfer piping arrangements. Another example
includes the use of existing Tank 7 supernate to suspend the Tank 5
sludge. This allows for the beneficial re-use of liquids needed to
slurry/mix the sludge from these tanks without creating additional "new"
waste volumes.

Tank inspections continue in accordance with visual and ultrasonic
inspection plans. No additional leak sites or tank wall cracks have been
identified below the waste level in the tanks.

All previous commitments associated with this subrecommendation have
been successfully completed and no additional commitments are planned
for this issue.

***Subrecommendation 2. Reassess the schedule and priority for selecting
a technology for a salt processing capability, and vigorously accelerate
the schedule leading to operation of a salt processing facility.***

[Background:]{.underline} At the point of Defense Waste Processing
Facility (DWPF) startup in 1996, the system plan consisted of two waste
pretreatment processes -- sludge preparation via the ESP and salt
preparation via ITP. Due to initial startup issues with the ITP process
(see Board Recommendation 96-1), DWPF began operations processing sludge
only. In 1998, due to concerns the ITP process could not
cost-effectively meet safety and production objectives, the contractor
recommended and the DOE agreed to suspend ITP startup activities and to
perform an extensive evaluation of alternative processing options. The
alternative evaluation resulted in the selection of a solvent extraction
based process for cesium removal in lieu of ITP. A contract has been
established to build and operate a Salt Waste Processing Facility (SWPF)
based on this solvent extraction process and the project is currently in
the design stage.

Originally, DOE expected to begin disposition of lower curie salt in
June of 2002 followed by a SWPF in the 2010 timeframe. The Department
believed this dual approach would provide short-term tank space relief,
a long-term solution for salt disposition, and protect both the public
and the environment. Congress, in Section 3116 of the Ronald W. Reagan
National Defense Authorization Act for Fiscal Year 2005, clarified the
Secretary's authority to determine, in consultation with the NRC, that
certain wastes from reprocessing, including certain waste at SRS, are
not high level waste if the provisions of section 3116 are met. DOE
issued a "Section 3116 Determination for Salt Waste Disposal at the
Savannah River Site (DOE-WD-2005-001)" after consultation with the NRC.
The salt disposal strategy discussed in the Section 3116 determination
concerns the disposal of 3 to 5 million curies of radioactivity in the
Saltstone Facility. The next major step in the process is issuance by
the State of South Carolina of a Class 3 Industrial Solid Waste Landfill
permit modification. In addition, a modified waste water treatment
operating permit for recent saltstone facility changes is also required.

[Re-evaluation:]{.underline} DOE's current salt disposition strategy
continues to be a multi-phased approach that dispositions limited
quantities of lower activity salt waste near-term and then processes the
bulk of the salt wastes through the SWPF when it comes online. The first
phase of salt disposition is known as Deliquification, Dissolution, and
Adjustment (DDA), and is intended to disposition only that volume of
salt solution needed to ensure sufficient tank space is available to
support: 1) continued sludge waste disposition and other material
stabilization activities, and 2) preparation of salt waste feed material
for efficient operation of the SWPF. The material to be dispositioned in
the first phase must meet the proposed Saltstone Production Facility
waste acceptance criteria and the solidified waste will not exceed NRC
concentration limits for Class C low level waste in 10 CFR 61.55.

In parallel with the 3116 waste determination process, DOE has readied
the Saltstone Facility to safely and efficiently process the low
activity salt solutions. In order to process the DDA material,
modifications were made to the Saltstone Facility to handle higher
activity levels than the original design basis of the Saltstone
Facility. The primary modifications were related to operating personnel
safety. Changes to the facility include increased equipment shielding to
reduce radiation exposure, improvements to increase equipment
reliability and reduce hands-on maintenance, and modifications to
effectively deal with process upsets.

In addition to the tank space recovered by the DDA process, space is
also expected to be recovered via proposed operation of two processes
that employ the same technologies as SWPF. These two new processes are
known as the Actinide Removal Process (ARP) and Modular Caustic Side
Solvent Extraction Unit (MCU). ARP reduces the actinide and strontium
content of limited quantities of salt solution via precipitation and
filtration and MCU reduces the Cs-137 concentration via a
counter-current decantation process using a highly specialized solvent
(BoBCalix) developed by the DOE for this purpose. ARP and MCU are
planned to be operated on an interim basis and shut down prior to SWPF
startup.

The proposed ARP processing will be accomplished by modification of two
existing buildings; the 241-96H building (previously known as the ITP
stripper building) and the 512-S building (previously known as Late
Wash). The 241-96H allows for a chemical strike of monosodium titanate
(MST) and the 512-S filters the actinide and strontium laden MST out.
MCU is a new structure within the H-Tank Farm. While MCU is not expected
to have the same throughput or removal efficiency as the SWPF, it does
have the ability to process salt solutions that have higher Cs-137
concentrations, when compared to DDA, and provide early feedback on
potential production-level operational issues with SWPF. The ARP and MCU
are currently planned to be completed and ready for operations in 2007.

ARP also has the ability to provide additional strontium and actinide
removal capability to supplement the capability of the SWPF when it
comes on line in 2011. DOE will evaluate the need for the additional
strontium and actinide removal capability provided by ARP closer to the
time of startup of the SWPF when the expected processing rates for the
SWPF are better known.

Several technical, regulatory, and permitting issues are inherent in
each of the above project schedules. An overall programmatic risk
assessment has been completed and is being maintained for the Salt
Program and individual project risk assessments are being maintained for
each project. The primary risks with the DDA process are not considered
to be technical feasibility risks. Facility modification construction
and testing activities are complete. The most significant technical risk
in the DDA process is the potential for higher activity salt solutions
during salt dissolution than expected. The first batch of dissolved salt
waste from Tank 41 has been staged and sample data so far indicates the
material meets existing plans for disposal. DOE intends to limit the
saltcake waste processed through DDA to the Tank 41 waste.

Saltcake core sampling of Tank 25 has been performed and analysis of the
samples is under way to provide advanced indications of the
acceptability of that material for interim salt processing (currently
planned for ARP/MCU). However, until the salt waste is processed and
sampled, the potential remains that Tank 41 or Tank 25 may not meet
requirements. Analysis of core samples taken from a third tank (28) is
underway in the event the salt waste planned to be disposed can not meet
requirements.

As previously discussed, a Saltstone Facility disposal permit change is
required from the State of South Carolina. DOE continues to work closely
with the State to resolve issues as they are identified, however delays
in this process have resulted in additional delays in the start of low
activity salt processing and the Department will not be in a position to
meet the commitment dates in Revision 3 to this IP. An additional
program risk exists relative to the potential for additional legal
actions. Although not required by Section 3116, DOE issued the draft
waste determination for public review concurrent with the NRC
consultation. The public submitted comments on the draft Section 3116
waste determination and the public will have the opportunity to be
involved in the permit process; however, the potential for legal
challenges cannot be ruled out. The Revision 4 commitment date to
complete processing of 100,000 gallons of salt solution does not include
contingency for resolution of potential legal challenges.

Relative to the ARP, modification design work and construction
activities are complete and startup testing has begun. By the nature of
the process, technical risks are primarily related to achieving
throughput and decontamination factors in a production environment. The
technical risks for the MCU are much higher than ARP due to the fact MCU
is still in the construction phase, the increased complexity of the
process, and questions concerning solvent carryover into the DWPF and
Saltstone Facility operations. Modifications to the MCU design and
downstream facilities are currently being evaluated to address the
solvent carryover issue. It should be recognized that ARP and MCU
operations are directly dependent on Saltstone Facility operations and a
prolonged delay of the Saltstone Facility permits could impact ARP and
MCU operations. It is judged to be unlikely that the required facility
permits tied to ARP/MCU operations would be unnecessarily delayed.

In addition to their primary functions, both ARP and MCU provide
contingency capabilities. In the event DDA samples were to unexpectedly
show higher than expected actinide levels, the ARP could be utilized to
reduce the actinide levels. Similarly, MCU could be used to reduce
cesium levels in waste targeted for DDA.

The SWPF represents the highest technical risks of the salt treatment
processes due to its early design stage, higher operational complexity,
and multiple interfaces with other facilities. DOE recognizes the
importance of this project to the long-term completion of its mission
and the short-term impacts on the tank farms. DOE has assigned dedicated
resources to manage the design, construction, and initial operation of
this facility and has utilized an Engineering, Procurement, and
Construction (EPC) contractor outside of the traditional Managing and
Operating (M&O) contract strategy for the SWPF. The forecast commitment
date for startup of this facility is viewed by DOE as a bounding date at
this time. The Department is currently working toward a Critical
Decision 2 milestone following completion of preliminary design in late
2006 that will establish a formal project baseline schedule and cost. A
more accurate forecast completion date will be available at that time.

In summary, DOE continues to aggressively pursue a multi-phased approach
to salt disposition, has identified the project risks, and is working to
address the risks identified. DOE continually re-assesses the impacts of
issues on program implementation and provides the DNFSB staff periodic
updates on program status and timely notification of significant events.

All previous commitments associated with this subrecommendation except
two have been successfully completed. The current DOE implementation
milestones for this sub-recommendation include the two carryover
commitments from Revision 2 of this IP and two new commitments:

> Commitment 2.9: Demonstrate the viability of the Deliquification,
> Dissolution, and Adjustment (DDA).
>
> Lead Responsibility: Manager, Savannah River Operations Office
>
> Deliverable: Complete disposition of 100K gallons of salt solutions in
> Saltstone.
>
> Due Date: 90 days after issuance of the low activity Saltstone
> Facility disposal permit (i.e., Industrial Solid Waste Landfill
> permit) \[Demonstration expected by October 2006\]
>
> Commitment 2.10: Demonstrate the viability of the actinide removal
> process (ARP).
>
> Lead Responsibility: Manager, Savannah River Operations Office
>
> Deliverable: Complete the first batch actinide removal process.
>
> Due Date: November 2007
>
> Commitment 2.13: Begin Modular CSSX (Caustic Solvent Side Extraction)
> Unit (MCU) radioactive operations.

Lead Responsibility: Manager, Savannah River Operations Office

Deliverable: Radioactive material introduced for processing in MCU.

Due Date: November 2007

> Commitment 2.14: Begin Salt Waste Processing Facility (SWPF)
> radioactive operations.

Lead Responsibility: Manager, Savannah River Operations Office

Deliverable: Radioactive material introduced for processing in SWPF.

> Due Date: September 2011

***Subrecommendation*** ***3. Develop and implement an integrated plan
for HLW tank space management that emphasizes continued safe operation
of the Tank Farms throughout its life cycle. This plan should include
enough margin to accommodate contingencies and reduce overall
programmatic risk. The plan should also restore operating margin to the
Tank Farms by including actions to: \[see sections a - e below\]***

[Background:]{.underline} The Tank Farm space management strategy is
based on a set of key assumptions involving DWPF canister production
rates, influent stream volumes, Tank Farm evaporator performance, and
space gain initiative implementation. Tank space management is a subset
of the overall integrated System Plan and as such is a life-cycle look
at the space available to accommodate contingencies and support site
missions.

Due to the delays in starting salt disposition activities and
infrastructure issues with the site evaporators, an already challenging
task of tank space management has been further complicated. DOE and the
operating contractor continue to explore options and develop contingency
plans up to and including interim facility shutdown strategies to
support the earliest mission completion dates.

[Re-evaluation]{.underline}:

> ***a. reduce or eliminate the DWPF recycle stream***

DWPF is the largest single contributor of waste volume to the tank
farms. Several actions were taken to reduce the more than 2 million
gallons of DWPF recycle waste sent to the Tank Farms annually. A major
reduction effort was implemented in January 2000 to isolate the steam
atomized scrubber (SAS) system from the melter off-gas system. This
resulted in an annual 700,000-gallon reduction in recycle being sent to
the Tank Farm. However recent operational experience has resulted in the
need to periodically restore scrubber flow to maintain a nominal
operational life of the high efficiency mist elimination filters.
Implementation of proposals associated with the frit transfer system and
reductions in sample line flushes also resulted in additional water
generation reductions.

Additional DWPF recycle reduction proposals (such as the installation of
a DWPF acid evaporator and the feasibility of sending some recycle
directly to the Saltstone) continue to be evaluated based on factors
including the status of interim salt processing, evaporator performance,
available tank space, and budget priorities. DWPF recycle is currently
intended to be used in salt disposition activities and out-year planning
shows the start of a DWPF evaporator project in FY07 with completion
tied to start of SWPF operations. The need for a DWPF evaporator is
expected to increase once SWPF begins operations due to the volumes of
water used to transfer the concentrated cesium waste to DWPF and
increased SAS system flow required during combined sludge/salt
stabilization. The total DWPF recycle is expected to about double.

> ***b. recover former ITP tanks for Tank Farm operations***

Tank 49 was returned to service in 2001.

> **Tank 50 continues to be in service as a receipt tank for Effluent
> Treatment Project bottoms and as a feed tank to the Saltstone
> Facility. As the primary interface tank between the Tank Farms and
> Saltstone, Tank 50 is a critical resource in salt disposition.** Tank
> 48, which contains approximately 250,000 gallons of precipitate from
> the original startup of the ITP process, was evaluated for possible
> return to the tank farm system. The Department considers recovery of
> Tank 48 as a critical element in assuring sufficient tank space is
> available to prepare and feed salt solutions to SWPF in an efficient
> manner. Technical challenges must be resolved in order to safely
> return Tank 48 to service including issues with organic levels in
> facilities downstream of the tank farms. A team was chartered to
> define an achievable and allowable end state for the Tank 48H Project.
> The team divided this major activity into three tasks: 1) identify a
> reasonable range of potassium tetraphenylborate (KTPB) residual
> quantities to be left in Tank 48H at the end of the project along with
> the technical basis and assumptions through a parametric evaluation,
> 2) identify a reasonably conservative KTPB degradation rate based on
> Savannah River National Laboratory studies, and 3) determine the
> impact of various residual amounts of KTPB on the downstream processes
> after Tank 48H is returned to service. Based on the results of these
> work activities, DOE provided to the Board a technical evaluation of
> acceptable Tank 48 residual levels on April 4, 2006 and closed
> Commitment 3.8.
>
> This IP revision (Revision 4) reflects a change in the approach to
> Tank 48 material disposition provided to the Board on April 4, 2006.
> Based on discussions with the State of South Carolina and the
> principle of minimizing the curies to be dispositioned in the
> Saltstone vaults, organic destruction is now the primary option for
> Tank 48 material disposition and aggregation will become the backup
> alternative. The proposed commitment date for completing this activity
> remains January 2010, as specified in the April 4, 2006 deliverable.
> Commitment 3.9a has been added in this revision of the IP to reflect
> this information
>
> ***c. assess the desirability of adding an additional HLW evaporator
> to support Tank Farm operations***

Sufficient evaporator capacity already exists in the Tank Farms. The
operational limitations on the existing evaporators are largely support
system related. The evaporators are heavily dependent on sufficient tank
space for storage of waste after it has been concentrated. Therefore, no
additional tank farm evaporators are proposed; however an evaporator at
DWPF is planned as a way to minimize generation of new salt waste in the
tank farms and reduce DWPF's dependency on Tank Farm evaporator
operations -- see subrecommendations 3a and 3e.

> ***d. assess the feasibility of constructing new HLW tanks***

Given the long lead times to permit and construct a new high level waste
storage tank and the increased costs for closure of an additional tank,
no additional high level waste tanks are proposed. Although no new high
level waste tanks are proposed, recent integrated flow balance
projections between DWPF, SWPF, and Saltstone have indicated a need for
reassessment for hold tanks to improve process efficiencies. Based on
discussions with the State of South Carolina DOE intends to further
explore the viability of constructing such tanks through its existing
acquisition processes, including performing any appropriate National
Environmental Policy Act review.

> ***e. resolve waste compatibility and equipment degradation problems
> to allow unconstrained operation of the three existing evaporators***

Attempts to resolve material compatibility issues have been only
partially successful to date. While the operating parameters were
expanded for each of the evaporators, the need to segregate high silica
waste streams from enriched uranium/aluminum waste has not been
eliminated. Therefore, the 2H evaporator continues to be dedicated to
silica waste streams and the 2F/3H systems continue to handle the
traditional waste streams.

Improvements made to the 2F evaporator system during FY 2000 have made
that system more reliable, and current performance has met system
planning requirements. While the 2F pot is currently beyond its
projected life expectancy, recent inspections demonstrate it remains in
good physical condition. A spare evaporator pot is available for either
the 2F or 2H evaporator in the event one is needed. Modifications are
required to the spare pot depending on the needed location. Work
packages have been pre-staged to perform these modifications and the
activities required to perform a pot replacement have been outlined.

> The 3H evaporator system is operating in an extremely limited mode
> because the concentrate receipt tank (Tank 37) is almost filled with
> saltcake and there is only a limited amount of space available in the
> tank. Due to delays in salt disposition, limited saltcake dissolution
> and removal from Tank 37 is being pursued to restore the ability to
> operate the 3H evaporator and support timely processing of the large
> quantity of water produced during sludge washing. The limited volume
> of saltcake is to be dissolved in Tank 37 and transferred to Tank 35
> for temporary storage until it can be transferred to the 2F evaporator
> and reconcentrated to saltcake.

The 2H evaporator continues to experience mixed performance. The heavily
concentrated material in the evaporator system was removed early in FY
2005. Afterward the evaporator ran well with excellent overhead rates.
In April 2005, the evaporator began to experience operational problems
due to recurrent scale buildup in the piping systems. The evaporator
discharge piping was cleaned and an inspection of the evaporator pot
itself concluded cleaning could be delayed until 2006. In early 2006,
attempts were made to clean the evaporator pot using concentrated
caustic solutions. These attempts were of limited success and planning
is currently ongoing to perform acid cleaning later this year. Piping
systems were successfully cleaned using mechanical methods and the
evaporator is currently operational.

Overall DWPF recycle disposition and storage continues to be the major
concern in Tank Farm space management relative to immediate impacts to
continued missions. As discussed in subrecommendation 3.a, work
continues in this area to implement alternative disposition paths for
this material.

DOE continues to monitor tank space utilization at SRS on a routine
basis. Performance indicators have been developed to provide management
the ability to assess performance against the goals of the interim
processing strategy. Projections are officially updated quarterly but
individual transfers and receipts are assessed for impacts against
plans. An updated system plan that models tank space until mission
completion, incorporates the revised salt strategy, and adds the current
planning for sludge processing is expected to be issued in the last half
of 2006. Any perturbations resulting from delays in the projects noted
above or resulting from refinements in approach for 3116 are expected to
be incorporated into that planning with contingencies developed to
mitigate impacts.

Another integration tool is a proposed program evaluation for
interfacing the various processing facilities. The purpose of this
evaluation is to take the input and issues from various technical
reports, program and project risk reviews, and define a path forward for
resolution or mitigation. As an example, full scale testing of CSSX is
currently planned to better define the actual expected processing
capabilities for SWPF and the results of these tests are a key to
determining the needed infrastructure to support an efficient operation.
Other activities including detailed modeling of transfer and system
operations are underway to determine what, if any, modifications are
required to support efficient operations. A specific example being
evaluated now is whether additional tank space is needed as a buffer
between DWPF and SWPF based on the DWPF SRAT processing capabilities
versus planned SWPF outputs. By the fall of 2006, it is expected that
sufficient data can be assembled to support the development of a program
evaluation that outlines the path forward, decisions needed, and
schedules required. The program evaluation is intended to focus and
drive decisions, evaluate program progress, and highlight emergent
issues either independently or in conjunction with the detailed modeling
currently encompassed by the system plan. As a result of delays in the
start of DDA, the program evaluation will be delayed several weeks to
allow for assessment of the initial DDA operations to be included in the
program evaluation. In the event DDA processing is delayed further, the
program evaluation will be completed by November 2006 and will reflect
the impacts of the delay.

All previous commitments associated with this subrecommendation have
been successfully completed. The current DOE implementation milestones
for this subrecommendation include new commitments:

Commitment 3.8: Complete technical evaluation of acceptable Tank 48
residual levels.

Lead Responsibility: Manager, Savannah River Operations Office

Deliverable: Technical report.

Due Date: March 2006

Status: Completed April 2006

> Commitment 3.9: Develop plan and schedule for return of Tank 48 to
> waste service.

Lead Responsibility: Manager, Savannah River Operations Office

Deliverable: Commitment date to restore Tank 48 to waste service

> Due Date: March 2006
>
> Status: Completed April 2006
>
> Commitment 3.9a: Return of Tank 48 to waste service.

Lead Responsibility: Manager, Savannah River Operations Office

Deliverable: Disposition of Tank 48 material to residual quantities and
authorization to introduce new waste into Tank 48

> Due Date: January 2010
>
> Commitment 3.10: Startup a DWPF evaporator
>
> Lead Responsibility: Manager, Savannah River Operations Office
>
> Deliverable: Begin radioactive operations of a DWPF evaporator.
>
> Due Date: July 2011
>
> Commitment 3.11: Issue a program evaluation for integration of
> processing facilities.
>
> Lead Responsibility: Manager, Savannah River Operations Office
>
> Deliverable: Program Evaluation.
>
> Due Date: November 2006

***Subrecommendation 4.  Reassess contractor incentives to ensure that
near-term production at DWPF is not overemphasized at the expense of
safety margin in the Tank Farms***

[Background]{.underline}: The current contractual arrangements were
modified such that the SRS Management and Operations (M&O) contractor is
paid based on the value of work completed. DOE evaluated other contract
mechanisms and the SWPF contract is a direct contract with DOE, not
associated with the SRS M&O. A similar contract arrangement was
established for Glass Waste Storage Building #2 design and construction.

## 

[Reevaluation]{.underline}: Based on the current contract period through
2006, no additional changes to the contract type are expected on the M&O
contract however, specific work scopes may be modified. No additional
changes to the contract type are planned for SWPF or Glass Waste Storage
Building #2. DOE continues to evaluate various contract mechanisms and
plans to heavily emphasize salt disposition and tank space management in
a new contract strategy beyond 2006. The request for proposals is
expected to be issued in late 2005.

All previous commitments associated with this subrecommendation have
been successfully completed and no additional commitments are planned
for this issue.

**5.0** **Management and Organization**

The Chief Operating Officer for Environmental Management is the
Responsible Manager for this IP. She has responsibility to perform all
associated planning, response, and implementation activities, consistent
with guidance provided in *Interface with the Defense Nuclear Facilities
Safety Board* (DOE M 140.1-1B). The Manager for the Savannah River
Operations Office is the point of contact for the site-specific actions
for this recommendation.

To ensure that the various Departmental implementing elements and the
DNFSB remain informed of the status of Plan implementation, DOE\'s
policy is to provide periodic progress reports until IP commitments are
completed. For this Plan, the Responsible Manager and/or designee is
expected to provide quarterly reports (either in oral briefings or
written format) to the DNFSB and/or its staff.

This Plan requires sufficient flexibility to accommodate changes in
commitments, actions, or completion dates that may be necessary due to
additional information, improvements, or changes in baseline
assumptions. DOE\'s policy is to (1) provide prior, written notification
to the DNFSB on the status of any Plan commitment that is not be
completed by the planned milestone date, (2) have the Secretary approve
all revisions to the scope and schedule of Plan commitments, and (3)
clearly identify and describe the revisions and basis for the revisions.
Fundamental changes to the Plan\'s strategy, scope, or schedule are
expected to be provided to the DNFSB through formal revision and
re‑issuance of the Plan. Other changes to the scope or schedule of
planned commitments are expected to be formally submitted in appropriate
correspondence approved by the Secretary, along with the basis for the
changes and appropriate corrective actions.