**\[DOE LETTERHEAD\]**

March 2, 2004

The Honorable John T. Conway

Chairman

Defense Nuclear Facilities Safety Board

625 Indiana Avenue, NW, Suite 700

Washington, DC 20004-2901

Dear Mr. Chairman:

This letter transmits the Programmatic Risk Assessment for the Savannah
River Site (SRS) Salt Processing Program (Commitment 2.12 of the
Department of Energy's Implementation Plan in response to Recommendation
2001-l), provides information on the Low Curie Salt (LCS) Program
(Commitment 2.11), and gives notice that Commitment 2.9 (Process the
first batch of LCS in Saltstone) was not met as scheduled.

In accordance with Commitment 2.12, please find enclosed the
Programmatic Risk Assessment for the SRS Salt Processing Program
(Enclosure 1). The assessment covers the risks and proposed mitigation
actions for the key facilities and activities required to execute all
three phases of the SRS Salt Processing Program: LCS processing, low
curie-high actinide processing, and high curie-high actinide processing.
The Department plans to maintain this assessment and update it as
needed. It will be used as a management tool to ensure that risks are
identified, managed, and mitigated to support our Accelerated Cleanup
Program goals.

One of the identified risks in the Programmatic Risk Assessment is how
ongoing litigation may delay certain aspects of the Salt Processing
Program. On July 3, 2003, parts of DOE Order 435.1 dealing with the
authority for determining waste incidental to reprocessing were declared
invalid by the U.S. District Court for the District of Idaho. This
ruling currently is on appeal to the U.S. Court of Appeals for the Ninth
Circuit. Accordingly, the Programmatic Risk Assessment did not undertake
a probability or consequence analysis of the litigation's outcome on the
Salt Processing Program and rated this risk as "Uncertain." Once this
litigation is resolved, the Department will provide you with an update
on salt waste processing and disposal plans.

An evaluation of the LCS Program as outlined in Commitment 2.11 has
found that while the LCS Program plans and schedules have not been fully
achieved, several key technical milestones have been met. The most
significant of these are:

-   The draining of higher curie interstitial liquid from high level
    waste saltcake in Tank 41 and dissolution of a portion of the
    remaining saltcake.

-   Modification of the Saltstone facility to process salt solutions
    with a cesium activity of 0.1 curies per gallon in anticipation of
    LCS feed.

-   Restoration of Building 512-S and the cold chemical demonstration of
    filter performance. Plant activities remain ahead of schedule to
    demonstrate actinide removal process viability by the June 2004
    commitment date.

Several issues have prevented the LCS Program from meeting all of its
objectives.

-   Technical problems were encountered with returning Tank 50 to
    service due to the discovery of excessive solids and
    tetraphenylborate on the bottom of the tank. As highlighted in the
    July 14, 2003, letter, these issues have been resolved; however,
    resolution delayed program progress.

-   The Saltstone Facility permit modifications required for processing
    LCS feed, and disposal of the resulting grouted waste, were
    submitted to the State of South Carolina in September 2002. The
    South Carolina Department of Health and Environmental Control
    notified the Department that it would take no official action on the
    permit applications pending resolution of the ongoing litigation
    concerning waste incidental to reprocessing. Without this permit,
    the current plan to process LCS at Saltstone (Commitment 2.9) cannot
    proceed.

-   While permit issues may prevent waste processing at this time, the
    Department and its contractors continue working to demonstrate the
    technical feasibility of the LCS processing option. Samples of the
    dissolved Tank 41 saltcake have been taken and the analytical
    results have been provided to your staff. These sample results show
    higher than anticipated activity levels and may result in the need
    for additional actions to achieve the total volume to be disposed of
    as LCS.

Should you or your staff have any questions concerning these issues,
please contact Jeffrey Allison at (803) 952-6337 or me at (202)
586-0738.

Sincerely,

***Dr. Inés Triay***

***Deputy Chief Operating Officer***

***Office of Environmental Management***

[Enclosure](../AttachedFile/tb04m02a_enc.pdf)

cc w/o encl:

Jessie Hill Roberson, EM- 1

Mark Whitaker, DR-1

Jeffrey Allison, SR