November 16, 1994

The Honorable Victor H. Reis
Assistant Secretary for Defense Programs
Department of Energy
Washington, D.C. 20585

Dear Dr. Reis:

Defense Nuclear Facilities Safety Board (DNFSB) staff visited the
Los Alamos National Laboratory (LANL) on August 31 - September 1,
1994.  The focus of the review was on plutonium repackaging and
consolidation efforts at the PlutoniumFacility.  The staff noted
that the program to repackage plutonium metal and oxide is
progressing.  However, the program to characterize and process
plutonium-bearing scrap and residues may require additional
attention toaddress concerns expressed by LANL personnel with
continued storage of thismaterial that was not intended for
long-term storage.

These scrap and residue materials are similar to those discussed in
DNFSBRecommendation 94-1.  We understand that some of these items
have also been addressed in theDepartment of Energy Plutonium
Environment, Safety, and Health VulnerabilityAssessment as having
specific vulnerabilities associated with them.  Thus, itwould
appear that activities to address this situation should be
consideredwithin the overall approach the Department of Energy is
developing to addressmaterial storage issues raised in DNFSB
Recommendation 94-1.

The enclosed report includes observations made during the review
and isforwarded for your information.  If you have any questions,
please call me.

                                                           

                                        Sincerely,

                                       John T. Conway
                                       Chairman

cc:      The Honorable Tara O'Toole, EH-1
         Mr. Mark Whitaker, EH-6
         Mr. Bruce Twining, Manager, Albuquerque Operations Office

Enclosure

DEFENSE NUCLEAR FACILITIES SAFETY BOARD

September 14, 1994       

MEMORANDUM FOR:  G. W. Cunningham, Technical Director

COPIES:          Board Members

FROM:            A. De La Paz

SUBJECT:         Report on Review of Plutonium Repackaging Program
at the Plutonium Facility -Los Alamos National
                 Laboratory

1.    Purpose:  This report documents a review of the plutonium
repackaging program at the Plutonium Facility at Los Alamos
National Laboratory (LANL) by Defense Nuclear Facilities Safety
Board (DNFSB) technical staff member Andrew De La Paz.  This review
was conducted on August 31 - September 1, 1994.  In addition,
outside expert Dr. Joseph Leary accompanied Mr. De La Paz during
discussions of the Automated Glovebox Can Out (AGC) Program    at
Sandia National Laboratories - Albuquerque (SNL-ALB) on August 30,
1994.  The AGC Program is a joint SNL-LANL effort.

2.    Summary:  LANL personnel are in the process of developing a
repackaging program for plutonium metal and oxide at the Plutonium
Facility.  A program for characterizing and limited processing of
plutonium-bearing scrap and residues is just beginning.  LANL
personnel noted that both programs, as well as research efforts to
support hese programs, are limited  due to a lack of funding.

      LANL personnel stated that the scrap and residue materials
pose a significant near-term risk to workers in the Plutonium
Facility.  The DNFSB staff is also concerned with the continued
storage of plutonium-bearing materials that were packaged for
short-term storage, primarily scrap and residues.

3.    Background:  The review documented in this report is the
third DNFSB technical staff review of plutonium storage issues at
LANL.  Previous reviews were conducted on October 27-28, 1993, and
January 31 - February 1, 1994.  The results of those reviews are
included in the DNFSB Technical Report DNFSB/TECH-1, Plutonium
Storage Safety at Major Department of Energy Facilities.

4.    Discussion/Observations:

      a.   Scrap Stabilization and Residue Consolidation:  LANL
personnel described a new initiative  to prioritize (based upon
hazard) plutonium-bearing items for repackaging and limited
processing and to develop storage criteria and processing options
for the large amount of scrap and residue items that are stored
in the Plutonium Facility.  Generally, the Plutonium Facility has
the facilities, personnel, and procedures for processing the
various residue materials.  Currently, the repackaging and
stabilization are only being performed on plutonium-bearing items
regarded as "emergencies" by the LANL TA-55 Nuclear Material
Management Group.  LANL plans on allocating about $3.5M for this
program in fiscal year 1995, but maintains that this funding level
is inadequate for the level of risk that this material poses to
personnel within the Plutonium Facility.
  
      b.   Plutonium-Bearing Items:  The Plutonium Facility 
contains the vast majority of plutonium-bearing items at LANL.  The
total number of items is about 7,600, which includes about 4,000
containers of reactive residues (e.g., pyrochemical salts), 2,000
containers of oxide, 1,500 containers of metal, and 120 containers
of solutions.  LANL personnel stated that the packaging of these
materials (primarily the reactive scrap and residues) is a
significant near-term personnel safety concern at the Plutonium
Facility.  LANL personnel also stated that specific funding to
repackage and/or stabilize these materials has not been allocated.

      c.   LANL Criteria for Repackaging Plutonium Metal and Oxide: 
The LANL criteria for the repackaging of plutonium metal and oxide
items are essentially the same as the criteria being developed by
the Department of Energy (DOE) as drafted (dated March 31, 1994) in
U.S. Department of Energy Criteria for Storage of Plutonium Metals
and Oxides.  LANL personnel are performing experimental work using
plutonium oxide to determine material characteristics such as
loss-on-ignition (LOI)--a method to determine the amount of water
and organics that are adsorbed on the oxide--and particle size
distribution as a function of the calcination temperature and the
type of oxide (from metal or precipitate).  LANL personnel believe
that the results of this experimental work can be used to show that
oxide fired at less than 1,000 degrees C or handled in an
environment with more than 100 ppm water (conditions required by
the draft DOE criteria include heating the oxide to at least 1,000
degrees C and handling and packaging oxide in a dry atmosphere to
retain 0.5% LOI ) may be acceptable under some circumstances. The
Plutonium Facility has at least three calcining ovens that have the
capability to fire oxide at 1000 degrees C.

      d.   Status of Plutonium Metal and Oxide Repackaging:  The
primary purpose of the DNFSB technical staff visit was to review
the status of metal and oxide repackaging in the  Plutonium
Facility.  A LANL document entitled TA-55 Metallic and Oxide SNM
Repackaging Plan, dated January 13, 1994, provided a preliminary
plan for the repackaging of metal and oxide plutonium materials. 
This plan calls for the long-term storage of plutonium metal and
oxide in two welded, nested, stainless steel containers without the
use of organic materials.  The welding is planned to be completed
in existing gloveboxes with a helium atmosphere that contains less
than 100 ppm water.  The goal is for long-term packaging at LANL to
generally be accomplished to the requirements of the draft DOE
criteria.  LANL personnel currently plan on implementing such a
program in the spring of 1995.  A demonstration of the repackaging
capability is tentatively planned to be completed before October 1,
1994.  The major items to be completed prior to beginning this
program include the certification of a process to weld the
stainless steel containers, as well as setup of the welding
process, and the development of procedures for the entire
repackaging  program.

           Recently, 28 metal items were retrieved from the TA-55
vault and radiographed to determine the degree that these items had
oxidized.  The sample was random.  The radiographs indicated that
approximately one third of the items exhibited various degrees of
oxidation, indicative of air leakage into the containers.

      e.   Resource Conservation and Recovery Act (RCRA)
Implications:  LANL personnel noted that DOE has not provided clear
guidance to LANL to aid in defining which plutonium-bearing
materials are to be regulated under RCRA.  LANL personnel suspect
that RCRA constituents potentially exist in a large fraction of 
the plutonium-bearing vault materials.  The implications for
classifying material to be regulated under RCRA include: 1) that if
materials are to be stabilized, the stabilization processes may
need to be permitted by the New Mexico Environmental Department
(NMED); and 2) inspection and labeling requirements may not be in
consonance with As Low As Reasonably Achievable (ALARA) practice. 
In the interim, processes that are used to stabilize materials on
an emergency basis are not permitted by NMED, other than as noted
below.

      f.   Nitrated Rags:  DOE recently received a 90-day permit
from the NMED to thermally stabilize nitrated rags that were
previously in storage under water in gloveboxes.  LANL personnel
noted that it took over a year for NMED to approve the emergency
permit request by DOE to thermally stabilize this material.

      g.   Automated Glovebox Can Out (AGC) Program:  A joint
program exists between  SNL and LANL to develop an AGC process that
could be utilized at the Plutonium Facility at TA-55.  This program
was initiated in January 1994 and includes the intent to meet the
DOE long-term plutonium metal and oxide storage criteria that is
cited above.  The AGC concept would utilize two robots.  One robot
would receive a material container from an electrolytice
contamination station, check for contamination, and place this
container in a leak testing station.  The second robot would place
the material container into a boundary container, and then place
the boundary container in successive stations where it would be
welded and then leak tested.  The AGC program currently plays a
very minor role in LANL's plan for developing a metal and oxide
repackaging process.  This is partly due to current SNL planning to
perform site testing at LANL in early 1996.

5.    Future Staff Actions:  The DNFSB staff will follow LANL
progress in the metal and oxide repackaging program, as well as the
scrap and residue characterization and processing program.