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[Federal Register Volume 77, Number 98 (Monday, May 21, 2012)]
[Notices]
[Pages 29986-29988]
From the Federal Register Online via the Government Printing Office [www.gpo.gov]
[FR Doc No: 2012-12179]

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DEFENSE NUCLEAR FACILITIES SAFETY BOARD

[Recommendation 2012-1]

Savannah River Site Building 235-F Safety

AGENCY: Defense Nuclear Facilities Safety Board.

ACTION: Notice, recommendation.

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SUMMARY: Pursuant to the Atomic Energy Act of 1954, as Amended, the 
Defense Nuclear Facilities Safety Board has made a recommendation to 
the Secretary of Energy concerning safety at the Savannah River Site 
Building 235-F.

DATES: Comments, data, views, or arguments concerning the 
recommendation are due on or before June 20, 2012.

ADDRESSES: Send comments concerning this notice to: Defense Nuclear 
Facilities Safety Board, 625 Indiana Avenue NW., Suite 700, Washington, 
DC 20004-2001.

FOR FURTHER INFORMATION CONTACT: Brian Grosner or Andrew L. Thibadeau 
at the address above or telephone number (202) 694-7000.

    Dated: May 15, 2012.
Peter S. Winokur,
Chairman.

RECOMMENDATION 2012-1 TO THE SECRETARY OF ENERGY Savannah River Site 
Building 235-F Safety Pursuant to 42 U.S.C. 2286a(a)(5), Atomic Energy 
Act of 1954, As Amended

Dated: May 9, 2012

Background

    The Defense Nuclear Facilities Safety Board (Board) believes that 
the Department of Energy (DOE) needs to take action to remove and/or 
immobilize the residual contamination within Building 235-F because of 
the potential dose consequences to collocated workers and the public. 
Furthermore, the Board believes that DOE must also take near-term 
action to more effectively prevent a major fire in Building 235-F.
    Building 235-F at the Savannah River Site (SRS) houses several 
partially deactivated processing lines including the Plutonium Fuel 
Form (PuFF) facility, Actinide Billet Line, Plutonium Experimental 
Facility, and the old metallography lab glovebox. Building 235-F no 
longer has a DOE mission. It is currently operated in a surveillance 
and maintenance mode and is normally unoccupied.
    With the exception of residual contamination, Building 235-F has 
been de-inventoried of special nuclear material. The remaining residual 
contamination is the principal hazard posed by Building 235-F and 
includes a significant quantity of plutonium-238 (Pu-238). More than 95 
percent of the Pu-238 is located in the PuFF facility; approximately 82 
percent is concentrated in 2 of the 9 PuFF facility cells. It should be 
noted that the residual Pu-238 contamination is a fine ball-milled 
powder that is in a highly dispersible form, which increases the 
potential dose consequences associated with a radiological release.
    The responsible SRS contractor, Savannah River Nuclear Solutions 
(SRNS), has determined that the unmitigated consequences of a 
seismically-induced full-facility fire are greater than 10 rem offsite 
and 27,000 rem to the collocated worker at 100 meters. F-Area routinely 
has more than a thousand site workers who are normally in the 
facilities, construction sites, and trailers located adjacent to 
Building 235-F. Some of the trailers that house workers are located 
within the Building 235-F fence line.
    While DOE does not conduct any operations within Building 235-F, 
fires could start inside the building if energized electrical equipment 
or wiring failed or was damaged during a seismic or other natural 
hazard event. Electrical sparks or heat from electrical equipment could 
ignite adjacent combustible material. Two of the key preventive 
controls for fire scenarios are eliminating potential ignition sources 
and controlling the amount of combustibles. In September 2011, during a 
walkdown of Building 235-F, the Board's staff identified a significant 
quantity of transient and fixed combustibles and unnecessary electrical 
equipment that had not been air gapped. DOE has taken action to remove 
the transient combustible material and to limit access to Building 235-
F. However, no actions are currently planned to remove the fixed 
combustibles or unneeded electrical equipment.
    In the event of a fire, Building 235-F has several vulnerabilities. 
First, the Building 235-F fire detection system is not credited, does 
not provide complete coverage, nor is the building normally occupied; 
consequently, a fire could smolder and burn undetected. Second, 
Building 235-F does not have a fire suppression system to prevent an 
incipient stage fire from growing into a room fire. Third, Building 
235-F does not have fire barriers with a qualified fire rating to 
prevent the spread of a fire to adjacent rooms. The Building 235-F Fire 
Hazards Analysis notes that the subdividing walls and floors are in 
many places incomplete or penetrated and are not adequately sealed to 
achieve a qualified fire rating. In addition, some of the existing 
walls contain cellulose, which is combustible and could allow a room 
fire to spread to other portions of the building. Fourth, the absence 
of standpipes or hose connections inhibits the ability of the fire 
department to fight a fire inside Building 235-F. To combat a fire, 
firefighters would need to prop open the exterior doors to allow the 
passage of fire hoses; this would allow smoke and firewater, 
potentially

[[Page 29987]]

contaminated with radioactive material, into the environment.
    The July 2011 draft of the Basis for Interim Operations (BIO), 
prepared by SRNS notes that the Building 235-F structure can only 
provide limited confinement during or following a seismic event because 
seismically-induced building cracks may develop. Consequently, the 
building structure cannot be credited as a control to prevent a post-
seismic unfiltered release. In 2010, DOE took action to improve the 
safety posture of Building 235-F by reducing the height of the 
abandoned stack located adjacent to the building. The contractor's 
structural analysis indicated that the concrete stack, prior to the 
height reduction, could have collapsed onto Building 235-F during a 
seismic event causing significant structural damage.
    In addition to fires, loss of confinement accidents could also 
release radioactive material. For instance, a release could be caused 
by a breach of the confinement or the ventilation system during a 
seismic event. However, the Building 235-F confinement ventilation 
system cannot be relied upon to continue to perform its safety function 
during or following a seismic event. The draft BIO states that non-
load-bearing building elements may fail during a Performance Category-3 
seismic event, resulting in impact damage to safety-related structures, 
systems, and components such as ventilation ducts. The draft BIO states 
that the metal ventilation ducts may leak after an earthquake because 
they are not completely welded and that the concrete roof exhaust 
tunnel may develop cracks.
    Loss of confinement can be caused by degraded equipment. The 
deteriorated condition of the PuFF facility was noted in an October 
1991 report by DOE's Office of Nuclear Safety,\1\ which identified as 
an issue the integrity of elastomer seals that form part of the 
confinement boundaries inside Building 235-F. In addition to 
degradation with age, these elastomer seals also degrade with exposure 
to Pu-238. Although identified two decades ago, this issue remains. The 
cells have numerous penetrations (e.g., glove ports, viewing windows, 
ventilation supply and exhaust, utility services). In the draft BIO, 
SRNS stated that ``the [elastomer] seals around the cell and glovebox 
penetrations are expected to be in a degraded condition due to the 
years of operation in a radiation environment.'' The continued 
deterioration of the elastomer seals increases the potential for the 
spread of the contamination outside of the cells. Even under normal 
operations, a loss of confinement from these cells would greatly 
increase the complexity and hazard associated with decontamination and 
decommissioning of Building 235-F.
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    \1\ U.S. Department of Energy, 1991, Report of an Investigation 
into the Deterioration of the Plutonium Fuel Form Fabrication 
Facility (PuFF) at the DOE Savannah River Site, DOE/NS-0002P, http://www.osti.gov/bridge/servlets/purl/6246281-tBgi3H/6246281.pdf.
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    DOE conducted a small fire drill at Building 235-F in December 
2011, which simulated a minor radiological release. While DOE conducts 
periodic drills, DOE has not conducted a Building 235-F radiological 
drill involving the adjacent Mixed Oxide Fuel Fabrication Facility or 
Waste Solidification Building construction sites to examine how these 
facilities would respond to a significant radiological release from 
Building 235-F. In the event of a significant radiological release, the 
amount of mitigation provided by sheltering in place may not be 
sufficient to protect nearby workers. This is especially true for 
seismically-induced fires, since the same seismic event may also damage 
nearby trailers and administrative buildings.
    The Board has previously identified the need to address the 
residual contamination in Building 235-F. In a June 12, 2003, letter to 
the Secretary of Energy, the Board noted that the risk associated with 
several hazards in Building 235-F, including the Pu-238 residual 
contamination, had been accepted rather than eliminated. The report 
enclosed with the June letter further noted that DOE should consider 
decontaminating areas with residual contamination to reduce the risk 
associated with a potential release. Since that time, DOE has on a 
number of occasions evaluated options and developed plans to address 
the residual contamination. However, these efforts have not 
successfully transitioned from planning to execution, and the residual 
contamination and the hazard it poses still remain in Building 235-F.
Conclusion
    The Board believes that due to the potential dose consequences to 
collocated workers and the public, it is unacceptable for the residual 
contamination within Building 235-F to continue to remain unaddressed.
Recommendation
    Given the continuing hazard posed by Building 235-F as detailed 
above, the Board recommends that DOE:
    1. Take action to immobilize and/or remove the Pu-238 that remains 
as residual contamination within Building 235-F.
    2. Concurrent with sub-Recommendation 1, take near-term actions and 
implement compensatory measures to improve the safety posture of 
Building 235-F and reduce the potential for and severity of a 
radiological release, including but not limited to the following.
    a. To the extent feasible, remove from Building 235-F all transient 
and fixed combustibles that are not directly necessary for surveillance 
and maintenance activities and ensure that the transient combustible 
loading in the facility remains as low as reasonably achievable.
    b. Ensure that all electrical equipment not necessary to support 
facility safety systems, life safety, or surveillance and maintenance 
activities is de-energized and air gapped. Remove all electrical and 
support equipment remaining within former process areas that is not 
necessary for surveillance and maintenance.
    c. Evaluate the condition and operability of early detection and 
alarm systems in the PuFF facility, such as the heat and smoke 
detectors (with the exception of those located within the PuFF facility 
cells, if evaluating them would require intrusion into the cells). Take 
action, as necessary, to ensure that these systems are credited in the 
safety basis, are remotely monitored, provide reliable detection of 
hazards, and are maintained in accordance with National Fire Protection 
Association 72, National Fire Protection Alarm and Signaling Code.
    3. Concurrent with sub-Recommendation 1, take action to ensure that 
the SRS emergency response to a radiological release from Building 235-
F is adequate and effective, including but not limited to the 
following.
    a. Ensure that an integrated emergency response plan is in place 
that considers the collocated workers in facilities, construction 
sites, and trailers located adjacent to Building 235-F. Development of 
this plan should include an evaluation of the specific locations where 
collocated workers are directed to shelter in place to ensure their 
adequate protection during and following a potential radiological 
release from Building 235-F.
    b. Ensure that periodic coordinated drills in response to a 
simulated event at Building 235-F are conducted. Such drills should 
include appropriate response actions by personnel in the adjacent 
facilities and construction sites, such as sheltering in place or 
evacuating depending on proximity to

[[Page 29988]]

the simulated plume of radioactive material.
    The Board urges the Secretary to avail himself of the authority 
under the Atomic Energy Act (42 U.S.C. 2286d(e)) to ``implement any 
such recommendation (or part of any such recommendation) before, on, or 
after the date on which the Secretary transmits the implementation plan 
to the Board under this subsection.''

Peter S. Winokur, Ph.D.,
Chairman.
[FR Doc. 2012-12179 Filed 5-18-12; 8:45 am]
BILLING CODE 3670-01-P
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