ENFORCEMENT LETTER FOR HANFORD TANK FARMS CONTRACTOR

Washington River Protection Solutions has received a letter of enforcement following an evaluation for unreviewed safety questions it identified, including one involving a discrepancy in the tank farm waste transfer system design temperature. The unreviewed safety questions also included unanalyzed freezing during active waste transfer and unanalyzed potential failure of relief valves due to solids precipitation. However, the Department of Energy Office of Enforcement and Oversight, which released the letter Tuesday, did not issue a notice of violation or take enforcement action. WRPS discovered the issue in late summer, finding that an analysis of the waste transfer piping assumed a minimum design temperature of 32 degrees but the analysis should have been done for temperatures as low as minus 25 degrees. Waste has been transferred through the above-ground lines for more than a decade without an apparent documented problem. “But it’s a potential accident scenario and that’s not acceptable in a nuclear environment,” said John Britton, a WRPS spokesman.

Circumstances that led to the inadequacies in the tank farm Documented Safety Analysis included procedures developed in September 2009 that did not define sufficiently the organizational roles and responsibilities to ensure that developed Functions and Requirement Evaluation Documents (FREDs) were technically accurate and complete, according to the enforcement letter. Training was not formally developed and conducted until November 2010, when all but one FRED had been issued. WRPS also determined that its nuclear safety engineers lacked sufficient understanding of what constitutes a support system that is credited in preventing failure of an intended safety function for another safety-significant system, structure or component. WRPS also did not realize that non-safety significant heat sources were credited to protect safety significant waste transfer piping.

The Office of Enforcement said WRPS identified the issue and is using extensive interim administrative controls to continue waste transfers. However, it is concerned about the processes used to ensure waste transfer hazards and potential accidents are fully analyzed and controlled, the letter said. “It is the responsibility of WRPS to ensure that personnel involved in these processes are fully trained and qualified on all technical aspects associated with safety basis development and maintenance and on the WRPS-specific implementing procedures,” the letter said. The Office of Enforcement will continue to monitor WRPS nuclear safety performance with the DOE Office of River Protection and the Office of Environmental Management.