On November 11, 1995, engineers at Hanford reviewed the authorization basis for the 222-S Analytical Laboratory and determined it was inadequate because it did not control the allowable quantity of strontium-90 and cesium-137 isotopes. Consequences of release of these isotopes are included in the extrinsic accident analysis for the Laboratory. The review was prompted by questions from the Hanford DOE staff. This lack of control is significant because an excess quantity of these isotopes could have placed the Laboratory in a condition outside the accident analysis. (ORPS Report RL--WHC-ANALLAB-1995-0037)

The authorization basis provided an analysis of the consequences of isotope release to the environment during the design basis extrinsic accident with maximum quantities of 10 curies for plutonium-239, 298 curies for strontium-90, and 47 curies for cesium-137. This analysis limits the allowable dose to the whole body at the site boundary during the design basis accident and depends on maximum allowable quantities of these three isotopes. However, the analysis does not require the quantity of strontium and cesium to be tracked creating the possibility that these isotopes could exceed the allowable maximum. As a result of these findings, the Laboratory manager restricted the receipt of additional quantities of these isotopes which could affect inventory until the issue is resolved.

Laboratory engineers conducted an inventory of isotopes and determined that the quantities are below the allowable maximum. Also, they reviewed the unapproved Laboratory interim safety basis and found that it adequately controls isotope quantities because it mandates a radionuclide inventory control program. In August 1995, the Westinghouse Hanford Company approved the interim safety basis as a replacement design basis document, but DOE has not yet approved it. On November 13, Westinghouse Hanford Company engineers submitted a justification for continued operation to the DOE that allows the interim safety basis to control the isotope inventory only. Other activities are controlled by the authorization basis until DOE approves the interim basis. On November 15, the DOE approved the justification for continued operation.

The Defense Nuclear Facilities Safety Board has been concerned about safety management. On October 11, 1995, the Board submitted Recommendation Letter 95-2 to the Secretary of Energy. In the letter the Board recommends, "Institutionalize the process of incorporating into the planning and execution of every major defense nuclear activity involving hazardous material those controls necessary to ensure that environment, safety and health concerns are achieved."

DOE 5480.22, Technical Safety Requirements, provides requirements for the preparing technical safety requirements, formerly called operational safety requirements for non-reactor nuclear facilities. Paragraph 9.b states in part: "Technical Safety Requirements shall define the operating limits and surveillance requirements, the basis thereof, safety boundaries, and management or administrative controls necessary to protect the health and safety of the public and to minimize the potential risk to workers from the uncontrolled release of radioactive or other hazardous materials and from radiation exposure due to inadvertent criticality." Managers at DOE facilities should review their programs for establishing and maintaining authorization basis documents to ensure their compliance with the Order.