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Nuclear Weapons: Design Reviews of DOE's Tritium Extraction Facility (Letter Report, 03/31/98, GAO/RCED-98-75).

Pursuant to a congressional request, GAO reviewed the Department of
Energy's (DOE) plans to build a Tritium Extraction Facility at its
Savannah River Site in South Carolina and the reports of three different
teams responsible for reviewing the project's conceptual design and
related products, focusing on: (1) the major comments raised by the
three reviews; and (2) the process used by DOE to respond to those
comments.

GAO noted that: (1) two of the teams that reviewed the Tritium
Extraction Facility's conceptual design found the project's scope, cost,
and schedule to be appropriate and found no issues that would
necessitate reevaluating the project; (2) the third team made no overall
comments on the project; (3) the three teams also had nearly 800
specific comments; (4) comments that the review teams considered to be
significant related to: (a) the design of the remote handling and
tritium extraction processes; (b) the need for the project's schedule to
allow for contingencies that could occur in the process and equipment
development; and (c) the adequacy of the level of detail in the
conceptual design report; (5) DOE handled each review team's specific
comments differently; (6) for one team, the Savannah River Project
Office prepared a response to each comment, and DOE headquarters had
three members of the original review team comment on the adequacy of the
responses; (7) for comments made by the second team, the Project Office
responded to all comments, but did not seek the team's review of the
responses; (8) for the third review team's comments, DOE responded to
each comment, but the design team has not yet reviewed the responses;
(9) overall, DOE made many changes to the conceptual design because of
the review teams' comments and appears to have been generally responsive
to the comments; (10) however, some comments--such as the one related to
a need to include contingencies in the projects' schedule--have not been
resolved to the satisfaction of the review teams; and (11) nonetheless,
DOE approved the conceptual design report and the project entered the
preliminary design phase in October 1997.

--------------------------- Indexing Terms -----------------------------

 REPORTNUM:  RCED-98-75
     TITLE:  Nuclear Weapons: Design Reviews of DOE's Tritium Extraction 
             Facility
      DATE:  03/31/98
   SUBJECT:  Nuclear weapons plants
             Atomic energy defense activities
             Facility construction
             Nuclear fuel reprocessing
             Projections
IDENTIFIER:  DOE Savannah River Tritium Extraction Facility
             
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Cover
================================================================ COVER


Report to the Committee on Armed Services, U.S.  Senate

March 1998

NUCLEAR WEAPONS - DESIGN REVIEWS
OF DOE'S TRITIUM EXTRACTION
FACILITY

GAO/RCED-98-75

Design of DOE's Tritium Extraction Facility

(141125)


Abbreviations
=============================================================== ABBREV

  DOE - Department of Energy
  GAO - General Accounting Office

Letter
=============================================================== LETTER


B-279101

March 31, 1998

The Honorable Strom Thurmond
Chairman
The Honorable Carl Levin
Ranking Minority Member
Committee on Armed Services
United States Senate

The Department of Energy (DOE) is responsible for managing the
nation's nuclear weapons stockpile, including providing tritium, a
gas used to enhance the explosive power of all nuclear weapons
currently in the nation's stockpile.  Because tritium decays, it has
to be periodically replaced in weapons, but DOE has not produced
tritium since 1988 and currently has no production capability.  The
Department is currently using tritium removed from dismantled weapons
to replace decayed tritium in active weapons.  However, that supply
is limited and new tritium production capacity will be needed in
2005. 

As part of its plans to provide tritium, DOE will build a Tritium
Extraction Facility at its Savannah River Site in South Carolina. 
The $383.4 million project, managed by the Commercial Light Water
Reactor Project Office at the Savannah River Site, is scheduled for
completion in 2005.  During 1997, DOE completed the project's
conceptual design, issued a conceptual design report, and began the
preliminary design for the project.  Three different teams reviewed
the conceptual design and related documents.  At your request, we
obtained information on (1) the major comments raised by the three
reviews and (2) the process used by DOE to respond to those comments. 


   RESULTS IN BRIEF
------------------------------------------------------------ Letter :1

Two of the teams that reviewed the Tritium Extraction Facility's
conceptual design found the project's scope, cost, and schedule to be
appropriate and found no issues that would necessitate reevaluating
the project.  The third team made no overall comments on the project. 
The three teams also had nearly 800 specific comments.  Comments that
the review teams considered to be significant related to (1) the
design of the remote handling and tritium extraction processes (the
processes considered to have the highest risk in the project); (2)
the need for the project's schedule to allow for contingencies that
could occur in process and equipment development; and (3) the
adequacy of the level of detail in the conceptual design report. 

DOE handled each review team's specific comments differently.  For
one team, the Savannah River Project Office prepared a response to
each comment, and DOE headquarters had three members of the original
review team comment on the adequacy of the responses.  For comments
made by the second team, the Project Office responded to all comments
but did not seek the team's review of the responses.  For the third
review team's comments, DOE responded to each comment, but the design
team has not yet reviewed the responses.  Overall, DOE made many
changes to the conceptual design because of the review teams'
comments and appears to have been generally responsive to the
comments.  However, some comments--such as the one related to a need
to include contingencies in the project's schedule--have not been
resolved to the satisfaction of the review teams.  Nevertheless, DOE
approved the conceptual design report and the project entered the
preliminary design phase in October 1997. 


   BACKGROUND
------------------------------------------------------------ Letter :2

Tritium, which makes possible smaller, more powerful nuclear weapons,
decays at a rate of 5.5 percent per year.  Therefore, for nuclear
weapons to be capable of operating as designed, the tritium in the
weapons must be periodically replaced.  DOE used to produce new
tritium in its reactors at the Savannah River Site, but the last of
these reactors was shut down in 1988 because of safety and
operational problems.  DOE currently has no tritium production
capability, although the Department has been able to meet its
requirements for tritium by reusing material recovered from
dismantled weapons. 

In order to meet currently planned requirements for tritium, a new
production capability must be available in 2005.  To accomplish this,
DOE is pursuing a dual-track program to select the primary production
source.  The first track is based on using a commercial light water
reactor to produce tritium.  Target rods containing lithium would be
placed in the reactor, and during the reactor's normal operations,
some of the lithium would be turned into tritium.  Once removed from
the reactor, the target rods would be transported to the Tritium
Extraction Facility, where the tritium would be removed. 

The second track involves building an accelerator as the primary
producer of tritium.  This device accelerates protons (particles
within an atom that have a positive electrical charge) to nearly the
speed of light.  The protons are crashed into tungsten, releasing
neutrons (particles within an atom that have no electrical charge),
which can be used to change helium into tritium.  As currently
envisioned, this process would not involve the Tritium Extraction
Facility. 

DOE's current plan is to choose one of the two tracks in late 1998. 
If the commercial-light-water-reactor track is chosen, the
accelerator will be pursued to the point of establishing an
engineering design for it, but it will not be built.  If the
accelerator track is chosen, the accelerator will be built and
operated and, as a backup, all aspects of the commercial light water
reactor option will be completed--with the exception of the actual
production of tritium.  The target rods will be produced, agreements
with utilities for the use of their reactors will be signed, and the
Tritium Extraction Facility will be built. 

Thus, under both tracks, DOE intends to build the Tritium Extraction
Facility.  Construction of the facility--to be managed by the
Commercial Light Water Reactor Project Office at the Savannah River
Site--is currently estimated to cost $383.4 million and is scheduled
for completion in 2005.\1 The Tritium Extraction Facility project
completed the conceptual design phase in October 1997.  The
preliminary design, currently being developed, is scheduled to be
completed in June 1998. 

The conceptual design for the Tritium Extraction Facility was
reviewed by three teams--the "Red Team," the "Independent Review
Team," and the "Formal Design Review Team." Although there is no
requirement for such reviews, they were requested by DOE
headquarters' Office of Commercial Light Water Reactor Production and
the Project Office at Savannah River to increase their confidence in
the conceptual design of the facility before proceeding to the
preliminary design phase.  All teams reviewed drafts of the
conceptual design and/or the conceptual design report.  Table 1 shows
how many and what type of participants each team had, what the team
was chartered to do, and when the review was performed. 



                                         Table 1
                         
                           Characteristics of the Review Teams

                                                                       Time frame of
Review team         Members             Charter                        review
------------------  ------------------  -----------------------------  ------------------
Red Team            10 members (9 from  Review the conceptual design,  February through
                    private firms and   concentrating on its scope     July 1997 (Report
                    universities and 1  and breadth                    issued in July
                    from DOE)                                          1997)
                                        Determine the conceptual
                                        design's appropriateness

                                        Recommend ways to reduce
                                        costs, risks, and workers'
                                        exposure to radiation and to
                                        increase efficiency,
                                        workability, and safety

Independent Review  4 members (DOE      Provide suggestions to         Early June 1997
Team                employees not       improve the conceptual design  (Report issued on
                    directly            report                         June 12, 1997)
                    associated with
                    the project)

Formal Design       19 members          Evaluate the project's         December 1996 and
Review Team         (Westinghouse and   baseline performance and       January 1997
                    laboratory          operational requirements       (Report issued on
                    personnel)                                         Jan. 30, 1997)
                                        Evaluate the scope of work
                                        for the conceptual design in
                                        comparison with the baseline
                                        requirements

                                        Evaluate the technical
                                        adequacy of plans to mitigate
                                        risks associated with the
                                        higher-risk strategies
-----------------------------------------------------------------------------------------

--------------------
\1 To finish purifying the tritium gas (after extraction and
processing in the Tritium Extraction Facility), an existing facility
at Savannah River, the Tritium Recycle Facility (Building 233-H),
will have to be modified.  The modifications will cost an estimated
$36.46 million in addition to the $383.4 million estimate for the
Tritium Extraction Facility.  These modifications are scheduled for
completion in the third quarter of fiscal year 2004. 


   REVIEW TEAMS' COMMENTS
------------------------------------------------------------ Letter :3

Two of the three teams that reviewed DOE's conceptual design for the
Tritium Extraction Facility made overall comments in their final
reports.  The Red Team and the Formal Design Review Team expressed a
favorable opinion overall of the facility's design and the related
documentation.  According to the Red Team, the conceptual design's
scope, cost, and schedule are appropriate; the technical concept and
approach are sound; all major risks have been identified; and the
building is constructible and, in general, appears to comply with
DOE's current requirements.  The Formal Design Review Team reported
that it did not identify any significant items that could not be
corrected with three documents due to be completed after the team's
review--the Facility Design Description, the System Design
Description, and the Conceptual Design Statement of Work.  The
Independent Review Team did not make any overall comments on the
conceptual design. 

In addition to the overall comments made by two of the review teams,
all three teams made a number of specific comments.  The Red Team had
34 comments (see app.  I for a listing of the Red Team's major
comments), and the Independent Review Team had 60 comments (see app. 
II for a listing of the Independent Review Team's major comments). 
The Formal Design Review Team made 691 specific documentary and
technical comments on the conceptual design and related
documents--none of which it considered to be major impediments to the
design and construction of the Tritium Extraction Facility.  The
specific comments made by all three review teams covered a wide range
of topics, including the design of specific systems, the design and
construction schedule, life-cycle costs, the method of contracting
for the design and construction, and the level of detail in the
supporting documentation and in the conceptual design report. 

Comments that the review teams considered to be significant and that
we believe cover issues that could affect the success of the project
related to

  -- the design of the remote handling and tritium extraction
     processes,

  -- the need to include contingencies in the schedule, and

  -- the level of detail in the conceptual design report. 


      REMOTE HANDLING AND TRITIUM
      EXTRACTION PROCESSES
---------------------------------------------------------- Letter :3.1

The remote handling system for the Tritium Extraction Facility, the
means by which nearly all facility processes and maintenance,
including moving tritium target rods and opening them, will be
controlled from a separate (remote) room.  The extraction process
involves heating the target rods in a furnace and removing the
tritium and other gases from them.  Project officials do not consider
design and construction of these systems to be high-risk, but they do
believe that they are the highest-risk tasks involved in the project. 

The Red Team reported that the remote handling and tritium extraction
processes include risks that need to be addressed in the near term. 
The team found that a plan to mitigate the risks was not evident and
that the subsystems to manipulate and open the target rods had not
been demonstrated.  The team believed that the time and cost to
engineer and develop the processes would be greater than the
estimates in the conceptual design report.  Similarly, in a comment
it deemed "significant," the Independent Review Team stated that the
target rod handling process was overly complex.  The team proposed an
alternative method and suggested that it be discussed in the
conceptual design report. 

The Red Team and the Independent Review Team consider DOE's actions
and responses to the comments on the remote handling and tritium
extraction processes to be generally adequate.\2 According to Red
Team members and the chairman of the Independent Review Team, much
has changed since their reviews were conducted.  Design alternatives
have been developed and changes have been made in the conceptual
design report that have satisfied the intent of the comments. 


--------------------
\2 Although DOE did not provide the Independent Review Team an
opportunity to review the Project Office's responses to the team's
comments, we provided a copy of the responses to the chairman of the
team and obtained his views on their adequacy. 


      SCHEDULE
---------------------------------------------------------- Letter :3.2

The Independent Review Team indicated a need to consider
contingencies, to provide allowances for unforeseen delays, in the
schedule--just as they are addressed in cost estimates.  The chairman
of the team told us that it was specifically concerned with the plans
for a mock-up of the remote handling process and a prototype of the
tritium extraction furnace--believing that any problems with them
could delay the project overall because the tasks run concurrently
with the development of the detailed design.  The chairman explained
that although the conceptual design report now contains more detail
on the project's schedule, it still does not include contingencies. 
Because he believes this feature to be very important, he considers
DOE's response to this comment to be inadequate. 

DOE officials informed us that they believe there is no need for the
schedule to include contingencies.  The Tritium Extraction Facility's
schedule is based on a 5 day per week, 8 hour per day work schedule. 
The option of working multiple shifts and/or weekends, as necessary,
offers adequate flexibility to respond to schedule issues. 


      LEVEL OF DETAIL IN THE
      CONCEPTUAL DESIGN REPORT
---------------------------------------------------------- Letter :3.3

All three review teams made numerous comments suggesting adding
additional information and detail to the conceptual design report and
related documents.  The suggestions concerned requirements, design
detail, equipment, analyses, schedules, risks, and planned
operations.  The Red Team concluded that the conceptual design
package was insufficient to permit an architect engineering firm to
independently proceed with the preliminary design. 

Since the three teams reviewed the draft conceptual design, the
Project Office has provided considerable additional information in
the issued conceptual design report.  Furthermore, according to
program officials, DOE never intended for an architect engineering
firm to develop the preliminary design independently, but rather for
the firm to work with the Project Office to develop the design. 
After reviewing the final conceptual design report, the Red Team and
the chairman of the Independent Review Team consider their comments
about the level of detail to be resolved.  The Formal Design Review
Team has yet to review DOE's actions subsequent to its review. 


   DOE'S PROCESS FOR HANDLING
   REVIEW TEAMS' COMMENTS
------------------------------------------------------------ Letter :4

Although one of the review teams was chartered by DOE headquarters
and two were chartered by the Savannah River Project Office, the
purpose of obtaining the independent reviews of the conceptual design
was similar in all three cases--to provide confidence in the adequacy
of the Tritium Extraction Facility's conceptual design. 
Nevertheless, there were no uniform guidelines established for these
reviews, and the comments made by each of the review teams were
handled differently.  In addition, DOE and the Project Office did not
reach closure with any of the review teams prior to initiating the
preliminary design phase. 

Neither DOE nor the Project Office at the Savannah River Site
initially responded to all of the Red Team's comments.  In April
1997, on the basis of a briefing provided by the Red Team, DOE
headquarters selected 10 items that it believed to be most important
and that required action before the beginning of the preliminary
design phase.  On October 31, 1997, the Project Office sent a letter
to DOE headquarters describing the actions taken in response to the
comments selected by headquarters and one other item added by DOE
officials at Savannah River.  For 8 of the 11 comments, the Project
Office analyzed the comments and formally documented its responses. 
The Project Office took no action on two of the comments, deferring
action until later in the project.  The Project Office disagreed with
one comment.\3

On December 2 and 3, 1997 (after DOE's October 31, 1997, approval to
proceed to the preliminary design phase), DOE headquarters officials
took a team composed of three former Red Team members to the Savannah
River Site to determine what had been done in response to all 34
comments contained in the team's report.  The Project Office prepared
a list of the actions taken, and the three members of the Red Team
concluded that, overall, the Project Office had been responsive to
the comments.  They concluded that the conceptual design had been
completed with the level of detail required by DOE orders and
concurred with the decision to proceed with the preliminary design. 
DOE project officials informed us that they intend to also have a
panel similar to the Red Team review the project's design at the
conclusion of the preliminary design phase. 

The Project Office handled the Independent Review Team's comments
differently.  On July 31, 1997, prior to the initiation of the
preliminary design phase, the Project Office formally responded to
all 60 of the team's comments.  Neither DOE nor the Project Office
transmitted the responses to members of the Independent Review Team,
and their review of the responses was not solicited.  However, we
asked the chairman of the Independent Review Team to review the
Project Office's responses.  The chairman considers the responses to
55 of the comments to be adequate and to 5, inadequate.  One of these
five comments involves the project's schedule, as discussed earlier. 
The chairman does not consider the other four to be significant. 

The Project Office handled the Formal Design Review Team's comments
in a different manner still.  By October 31, 1997, the Project Office
had reviewed each of the Formal Design Review Team's 691 comments and
recommended 454 for closure--that is, that the Project Office's
actions satisfied the comments.  A number of the comments recommended
for closure (about 12 percent) pertained to work at Building 233-H
that will be conducted as part of another project.  These comments
will be forwarded to the office managing that project for
consideration and disposition.  According to the Project Office, the
237 outstanding comments will be dealt with during the preliminary
design phase of the project. 

The original intention was for the Formal Design Review Team to
review the Project Office's responses and for the chairman of the
team to issue a "closure" memo (1) stating that the team had reviewed
and agreed with the Project Office's responses to its comments and
(2) endorsing the conceptual design.  As of January 1998, the Formal
Design Review Team had not reviewed the Project Office's responses
and the chairman had not issued such a memo.  Project Office
officials informed us that relevant action plans will be completed by
the spring of 1998, at which time the chairman could issue the memo. 


--------------------
\3 This comment was the one asserting that there was insufficient
information in the conceptual design report to allow an architect
engineering firm to do the preliminary design. 


   CONCLUSIONS
------------------------------------------------------------ Letter :5

Given the overall favorable responses to the Tritium Extraction
Facility's conceptual design, it may have been prudent to proceed
with the preliminary design phase in October 1997.  However, the
intent of having independent reviews was to enhance confidence in the
conceptual design, and numerous concerns were identified, some of
which the review teams considered to be important.  None of the
various approaches for handling the review teams' comments resulted
in reaching closure with the teams before the start of the
preliminary design phase.  A structured, consistent approach to
resolving comments and obtaining concurrence would have helped ensure
that the project received the maximum benefit from the reviews.  Such
a structured approach could apply in the future, as DOE intends to
have an independent team review the Tritium Extraction Facility's
design after the preliminary design work is completed. 


   RECOMMENDATION
------------------------------------------------------------ Letter :6

We recommend that the Secretary of Energy establish guidelines for
formally responding to and reaching closure within a reasonable time
frame on comments made during future independent design reviews of
the Tritium Extraction Facility project. 


   AGENCY COMMENTS AND OUR
   EVALUATION
------------------------------------------------------------ Letter :7

We provided a draft of this report to DOE for its review and comment. 
Overall, DOE agreed with the facts contained in the report and
concurred with the recommendation.  DOE stated that it is instituting
a tracking system in which all action items will be included with due
dates and responsibility assignments for tracking and disposition. 

DOE had two specific comments.  First, DOE stated that our report
inferred that the Department began the preliminary design prematurely
because not all of the review teams' comments were resolved.  As
stated in our draft report, given the overall favorable responses to
the conceptual design, we believe it may have been prudent to proceed
with the preliminary design phase.  However, as a general practice,
we believe that to maximize the usefulness of a design review team's
comments, DOE should present the team with responses to each comment
and reach closure with the team on how and when the comment will be
resolved.  By responding to the design review team's comments in this
manner, DOE would ensure agreement by all parties on the appropriate
timing and proper course of action required to resolve the problems
noted.  In cases in which DOE disagrees with the comment, this type
of formal response process could open a dialogue that could convince
the design review team that no action is required or would at least
provide a record of the reasons why DOE and the design review team
chose to disagree. 

Second, DOE expressed the opinion that addressing contingencies in
the schedule, as advocated by the Independent Review Team, is not a
major concern.  However, the chairman of the Independent Review Team
still believes that the lack of this feature is significant.  Both
DOE and the Independent Review Team's perspectives are presented in
our report.  We believe that this disagreement demonstrates why DOE
needs a formal procedure for dealing with design review teams'
comments.  In this case, DOE did not provide the Independent Review
Team with responses to its comments, and there was no effort made to
discuss and document areas of disagreement.  As a result, the comment
has not been resolved.  The full text of DOE's comments is included
as appendix III. 


   SCOPE AND METHODOLOGY
------------------------------------------------------------ Letter :8

To obtain information on the major comments made by the review teams,
we obtained and reviewed the teams' reports.  For the Independent
Review Team, we also obtained the Project Office's formal responses
to the comments contained in the report.  In its report, the Red Team
formally listed its comments, and DOE had not initially formally
responded to them.  As a result, we analyzed the Red Team's report to
create a list of major comments, which we presented to DOE.  DOE and
members of the Red Team reviewed that list and agreed that it
comprised the major comments of the report.  DOE and the Red Team
members then used our list during their December 1997 review of the
Project Office's responses to the Red Team's report.  We obtained the
results of that review.  At the time of our review, the Project
Office had not formally responded to the Formal Design Review Team's
comments. 

To obtain information on the process DOE used to respond to the
comments raised by the review teams, we reviewed the review teams'
charters; correspondence between the review teams, the Project
Office, and DOE; and the teams' reports and related documents.  We
also discussed the processes with DOE and Project Office officials
and representatives from the review teams.  We conducted our review
from October 1997 through February 1998 in accordance with generally
accepted government auditing standards. 


---------------------------------------------------------- Letter :8.1

As arranged with your offices, unless you publicly announce its
contents earlier, we plan no further distribution of this report
until 30 days after the date of this letter.  At that time, we will
send copies of the report to the Secretary of Energy; the Secretary
of Defense; and the Director, Office of Management and Budget.  We
will also make copies available to others on request. 

If you or your staff have any questions about this report, please
call me at (202) 512-8021.  Major contributors to this report include
William F.  Fenzel, Assistant Director, and Kenneth E.  Lightner Jr.,
Senior Evaluator. 

Gary L.  Jones
Associate Director, Energy,
 Resources, and Science Issues


STATUS OF MAJOR COMMENTS BY THE
RED TEAM
=========================================================== Appendix I

Major comments                                     Status
-------------------------------------------------  --------------------------------------
Implementation of the integrated technical and     Partially closed. Essential processes
management approach for the design, construction,  are in place; additional analysis has
and start-up of the Tritium Extraction Facility    been either documented or is in
as described in the Systems Engineering            process.
Management Plan is poor and inconsistent.
Critical decisions appear to have been made
without the benefit of sufficient analysis of the
alternatives.

Two recognized risks, the tritium extraction and   Partially closed. An action plan for
remote handling processes, represent major         the tritium extraction and remote
vulnerabilities that need to be mitigated in the   handling processes has been prepared.
near term. A plan to develop the tritium           A proven mechanical system for tritium
extraction process and to mitigate risks is not    extraction has been incorporated into
evident. The subsystems for handling and opening   the conceptual design. Corrective
the target rods are not proven applications of     action plans for the subsystems are
existing technology. Much of the remote handling   being implemented. The cost to develop
will be first-of-a-kind applications. Each         remote handling operations could still
represents significant uncertainties, in terms of  be significant.
scope, cost, and schedule. The time and cost to
engineer/develop the applications will be greater
than the current plan estimates.

There are no clear limits for releases of          Partially closed. A report defining
radioactivity, requirements for confinement        requirements has been issued.
systems, or goals for minimizing workers'          Guidelines for minimizing workers'
exposure.                                          exposure are being established.

The conceptual design package is not an adequate   Closed. DOE completed an assessment of
basis to start preliminary design. It is           its readiness to proceed to the
insufficient to permit an architect engineering    preliminary design. The team agreed
firm to independently proceed with the             with DOE's decision to proceed.
preliminary design.

It is not evident that DOE has reviewed the        Partially closed. The lessons learned
lessons learned from other projects and applied    from other projects have been
them to the Tritium Extraction Facility project's  identified and evaluated and are being
conceptual design and plan.                        incorporated into the project design
                                                   and project implementation processes.
-----------------------------------------------------------------------------------------
Note:  From reviewing the Red Team's report, we compiled a list of
the team's major comments, with which DOE and members of the team
concurred.  The status of these comments is as described by the three
team members that met on December 2 and 3, 1997, to review DOE's
responses to the comments.  The status summaries (closed or partially
closed) are the result of our analysis of the team members'
description of each comment's status.  The three team members
concluded that, overall, the Project Office had been responsive to
the comments. 


STATUS OF MAJOR COMMENTS BY THE
INDEPENDENT REVIEW TEAM
========================================================== Appendix II

Major comment                           Status
--------------------------------------  -------------------------------------------------
The conceptual design report should be  Closed. Additional information has been added to
a more stand-alone document.            the conceptual design report.

The remote handling process is overly   Closed. Improvements have been made to the design
complex.                                for the remote handling process.

A section devoted to the project's      Open. Additional information on the schedule was
schedule should be added to the         added to the conceptual design report; however,
conceptual design report.               the schedule does not include contingencies,
                                        which represents a high risk.

There should be a section in the        Closed. References to applicable design and
conceptual design report that           construction codes and standards have been added
discusses applicable design and         to the conceptual design report.
construction codes and standards.

Any segment of the facility should be   Closed. DOE plans a joint effort by the Project
designed totally in-house or totally    Office and an architect engineering firm. The
subcontracted.                          Independent Review Team's chairman now agrees
                                        with this approach.

The life-cycle cost analysis should     Open. The life-cycle cost analysis does not yet
include the number of target rods that  include the number of extractions required to
must be processed to meet the           meet the production requirements. The staffing
facility's production requirements.     levels proposed are excessive. The team's
                                        chairman no longer considers this a major
                                        comment.

The Process Development Program (a      Closed. While the program has not been
program to develop facility processes   accelerated, DOE has recognized the risk to the
by using prototypes and mock-ups)       project's cost and schedule and will attempt to
should be accelerated.                  mitigate the risk.
-----------------------------------------------------------------------------------------
Note:  The Independent Review Team's major comments appeared in its
final report.  The status of the comments is as described to us by
the team's chairman. 




(See figure in printed edition.)Appendix III
COMMENTS FROM THE DEPARTMENT OF
ENERGY
========================================================== Appendix II



(See figure in printed edition.)


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