[SOE LETTERHEAD]
March 18, 2005
The Honorable John T. Conway
Chairman
Defense Nuclear Facilities
Safety Board
625 Indiana Avenue, NW, Suite
700
Washington, D.C. 20004
Dear Mr. Chairman:
The Department of Energy
(Department or DOE) acknowledges receipt of the Defense Nuclear Facilities
Safety Board’s Recommendation 2004-2, Active Confinement Systems, issued on December 7, 2004. We appreciate the Board’s background material
contained in the enclosed technical report, DNFSB/TECH-34, Confinement of Radioactive Materials at Defense
Nuclear Facilities, and
the opportunity to discuss the confinement issues and the technical
underpinnings of the recommendation and TECH-34 with your staff on several occasions.
The Department has completed its
assessment of the Board’s recommendation and plans to implement it as described
below.
The Department agrees with the
Board that DOE cannot rely solely on passive building confinement when such
reliance cannot be justified. The
Department agrees that active building ventilation confinement systems can
provide added safety benefit and are normally the preferred alternative when a
building confinement safety function is needed to provide adequate protection
to the public or collocated workers. We
also recognize the limitations of computational models and assumptions used for
determining leak path factors when evaluating the building confinement
performance. We concur with the Board’s
observation that “certain Hazard Category 2 and 3 defense nuclear facilities
may not benefit significantly from an active confinement ventilation system”
due to such factors as intrinsically safe form or containerization of the
nuclear hazards, declining nuclear material inventories, and planned decommissioning
in the near future.
We accept the recommendation
based on the understanding that it can be implemented as follows: DOE will proceed to review all Hazard Category
2 and 3 defense nuclear facilities. The
review criteria will be based in large part on the Department’s existing
regulatory infrastructure, requirements and methodologies established in 10 CFR
Part 830, DOE Order 420.1A, DOE-STD-3009, and related guidance documents. First, we will establish criteria to exclude
certain facilities and operations from further review based on sound safety considerations.
Facilities not excluded by these
criteria will then be reviewed to ensure that the selected confinement strategy
is properly justified and documented. Priority would be given to design and
construction projects, including ongoing major modifications of existing facilities.
We understand the recommendation
is based on a fundamental premise that a more prescriptive safety requirement
is likely needed to institutionalize the application of these principles at
defense nuclear facilities. Accordingly,
after all facility-specific reviews have been concluded and changes to the
safety approach have been made where necessary, the need for changes in DOE’s
directives and guidance will be assessed.
I have asked Richard Black,
Director, Office of Nuclear and Facility Safety Policy, to lead the response
team that will develop the Department’s 2004-2 Implementation Plan. He can be contacted
at 301-903-0104.
Sincerely,
Samuel W. Bodman