[DNFSB
LETTERHEAD]
September 19, 2005
The Honorable Samuel W. Bodman
Secretary of Energy
1000 Independence Avenue, SW
Washington, DC 20585-1000
Dear Secretary Bodman:
The Defense Nuclear Facilities
Safety Board (Board) has received your letter dated August 22, 2005, enclosing
the Department of Energy’s Implementation Plan for the Board’s Recommendation
2004-2, Active
Confinement Systems. The Board has reviewed the Implementation
Plan and finds that it satisfies the Board’s Policy Statement 1 and is responsive
to the issues documented in the Recommendation.
The Implementation Plan,
however, indicates that existing facilities with once-through process
ventilation systems, such as many aspects of the Tank Farm facilities at
Hanford and Savannah River sites, would be considered for categorical exclusion
under the Non-Beneficial criteria. These
facilities encompass a variety of activities and operations, including waste processing,
that should not be categorically excluded from implementation of this Recommendation.
The Board believes that the process
described in Sections 7.6 and 7.7 of the Implementation Plan should be applied
to these facilities as well, to ensure a systematic and deliberate
implementation of the Recommendation. For this reason, the Board counsels against granting
a categorical exclusion to these facilities.
The Board looks forward to
working with you as the Implementation Plan with the above noted modification
is executed.
Sincerely,
A.
J. Eggenberger
Chairman
c: Mr. Mark B. Whitaker, Jr.