[DOE LETTERHEAD]
NATIONAL NUCLEAR
SECURITY ADMINISTRATION
January 15, 2003
The Honorable John T. Conway
Chairman
Defense Nuclear Facilities Safety Board
625 Indiana Avenue, NW.
Suite 700
Washington, D.C. 20004-2901
Dear Mr. Chairman:
The National Nuclear Security Administration
(NNSA)
has received your letter of
November 13, 2002, regarding Pantex’s interpretation of DOE STD-3009-94. Your letter took issue with how the
Continuous Air Monitor and Radiation Alarm Monitor (CAM/RAM) systems are credited
in-site authorization basis documents.
The NNSA agrees with the Defense Nuclear Facilities Safety Board (DNFSB)
that the hazardous scenarios in question warrant Technical Safety Requirement
(TSR) level control. NNSA’s Pantex Site Office (PXSO) approved authorization
basis documents that credit the CAM/RAM systems as a TSR-level administrative
control program, whereas your letter advised that these systems should be
credited as safety significant controls.
After discussions with your staff, PXSO has
directed the Pantex contractor to make changes to the authorization basis
documents. These changes, detailed in
the enclosure, will eliminate exclusive reliance on the CAM/RAM systems for
worker protection without changing their designation to safety significant. These systems will also continue to be
credited as TSR-level controls.
If you have further questions, please
contact me or have your staff contact Mr. David E.
Beck at 202-586-4879, Mr. Jeff Underwood at
301-903-8303, or Mr. Steve Erhart of PXSO at 806-477-6150.
Sincerely,
Everet H. Beckner
Deputy Administrator
for Defense Programs
Enclosure
cc w/enclosure:
Mark Whitaker, EH-9
NNSA Actions
to Address Concerns of DNFSB Letter of November 13, 2002
The PXSO will direct the Pantex contractor
to take the following actions relative to authorization basis documents that
contain scenarios for which the Continuous Air Monitor and Radiation Alarm
Monitor (CAM/RAM) systems are currently credited as the only control to prevent
potentially significant worker exposure:
·
Each scenario
involving potential significant exposure to the worker will be identified and
the initiator will be clearly defined (i.e., reservoir drop, squib valve
actuation, pit drop, etc.)
·
Worker
training that ensures the worker will exit the facility immediately once any of
these initiators have occurred will be identified as the primary control to
prevent significant exposure.
·
The revisions
to the AB documents will occur as part of the next annual update.
The CAM/RAM systems will continue to be
credited via a Technical Safety Requirement level administrative control
program.