[DOE LETTERHEAD]
NATIONAL NUCLEAR SECURITY ADMINISTRATION
October 1, 2007
The Honorable A.J.
Eggenberger
Chairman
Defense Nuclear Facilities Safety Board
Dear Mr. Chairman:
The purpose of this letter is to transmit the National Nuclear Security Administration
Central Technical Authority (CTA) implementing guidance regarding expectations that
the safety bases and controls be finalized and approved before a Contractor Readiness
Assessment begins. I will be
transmitting this guidance to the Site Office Managers in
my role as Line Management Authority for the site
offices.
I mentioned this CTA guidance
in my August 14, 2007, letter to you as a pending action.
If you have any comments or feedback, please call me or Mr. Steve Goodrum, Assistant
Deputy Administrator
for Military Application and Stockpile Operations at
(202) 586-4879.
Sincerely,
Martin J. Schoenbauer
Principal Assistant Deputy Administrator
for Operations
Defense Programs
Enclosure
September 27, 2007
MEMORANDUM FOR MARTIN
J. SCHOENBAUER
PRINCIPAL
ASSISTANT DEPUTY ADMINISTRATOR
FOR OPERATIONS
FROM: WILLIAM
C. OSTENDORFF
CENTRAL
TECHNICAL AUTHORITY (CTA)
SUBJECT: STARTUP
AND RESTART OF NUCLEAR FACILITIES
The safe startup and restart of nuclear facilities is ensured by a rigorous process set forth
in Department of Energy (DOE) Order 425.1C, Startup and Restart of Nuclear Facilities,
and DOE Standard (STD) 3006-2000, Planning and Conduct of Operations Readiness
Reviews. During the last 18 months, several instances have occurred in which DOE
requirements and best practices for startup activities may have been circumvented. I am
issuing this memorandum to establish clear expectations in two key areas and to direct
actions to institutionalize these expectations through the directives
process.
The first area involves facility safety documentation. DOE O 425.1C establishes a set of
Minimum Core Requirements (MCRs) for readiness. The seventh MCR requires safety
documentation to be in place and implemented that describes the safety envelope of the
facility being started or restarted. It is an NNSA expectation that this MCR applies to all
readiness assessments and reviews. Facility safety documentation that addresses an
activity being started or restarted must be approved and implemented prior to beginning
the contractor readiness assessment or readiness review for the activity. When facility
safety documentation requires NNSA approval, that approval must be obtained before the
start of the contractor’s readiness assessment or review.
The second area involves startup notification reports (SNRs). DOE O 425.1C establishes
SNRs as the vehicles by which agreement on types of review and authorization authority
is documented, and by which senior management is kept informed. The Order requires
periodic submission of SNRs and recommends a quarterly submission period. Effective
October 15, 2007, it is an NNSA
expectation that SNRs be submitted quarterly and
that copies be submitted to NA-10 and to the Chief of Defense Nuclear Safety (CDNS).
Quarterly
SNRs must include summary-level information on all scheduled activities
that may require readiness reviews and that are projected to occur within the subsequent
12 months. More detailed information, as described DOE O 425.1C and
DOE-STD-3006-2000, must be included for activities that have not
been included on
previous SNRs. Proposed startups or restarts that arise between quarterly SNR submittals
(e.g. for short notice activities or unplanned shutdowns) may be approved as amendments
to the previous quarterly SNR.
I request that you formalize these expectations for all Hazard Category 1, 2, and 3 nuclear
activities and operations under your authority. I also request that you advise the Defense
Nuclear Facilities Safety Board that the commitment in your memorandum of August 14,
2007, for the CTA to issue guidance on this subject, has been met. Finally, as CTA, I am
initiating an action through the CDNS, to ensure that these expectations are
institutionalized through the directives process.
cc: Thomas
D’Agostino, NA-1
James
McConnell, NA-2.1
Richard
Crowe, NA-2.1
Michael
Thompson, NA-17
Carl
Sykes, NA-17
Manager,
Sandia Site Office
Manager,
Pantex Site Office
Manager,
Manager,
Y-12 Site Office
Manager,
Manager,