[DOE
LETTERHEAD]
February 7, 2007
The Honorable A. J. Eggenberger
Chairman
Defense Nuclear Facilities Safety Board
625 Indiana Avenue, NW, Suite 700
Washington, DC 20004-2901
Dear Mr. Chairman:
In a letter dated September 14, 2005, you
requested the Department of Energy (DOE) report on the following issues:
·
The
adequacy of local DOE and contractor implementation procedures for DOE Order 420.1A,
Facility Safety; DOE
Order 425.1C, Startup and Restart of Nuclear Facilities, and 10 CFR 830, Subpart B, Nuclear Safety Management, with particular focus on the definition of a “new Hazard Category 1, 2,
or 3 nuclear facility,” and “substantial modification.”
·
The
actions necessary to ensure that
any deficient site procedures are corrected and that site contractors
appropriately apply design requirements, develop Preliminary Documented Safety
Analyses (PDSAs), and perform Operational Readiness Reviews (ORRs) for new Hazard Category 1, 2, and 3 nuclear
facilities as required.
·
The need
for revision or clarification of the definition of a “new Hazard Category 1,
2, or 3 nuclear facility” and/or “substantial
modification” within the DOE directives system.
In a letter dated December 13, 2005, DOE
reported on these issues and the follow-up actions it intended to take. As part of these follow-up actions in early
2006, the National Nuclear Security Administration (NNSA) performed a
high-level review of the processes for developing PDSAs and determining the
appropriate level of startup reviews for new facilities and significant modifications
at its sites and found them to be appropriate. NNSA briefed the Board staff on these results on February 14, 2006. In addition, as committed in a letter dated May 9, 2006, the Office of
Environmental Management (EM) conducted
a focused review of the processes for developing PDSAs and determining the
appropriate level of startup reviews for new facilities and significant
modifications at the Savannah River and Hanford sites where your staff had identified
concerns. These reviews were performed
in May of 2006 and identified several deficiencies with the application of
nuclear safety definitions in determining whether to develop PDSAs or to
perform ORRs. These sites have taken
appropriate action to correct the deficiencies (see Enclosure).
Further, in December 2006, DOE reviewed the
Idaho National Laboratory’s startup procedures and the implementation of their
procedures for the recent startup of a remote-handled transuranic waste drum operation in response to some new concerns identified by
your staff. This review also identified
deficiencies with the implementation of DOE Order 425.1C. EM is working with the site to ensure the
deficiencies are corrected.
DOE’s evaluation of all of these reviews indicate that there is a
need for more rigorous and conservative implementation of the directives
related to startup of new and substantially modified facilities. DOE is taking (or has taken) the following
actions to improve the implementation of the directives related to startup of
new and substantially modified
facilities:
·
The
Office of Health, Safety and Security (HSS) is coordinating the development and
dissemination of a lessons learned document from the NNSA and EM reviews to
promote improved implementation throughout the complex.
·
Both the
NNSA and EM have added evaluations of the startup process to their periodic headquarters oversight reviews of
their field operations.
·
EM has
issued specific direction to its field managers to strengthen management
control of the startup process.
·
HSS’s
Office of Independent Oversight is including an evaluation of the
implementation of the decision-making process for determining the appropriate
level of facility startup analysis and review (e.g., whether a PDSA should be developed and an ORR or RA performed) as part of its Environment, Safety and Health site
inspections.
·
HSS is
establishing a DOE-wide working group to examine the facility restart review process to
identify improvements and any appropriate revisions to the restart Order. This working group met in Richland, Washington, in late January with
participation by your staff.
Although DOE did not identify a need for
revision or clarification of the definition of a “new Hazard Category 1, 2, or
3 nuclear facility” and/or “substantial modification” within the DOE directives
system, additional detail on what constitutes a “major modification” is being
including in the latest draft of
DOE Standard 1189, Integration of Safety into the Design Process, and will be considered for inclusion in DOE
guidance documents that address “substantial modifications” for consistency.
If you have further questions on our efforts
on this issue, please contact me at (301) 903-3777 or have your staff contact
Dr. James O’Brien at (301) 903-1408.
Sincerely,
Glenn S. Podonsky
Chief Health, Safety and Security Officer
Office of Health, Safety and Security