[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.