[DNFSB LETTERHEAD]
July 14, 2003
The Honorable Spencer Abraham
Secretary of Energy
1000 Independence Avenue, SW
Washington, DC 20585-1000
Dear Secretary Abraham:
The Defense Nuclear Facilities Safety Board
(Board) received your letter dated June 26, 2003, enclosing the Department of
Energy’s (DOE) Implementation Plan for the Board’s Recommendation 2002-3, Requirements
for the Design, Implementation, and Maintenance of Administrative Controls. The Board has reviewed the Implementation
Plan and finds that it satisfies Board Policy Statement 1 and is responsive to
the issues documented in the Recommendation.
The Board agrees that DOE’s Implementation
Plan should ensure the reliability and effectiveness of important
administrative controls in the defense nuclear complex. The Board strongly endorses the commitment
to revise DOE’s safe harbor methodologies under Title 10 of the Code of Federal
Regulations, Part 830, Nuclear Safety Management, to strengthen the
requirements associated with administrative controls. In addition, the Board anticipates that through the field reviews
in this plan DOE will re-evaluate the rationale for selecting safety-related
administrative controls in lieu of engineered safety controls, replace
administrative controls with engineered controls where appropriate, and ensure
that administrative controls still deemed appropriate are developed,
implemented and maintained in accordance with their safety function. We look forward to reports outlining the
success of your efforts.
Sincerely,
John T. Conway
Chairman
c:
The Honorable Linton Brooks
The Honorable Beverly Ann Cook
The Honorable Jessie Hill Roberson
Mr. Mark B. Whitaker, Jr.