[DNFSB
LETTERHEAD]
November 23, 2005
The Honorable Samuel W. Bodman
Secretary of Energy
1000 Independence Avenue, SW
Washington, DC 20585-1000
Dear Secretary Bodman:
On April 5,
2004, the Defense
Nuclear Facilities Safety Board (Board) sent a letter to the Secretary of
Energy outlining issues related to the Department of Energy’s (DOE) approach
with respect to the use of formal risk assessment in oversight, operations, and
decision making at defense nuclear facilities. In response to the Board’s letter, DOE
committed to the development of a comprehensive policy governing the
development and application of risk assessment methodologies, including
expectations related to the quality and level of review required for specific
applications of formal risk assessments. Earlier this year DOE proposed finalizing this
policy by March 2006.
The Board has reviewed an early
draft of DOE’s policy on the use of the risk assessment and offers general
comments in the enclosure. In addition
to these comments, the Board is concerned that even though DOE has not yet
developed expectations, guidance, and implementing procedures governing the use
of formal risk assessment, individual program elements and field entities
continue to apply various approaches on an ad hoc basis. Examples of these applications include the
ongoing activities associated with evaluating the risk of multi-unit operations
at Pantex, as well as the proposed use of risk assessment to disposition some
of the technical issues associated with Recommendation 2004-2, Active Confinement
Systems. Such an approach is almost
certain to lead to the development and application of a wide range of
methodologies of varying quality and utility, some of which could lead to
inappropriate safety decisions.
Furthermore, it appears that
other potential applications may exist but have not been targeted for a
systematic assessment of risk. One such
example is that of the various dismantlement options being proposed for the B53
weapon system. Therefore, pursuant to 42
U.S.C. § 2286b(d), the Board requests a
report within 60 days of receipt of this letter providing the details of a more
aggressive plan for developing and implementing an appropriate DOE-level
policy, along with the necessary implementing guidance, to ensure the
appropriate use of risk assessment methodologies at defense nuclear facilities.
Sincerely,
A.
J. Eggenberger
Chairman
c: The Honorable Linton Brooks
The
Honorable John S. Shaw
The
Honorable James A. Rispoli
Mr.
Mark B. Whitaker, Jr.
Enclosure
ENCLOSURE
Comments
on Draft Policy, DOE PXXXX,
Department
of Energy Nuclear Risk Assessment Policy
1.
The
draft policy does not establish sufficient guidance or direction that would be
useful in enhancing DOE’s use of risk assessment. The goal of the policy should be to mandate a consistent
and uniform approach to the use of risk assessment methodologies.
2.
DOE
should avoid the development of new terms and definitions, such as “enhanced
risk assessments”, that are not widely used in the risk assessment community.
3.
The
policy should contain more clearly defined roles and responsibilities. Furthermore, the authority to determine the
adequacy of DOE’s overall approach to risk analysis should not be delegated
down to the field and site office managers.
4.
The
policy should not be limited to nuclear risk assessment, but should also be
applicable to non-nuclear risk assessments at defense nuclear facilities.
5.
To
limit misuse of risk assessment methodologies, the policy should address inappropriate
application of probabilistic approaches.