[SOE LETTERHEAD]
January 31, 2003
The Honorable John T. Conway
Chairman
Defense Nuclear Facilities Safety Board
625 Indiana Avenue, NW, Suite 700
Washington, D.C. 20004
Dear Mr. Chairman:
The Department of Energy (Department)
acknowledges receipt of the Defense Nuclear Facilities Safety Board’s (Board)
Recommendation 2002-3, Requirements for the Design, Implementation, and
Maintenance of Administrative Controls.
Recommendation 2002-3 was issued on December 11, 2002 and published in
the Federal Register on December 20, 2002. The Department agrees that we must assure
the critical assumptions used in defining and analyzing the basis for safe
operations are properly developed, appropriately implemented, and effectively
preserved. If the critical assumptions
depend on administrative controls, we agree those controls should be treated
appropriately. Therefore, the
Department accepts the recommendation and will develop an implementation plan
to respond to the recommendation.
The Department of Energy’s (DOE)
implementation plan will address how we will review existing DOE requirements
and guidance to determine where further consolidation or clarification is
needed to assure proper focus on those administrative controls that perform
important safety functions similar to safety-class or safety-significant
controls. Additionally, the plan will
address how we will evaluate safety basis documents to identify administrative
controls critical to preventing or mitigating accident consequences. We will strengthen our processes to ensure
those critical administrative controls are properly implemented.
I have asked the Assistant Secretary for
Environment, Safety and Health, Beverly Cook, to ensure the successful
completion of the implementation plan we will develop in response to your
recommendation. Mr. Richard Black,
Director of the Office of Nuclear and Facility Safety Policy, is the
responsible manager for the preparation of the Department’s implementation
plan.
Sincerely,