January 31, 2003
The Honorable John T. Conway
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.