July 11, 2003
The Honorable John T. Conway
Defense Nuclear Facilities Safety Board
625 Indiana Avenue, NW, Suite 700
Washington, DC 20004-2901
Dear Mr. Chairman:
Thank you for your letter expressing concerns related to implementation of the Department of Energy protocols for testing High-Efficiency Particulate Air (HEPA) filters at the Departmentís defense nuclear facilities.
The Department is committed to meeting the protocols identified in my letter of June 4, 2001.† The configuration and reliability of vital safety systems are essential to the performance of the Departmentís facilities and to the protection of the public, workers, and environment.† I hold line management responsible for assuring the HEPA filters fulfill their intended safety function.† Line managers are also responsible for implementing the Department requirements for HEPA filters, including the conduct of testing and self-assessment.† The status of Environmental Management and the National Nuclear Security Administration in meeting the actions identified in my letter of June 4, 2001, is summarized in the attached enclosures.
The National Nuclear Security Administrationís review of the requested information to respond to your January 9, 2003, letter has determined that the required 100 percent testing of HEPA filters at the Filter Testing Facility (FTF) used in safety significant and habitability systems to the FTF is being followed.† However, National Nuclear Security Administration notes that the self-assessment activities covering the sites required HEPA filter programs are not as rigorous or well defined as expected.† The National Nuclear Security Administration will take the necessary action to improve and strengthen these programs where needed.
With respect to the particular issues you highlighted in your letter, the Department will continue to fund the Oak Ridge Filter Testing Facility (FTF) until such time as the facility is scheduled for deactivation and decommissioning; this is now expected in April 2005.† The Departmentís policy continues to be to send 100 percent of filters used in safety class, safety significant, and habitability systems to the FTF for testing.† The Department will brief the Defense Nuclear Facilities Safety Board prior to any changes in this policy.
Ms. Beverly A. Cook, Assistant Secretary for Environment, Safety and Health is establishing a corporate Quality Assurance (QA) office for the Department.† This corporate QA office will establish requirements and policies to evaluate the effectiveness of existing programs for a broad range of quality issues, including the effectiveness of HEPA filter testing protocols, and coordinate implementation of corporate strategy for improvements.† The Department will brief the Defense Facility Nuclear Safety Board prior to implementing any changes in the June 4, 2001, protocols.
The Department will continue to implement the currently establish HEPA filter testing measures.† If the Board so desires, we are prepared to have the appropriate technical staff brief you in more detail on current implementation status.
If you have any further questions, please contact me or Ms. Beverly A. Cook, Assistant Secretary for Environment, Safety and Health, at (202) 586-6151.