[SOE LETTERHEAD]
July 11, 2003
The Honorable John T. Conway
Chairman
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 Department’s
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 Department’s 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
Administration’s 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 Department’s 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.
Sincerely,