[SOE LETTERHEAD]
March 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 regarding the Defense Nuclear Facilities Safety Board’s (Board) concern
for the improper interpretation and implementation of the Department of
Energy’s (DOE) guidance provided in DOE-STD-3009, Preparation Guide for U. S. Department of Energy Nonreactor Nuclear
Facility Documented Safety Analyses.
Line management is
responsible for establishing realistic yet conservative input conditions
necessary to achieve a representative set of bounding consequences in the
facility or activity safety analysis.
Selecting and defending a set of realistic and conservative input
conditions is a process that is very important and complex where safety
professionals can differ in approaches.
In order to meet Title 10 of the Code of Federal Regulations (CFR) Part
830 (10 CFR Part 830) schedule of April 10, 2003, for the submittal of DSA for
DOE review and approval, it is crucial to have the DOE line organizations
review and assess the input conditions used in DSA development at selected
facilities under their responsibility.
Your concern is
supported by a number of instances, identified by your staff, where Documented
Safety Analyses (DSA) do not properly reflect bounding conditions when
estimating the unmitigated consequences of postulated accidents. This letter is in response to your request
that we keep you informed of our activities and initiatives to address this
concern.
I have asked the
Office of Environmental Management (EM) and the National Nuclear Security
Administration (NNSA) to initiate appropriate actions within their
organizations to address your concerns and keep the DNFSB and the staff
informed.
cc:
J. Roberson, EM-l
L. Brooks, NA-1
W. Magwood, NE-l
G. Pondonsky, OA-1
R. Orbach, SC-l
M. Whitaker, S-3.l
B. Cook, EH-1