[SOE LETTERHEAD]
July 21, 2004
The Honorable John T. Conway
Chairman
Defense Nuclear Facilities
Safety Board
625 Indiana Avenue, NW, Suite
700
Washington, DC 20004-2901
Dear Mr. Chairman:
The Department has thoroughly
reviewed Recommendation 2004-1 regarding oversight of complex, high-hazard
nuclear operations issued by the Defense Nuclear Facilities Safety Board
(Board) on May 21, 2004.
The Department remains firmly
committed to its Integrated Safety Management (ISM) program as the foundation
for performing work safely throughout the Department. The Department’s response will include actions
to enhance the effectiveness of our ISM program. We remain committed to safety as our top priority
and will not sacrifice safety to meet production goals. In January, we highlighted our commitment to
continued safety improvement by establishing safety as one of the seven
Department-wide Management Challenges for 2004.
As you observed as background to
the recommendation, the Columbia accident and the Davis-Besse incident provide
valuable lessons from which the Department can learn as we continue to improve
our safety management. The lessons from
these events will be key inputs in our action planning in response to your
recommendation.
The Department accepts Recommendation
2004- 1 and will develop an implementation plan to accomplish the following
actions for nuclear operations at defense nuclear facilities:
1.
Clarify
and/or establish formal requirements regarding delegation of authority on
safety matters to ensure that delegations are made with clear criteria. Ensure that adequate oversight and technical
capability are in place to fulfill these safety responsibilities at all levels
of the Department.
2.
Identify
applicable lessons from the Columbia accident and Davis-Besse incident and
implement corrective actions to improve safety throughout the organization.
3.
Establish
a technically-competent, central authority or authorities with core safety
responsibilities.
4.
Identify
safety research, analysis, and testing needs and institute a program to ensure
effective management, integration, and execution of efforts to address these
needs.
5.
Revise
and implement the Functions, Responsibilities and Authorities documents and
Quality Assurance Plans, as needed, to achieve the actions described above and
to ensure direct and unbroken lines of roles and responsibilities for the
safety of nuclear operations.
6.
Validate
that safety responsibilities, capabilities, and authorities are implemented and
consistent with requirements.
The Department’s understanding
is that Recommendation 2004-1 does not require changes to the structure of the
directives management system or to the existing DEAR clauses.
Regarding delegations of
authority on defense nuclear safety matters, I have directed the Department’s
senior managers to make no new field delegations, except as approved by me or
the Deputy Secretary until the Department completes the applicable actions
identified in the Department’s 2004-1 implementation plan. To clarify, this restriction does not apply to
delegation modifications that may be required as a result of personnel changes
or delegation expirations.
I have asked Mr. Ted Sherry,
Deputy Manager, National Nuclear Security Administration Y-12 Site Office, to
lead the response team that will develop the Department’s 2004-1 implementation
plan. If you have questions, please
contact him at (865) 576-0752.
Sincerely,
Spencer Abraham