[DOE LETTERHEAD]
October 22,
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 purpose of this letter is to
respond to your September 8, 2004,
letter regarding Integrated Safety Management System (ISMS) for the Hanford
Tank Farms. We share your concerns, and
the U.S. Department of Energy (DOE), Office of River Protection (ORP) site manager, Roy Schepens has communicated these concerns to the
Tank Farms Contractor CH2M HILL Hanford Group, Inc. (CH2M HILL) and reduced the CH2M HILL fee by
$300,000 because of these concerns. A
copy of the August 25, 2004, letter and the two reports identified in it have
been provided to your staff.
CH2M HILL recently completed the
root cause analysis for the July 2004, 244-CR Vault Thermocouple Removal event,
identified corrective actions and completed a common cause analysis associated
with five similar events referenced in the Schepens’ August 4, 2004, letter. The results of the analysis identify workforce
and management issues that are being addressed with compensatory actions and
longer term improvement initiatives.
Compensatory measures have been
implemented by Management Directive TFC-MD-038 “Compensatory Controls for Radiological
Control Performance” (MD-038). MD-038
establishes a rigorous process for ensuring the adequacy of work packages for
all high and medium risk work prior to work authorization. A formal
process controlled by procedure has been established to categorize work as high,
medium, or low risk. DOE Facility
Representatives closely followed development of the compensatory measures and
are closely monitoring their implementation. CH2M HILL is also assigning a Senior
Supervisory Watch to medium and high risk radiological work to ensure
performance is consistent with DOE expectations. These expectations include a conservative
approach to planning when detailed radiological data is not available or the
data is potentially unreliable. Radiation
Work Permit (RWP) limits, actions required when RWP limits are reached, and
steps to place the facility in a safe condition will be more clearly specified
in the work instructions and extensively reviewed during pre-job briefings. ORP is also reviewing low risk work to
validate that it is properly categorized as low risk.
ORP has established a Tank Farm
ISMS Improvement Validation Team. This team
is comprised of independent experts that will evaluate Tank Farm ISMS in two
reviews. The first review will be
completed by early November 2004. An interim
briefing will be provided to the Board on the results. We will provide this briefing within the
60-day period established by your letter. The initial review will verify the adequacy of
the CH2M HILL evaluation of events and corrective action determinations. A second review scheduled to begin March 7,
2004, will focus primarily on Field Operations and evaluate the adequacy of
implemented improvements. The start date
of the second review may be adjusted to ensure that most corrective actions are
declared implemented and an adequate level of Field work activity is scheduled
for the team to observe and evaluate. A
final comprehensive
written report will be prepared following the second review. The nature of the corrective actions planned
by CH2M HILL and the length of time to implement these actions preclude the
completion of the second review during the 60-day period.
The planned approach to
addressing our mutual concerns utilizing the Tank Farm ISMS Improvement
Validation Team is consistent with DOE Guide 450. 4-1B, Integrated Safety
Management System Guide (Volume
l), and has been discussed with your senior staff.
If you have any further
questions, please call me at (202) 586-7709 or Mr. Roy Schepens at (509)
376-8052.
Sincerely,
Paul M. Golan
Acting Assistant Secretary for
Environmental Management