National Nuclear Security Administration
July 25, 2006
The Honorable A. J. Eggenberger
Defense Nuclear Facilities Safety Board
625 Indiana Avenue, N.W., Suite 700
Washington, D.C. 20004-2901
Dear Mr. Chairman:
The National Nuclear Security Administration (NNSA) completed its review of potentially outdated and inaccurate Department of Energy (DOE) Orders of Interest to the Defense Nuclear Facilities Safety Board (Board), fulfilling a commitment from our September 9, 2005, letter. The review focused on two areas: (1) accurate reflection of NNSA organizational roles and responsibilities, and (2) completeness in specifying unique NNSA safety responsibilities. Where issues were identified, NNSA contacted the organization responsible for the Order to determine whether revisions were currently ongoing or planned.
Based on the review, NNSA found that the majority of the Orders that require revision are either currently undergoing a revision or are planned for revision in the near future. NNSA currently is working directly with several of the organizations that are revising their Orders and will continue to assist as appropriate.
NNSA found six Orders that did not have adequate references to NNSA and were not currently planned for revision. The six Orders are DOE Order 5400.5 Change 2, Radiation Protection of the Public and the Environment; DOE Order 5480.4 Change 4, Environmental Protection, Safety, and Health Protection Standards; DOE Order 252.1, Technical Standards Program; DOE Order 5480.19 Change 2, Conduct of Operations Requirements for DOE Facilities; DOE Order 5480.20A Change 1, Personnel Selection, Qualification, and Training Requirements for DOE Nuclear Facilities; and DOE Order 5480.30 Change 1, Nuclear Reactor Safety Design Criteria. NNSA is requesting the DOE Office of Management to initiate the revision process for these six Orders.
An enclosure to our letter of June 4, 2004, included a list of Orders of Interest to the Board that were either archived or deleted that may still be included in contracts. The contracts for NNSA sites were reviewed for the Orders on this list and it was concluded that archived or deleted Orders generally were not included in the contracts except as noted below:
! DOE Order 5400.1, General Environmental Protection Program, is still included in the Nevada Test Site Tri-Lab Work Smart Standards set that applies to work performed by Sandia, Los Alamos, and Lawrence Livermore National Laboratories at the Nevada Test Site. The Nevada Site Office is in the process of converting the work smart standards set into a List B requirements format for the National Security Technologies contract. DOE Order 5400.1 will not be included in the List B that is expected to be completed by the end of Fiscal Year 2006.
! Eight cancelled Orders from the list are currently included in the Y-12 Wackenhut and/or BWXT contract. All of these Orders will be deleted during the next contract modification cycle in July 2006.
The actions described in this letter, combined with our March 27, 2006, letter complete NNSA’s response for DOE Orders of Interest to the Board and supplemental directives from former Operations Offices. Our next step will be to complete a review to identify standards and other documents that may need revision in conjunction with the update of the NNSA Safety Management Functions, Responsibilities and Authorities Manual (FRAM). We expect to complete this review by October 31, 2006, and will provide you the results of our review.
If you have any questions, contact Lynn Maestas at (505) 845-6388 or Rabi Singh at (301) 903-5864.
Thomas P. D’Agostino
for Defense Programs
L. Brooks, NA-1
J. Cavanagh, NA-1
T. Przybylek, NA-1
J. Paul, NA-2
M. Whitaker, DR-1