October 5, 2006
The Honorable A. J. Eggenberger
Defense Nuclear Facilities Safety Board
625 Indiana Avenue, NW, Suite 700
Washington, D.C. 20004
Dear Mr. Chairman:
Subject: Interface with the DNFSB and Review of Draft DOE M 140.1-1C
As you are aware, on August 30, 2006, the Secretary of Energy created the Office of Health Safety and Security (HSS) and that this office includes the responsibilities for the interface function with the DNFSB. We believe that the integration of the Departmental Representative and the safety offices in HSS can more effectively support the coordination and resolution of DNFSB recommendations and interactions.
As we work to standup HSS and to more effectively implement the many important functions that are part of this office, we decided to examine the current draft of the DNFSB Interface Manual (DOE Manual 140.1-1C, Interface with the Defense Nuclear Facilities Safety Board), and have been struck by the shear volume of information regarding our process. The need for a manual of such magnitude seems to be counterintuitive to our common objective for improving and maintaining health and safety at our defense nuclear facilities. The sheer volume of the process details in the current draft Manual may cloud our common objective or distract us from effectively addressing the actual problem. We understand the DNFSB interface process is rooted in its enabling legislation to evaluate and provide input to the Department and the public on defense safety matters. We are not questioning the need to have an agreement on how we coordinate our activities; however, we believe there may be a better overall approach.
We plan to re-examine the basis behind the existing Manual and determine if there is a better approach that can enhance our working relationship, one that diffuses any implied adversarial relationship, one that doesn’t inadvertently distract us from improving and maintaining health and safety at our defense nuclear facilities. In the short term, please be assured that this Office will continue to work with the Board, its staff, and the appropriate Departmental elements as specified in the existing Manual. This will give us some time to clearly determine the true interface details needed and more fully understand any potential interface difficulties. We can then move forward in a cooperative manner and devise the appropriate process manual.
In closing, please understand that it is our goal to effectively, efficiently and responsibly work together so that real progress can be made. With the creation of HSS, we are sure this is the beginning of a renewed opportunity to strengthen health, safety and security throughout the Department. I look forward to personally working with the Board and its staff to help us make that difference. Please feel free to contact me at (301) 903-3777.
Glenn S. Podonsky
Chief Health, Safety and Security Officer
Office of Health, Safety and Security
C. Sell, DS
A. Ingols, DS
M. Kilpatrick, HS-1
R. Shearer, HS-1
M. Whitaker, HS-1.1