May 7, 2007
The Honorable A. J. Eggenberger
Defense Nuclear Facilities Safety Board
625 Indiana Avenue, NW, Suite 700
Washington, DC 20004-2901
Dear Mr. Chairman:
On June 26, 2006, you requested the Department of Energy (DOE) review DOE Standard (STD) 1027, Change Notice 1, Hazard Categorization and Accident Analysis Techniques for Compliance with DOE Order 5480.23, Nuclear Safety Analysis Report, to ensure defense nuclear facilities are applying the standard consistently and correctly.
In a letter dated October 25, 2006, we forwarded you a list of potential areas for improvement in DOE-STD-1027 that included those identified in your June 26 letter and others identified by the Chief of Defense Nuclear Safety and the Chief of Nuclear Safety, and committed to establish a working group to evaluate them. Furthermore, we committed to establish a path forward to: (1) revise DOE-STD-1027, as appropriate, (2) identify any defense nuclear facilities affected by problems implementing DOE-STD-1027, and (3) ensure the standard is correctly implemented to prevent problems in the future.
The DOE-STD-1027 working group has completed its evaluation and has recommended several improvements in DOE-STD-1027. These improvements are summarized in Enclosure 1. Most of the recommended changes are consistent with the intent and fundamental elements of DOE-STD-1027 but provide amplifying guidance. For these changes, the Office of Health, Safety and Security has developed supplemental guidance for DOE-STD-1027 for use in supporting consistent implementation of DOE-STD-1027 throughout DOE (Enclosure 2). This guidance can also be utilized by DOE elements to evaluate whether any current facilities hazard categorizations may need to be revised to ensure that the areas of DOE-STD-1027, which may have been misinterpreted (Enclosure 3), did not result in inappropriate hazards categorizations.
We also plan on revising DOE-STD-1027 to incorporate the supplemental guidance and the other improvements, which impact the intent or fundamental elements of the standard. However, this will be an extended effort; and we therefore believe the issuance of the supplemental guidance is warranted at this time.
If you have further questions on our efforts on this issue, please contact me at (301) 903-3777 or have your staff contact Dr. James O’Brien at (301) 903-1408.
Glenn S. Podonsky
Chief Health, Safety and Security Officer
Office of Health, Safety and Security