The Defense Nuclear Facilities Safety Board has concerns about the Department of Energy’s proposed change to nuclear safety management rules governing the agency and its contractors.
The proposed rule, published in the Aug. 8 Federal Register, does not spell out certain bedrock nuclear safety principles such as “defense in depth” and the “hierarchy of controls,” the independent safety watchdog said in comments dated Oct. 5. These concepts are included in supporting documents, the DNFSB said, but putting them in the rule itself “would emphasize their importance and encourage more consistent implementation.”
Defense in depth stresses multiple layers of protections to prevent inadvertent nuclear releases, so workers and the public don’t have to rely solely on any one safeguard, according to the DNFSB. The hierarchy of controls seeks first to minimize the use of hazardous materials, and prefers engineered controls over administrative measures in order to prevent or reduce the impact of accidents.
The DNFSB submitted its remarks as part of the public comment process for DOE’s update to the nuclear safety management rules issued between 1994 and 2001 in response to studies from the National Academy of Sciences.
The DOE has said it is seeking to update the rules with lessons learned from experience, and also eliminate redundant or unnecessary standards.
The Energy Department held public hearings during August and September near several DOE facilities and took comments on the rule through Oct. 9.
The board also believes it would be a mistake to eliminate DOE’s annual review and approval of documented safety analyses for its active nuclear operations, cleanup sites, and transportation projects: “There is a potential for the safety basis and facility operations to drift outside the envelope approved by DOE.” It is also not clear what problem the department is trying to fix here, the DNFSB said.
The DSA under the proposal would still need to be submitted annually by contractors to the Energy Department, but it would not require approval of the agency. Eliminating the annual reviews would make it more difficult for DOE to fulfill its responsibility to ensure the safety of these government-owned sites, the DNFSB said.
