**\[DOE LETTERHEAD\]**

February 2, 2004

The Honorable John T. Conway

Chairman

Defense Nuclear Facilities Safety Board

625 Indiana Ave, NW, Suite 700

Washington, DC 20004

Dear Mr. Chairman:

This letter is being provided in response to Commitment 4.6 of the
Department of Energy (DOE) Implementation Plan for Defense Nuclear
Facilities Safety Board's Recommendation 2002-3, *Requirements for the
Design, Implementation, and Maintenance of Administrative Controls*.
This commits the Office of Environmental Management (EM) to review field
implementation of critical administrative controls and verify that they
are developed, implemented, and maintained as part of safety basis
implementation or operational oversight. The first deliverable of this
commitment is a schedule for implementation reviews and implementation
review reports.

In July 2003, the Assistant Secretary for EM initiated field reviews at
EM sites to evaluate the overall control selection methodology
established within the safety basis for selected EM facilities. So far,
Mr. Dae Chung and his team of selected individuals from around the DOE
complex, has performed reviews at the Savannah River and Hanford sites
(including facilities managed by the Office of River Protection).
Reviews have focused on the adequacy of controls within facility safety
bases, as well as DOE field office safety basis review process and
functional assessment activities.

Based on insights from the initial review at Savannah River, a review
plan was prepared and issued to the EM field sites in October 2003. The
review schedule was temporarily postponed in order to consider
implications of the Nuclear Technical Safety Position and a draft DOE
technical standard on administrative controls, both prepared in
accordance with commitments in the 2002-3 implementation plan. Given the
time frame for finalizing the draft standard, EM will resume field
reviews and continue to evaluate the overall control selection process
and attention given to critical administrative controls. EM will also
continue to participate in the draft standard's development and ensure
that it is reflected within review criteria, as appropriate. Once the
draft standard is finalized, EM plans to evaluate whether DOE
expectations are appropriately reflected within EM facility safety
bases.

The current review schedule is as follows:

-   March 2004 -- Oak Ridge Reservation/Oak Ridge Operations Office

-   April 2004 -- Paducah and Portsmouth/Lexington Office

-   May 2004 -- Idaho National Engineering and Environmental
    Laboratory/Idaho Operations Office

-   June 2004 -- Lawrence Livermore National Laboratory/Livermore Site
    Office (EM operations)

-   June 2004 -- Nevada Test Site/Nevada Site Office (EM operations)

-   July 2004 -- Waste Isolation Pilot Plant/Carlsbad Operations Office

-   September 2004 -- Follow-up at Hanford and Savannah River Sites as
    needed to capture any changes to original review criteria

A final report will be issued consistent with milestone 4.6.2 in the
2002-3 implementation plan, and EM will issue draft summaries of
observations and lessons learned within 30 days of each review. These
summaries will be provided to the Board's staff.

Irrespective of field review activities, EM continues to emphasize the
important role of administrative controls at our facilities. It is my
expectation that DOE safety basis reviewers will verify adequacy of
contractor implementation actions necessary to implement all facility
safety controls consistent with supplemental guidance issued by the
Assistant Secretary on May 28, 2002. Further, EM field sites have been
provided with specific guidance on administrative controls as discussed
in *EM Guidelines and Lessons Learned for Nuclear Facility Safety
Control Selection and Implementation*, issued on May 20, 2003.

If you have any questions, please call me or Mr. Dae Chung, Acting
Director of Licensing and Chief Safety Officer, at 301-903-3968.

Sincerely,

***Inés Triay***

***Deputy Chief Operating Officer***

***Office of Environmental Management***

cc: Mark Whitaker, DR-1