Nuclear Security & Deterrence Vol. 19 No. 32
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Nuclear Security & Deterrence Monitor
Article 11 of 18
August 28, 2015

DOE Submits Justification to Revise DOE Emergency Management Order

By Brian Bradley

Alissa Tabirian
NS&D Monitor
8/28/2015

The Department of Energy (DOE) has submitted a document justifying revisions to its emergency preparedness and response guidelines in response to recommendations from the Defense Nuclear Facilities Safety Board (DNFSB), according to an Aug. 19 letter from the National Nuclear Security Administration (NNSA) to the DNFSB. The memorandum provides reasoning to revise DOE’s Order on the Comprehensive Emergency Management System that guides the development and control of emergency planning and response at all DOE and NNSA facilities.

An April 24 DOE letter on the implementation plan to the DNFSB notes “the inconsistent interpretation and implementation of requirements at some DOE sites,” “the need for improvements to site programs,” and “the need to incorporate lessons learned, most notably those from Fukushima, addressing severe events, into the Order.”

According to the justification memorandum, the order requires revision to address “conflicts, omissions, deficiencies, and inconsistent interpretations within the existing DOE Order” since its 2005 issuance, as identified “through a series of assessments conducted by oversight entities.” The revision will also incorporate documents from the Department of Homeland Security (DHS) that have been updated since the order was issued, “such as the Incident Command System, the National Response Framework, and the National Incident Management System,” the memo says. It adds that the updated order will provide “more emphasis on emergency management requirements related to severe events” due to “lessons learned from the 2011 Fukushima Daiichi nuclear power plant disaster.”

NNSA spokeswoman Shelley Laver told NS&D Monitor that severe events – natural disasters, fires, or explosions, for example – were previously addressed separately in various DOE memos. This revision, she said, “will pull the severe event actions into the main order” for standardized application at all DOE sites. Laver said another letter outlining the contents of the revision will follow this justification, “and then there’s the actual writing of the revision document.” The publication date of the final revision remains unclear. 

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