ECA sent the following letter to the Defense Nuclear Facilities Safety Board on April 23, 2020:
Dear Chairman Hamilton and Members of the Defense Nuclear Facilities Safety Board,
On behalf of the Energy Communities Alliance (ECA), I am writing regarding the Board’s recently published Recommendation 2020-01, Nuclear Safety Requirements, as sent to the Department of Energy (DOE) in February 2020. ECA generally agrees with the Defense Nuclear Facilities Safety Board (DNFSB) assessment and
supports efforts to ensure the safety of the public, the workers and the environment. As the only organization representing the local governments and communities that host and are most directly impacted by DOE and National Nuclear Security Administration (NNSA) activities, ECA believes it is critical that these safety assurances remain a priority when creating any regulatory framework. Another critical component for established safety measures is that DOE and DNFSB be on the same page regarding
the regulatory framework, and ECA is concerned that is not currently the case. To that end, we write to request materials for public education and public outreach on Recommendation 2020-01 in order to facilitate community education because the sites that are most impacted should have the clearest understanding of potential regulatory changes.
While DOE has established internal review procedures, the presence of DNFSB as an independent, non-duplicative body adds needed trust for communities supporting federal facilities across DOE’s weapons complex. Although the Board does not possess regulatory authority, ECA believes you all play a critical
third-party role providing information on the actual risk and actions needed to mitigate risk to our communities. ECA supports the Board based on that trusted oversight role but urges DNFSB to more effectively communicate with the communities it seeks to protect and consider the availability of Congressional appropriated funding in its recommendations.
With that goal in mind, ECA is requesting additional information about Recommendation 2020-01 that can be more easily understood by a wider audience. Health and safety oversight are most important to communities, and the public needs to understand any differences in DNFSB and DOE priorities. ECA is concerned that the
absence of an understanding can lead to unresolved and unreported safety issues at DOE sites – something that no one wants to see. A simpler overview is requested, with the intention of distribution among ECA communities.
ECA also is requesting that DNFSB continue to work with DOE/NNSA to develop solutions to problems identified in its reports – especially in regard to safety regulations. The host communities’ impression is that DNFSB and DOE/NNSA’s failure to work together has caused significant project delays and unnecessarily
increased costs. ECA suggests considering as a model the current communication pipeline between state regulators and the Environmental Protection Agency. Because there is a framework to facilitate open communication on environmental issues, when disagreements occur, they can be met with jointly-developed solutions which keeps projects that impact health, safety and national security moving forward.
ECA welcomes the opportunity to discuss our concerns and ways in which can help improve communication and engagement between DNFSB and local communities. If you have any questions or concerns on this matter, please contact ECA Executive Director Seth Kirshenberg at (202) 828-2317.
Sincerely,
Ron Woody
County Executive; Roane County, TN
ECA Chair
