To: From: Ray W... ‘ncan, Stanley, DOE/PASO Ayed FOR MR. RAY DUNCAN'S EYES ONLY Department of Energy Pacific Area Support Office PO. Box 29939 DOE/NV MAR 23 1978 Honolulu, Hawaii 96820 Ray D. Duncan, Assistant Manager for Administration, NV NV SAFETY POLICY AND PROCEDURE - PACIFIC OPERATIONS Pursuant to your verbal request for PASO input on the above subject, there is shown at Enclosure I, a summary of pertinent significant events and actions. Also, there follows my recommendations as to how the present untenable situation could be clarified and improved. PASO Position and Recommendation All NV Divisions and Offices should support NV Pacific Operations to the same extent that NV Operations are supported elsewhere, unless there is a formal delegation or transfer of their responsibility to others. The fact that NV delegates command and control of Holmes & Narver/PTD work forces at Johnston Atoll and Enewetak Atoll to the Defense Nuclear Agency, does not abrogate NV responsibility in any way for the safety of H&N/PTD employees, there employed. This fact, however, does complicate the application of DOE and NV policies and regulations, to JA or Enewetak, because it obviously requires the cooperation and support of the Defense Nuclear Agency. DNA does not have an Office of Safety, per se, but does utilize AFFRI at Enewetak in this capacity. FC/DNA has a Health Physicist on its staff. JA has no direct DNA safety representative, but Enewetak does have apparently fully qualified radiation safety experts. ft appears from the foregoing that some mutually acceptable agreement on safety must be obtained both within NV and with DNA. The alternative of continuing in our present mode of operation is not considered acceptable because it does not ensure compliance with certain safety requirements which perhaps should be considered nonnegotiable by DOE (e.g., (1) acceptable levels of PCB at JA; or (2) acceptable levels of medical care at JA). Therefore, I recommend that an NV Task Force be nominated by the Manager, NV, and tasked with the development, coordination and negotiation of a modification to Contract No. EY-16-C-08-0606, REPOSITORY souscrion BOX No. FOLDER Dez/ PPA se DOELiv JA36_ S49 FY/?Lee77 itonini hs, cas ara