2. Reviewing and Approving Safety Documents for Nuclear Facilities Downgraded Below Hazard Category 3 Threshold Quantities by Analysis

Management System: Environment, Safety, and Health

Subject Area: Facility Safety Authorization

Procedure 2. Reviewing and Approving Safety Documents for Nuclear Facilities Downgraded Below Hazard Category 3 Threshold Quantities by Analysis

Subject Matter Expert: CAROL SOHN
Management System Owner: PATRICK SMITH
Secondary Management System Owner: KARL MORO

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Issue Date:  09/11/2012
SCMS Revision:  4.0

1.0  Applicability

This procedure applies to Office of Science (SC) Hazard Category 2 and 3 nuclear facilities that have been downgraded to below Hazard Category 3 threshold quantities (TQs) by analysis. This procedure does not apply to facilities which have inventories below the Hazard Category 3 TQs, based on inventory alone (i.e., radiological facilities), unless the SC Site Office has withdrawn the contractor’s authorization to approve these documents (e.g., radiological Auditable Safety Analysis [ASA]). This procedure provides the SC staff with a consistent method to review and approve safety documents for nuclear facilities downgraded to below Hazard Category 3 TQs by analysis and Radiological facilities submitted by contractors.

2.0 Required Procedure

Step 1

The SC Site Office Manager, if applicable, designates a responsible individual to lead the review of safety documentation to downgrade a nuclear facility to below Hazard Category 3 TQs by analysis or safety document for a Radiological facility in which the contractor’s Approval Authority has been withdrawn.

NOTE: Site Office procedures may designate the Review Team Leader (with Approval Authority agreement). This approved designation eliminates the need for Steps 2 and 3.

Step 2
  1. If an individual at Headquarters (HQ) is the Approval Authority, the SC Site Office Manager or designee prepares a memorandum recommending the appointment of the Review Team Leader for the review of safety documentation to downgrade a nuclear facility to below Hazard Category 3 TQs by analysis and submits it to the SC Deputy Director for Field Operations (SC‑3) for signature.

  2. When approval authority has been delegated to an individual in the SC Site Office, the SC Site Office Approval Authority signs the memorandum designating the appointment of the Review Team Leader.

NOTE: The memorandum is normally prepared in advance of the safety basis documentation being submitted for approval.

Step 3

The Approval Authority formally approves the Review Team Leader appointment and provides that information to:

  • The SC Site Office Manager or designee (if an individual at HQ is the Approval Authority) or

  • The Review Team Leader (if an individual in the SC Site Office is the Approval Authority).

NOTE: Safety basis documents to be submitted for DOE approval must be formally transmitted from the contractor to the responsible SC Site Office.

Step 4 The Review Team Leader evaluates the scope of the review effort to determine what, if any, additional resources are required. The Review Team Leader requests support as needed from SC Site Office, Integrated Support Centers (in conjunction with SC Site Office) and HQ.
Step 5 Using a graded approach, the Review Team Leader prepares and submits a review plan to the SC Site Office Manager for approval. Review Team membership should include program representation and other disciplines consistent with the degree of changes in the safety document, nature of the hazards and/or work being requested for approval.
Step 6 The Review Team Members review the safety document, evaluate its technical accuracy and adequacy, and document any comments or issues identified.
Step 7 For nuclear facilities downgraded to below Hazard Category 3 TQs by analysis, the Review Team Members ensure the technical bases and assumptions used to support the facility hazard categorization downgrade are consistent with DOE‑STD‑1027‑92, Change Notice 1, Hazard Categorization and Accident Analysis Techniques for Compliance with DOE Order 5480.23, Nuclear Safety Analysis Reports, and Nuclear Safety Technical Position (NSTP) 2002‑2, Methodology for Final Hazard Categorization for Nuclear Facilities from Category 3 to Radiological.
Step 8

The Review Team Members ensure that the safety document(s) identifies, analyzes, and controls the hazards.

The team also ensures that controls are specified to appropriately maintain the conditions, parameters, and assumptions that form the basis for the downgrade.

Step 9 For safety document approval:
  • If the safety document(s) can be approved, the Review Team Members contributes to the preparation of the Safety Evaluation Report (SER) or SER‑like document (as directed by the Review Team Leader) to document the review and basis for approval.

  • If the safety document(s) cannot be approved, the Review Team Members specifically identify to the Review Team Leader the basis for not approving the document.

Step 10 The Review Team Leader promptly communicates comments/issues generated during the review to the contractor through formal communications from the SC Site Office Manager or designee. The Review Team Leader elevates areas where agreement cannot be reached through the chain of command for resolution.
  • If DOE is unable to approve the submitted documents without substantial clarification and/or numerous conditions for approval, the Review Team Leader notifies the appropriate SC Site Office individual with programmatic responsibility for the facility of the required action and formally transmits the document back to the contractor, with the basis for DOE’s rejection clearly documented.

  • If the safety basis documents can be approved, the Review Team Leader prepares a SER to document the review and basis for approval of the hazard categorization downgrade or SER‑like document to document the review and basis for approval of the safety document for the Radiological facility in which the contractor’s approval authority has been withdrawn.

    NOTE: Although DOE‑STD‑1104‑2009, Review and Approval of Nuclear Facility Safety Basis and Safety Design Basis Documents, provides the SER format and content requirements for the review and approval of Documented Safety Analyses and Technical Safety Requirements, it can be conceptually utilized for documenting the review and basis for approval of these safety documents.

Step 11 For nuclear facilities downgraded to below Hazard Category 3 TQs by analysis:
  • The SC Site Office Manager or designee submits the SER and the safety document for written approval by the Approval Authority.

    1. If the Approval Authority is an individual in the SC Site Office, the submittal can come from the Review Team Leader or Line Manager.

    2. If the Approval Authority is at SC HQ, the SC Site Office Manager or designee prepares a memorandum recommending approval of the safety document with a provision on the memorandum for the Approval Authority to mark as either Approved or Disapproved. The approval recommendation memorandum, SER, and safety basis document are submitted to SC‑3.

  • The Approval Authority reviews the SER and formally approves or disapproves the document. The Approval Authority provides a copy of the approval/disapproval to:

    • The SC Site Office Manager (if an individual at HQ is the Approval Authority) or

    • The Review Team Leader/Line Manager (if an individual in the SC Site Office is the Approval Authority).

For Radiological facilities in which the contractor’s approval authority has been withdrawn:
  • The Review Team Leader submits the SER‑like document to the SC Site Office Manager or designee for approval.

  • The SC Site Office Manager or designee reviews the SER‑like document and approves or disapproves the document.

Step 12 After the safety document is approved, the SC Site Office Manager or designee prepares and formally transmits to the contractor the approval letter with a copy of the SER or SER‑like document. The transmittal letter establishes DOE’s expectations regarding any implementation issues (e.g. changes and/or amendments to the safety documents).
Step 13

The SC Site Office Manager or designee ensures the contractor has properly implemented the safety document requirements.

The SC Site Office Manager or designee ensures that the conditions, parameters, and assumptions that form the bases for the downgrades are protected and linked to an overall inventory control process. The SC Site Office Manager or designee also ensures that the contractor periodically revisits the safety documents to ensure the hazard categorizations remain valid (recommended to be annual).

NOTE: The submitted safety documents for downgrading the nuclear facility to below Hazard Category 3 TQs by analysis (e.g., Final Hazard Categorization Documents) and safety documents for the Radiological facility in which the contractor’s approval authority has been withdrawn (e.g., Auditable Safety Assessment, Health and Safety Plan), the SER or SER‑like document, and supporting documentation associated with DOE’s review and approval of a safety basis document (e.g., review plan, review comments, resolution matrices, transmittal correspondence between the contractor and DOE and between the Approval Authority and the SC Site Office, independent analyses or calculations performed by or for DOE) are quality assurance records and must be controlled and maintained by the responsible SC Site Office organization.

3.0  References


This is the online OFFICIAL SCMS COPY of this file. Before using a printed copy, verify that it is the most current version by checking the Last Major Revision and Last Minor Revision dates (at the bottom of each document) on the SCMS Web site.


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