1. Interfacing with the Central Technical Authority and the Chief of Nuclear Safety

Management System: Environment, Safety, and Health

Subject Area: Performance Assurance for Federal Environment, Safety, and Health (ES&H) Functions

Procedure 1. Interfacing with the Central Technical Authority and the Chief of Nuclear Safety

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

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Issue Date:  09/10/2012
SCMS Revision:  2.0

1.0  Applicability

The provisions of this procedure apply to SC staff responsible for oversight of Hazard Category 1, 2, and 3 nuclear facilities, which includes SC Field Office Managers. The purpose of this procedure is to define SC roles and responsibilities and interfaces with the SC Central Technical Authority (CTA) and SC Chief Nuclear Safety (CNS). The Director of the Office of Science (SC‑1) is the respective SC CTA.  The SC CNS provides expertise and assistance to the SC CTA.  Roles and responsibilities of each of these positions are described in U.S. Department of Energy (DOE) O 410.1, Central Technical Authorities Responsibilities Regarding Nuclear Safety Requirements; DOE O 450.2, Integrated Safety Management; and the most recent memo from the Deputy Secretary of Energy regarding the CTAs (see Section 3.0). Nothing in this issuance changes the requirements contained in any Department of Energy (DOE) Directive, Standard, or regulation.

2.0  Required Procedure

If scope is associated with Prime Contract Nuclear Safety Requirements as Defined in DOE O 410.1, go to Step 1

If the scope is associated with Exemptions/Exceptions to Nuclear Safety Requirements, go to Step 8.

If scope is associated with the Interface Between the SC CTA/SC CNS and DOE Headquarters (HQ) SC Deputy Director for Field Operations (SC‑3), go to Step 17.

Prime Contract Nuclear Safety Requirements as Defined in DOE O 410.1
Step 1 SC Field Office Managers ensure that mandatory nuclear safety requirements as defined in DOE O 410.1 are included in new prime contracts and updates to prime contracts. SC Field Office Managers maintain a list of the nuclear safety requirements in each approved prime contract.
Step 2

SC Field Office Managers submit the list of proposed directives/requirements (consistent with DOE O 410.1) for each prime contract to SC‑3 at least 20 working days prior to when contracts are be initiated or updated

NOTE: Recommendations for deletions and additions to the nuclear safety directives are to be included in the listing.

Step 3 SC‑3 reviews, concurs, and provides the list to SC‑1, the SC CTA, and the SC CNS.
Step 4

The CNS advises the SC CTA and SC‑1 on approval of the list.

Step 5 The SC CTA either approves the list or provides feedback to SC organizations for revision until the list can be approved. When the list is approved, the SC CTA notifies SC‑3.
Step 6 SC‑3 notifies the respective SC Field Office Manager of the SC CTA's decision.
Step 7 If approved, SC Field Office Managers use the list for prime contracts. This part of the procedure is now concluded.
Exemptions/Exceptions to Nuclear Safety Requirements
Step 8

SC Field Office Managers ensure that exemptions and exceptions to nuclear safety requirements as defined in DOE O 410.1 are identified by the contractor and submitted to SC Field Offices in prime contracts and updates.  SC Field Office Managers maintain a list of approved exemptions and exceptions to nuclear safety requirements in existing prime contracts.

If applicable, contractors also submit request for approval of deviations from the double contingency principle in operations involving criticality hazards (reference DOE O 420.1B, Change 1, Facility Safety).

Step 9 SC Field Offices review contractor submittals of justifications for exemptions/exceptions.
Step 10

SC Field Office Managers submit the list of exemptions and exceptions to nuclear safety requirements (consistent with DOE O 410.1) with the contractor submittal and SC Site Office recommendations for each prime contract to SC‑3 at least 20 working days prior to when contracts are to be initiated or updated

If applicable, SC Field Office Managers are also to request SC CTA's concurrence on their approval of situations that could result in deviations from the double contingency principle in operations involving criticality hazards (reference DOE O 420.1B, Change 1). 

If an alternate safe harbor is proposed to Table 2 of 10 CFR 830.207, the methodology must be concurred on by the SC CTA and follows a similar review and approval process.

Step 11

SC‑3 reviews, concurs, and provides the list of exemptions and exceptions to SC‑1, the SC CTA, and the SC CNS. 

NOTE: SC‑1 is responsible for approving exemptions to 10 CFR 830.

Step 12

The SC CNS advises the SC CTA and SC‑1 on concurrence/approval of the list.

Step 13 SC‑1 approves/disapproves the exemption/exception.
Step 14

The SC CTA either concurs with the exemptions/exceptions or provides feedback to SC organizations for revision until the list can be concurred upon or a decision is made to not concur. The SC CTA notifies SC‑3 of his or her concurrence or non‑concurrence decision.

NOTE: The SC Director is responsible for approving exemptions to 10 CFR 830.

For deviations from the double contingency principle in operation involving criticality hazards (reference DOE O 420.1B, Change 1), the SC CTA concurs or non‑concurs on the recommendation and provides that input to SC‑1, who then approves or disapproves.

Step 15 SC‑3 notifies the respective SC Field Office Manager of the decision.
Step 16 SC Field Office Managers notify the contractor of approval/disapproval of exemptions/exceptions. This part of the procedure is now concluded.
Interface Between the SC CTA/SC CNS and SC‑3
Step 17

SC Field Offices and SC HQ may request assistance from the SC CNS as needed for:

  • Document reviews,
  • Operational readiness reviews,
  • Readiness assessments,
  • Independent technical reviews,
  • Quality assurance and software quality assurance assessments,
  • Integrated safety management (ISM) verification assessments, and
  • Oversight assessments. 

NOTE: The SC CTA may assign the SC CNS to perform assessments or reviews at SC Field Offices as deemed appropriate.

Step 18

The SC Senior Safety Advisor shall prepare an annual report summarizing the nuclear safety oversight activities by SC for Hazard Category 1, 2, and 3 nuclear facilities and provide the report to the SC CTA.

NOTE: The annual report and quarterly briefings shall enable the SC CTA to maintain awareness of the state of implementation of the SC line management programs, plans, and processes; and contractor assurance systems associated with Hazard Category 1, 2, and 3 nuclear facilities.

Step 19 The SC CTA and SC CNS will communicate identified issues and trends to SC line management, provide advice concerning technical solutions or options, and be able to follow up to ensure proper closure or implementation. This part of the procedure is now concluded.

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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