Facility Safety Authorization Roles and Responsibilities

Management System: Environment, Safety, and Health

Subject Area: Facility Safety Authorization


Exhibit 1: Facility Safety Authorization Roles and Responsibilities


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

The table below represents the high‑level responsibilities of SC managers and employees associated with the review and approval of nuclear, radiological and accelerator safety documentation in their work.

Roles

Responsibilities

Under Secretary for Science (USS)

When delegated from the Secretary, approves the initial startup of new Hazard Category 1 and 2 nuclear facilities.

Science Central Technical Authority (CTA)

For Hazard Category 1 and 2 nuclear facilities and other high‑hazard facilities:

  1. Maintains awareness of the implementation of authorization agreements as necessary to evaluate the adequacy of safety controls and implementation.

For high consequence accelerator facilities and modules:

  1. Maintains operational awareness to ensure that the U.S. Department of Energy’s (DOE’s) safety policies and requirements are adequate and properly implemented.

  2. Maintains awareness of the content of applicable DOE line oversight programs, plans, and processes, and contractor assurance systems by monitoring, evaluation and trend analyses, and by participation in oversight activities.

  3. Maintains awareness of the state of implementation of these line management programs, plans, and processes, and contractor assurance systems by monitoring associated assessment reports.

Director, Office of Science (SC Director) (SC-1)

Approval Authority for Hazard Category 1, 2, and 3 nuclear facilities safety basis documentation has been specifically delegated in writing to the Deputy Director for Field Operations (DDFO) (SC-3) per January 26, 2012 memorandum from the SC Director. Some additional delegations have been made to Site Office Managers beyond SC-3. See current delegations at http://scms.sc.doe.gov/Reports/DelegationsList.cfm

  1. Approves exemptions to 10 CFR 830, Subpart B for SC Hazard Category 1, 2, and 3 nuclear facilities. This authority cannot be delegated.

  2. Approval Authority for alternate safe harbor methodologies for Hazard Category 1, 2, and 3 nuclear facilities following Office of Health, Safety & Security (HSS) concurrence has been specifically delegated in writing to the Deputy Director for Field Operations (DDFO) (SC-3) per January 26, 2012 memorandum from the SC Director. See current delegations at http://scms.sc.doe.gov/Reports/DelegationsList.cfm.

Startup Authorization Authority for:

  1. Initial startup after conversion of an existing facility to a new Hazard Category 1 or 2 nuclear facility with a new DSA and TSRs when delegated.

  2. Restart of facility, activity or operation that has upgraded its hazard categorization to hazard category 1 or 2, when delegated.

  3. Restart of a Hazard Category 1 nuclear facility, activity, or operation following extended shutdown (>12 months).

  4. Approval of Startup Notification Reports when SC-1 is the Startup Authorization Authority; otherwise make recommendation regarding approval.

  5. Approval of Startup Notification Reports when SC-1 is the startup Authorization Authority; otherwise make recommendation regarding approval.

  6. Reviews and approves exemptions to DOE O 425.1D for SC facilities.

For an accelerator facility (or module) that have the potential for more than minor onsite or more than negligible offsite impacts to workers, the public or the environment:

  1. Appoints Review Team Leader for accelerator safety documents.

  2. Approves documentation of DOE reviews and bases for approval and associated Accelerator Safety Envelopes (ASEs), ASE revisions, and Unreviewed Safety Issue (USI) change packages.

  3. Approval Authority for commissioning, startup, and restart of accelerator facilities and modules and exemptions from the requirements of DOE O 420.2C.

SC Deputy Director for Field Operations (DDFO), Office of Science (SC‑3)

The SC DDFO is the Approval Authority for Hazard Category 1, 2, and 3 nuclear facilities safety basis documentation per the delegation letter from the SC Director to the Deputy Director for Field Operations (DDFO) (SC-3) per January 26, 2012 memorandum. Some additional delegations have been made to Site Office Managers beyond SC-3. See current delegations at http://scms.sc.doe.gov/Reports/DelegationsList.cfm.

  1. Ensures that all SC sites have approved Documented Safety Analyses (DSAs), Technical Safety Requirements (TSRs) and Safety Evaluation Reports (SERs) for its Hazard Category 1, 2, or 3 nuclear facilities and onsite transportation actives meeting Hazard Category 2 and 3 nuclear facilities criteria.

  2. Appoints Review Team Leader for safety basis documents and contractor’s new or revised procedure for its USQ process.

  3. Approves SERs and associated DSAs, TSRs, Justification for Continued Operations (JCOs), Unreviewed Safety Question (USQ) change packages and other safety documents for Hazard Category 1, 2, or 3 nuclear facilities and facilities downgraded to below Hazard Category 3 Threshold Quantities by analysis.

  4. Approves SERs and associated Transportation Safety Documents (TSDs), USQ change packages, and other safety documents for onsite transportation activities meeting Hazard Category 2 or 3 nuclear facilities criteria.

  5. Approves SERs and contractor’s new or revised procedure for its USQ process.

  6. Approves requests for any changes to due dates related to the review and approval of a safety basis document for Hazard Category 1, 2, or 3 nuclear facilities that extends beyond the established time frame.

  7. Assists and oversees the Site Offices of Hazard Category 1, 2, and 3 nuclear facilities implementation of their safety basis responsibilities to ensure compliant and effective programs.

For startup and restart of Hazard Category 1, 2, and 3 nuclear facilities serves as the Startup Authorization Authority for:

  1. Newly constructed Hazard Category 3 nuclear facility with a new DSA and TSRs.

  2. Initial startup of a newly constructed Hazard Category 1, 2 or 3 nuclear activity or operation with a new DSA and TSRs that is commensurate with the DSA approval authority.

  3. Initial startup after conversion of an existing facility to a new Hazard Category 3 nuclear facility with a new DSA and TSRs.

  4. Restart of facility, activity or operation that has upgraded its hazard categorization to hazard category 3.

  5. Restart of a Hazard Category 2 nuclear facility, activity, or operation following extended shutdown (>12 months).

  6. Restart following shutdown because of substantial process, system or facility modifications of a Hazard Category 1 or 2 nuclear facility, activity or operation. Restart of a Hazard Category 1 nuclear facility following shutdown due to a violation of a safety limit.

  7. Approval of Startup Notification Reports when SC-3 is the Startup Authorization Authority; otherwise make recommendation regarding approval

For an accelerator facility (or module) that have the potential for more than minor onsite or more than negligible offsite impacts to workers, the public or the environment, as delegated by the SC Director:

  1. Appoints Review Team Leader for accelerator safety documents.

  2. Approves documentation of DOE reviews and bases for approval and associated ASEs, ASE revisions, and USI change packages.

  3. Approval Authority for commissioning, startup, and restart of accelerator facilities and modules and exemptions from the requirements of DOE O 420.2C.

Ensures through staff the implementation of this subject area and its procedures by the SC Site Offices.

SC Senior Nuclear Safety Advisor (SNSA)

The SC SNSA:

  • Ensures that Site Offices have authorization agreements for the appropriate facilities.

  • Ensures implementation by Site Offices of this subject area and its procedures.

  • Ensures delegations of approval authority for safety basis documentation and Startup Authorization Authority are appropriate,

  • Ensures that candidates are technically qualified and their organizations possess or have access to sufficient staff with necessary qualifications and experience,

  • Ensures organizations have proper processes and procedures for the review and approval of safety basis documentation,

  • Ensures that compensatory measures are identified for situations where candidates do not fully meet established criteria,

  • Prepares delegation letters and obtains the necessary signatures,

  • Conducts an assessment every two or three years to verify the individuals with delegated approval authority and their organizations maintain the necessary capability and capacity to carry out their responsibilities.

  • Reviews safety basis and startup restart products for adequacy.
  • Reviews Safety Basis Information System (data) periodically.

SC Site Office Managers

Note that this list is dependent upon if the Approval Authority has been delegated

  1. When delegated Approval Authority by SC‑3, approves SERs and associated DSAs, TSRs, JCOs, USQ change packages, TSDs, USQ procedure and other safety documents for nuclear facilities safety basis. If the Approval Authority is at Headquarters (HQ), transmits the request for approval (including the contractor safety basis document and corresponding SER) to the HQ Approval Authority.

  2. Prepares SERs and makes recommendations to the Approval Authority for associated DSAs, TSRs, JCOs, TSDs, USQ change packages and other safety documents for Hazard Category 1, 2, or 3 nuclear facilities, facilities downgraded to below Hazard Category 3 Threshold Quantities by analysis, and onsite transportation actives meeting Hazard Category 2 and 3 nuclear facilities criteria.

  3. Prepares SERs and makes recommendations to the Approval Authority for new or revised contractor’s procedure for its USQ process.

  4. Prepares and provides input to the Safety Basis Information System on a quarterly basis (March, June, September, and December each year) SBIS specific to their nuclear facilities (Reference DOE O 231.1B, Environment, Safety and Health Reporting).

  5. Ensures that contractors develop safety basis documentation consistent with the Approval Authority’s expectations.

  6. Establishes a management process consistent with regulatory and Departmental expectations for the review and approval of safety basis documents and that also addresses the following requirements:

    • Timeframes for reviewing and approving safety basis documents consistent with the approval authority’s expectations;

    • Documentation of the review and basis for approval in the SER;

    • Approval of SERs and their corresponding safety basis documents, including transmittal of recommendations for approval to the approval authority if approval has not been delegated;

    • Transmittal of comments/issues and approvals to the contractor, through the Contracting Officer’s Representative;

    • Prompt identification, proper reporting, and timely correction of safety basis document implementation issues;

    • Maintenance of a list of Hazard Category 1, 2, and 3 nuclear facilities, facilities downgraded to below Hazard Category 3 Threshold Quantities by analysis, and onsite transportation actives meeting Hazard Category 2 and 3 nuclear facilities criteria and their corresponding safety basis documents; and

    • Evaluation of contractor’s annual summary report for USQ determinations performed since its last submittal.

  1. Maintains a sufficient number of qualified staff to review safety basis documents and prepares SERs in conjunction with resources available from the Integrated Support Centers and DOE‑HQs.

  2. Provides guidance to contractors concerning safety basis issues, when necessary.

  3. Reviews submitted safety basis documents and new or revised contractor’s procedure for its USQ process for technical accuracy and compliance with 10CFR830 and established DOE requirements, within the established timeframes, and document in the SER the results of the reviews.

  4. Ensures contractor submits annually to DOE a summary of USQ Determinations performed since the prior submission and evaluates the adequacy of the summaries.

  5. When made aware of a Potential Inadequacy in Safety Analysis (PISA), monitors the contractor’s actions to place or maintain the facility in a safe condition, appropriately notify DOE, perform a USQ determination and notify DOE promptly of the results, and complete a EOS and submit it to DOE prior to removing any operational restrictions; evaluates actions to ensure they are appropriate and directs additional actions if necessary; reviews the USQ determination and directs changes if warranted; and reviews the EOS.

  6. Resolves issues, comments and differing technical opinions that cannot be satisfactorily resolved by the reviewers.

  7. Assesses contractor safety basis processes and activities.

  8. Reviews proposed exemption requests and alternate safe harbor methods, and provides recommendations and submits to the SC Director.

  9. Ensures safety documents, new and revised contractor’s procedure for its USQ process, SERs, and associated review and approval documentation are controlled and maintained as quality assurance records.

For Radiological Facilities, the Site Office Manager is the Approval Authority when the DOE Site Office has withdrawn the contractor’s authorization to approve its own radiological facility safety basis documents.

For startup and restart of Hazard Category 1, 2, and 3 nuclear facilities:

  1. Determines and ensures the contractor determines if the appropriate type of readiness review is required for startup or restart of SC nuclear facilities using the requirements from DOE O 425.1D.

  2. Serves as the Startup Authorization Authority for startups and restarts for which ORRs/RAs are required if a field official deemed an ORR/RA appropriate.

  3. Reviews and approves each SNR from site’s contractor(s). Provides comments and makes a recommendation regarding approval of SNRs to SC‑Headquarters when the Startup Authorization Authority resides at Headquarters.

  4. Forwards SNRs with Site Office comments and actions/approval to the SC-3, HSS, and the SC Central Technical Authority as appropriate.

  5. For ORRs/RAs, requires the contractor to prepare SNRs, plans of action, ORRs/RAs and final reports. Prepares as appropriate DOE plans of action, ensures ORR team leaders prepare ORR Implementation Plans and final reports. Ensures resolution of all findings from the ORRs are documented and maintained with plans of actions, implementation plans and final reports.

  6. For DOE ORRs/RAs, develops the breadth of the ORR/RA and documents it in the Plan of Action.

  7. For ORRs/RAs, ensures the contractor and DOE ORR/RA Plans of Action are approved by the appropriate Startup Authorization Authority. Ensures that the contractor’s Plan of Action specifies the prerequisites for starting the contractor’s ORR and prerequisites address each of the core requirements of DOE O 425.1D. Ensures the DOE Plan of Action specifies additional prerequisites. Ensures the DOE and contractor Plans of Action are provided for review and comment to HSS.

  8. Ensures that contractor management appoints review team leaders in accordance with the qualifications and training requirements of DOE O 425.1D.

  9. Ensures that ORR/RA teams do not include senior members from offices assigned direct line management responsibility for the work being reviewed unless the startup authorization authority has approved an exemption.

  10. Ensures that the contractor’s ORR team determines the criteria and review approaches to be used for their review based on the approved breadth given in their Plan of Action.

  11. Ensures that the review team (both DOE and contractor) documents the criteria and review approaches in their ORR Implementation Plans.

  12. Ensures that the contractor’s ORR team leader approves their implementation plan to conduct the ORRs.

  13. Requires the DOE and contractor POAs, implementation plans, readiness to proceed memoranda and final reports be provided to the HSS, the SC Central Technical Authority and SC-3 for review and comment.

  14. Ensures all actions required for an ORR/RA startup or restart are completed with the exception of a manageable list of open pre‑start findings.

  15. Ensures that actions are documented that verify Site Office and contractor readiness, including review of closure of contractor ORR/RA findings, assessments of completion of defined prerequisites and other assessments performed to ascertain readiness.

  16. Ensures the DOE ORR/RA team leader prepares and approves a final report that documents the results of the ORR/RA and makes a conclusion as to whether startup or restart of the nuclear facility can proceed safely.

  17. Ensures the mechanism for closure of DOE ORR findings includes the following: (1) development of plans of actions approved by DOE to correct the findings. Action plans must provide evaluation of any overall programmatic deficiencies and root causes; (2) documentation of completion of response actions responding to the findings in a closure package. Closure packages must include a brief description of actual corrective actions taken and reasons for concluding that closure has been achieved; (3) DOE verification of closure of pre‑start findings.

  18. Ensures the contractor has satisfactorily resolved all pre‑start findings of the DOE ORR prior to the startup or restart of the nuclear facility.

  19. Establishes procedures for readiness reviews consistent with DOE O 425.1D.

  20. Ensures contractors procedures gain Site Office concurrence prior to implementation of the order These procedures must require submittal of a startup notification report to obtain approval to use an RA/ORR and preparation of a formal Plan of Action that includes, as a minimum, the breadth of the assessment, team leader designation, and prerequisites for the assessment. Ensures the SNR and Plan of Action are approved by the Startup Authorization Authority.

  21. Ensures that the core requirements consistent with DOE O 425.1D, are applied when developing an ORR and an RA.

  22. Ensures that the core requirements applicable to Site Office personnel have been evaluated and documented in the DOE Plan of Action.

  23. Ensures that Site Office and contractor procedures are consistent with DOE O 425.1D.

  24. Maintains a sufficient number of qualified staff to provide readiness activities expertise to the Site Office.

For facilities which have Authorization Agreements:

  1. Determines which facilities should have authorization agreements.

  2. Maintains authorization agreements with the contractor responsible for facilities that are designated to have authorization agreements.

  3. Initiates update of authorization agreements with the contractor as necessary.

  4. Ensures implementation of authorization agreements are verified annually.

  5. Ensures violations of authorization agreements are properly reported.

  6. Ensure authorization agreement records are properly retained as Quality Assurance records.

For accelerator facilities and modules:

  1. Ensures the contractor appropriately applies the graded approach in the development of accelerator safety documents; establishes the requirement that any activity violating the ASE must be terminated immediately and the Site Office notify; establishes and implements an effective internal review and approval process for accelerator safety documentation; and keeps the Site Office aware of Safety Assessment Document (SAD) preparation status and proposed changes.

  2. Ensures the contractor has properly implemented the accelerator safety documentation.

  3. Ensures accelerator safety documents, documentation of DOE reviews and bases for approval, and associated review and approval documentation are controlled and maintained as quality assurance records.

For an accelerator facility (or module) that have the potential for more than minor onsite or more than negligible offsite impacts to workers, the public or the environment, reviews ASEs, ASE revisions, USI change packages and accompanying SADs; prepares documentation of DOE reviews and bases for approval, and obtains approval of the ASEs, ASE revisions, USI change packages, and documentation of DOE reviews and bases for approval from the Approval Authority.

For an accelerator facility (or module) that do not have the potential for more than minor onsite or more than negligible offsite impacts to workers, the public or the environment, reviews ASEs, ASE revisions, USI change packages and accompanying SADs; prepares documentation of DOE reviews and bases for approval, and approves the ASEs, ASE revisions, USI change packages, and documentation of DOE reviews and bases for approval.

For small non‑complex accelerator facilities and modules with the potential for only local work area impacts (DOE G 420.2‑1, Table 1), ensures the contractor appropriately implements the applicable standards and guides.

For startup and operation of accelerator facilities and modules:

  1. Approves the start of commissioning for an accelerator facility (or module) that does not have potential for more than minor onsite or more than negligible offsite impacts to workers, the public or the environment after evaluating the ASE, accelerator readiness review (ARR), and SAD and determining that a specific ASE will appropriately bound commissioning; that an appropriate ARR was conducted; and that the risks as analyze in the SAD are acceptable when commissioning is conducted within the specified ASE.

  2. Approves start of routine operation for an accelerator facility (or module) that does not have potential for more than minor onsite or more than negligible offsite impacts to workers, the public, or the environment after evaluating the ASE, ARR and SAD and determining that the ASE will appropriately bound routine operation; that an appropriate ARR was conducted; and that the risks as analyzed in the SAD are acceptable when routine operations are conducted within the specified ASE.

  3. After ensuring that an appropriate ARR was conducted and that the risks as analyzed in the SAD are acceptable when commissioning is conducted within the specified ASE, recommends to the SC Director approval for start of commissioning activities for an accelerator facility (or module) that has the potential for more than minor onsite or more than negligible offsite impacts to workers, the public, or the environment.

  4. After ensuring that an appropriate ARR was conducted and that the risks as analyzed in the SAD are acceptable when routine operations are conducted within the specified ASE, recommends to the SC Director approval for start of routine operations for an accelerator facility (or module) that has the potential for more than minor onsite or more than negligible offsite impacts to workers, the public, or the environment.

  5. Approves restart of an activity at an accelerator facility after shutdown that was ordered by a Site Office Manager because of an USI, ASE violation, or other safety concern.

  6. Approves exemptions from requirements of DOE O 420.2C for an accelerator facility or module that does not have the potential for more than minor onsite or more than negligible offsite impacts to workers, the public or the environment.

  7. Ensures that the Contractor Requirements Document of DOE O 420.2C or alternative standard (consistent with the terms of the laws, regulations, and DOE directive clause of the contract) is incorporated into the contract of each affected site/facility management contractor through the cognizant contracting officer.

  8. Implements the site office responsibilities of this procedure.

Safety Basis Review Team Leader

  1. Prepares review plan using a graded approach, and submits to the Approval Authority for approval.

  2. Promptly communicates comments/issues through the Site Office generated during the review to the contractor through formal communications. Elevates areas where agreement cannot be reached through the chain of command for resolution.

  3. For Hazard Category 1, 2, and 3 nuclear facilities, facilities downgraded to below Hazard Category 3 Threshold Quantities by analysis, and onsite transportation actives meeting Hazard Category 2 and 3 nuclear facilities criteria, prepares an SER (or coordinates the review team’s input on the SER) to document the review and basis for approval of safety basis documents in accordance with DOE‑STD‑1104‑2009, Review and Approval of Nuclear Facility Safety Basis and Safety Design Basis Documents.

  4. For accelerators, prepares documentation, or coordinates the review team’s input on the documentation, to document the review and basis for approval of submitted documents

Readiness Review Team Leader Team Leader

  1. Selects team members and documents qualifications of ORR/RA Review Team Members.

  2. Determines the criteria and review approaches to be used for their review based on the approved breadth given in the DOE Plan of Action.

  3. Prepares and approves the DOE implementation plan to conduct the ORRs.

  4. Conducts the readiness review consistent with the DOE implementation plan.

  5. Prepares and approves the final readiness review report.

  6. Ensures the readiness review report documents the results of the readiness review and makes a conclusion as to whether startup or restart of the nuclear facility can proceed safely.

  7. Ensures there is a lessons learned section of the final readiness review report

  8. Submits the final report to the startup authorization authority to be used as a basis to grant approval of the startup or restart of the nuclear facility. A copy of the final report must be provided to the HSS, SC-3 and the SC CTA for review and comment.

Integrated Support Center (ISC) Managers

  1. Provide expertise as requested to Site Offices and DOE‑HQ associated with safety basis reviews, Operational Readiness Reviews, Readiness Assessments, and inquiries.

  2. Maintain a sufficient number of qualified staff to review safety basis documents, prepare SERs, SER‑like documents, and documentation of DOE reviews and bases for approval and provide readiness activities expertise to the Site Offices and DOE‑HQ.

U.S. Department of Energy Headquarters (DOE‑HQ) Subject Matter Experts

  1. Provide expertise as requested to Site Offices and DOE‑HQ associated with safety basis reviews, Operational Readiness Reviews, Readiness Assessments, and inquiries.

  2. Maintain a sufficient number of qualified staff to review safety basis documents, prepare SERs, SER‑like documents, and documentation of DOE reviews and bases for approval and provide readiness activities expertise to the Site Offices and DOE‑HQ.


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.

Last Major SCMS Revision: 09/11/2012