Management System: Environment, Safety, and Health
Subject Area: Facility Safety Authorization
Procedure 3. Reviewing and Approving Contractor's Unreviewed Safety Question (USQ) Process and Processing Potential Inadequacies of the Document Safety Analysis (PISA)
| Subject Matter Expert: | ROGER CASTEEL |
|---|---|
| Management System Owner: | LARRY KELLY |
| Secondary Management System Owner: | JUSTIN ZAMIROWSKI |
Issue Date: 06/21/2011
SCMS Revision: 3.0
1.0 Applicability
This procedure is to provide the Office of Science (SC) a consistent method for reviewing and approving contractor’s new or revised procedure for its Unreviewed Safety Question (USQ) process and evaluating the contractor’s annual submittal of USQ Determination summaries.
This procedure also provides a consistent method for processing the notifications of Potential Inadequacies of the Documented Safety Analysis (PISAs) and the associated evaluations of the safety of the situations (ESSs) and approving actions by the contractor to remove any operational restrictions initiated upon the discoveries of PISAs.
2.0 Required Procedure
Section 830.203 requires a contractor responsible for a Hazard Category 1, 2, or 3 nuclear facility to submit its procedure to the U.S. Department of Energy (DOE) for approval. Section 830.203 further requires documentation of DOE’s approval in a Safety Evaluation Report (SER). The SER will be used to document DOE’s review and provide the basis for approval of the contractor’s procedure for its USQ process.
For PISAs that are determined to involve USQs, the review and approval of safety basis documents intended to address these PISAs, such as Justifications for Continued Operation (JCOs), USQ Change Packages, etc., are addressed by Procedure 1, Reviewing and Approving of Nuclear Facility Safety Basis Documentation, in this subject area.
For reviewing and approving of contractor’s procedure for its USQ process, go to Step 1.
For evaluating of the contractor’s annual submittal of USQ Determination summaries, go to Step 10.
For processing of notifications of PISAs, evaluating ESSs, and approving actions by the contractor to remove any operational restrictions initiated upon discoveries of PISAs, go to Step 12.
This procedure correlates with Title 10 Code of Federal Regulations (CFR) Part 830, Subpart B, Section 830.203, Unreviewed Safety Question Process (Nuclear Safety Management), latest version.
| Reviewing and Approving of Contractor’s Procedure for its USQ Process | |
| Step 1 | The SC Site Office Manager, if applicable, designates a responsible individual to lead the review of contractor's new or revised procedure for its USQ process.
NOTE: SC Site Office procedures, written agreements, or correspondence may designate the Review Team Leader (with Approval Authority agreement). This approved designation eliminates the need for Steps 2 and 3. |
| Step 2 |
NOTE: The memorandum is normally prepared in advance of the contractor’s procedure 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 (if an individual at HQ is the Approval Authority) or Review Team Leader (if an individual in the SC Site Office is the Approval Authority). NOTE: The contractor’s new or revised procedure for its USQ process submitted for DOE approval must be formally transmitted from the contractor to the responsible SC Site Office. |
| Step 4 | The Review Team Leader performs the following:
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| Step 5 | The Review Team Members perform the following:
NOTE: Contractors that choose to implement the Expert USQ Process and have an approved procedure are expected to enhance their oversight of the Expert USQ Process for the first 1-2 years of implementation. Similarly, Site Offices should increase their oversight of the contractor’s Expert USQ Process for the same time period until proven reliable.
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| Step 6 | The SC Site Office Manager or designee submits the SER and the contractor’s new or revised procedure for written approval from the Approval Authority.
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| Step 7 | The Approval Authority reviews the SER and formally approves or disapproves the document. The Approval Authority provides a copy of the approval or 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). |
| Step 8 | After the contractor’s new or revised procedure for its USQ process 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.
NOTE: The transmittal letter establishes DOE’s expectations regarding any implementation issues. |
| Step 9 | The SC Site Office Manager or designee ensures the contractor has properly implemented its USQ procedure. NOTE: This portion of the procedure is concluded; for Record Retention, go to Step 15 |
| Evaluating of the Contractor’s Annual Submittal of USQ Determination Summaries | |
| Step 10 | The SC Site Office Manager or designee ensures the contractor annually submits a summary of USQ Determinations performed since the prior submission to DOE. |
| Step 11 | The SC Site Office Manager or designee evaluates the adequacy of the summary of USQ Determinations and requests additional information from the contractor as warranted. The SC Site Office Manager or designee should document the results of their review. NOTE: This portion of the procedure is concluded; for Record Retention, go to Step 15. |
| Processing of Notifications of PISAs, Evaluating ESSs, and Approving Actions by the Contractor to Remove Any Operational Restrictions Initiated Upon Discoveries of PISAs | |
| Step 12 | After the SC Site Office is notified of a PISA, the SC Site Office Manager or designee monitors the contractor’s actions to ensure the requirements of 10 CFR 830.203 are implemented in an appropriate and timely manner.
The SC Site Office Manager or designee ensures the contractor:
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| Step 13 | The SC Site Office Manager or designee evaluates the contractor’s actions to place or maintain the facility in a safe condition for appropriateness and directs the contractor to take additional actions if necessary. NOTE: Justifications for Continued Operation (JCOs) offer an alternative to ceasing operations when a condition arises that would otherwise require shutting down the facility. JCOs should be used only as a short‑term, temporary measure until a permanent change to the safety basis document can be developed, approved, and implemented. DOE’s review and approval of JCOs are addressed by Procedure 1, Reviewing and Approving Nuclear Facility Safety Basis Documentation. Recommended format and contents of a JCO are addressed in DOE G 424.1-1B. |
| Step 14 | The SC Site Office Manager or designee reviews the ESS provided by the contractor.
This portion of the procedure is concluded; for Record Retention, go to Step 15. NOTE: The ESS is an assessment of the safety of the situation. For a negative USQD, the ESS provides evidence that the immediate controls placed on the facility or activity to ensure a safe condition are not required and can be removed. For a positive USQD, the ESS provides the basis for how the actions taken (including the implementation of operational restrictions) and/or planned actions, ensure safety. Please reference DOE G 424.1-1B for recommended content of an ESS. |
| Step 15 | The responsible SC Site Office organization must control and maintain the following documents as quality assurance records which include:
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3.0 References
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10 CFR 830, Subpart B, Safety Basis Requirements (Nuclear Safety Management)
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Criteria for Office of Science (SC) Expert Unreviewed Safety Question (USQ) Process Implementation
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DOE G 424.1-1B, Implementation Guide for Use in Addressing Unreviewed Safety Question Requirements
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DOE‑STD‑1104‑2009, Review and Approval of Nuclear Facility Safety Basis and Safety Design Basis Documents
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DOE‑STD‑1183‑2007, Nuclear Safety Specialist Functional Area Qualification Standard
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Procedure 1, Reviewing and Approving Nuclear Facility Safety Basis Documentation
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Unreviewed Safety Question (USQ) Procedure Requirements Checklist
This is not the online OFFICIAL SCMS COPY of this file. Before using this 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.
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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Last Major SCMS Revision: 06/21/2011