NNSA Tech Bulletin Readiness Questions

In order of date of issuance

1st Quarter, 2004

Question #2: Describe the CDNS's involvement in Readiness process and how the office will interface with EH. Will the CDNS replace EH's role in reviewing SNRs, POAs and IPs for Readiness Reviews for NNSA sites?

Per the current DOE O 425.1C, both EH and NNSA have specific responsibilities called out. EH is the OPI for this order per Office of Management Communications, ME-43. As an organization they own the order, guide and associated training curricula. EH currently also represents DOE/NNSA to the DNFSB on readiness issues quarterly. Roll up of EH's observations of the current state of readiness preparations, including common findings across the complex as well as other specific issues as requested by the DNFSB are addressed in these quarterly meetings. DOE Order 425.1C also requires EH to provide feedback to the PSO on various aspects of Readiness Preparations.

I believe the best way to address this issue is to provide a set of additional questions and answers to better describe the rules of the game today, and where NNSA is heading in the near future.

A. What are the requirements?

Answer: Specific sections pertinent to this discussion are:

  • Section 3.a-states this order applies to NNSA
  • Section 4.a.4.c-"Each SNR, including the field office comments and actions, must be forwarded to the PSO, the Office of Corporate Safety Assurance, and the site Lead Program Secretarial Officer, as appropriate.
  • Section 5.c-"…assigns the Deputy Assistant Secretary for Corporate Safety assurance to review and comment on the startup and restart process for nuclear facilities."
    1. Perform independent reviews
    2. Review Site Office and Contractor startup/restart procedures
    3. Independent review of SNRs
    4. Review POAs
    5. Review final report recommendations
    6. Provide dissenting opinions if necessary
    7. Concur on final decision if requested by the Secretary

B. Who is "the Office of Corporate Safety Assurance" referenced in the order?

Answer: EH has reorganized in June 2002 subsequent to this writing and, therefore, while the title is no longer accurate, the position/responsibility to which it has transferred is the Director of the Office of the Deputy Assistant Secretary for Facility Safety (Raymond J. Hardwick, EH-2)

C. What are we doing to satisfy these requirements today?

Answer: Not enough.

First of all, it is recognized the Site Offices and Service Center are performing significant work to implement most of the requirements of this order in support of the actual RA/ORR performance; however, corporately we are failing to meet the full intent of the order.

Some NNSA sites are sending POA and SNR data to Bill Weaver of EH. EH currently fulfills the role as an "independent review" but is not required to approve or even concur on readiness activities. Result is: EH is asking for information from NNSA that it does not always receive. When they do receive information, they perform an "independent review" that often has no audience.

The goal is that NNSA has a process that meets all the requirements of the order and results in improved readiness conditions.

D. What will NNSA be doing?

Answer: CDNS Office will:

  • Assign one FTE, per the staffing plan, to be the NNSA Readiness Review process owner. That person will be the NNSA recipient of all SNR and POA reports as required per the order and he/she will be the single POC to provide related information to EH.
  • Represent NNSA in discussions with DNFSB on this topic.
  • Perform the reviews and comments required by 5.c of the order and communicate those actions to the appropriate Site Office Manager with a copy to EH. Note the CDNS will accomplish this via sampling methodology in lieu of a 100% review of all SNRs/POAs.

SC should perform the following functions:

  • Maintain a cadre of qualified individuals who primary purpose is to act as ORR/RA team leads and support of other NNSA readiness review activities.
  • Maintain a table of all scheduled NNSA RAs/ORRs (via the SNRs) with assigned team leads and provide this as a service to CDNS.

Site Offices should:

Submit SNRs and POAs data per DOE O 425.1C to the CDNS POC (once that position has been filled) with a copy to the SC (for table development) quarterly. Pending staffing of the CDNS office, submit the same data to Bill Weaver of EH.

Fist Quarter 2005

What is the role of the Authorization Authority with respect to startup/restart of nuclear facilities and what is the Authorization Authority's relationship to the ORR team?

In accordance with DOE Order O 425.1C, Startup and Restart of Nuclear Facilities, "the authorization authority has the following responsibilities:

  • Approves Startup Notification Reports (SNRs)
  • Approves both the contractor and DOE Plans of Action (POAs)
  • Designates the NNSA ORR or RA team lead
  • Directs the NNSA ORR or RA to commence when readiness is achieved
  • Directs startup or restart

As delegated by the Secretary, the NNSA Administrator is the Authorization Authority for startup of new hazard category 2 nuclear facilities. Delegation of this authority to the Principal Deputy Administrator and the Deputy Administrator for Defense Programs is being finalized with specific conditions for further delegation.

There has been confusion with respect to the ORR team composition in relation to the Authorization Authority. NNSA ORRs are conducted by teams whose leaders are designated by the Authorization Authority. There is no such thing as a "Headquarters ORR" or "Field ORR." In reality, the site office will perform the majority of the NNSA line management effort including development of SNRs, POAs, and preparation for readiness. Readiness review team leadership and team composition can come from anywhere in NNSA, DOE, or from support service contractors as long as the required independence is achieved.

During readiness reviews and assessments, occasionally issues will be discovered with the documented safety analysis (DSA). For example, a hazard may have not been fully analyzed, or the controls proposed may not apply to all of the bounded accidents in a family of accidents. As a prerequisite to the readiness review, an NNSA Safety Basis Review Team (SBRT) would have already reviewed the DSA, and it would have already been approved by NNSA. So, shouldn't such issues be treated as being outside of the scope of the readiness review?

The short answer is "No." Although it is not the function of the readiness review to duplicate recent independent reviews, any issue that is discovered during a readiness review that affects the readiness of the facility to operate is automatically within scope of the review. Minimum Core Requirement #7 in DOE Order 425.1C treats both the implementation and the adequacy of the DSA. In general, the recent review of the DSA by the SBRT establishes its adequacy for the purposes of the review, and only implementation of the DSA and pre-start conditions of approval need to be explicitly included in the scope of the review. However, if, while reviewing the implementation of the DSA, deficiencies are identified in the approved analysis or the adequacy of approved controls, such deficiencies or inadequacies should be reported as pre-start or post-start findings.

Third Quarter 2005

1. What are the requirements for Startup Notification Reports?

DOE Order 425.1C, Startup and Restart of Nuclear Facilities, requires a Startup Notification Report (SNR) for every startup or restart of a nuclear operation other than routine resumption of operations after a short, planned interruption.

Startups requiring review should be started or restarted using an Operational Readiness Review or properly scoped Readiness Assessment. Routine resumptions of operations can be conducted without a readiness review using normal contractor operating procedures for the facility or activity. Contractor routine procedures should not be developed for the purpose of avoiding a properly scoped Readiness Assessment.

DOE line management procedures must require the contractor to prepare SNRs. SNRs must be submitted at a periodicity specified by DOE (recommended to be quarterly).

Each SNR must project ahead at least one year and update information from previous periods for startups that have not yet occurred and add information for each startup or restart that has been identified since the last report. The SNR is to be approved by DOE.

The procedures should require the following elements:

  1. Minimum information in the SNR for each startup or restart should include the following:
    1. A brief description of the facility or program work
    2. Reason for non-operation (e.g., maintenance or modification, outage, no
    3. program work, new facility, shutdown for safety concerns, etc.)
    4. The approximate date operations were last conducted (for restarts) and the
    5. projected date for the startup
    6. Proposed type of readiness review
    7. Basis or justification for proposed type of readiness review
    8. Proposed authorization authority
  2. Each SNR should be reviewed and approved by DOE field office management. If the startup authority resides with the Program Secretarial Officer (PSO), the field office management should comment and make a recommendation regarding approval.
  3. Each SNR, including the field office comments and actions, must be forwarded to the PSO, the Office of Corporate Safety Assurance, and the site Lead Program Secretarial Officer and/or cognizant Secretarial Officer, as appropriate.
  4. Contractor readiness review action to start or restart operations should not commence until the DOE authorization authority has approved the proposed readiness review process.

The purpose of these reports is to establish early the appropriate authorization authority and appropriate review methodology for the startup/restart. Quarterly reports add new startup/restarts and update previously reported startups and restarts.

Not all NNSA sites are meeting the requirements for SNR development and submittal. SNRs should be submitted at least quarterly to NA-10 and the CDNS (Dick Crowe).

The CDNS office will provide a copy to EH to fulfill that requirement. Many discussions take place concerning the appropriate review methodology (ORR or RA). The SNR is the vehicle for the contractor to justify, in detail, the recommended readiness review.

Some cases have occurred where past practice was the justification for a review recommendation. That past practice needs to be clearly documented with appropriate approvals to be defensible. Early submittal of SNRs will allow resolution of questions prior to planned startups and restarts.

Any questions in this area should be addressed to the Technical Lead for Operations and Readiness (Dick Crowe 301-903-6214, richard.crowe@nnsa.doe.gov).

2. How does NNSA intend to interface with EH in the area of startups and restarts?

DOE Order 425.1C lists several responsibilities for EH including the following:

  1. In coordination with the PSO, perform independent reviews of startup and restart activities as appropriate and provide results of these reviews to DOE Operational Readiness Review team leaders, cognizant operations office managers, and cognizant Secretarial Officers for resolution.
  2. Review and comment on the PSO, operations office, and contractor procedures for startup or restart of nuclear facilities and provide results of these reviews to cognizant operations office managers, and cognizant Secretarial Officers for resolution.
  3. In coordination with the PSO and the field office, perform independent review of contractor SNRs and provide results of these reviews to cognizant operations office managers and cognizant Secretarial Officers for resolution.
  4. Review and comment on contractor and DOE plans of action and implementation plans for startup or restart of nuclear facilities for both readiness assessment and Operational Readiness Reviews, including specification of involvement in startup or restart activities proposed by the Office of Corporate Safety Assurance.
  5. Review and comment on the Operational Readiness Review final report recommendations regarding startup or restart to the DOE authorization authority.
  6. Provide any dissenting opinion on the readiness of a facility to startup or restart to DOE line management or the Secretary if a significant safety concern is not being properly corrected.
  7. If requested by the Secretary, concur in the final decision to startup or restart a nuclear facility.

The Technical Lead for Operations and Readiness (Dick Crowe) in the office of the CDNS is the NNSA corporate interface with EH in fulfilling these responsibilities. The office of the CDNS will provide copies of the site readiness documents to EH and provide any feedback from EH to the sites. This will relieve the sites from the necessity of providing these documents directly to EH. Feedback from EH should be reconciled as appropriate.

Forth Quarter 2005

1. When is it appropriate for Contractors to startup or restart nuclear activities and operations using routine operating procedures, and when should site offices require their contractors to conduct a graded Readiness Assessment instead?

Note: Readiness Assessments (RAs) and Operational Readiness Reviews (ORRs) are only required for Hazard Category 1, 2 or 3 nuclear facilities, and this answer is limited to those facilities. The requirements for when to conduct ORRs are well defined in DOE O 425.1C; this answer is limited to the need for RAs. The following discussion uses the term 'program work' as defined in DOE STD 3006-2000.

The readiness order (DOE O 425.1C) and its accompanying standard (DOE STD 3006-2000) do not specify a bright-line that separates the situations for which site offices should require RAs from the situations for which routine operating procedures should be used for startups and restarts. Both directives say that the contractor must evaluate whether an RA is needed for situations where an ORR is not required. They also say that if a readiness review is needed, it must be at least an RA. They allow that a readiness review is not needed for short and routine shutdowns of program work, but in other situations they relegate to the site office and contractor readiness procedures the task of defining when a readiness review (and hence an RA) is needed. Neither the Order nor the Standard provides much discussion to help guide the choice between using an RA or routine contractor procedures; they focus on the choice between RAs and ORRs.

Deciding whether to conduct an RA or to verify readiness using contractor operating procedures requires some judgment. Obviously, restarting operations after they were routinely shutdown at the end of the day does not require an RA when they start back up the next morning. But, what if other factors arise and the shutdown stretches to a week, then a month or longer? Similarly, if I add a new common hand tool to an ongoing operation then I wouldn't usually expect an RA; but what if the tool isn't common? At what point is an operating procedure no longer adequate and an RA needed?

An aide to judgment when deciding if an RA is warranted is to consider the reason we perform readiness reviews. Readiness reviews are conducted to verify that hardware, personnel and management control systems are ready to safely conduct program work within the bounds of the authorization basis (AB). The bounds of the AB are defined by the commitments made in the AB and for which the site is responsible. AB commitments include the safety basis safety systems, structures and components but are not limited to those controls; AB commitments also include other provisions that have been established to protect the environment, safety and health of workers and the public. When work suspension or other changes call into question the readiness of hardware, personnel and management control systems to safely conduct program work within the bounds established by AB commitments, then management should exercise a formal process to achieve readiness, and should verify that readiness has been achieved prior to conducting program work. If there could be a significant failure to meet AB commitments, or if the ability to conduct program work could be significantly impacted if it turned out that people, hardware or procedures were not ready to perform work safely, then the readiness verification should take the form of an RA. The type of review and the authorization authority is proposed by the contractor and discussed with the Site Office. The final decision on the type of review belongs to the NNSA Site Office Manager, and is formalized through the approval of the Startup Notification Report.

Some sites have formalized tools that they use to help them to make this judgment. Tools such as checklists of high-priority commitments may be helpful as aides to help ensure potential issues are not overlooked when proposing a review type; but these checklists should never be used in place of judgment as a definitive means to assign review levels. Neither is it useful to narrowly define what constitutes a commitment in the AB; it would be incorrect, for example, to restrict the term 'commitments' to just those controls for which Technical Safety Requirements exist. The point of the exercise is to think about the suite of areas for which a site is accountable through the AB or with respect to programs, and to then judge the significance of the impact that a premature startup or restart could have.

As an aside, this same thought process is useful for determining whether the contractor or NNSA should be the Authorization Authority for an RA. For certain RAs, the required Authorization Authority is already specified in DOE STD 3006. In other situations, if the potential impacts to safety, program work, and other AB commitments are small, and the contractor has demonstrated adequate performance of readiness reviews for similar activities, it is appropriate for the contractor to serve as the Authorization Authority if permitted by the Site Office procedure. Otherwise, a higher level authority is warranted. The final decision on the Authorization Authority also belongs to the NNSA Site Office Manager, and is formalized through the approval of the Startup Notification Report.

Fist Quarter 2006

For startup or restart of nuclear facilities that do not require an Operational Readiness Review under DOE O 425.1C, how should site offices and contractors decide how many different types of Readiness Assessments to put into their procedures, and what the requirements are for the different types of procedures?

There is no cookbook method for deciding the different types of Readiness Assessments (RAs) that should exist at all NNSA sites. DOE O 425.1C requires sites to develop RA procedures, but allows flexibility to develop a system that makes sense and addresses particular needs. When developing procedures, readiness personnel should consult section 5.10 of DOE-STD-3006-2000, which contains valuable guidelines and considerations. The guidance in the Standard will not be repeated here, but a couple of additional observations may be helpful, rising out of observations made during reviews of readiness processes.

The first has to do with the development of the Startup Notification Report (SNR). Site procedures should reflect the fact that choosing a review level, no matter how well defined the site process becomes, will always involve application of judgment.

Differences of opinion are to be expected between NNSA and its contractors in this area. For this reason, site procedures should pay particular attention to a robust implementation of the SNR as required by DOE O 425.1C and discussed in section 5.1 of DOE-STD-3006-2000. The SNR serves as a catalyst to ensure adequate discussion and acceptance of the final level of review that is chosen. The discussion provided in the SNR should clearly justify the level of readiness review associated with individual startup. The justification is particularly important. It should demonstrate compliance with any review criteria defined in the site procedures, but also demonstrate that the criteria make sense from a readiness perspective when applied to the particular startup or restart.

As for creating different types of RAs for different situations, it is generally useful to identify a level below which contractor startup procedures are used, and for which no plan of action or implementation plan is required. Other levels of review need only be defined to the extent that they promote agreement on what will be reviewed and why it makes sense. It is generally not useful to pre-define which minimum core requirements should be addressed by specific levels of review-these need to be determined on a case-by-case basis, and are agreed to during the development and approval of the Plan of Action. Site criteria for choosing which type of review to use for a given startup or restart should be derived from the level of readiness that it is reasonable to expect exists in a given situation, and what should be verified by review.