Reviewers or the preparer of the DSA may appeal the disposition of an issue by the
review team leader to the approval authority. The approval authority determines the final
disposition of issues as it is the ultimate responsibility of the approval authority to achieve
a defensible position for the final product (i.e., determine when resolution is adequate).
Neither a reviewer nor the preparer has veto power over ultimate resolution or disposition
of an issue and neither need be satisfied with the final resolution. The review team
leader ensures that final disposition of significant issues is documented (i.e., traceable,
written record), including minority opinions and dissenting views.
As stated in 10 CFR 830.202, contractors must incorporate in the safety basis any
changes, conditions, or hazard controls directed by DOE. The regulat ion also states that
the SER must document the basis for approval of the safety basis for the facility including
any conditions of approval. Documenting directed changes and conditions of approval in
the SER provides a way to address inadequacies in the safety basis that are not
significant enough to warrant rejection of the safety basis but which need to be
addressed. Section 2.6 provides guidance on what constitutes an appropriate condition
of approval for DSAs. Section 4. 11 presents guidance on inform ation to be documented
in the SER for each condition of approval.
To ensure adequate tracking and closure of conditions of approval DOE site office staff
· Verify that contractors have a documented process for
o tracking conditions of approval to closure (including any required
o verifying satisfactory closure of the condition of approval,
o notifying DOE when a condition of approval has been satisfied, and
o managing any conditions of approval until they are closed;
· Ensure that when a condition of approval is satisfied the basis for closure is
documented in the next update of the DSA and the closure of the condition of
approval is noted in the DOE approval of that update of the DSA; and
· Periodically assess the closure and status of conditions of approval, as well as
the contractor tracking process.
TSRs identify the limits, controls, and related actions that establish the specific
parameters and requisite actions for the safe operation of a nuclear
facility/activity/process. Consistent with 10 CFR 830.202 the SER may direct changes or
impose additional hazard controls to be applied to the TSRs before operation, but it is not
appropriate to specify temporary conditions to be applied to TSRs. These directed
changes must be incorpor ated into the approved TSRs prior to operation under the
approved safety basis.