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Doe Standard Review and Approval of Nuclear Facility Safety Basis Documents
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DOE-STD-1104-96
1.4
Issue Origination and Resolution
Traditionally, in reviewing DSAs, both line management personnel and representatives of
other organizations, were known to generate a large number of comments, many of
which were not commensurate with a consistent concept of the DSA and its purpose.
The preparer of the DSA has often born e the sole burden of resolving all such comments
while reviewers have not been held accountable for justifying comments. This often
resulted in forced integration of contradictory comments or comments contrary to a
particular approach or structure for the DSA. To prevent such occurrences, the approval
authority, through the review team leader, maintains authority to determine what issues
are significant and are transmitted to the preparer for formal (i.e., a documented,
traceable, written record) resolution. For this reason, increased "burden of proof" lies
with reviewers to justify the safety significance of an issue through substantiation of its
impact on the safety basis if left unresolved. Each significant issue submitted should be
accompanied by jus tification for its significance. The review team leader, and
subsequently the approval authority, rely upon these justifications in determining the
relevance of all issues.
A significant issue identifies a problem or concern that affects the utility or validity of the
safety basis documentation. Such issues are generally those involving: (1) hazardous
material or energy release with significant consequences to the public, worker, or
environment that will otherwise be left without coverage in the DSA; (2) technical errors
that invalidate major conclusions relevant to the safety basis; or (3) failure to cover topical
material required by DOE regulations, directives, and guidance on DSAs. DSAs
prepared in accordance with 10 CFR 830 use the graded approach in documenting the
facility safety basis. The absence of information in a DSA is not a potential issue unless
that absence adversely impacts the adequacy of the facility safety basis documentation.
For example, DOE-STD-3009 Change Notice No. 2 states that standard industrial
hazards are not generically covered in the DSA. But an issue requiring that a standard
industrial hazard be included in a DSA would be justified if a clear case can be made
there is a potential contributor to a significant release of hazardous material involving that
hazard. If thorough justification of the significance of an issue is not provided and
supported, then the review team leader may refrain from transmitting to the DSA preparer
the issue as significant and requiring resolut ion. Such judgments may be appealed to the
approving authority.
While only significant issues require formal resolution, the review team leader will
typically transmit all issues to the preparer that will improve overall preparation of the
DSA. The preparer may resolve these issues to the extent they enhance the final
product without formal response. In the process outlined by this Standard, the objective
is not to document a large number of issues but to contribute to improving the DSA to
meet the mission established by 10 CFR 830 and the intent of amplifying guidance, (i.e.,
to provide assurance that the DSA appropriately establishes the safety basis of the
facility).
For issues transmitted to the preparer as significant, the preparer formally prepares
resolutions and submits them to the review team leader. The review team leader
transmits proposed resolutions to reviewers originating the issues, who may in turn
respond if a resolution is considered unsatisfactory. All responses are transmitted
through the review team leader, who schedules and arbitrates the process of resolution.
The review team leader may consider proposed resolutions satisfactory in the absence of
timely responses or adequate justification of unacceptability by the issue originator. As a
matter of course, the review team leader ensures that the preparer is formally notified of
acceptable and unacceptable resolutions proposed for significant issues.
6


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