Issue Origination and Resolution cont'd

DOE-STD-1104-96

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 regulation 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 information 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

should:

Verify that contractors have a documented process for

o tracking conditions of approval to closure (including any re quired

compensatory measures),

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 incorporated into the approved TSRs prior to operation under the

approved safety basis.