Issue Origination and Resolution - DOE-STD-1104-96

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 borne the sole burden of res olving 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 justification 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 invol ving 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 resolution. 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 leade r, 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 cours e, the review team leader ensures that the preparer is formally notified of

acceptable and unacceptable resolutions proposed for significant issues.