Interactions - doe-std-1104-96

DOE-STD-1104-96

the SER to document the basis and the extent and detail of the review. The primary

focus of DOE oversight of the review process is the basis for the extent and detail of the

review, with secondary focus being the adequate implementation of the review.

Documentation establishing the basis and conduct of the review is maintained for

subsequent demonstration that the review process was complete and adequate.

An important part of planning is selecting the individuals composing the review team.

Members of the review team are typically selected based on technical qualifications,

experience, familiarity with the subject matter, independence from preparation of the

DSA, understanding of DOE's safety assurance strategy (e.g., nuclear safety

requirements), and availability. The review team requires a core team with expertise in

process hazards analysis and accident analysis. The core of the review effort is

assessing the hazard and accident analysis in the DSA because these analyses are the

primary sources of original materi al with which the remainder of the DSA is aligned.

Other personnel with diverse experience in safety and health and facility operations are

not necessarily members of the core team but collectively provide support as needed for

a thorough assessment of the facility safety basis. The extent of support necessary is

generally reflected by the hazard and complexity level of the activities being examined.

Personnel resources may be augmented with available personnel from DOE

Headquarters or unaffiliated Field/Operations Offices. To support single review efforts,

the review team should include representatives from any party responsible for the review

of the DSA and may also include representatives of parties responsible for oversight of

the review and approval to monitor the review process.

1.3

Interactions

DOE has certain fundamental limits on its ability to completely separate the DSA

preparation and review processes because it is responsible for both the operation and

regulation of the facilities for which DSAs are prepared, reviewed, and approved.

Therefore, reviews are not expected to be conducted completely segregated from

preparation of the DSA. Some degree of interaction between the preparation and review

processes is useful in streamlining the review an d approval. This interaction provides the

means by which DOE keeps abreast of issues that arise during development of the DSA

and by which DOE responds to requests from the DSA preparer to assist in resolving

fundamental conceptual issues. It is through such interaction that DOE is afforded the

opportunity to commence research on potential issues in preparation for the official

review.

It is important to maintain a balance in the interaction of the review and preparation

processes. Requests for material outside the provisions of the review plan are made

solely by the review team leader. Reviewers do not directly request draft material from

the preparers. Informal direction of preparation by reviewers is unacceptable.

Tendencies exist for facility cont ractors to view any comments or direction offered by

reviewers as a firm prerequisite for approval. The actual preparation of and changes to a

DSA are the responsibilities of the preparers, not the review team or its members.

Therefore, comments or advice affecting preparation should result from unequivocal

solicitation by the preparer. Even so, the review team leader, as authorized by the

approval authority, is the only authority for originating any official intervention driving the

content and details of a DSA. Any intervention is officially communicated by DOE to the

facility contractor after ensuring that it is crucial to the development of the facility safety

basis and originates from a sound technical foundation (i.e., undergone technically

qualified independent review). Even then, intervention generally takes the form of

guidance or recommendation and is well documented for subsequent reference by the

reviewers during the review.