The ORR/RA and the Authorization Basis May 2005 Revision

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The ORR/RA and the Authorization Basis May 2005 Revision Safety Analysis Reports, Technical Safety Requirements, Authorization Agreements, S/RIDs, Basis for Interim Operations, Permits, etc... 2T2L 1

Upon successful completion of this topic, you should be able to: Describe what constitutes a facility’s Authorization Basis. Describe how the Authorization Basis relates to the ORR/ RA. Describe how the ORR/RA checks implementation of the Authorization Basis. 2T2L May 2005 Revision 2 2

The Authorization Basis Authorization Basis means the combination of information relating to the control of hazards at a nuclear facility (design, engineering analyses, and administrative controls) upon which DOE/NNSA depends for its conclusion that activities at the facility can be conducted safely. Basis by which DOE/NNSA accepts the risk associated with permitting the facility or activity to operate. 2T2L May 2005 Revision 3 3

Authorization Basis Those aspects of the design of facility Structures, Systems, and Components (SSCs) and operational requirements relied upon by DOE/NNSA to authorize operation. These aspects are considered to be important to the safety of facility operations. 2T2L May 2005 Revision 4 4

Authorization Basis (continued) The Authorization Basis is described in documents such as: - Facility DSA/SARs/BIOs/HAR/ASA and other safety analyses; - TSRs / OSR / ABCD. Safety Evaluation Reports (SERs). Facility-specific implementing mechanisms to comply with DOE/NNSA Orders, policies, or other contract provisions (infrastructure program). Permits . . . 2T2L May 2005 Revision 5 5

The Directives and Guides to Implement the Nuclear Safety Rule Nuclear Safety Rule 10 CFR 830.200 superceded, but did not invalidate for existing AB documents: DOE 5480.22, Technical Safety Requirements; DOE 5480.23, Nuclear Safety Analysis Reports; DOE 5481.1B, Safety Analysis and Review Systems. Guidance in DOE STDS 3009; 3011; 1120 . . . . DOE Guides 421.1-1/2 (Crit Safety, DSA); 423.1-1 (TSR); 424.1-1 (USQ) . . . Acceptable Methodologies . . . 2T2L May 2005 Revision 6 6

Definition: Safety Analysis A documented process to: Define the work within the scope of Activity or Facility Provide a systematic identification of hazards within a DOE/NNSA operation, activity or facility. Analyze and evaluate potential accidents and their associated risks. Evaluate measures (hardware, procedures, systems) to reduce the probability and/or consequences of potential accidents. Develop and define the engineered (SSC) and Administrative controls. 2T2L May 2005 Revision 7 7

Basis for Interim Operation (BIO) Establishes interim safety basis until SAR and TSRs per O 5480.22 and O 5480 .23 are developed and approved. Single document applying to both O 5480.22/.23. DOE-STD-3011 provides guidance. Establishes interim safety basis. Utilizes existing material (when possible) by reference. 10 CFR 830.200 Limits Applicability: BIO replaced by DSA, or Facility mission complete. 2T2L May 2005 Revision 8 8

Technical Safety Requirements (TSRs) The TSR and its appendices constitute an agreement or contract between the DOE/NNSA and facility operating management regarding the safe operation of the facility. DOE G 423.1-1 Defines Form and Content expectations. Cannot be changed without DOE/NNSA approval. OSRs have similar expectations. Rigorous Implementation Expectations! 2T2L May 2005 Revision 9 9

Technical Safety Requirement Format Safety Limits; Operating Limits: Limit Control Settings (LCS), Limiting Conditions for Operation (LCO); Surveillance Requirements; Administrative Controls. 2T2L May 2005 Revision 10 10

Safety Evaluation Reports (SERs) The DOE/NNSA: document review of an SAR with a written Safety Evaluation Report (SER); impose conditions of approval, such as constraints on TSRs, or alterations to other commitments. Implementation expectations for SER same as DSA/TSR! 2T2L May 2005 Revision 11 11

ORR Focus re: Safety Documentation What is the Authorization Basis for this activity and is it adequately implemented? If a SAR or DSA and TSRs, are they current;? Have all aspects of the Authorization Basis been approved by appropriate authority? Annual updates current? 2T2L May 2005 Revision 12 12

ORR Focus re: Safety Documentation Are the requirements and assumptions of the Authorization Basis implemented? Structures, Systems, Components operable? Surveillances sufficient and current? Modifications controlled, status known? Procedures complete? Infrastructure programs in place? Administrative controls complete? 2T2L May 2005 Revision 13 13

Is the Safety Envelope in Place? All Limits, Controls, and Requirements: Identified; Understood; Implemented; Maintained? Controllers/Managers/Supervisors of Operations must know the condition of their safety envelope! 2T2L May 2005 Revision 14 14

The ORR/RA Role in the Safety Basis The ORR/RA is not the mechanism by which the Authorization Basis is approved. Rather, the ORR/RA team must evaluate the activity/facility/operation against the description, requirements, and assumptions: within the safety envelope; incorporates all of the applicable requirements of the Authorization Basis. Verify accurate and continuous implementation! 2T2L May 2005 Revision 15 15