[Federal Register Volume 60, Number 202 (Thursday, October 19, 1995)]
[Notices]
[Pages 54065-54067]
From the Federal Register Online via the Government Publishing Office [www.gpo.gov]
[FR Doc No: 95-25946]
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DEFENSE NUCLEAR FACILITIES SAFETY BOARD
[Recommendation 95-2]
Safety Management
AGENCY: Defense Nuclear Facilities Safety Board.
ACTION: Notice; recommendation.
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SUMMARY: The Defense Nuclear Facilities Safety Board (Board) has made a
recommendation to the Secretary of Energy pursuant to 42 U.S.C.
2286a(a)(5) concerning Safety Management. The Board requests public
comments on this recommendation.
DATES: Comments, data, views or arguments concerning this
recommendation are due on or before November 20, 1995.
ADDRESSES: Send comments, data, views or arguments concerning this
recommendation to: Defense Nuclear Facilities Safety Board, 625 Indiana
Avenue NW., Suite 700, Washington, DC 20004.
[[Page 54066]]
FOR FURTHER INFORMATION CONTACT:
Kenneth M. Pusateri or Carole J. Morgan, at the address above or
telephone (202) 208-6400.
Dated: October 16, 1995.
John T. Conway,
Chairman.
[Recommendation 95-2]
Safety Management
Dated: October 11, 1995.
The Defense Nuclear Facilities Safety Board (Board) has issued and
the Secretary of Energy has accepted three sets of recommendations (90-
2, 92-5, and 94-5) concerning the use of standards by contractors at
the Department of Energy's (DOE) defense nuclear facilities, and the
level of conduct of operations to be maintained at these facilities.
These recommendations intersect in many of their implications. The
Board now wishes to combine and modify these recommendations into a
form that (1) reflects what it has learned from DOE's response to the
recommendations, (2) more sharply focuses continued activity on the
objectives DOE and the Board seek to achieve, and (3) is more clearly
consonant with the actions which DOE has under way to modify DOE's
system of Orders.
On March 8, 1990, the Board forwarded to the Secretary of Energy
Recommendation 90-2. Briefly paraphrased, it recommended that (1) DOE
identify the particular standards that it considered should apply to
certain designated defense nuclear facilities of DOE, (2) DOE provide
its views of the adequacy of these standards, and (3) DOE establish the
extent to which the standards were being applied to the facilities. The
Secretary accepted this Recommendation on June 11, 1990, and provided
the Board with an acceptable Implementation Plan on November 9, 1994.
The principal product of implementation was to be a set of
facility-specific documents that set forth the applicable standards and
requirements for a selected set of DOE's defense nuclear facilities.
These were termed Standards/Requirements Implementation Documents (S/
RIDs). The S/RID was to contain those requirements considered necessary
and sufficient for ensuring safety in the particular application. These
were to be principally extracted from DOE Orders, appropriate
standards, NRC guides, and similar sources. The S/RID was envisioned as
the basis upon which work controls would be developed and implemented.
This concept has been maturing in the course of its application to
several DOE defense nuclear facilities. Subsequently, in connection
with its internal plans to restructure its system of Orders, DOE has
developed the concept of the ``necessary and sufficient'' set of
requirements at a site or a facility or for an activity. As applied to
safety requirements, we recognize the ``necessary and sufficient'' and
S/RID concepts to be identical. In the following, the identity of the
two will be implicitly understood, although we shall continue to use S/
RID as the preferred term for the documented set of applicable
standards and requirements in agreements between DOE and its defense
contracts. This is the nomenclature found in implementation plans
submitted by DOE to the Board. To avoid confusion, we suggest that DOE
continue uniform use of the term S/RID in this connection.
DOE is to determine the extent to which standards are implemented
through a process of Order Compliance Self-Assessment. This has
generally been accomplished through review of detailed compliance with
the DOE safety Orders of interest to the Board. The practice is to be
followed until S/RIDs are in place, after which time, the issue becomes
compliance with requirements in S/RIDS.
The Board has viewed the Order Compliance Self-Assessment Program
of DOE as an initial activity in the formulation of the S/RIDs. As part
of this compliance self-assessment, DOE required the contractors to
justify in documented form the rationale for judging requirements to be
non-applicable. This procedural requirement has been reported to have
caused the expenditure of more effort than merited to achieve the end
result the Board sought, which was the establishment of the particular
subset of requirements upon which the safety management programs at a
site would be structured. In the recommendations below, the Board seeks
to streamline the process of arriving at an Authorization Basis and
Authorization Agreements with respect to DOE's safety management of its
sites, facilities, and activities. The review and acceptance by DOE of
(1) the hazards assessment of the work contracted, (2) the standards/
requirements identified as appropriate, and (3) safety management
controls committed by the contractor for the work would in effect
constitute, in the view of the Board, a DOE determination of adequacy
relative to sufficiency of the requirements base.
In another action, on August 17, 1992, the Board forwarded its
Recommendation 92-5, which called for establishing certain safety
policies at defense nuclear facilities faced with missions that were
changing in response to the shifting world situation. The principal
features of Recommendation 92-5 can be paraphrased as follows: (1) that
facilities to be used in the longer term in nuclear defense missions or
in cleanup from previous nuclear defense activities should be operated
according to a superior level of conduct of operations, (2) that
certain safety practices be followed at nuclear defense facilities
being restarted after a long period of idleness, and (3) that defense
nuclear facilities designated for various other kinds of use (such as
standby) should be subject to a graded approach of safety criteria and
requirements to be developed. The Board requested that it be informed
on a timely basis of changes in the intended use of DOE's defense
nuclear facilities.
Implicit in the Recommendation was a broader view of conduct of
operations than adherence to written procedures and related activities
directly in support of operations. It encompassed the entire set of
practices used to ensure safety in a facility, and in the operations
conducted therein, extending to coverage implied by the term ``safety
culture.''
On December 16, 1992, the Secretary of Energy accepted
Recommendation 92-5, and forwarded to the Board an Implementation Plan
which the Board accepted on January 8, 1993.
Circumstances affecting DOE's defense programs have continued to
evolve since then, and the view of the future of the defense nuclear
establishment is now different from that in late 1992. Many facilities
then scheduled for restart or standby are now slated for deactivation
and decommissioning. Though the future form of the establishment
continues to be uncertain, the Board believes that the extent of the
changes and other intervening events makes it necessary to bring major
features of its Recommendation 92-5 up to date and in line with the
updating of Recommendation 90-2.
Another important development has been the elaboration of the S/RID
concept into a system view of a standards-based safety management
system.\1\ This has shed further light on such important matters as
permissible variability of safety management at facilities of different
kinds and different levels of risk, and the formal means whereby an
Authorization Agreement
[[Page 54067]]
related to environment, safety and health objectives is incorporated
into contractual terms.
\1\ Fundamentals for Understanding Standards-Based Safety
Management, Joseph J. DiNunno, DNFSB/TECH-5.
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Principles that should guide the structure and use of safety
management, the framework for conduct of operations appropriate to
different cases, the basis for grading of safety management and conduct
of operations, and the application to the important defense nuclear
laboratories of the Department of Energy, are outlined in another
document in the DNFSB/TECH sequence.\2\ The points laid out in DNFSB/
TECH-6 are consistent with those in DNFSB/TECH-5. Although the concepts
and processes discussed in these documents are couched in terms of
radiological hazards, they are more general, and apply as well to
hazards of other kinds. In addition, they offer an appropriate match to
requirements established elsewhere for safety in decommissioning of
facilities, and would serve as a bridge to such operations.
\2\ Safety Management and Conduct of Operations at the
Department of Energy's Defense Nuclear Facilities, DNFSB/TECH-6.
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The Board agrees with the view adopted by DOE in certain pilot
tests presently under way, that the contractor for a site, facility, or
activity should originate the drafting of the Safety Management Plan
and the S/RID with assistance and input as appropriate by DOE. DOE has
the responsibility for determining that the proposed S/RID will ensure
an adequate level of safety, and finally approving it when it is found
to be satisfactory. In the Board's view, an S/RID should be the central
component of the Authorization Agreement which should have contractual
status as part of the agreement with the contractor relevant to
performance of the work authorized for the site, facility, or activity.
In accordance with its statutory directive to review DOE's safety
standards and their implementation, the Board plans to track selected
S/RIDs and the associated Safety Management Programs as they are
developed. The Board will formally review them after their completion
and will provide its comments to DOE in letters to the Secretary or in
the statutory form of recommendations. The Board would normally expect
DOE to have performed its own review with documentation of the results
before being formally provided with the Board's comments.
We recognize that the various DOE organizational units which may be
delegated review and approval authority for S/RIDs and associated
Safety Management Programs may not have enough individuals with
qualifications in the technical specialties required to carry out
effectively the streamlined process being recommended. This means that
technical assistance may need to be retained from elsewhere to
compensate for such personnel deficiencies where they exist. It also
means that DOE may need to augment its own technical expertise so as
not to be obliged to continue indefinitely to rely on technical
assistance from outside DOE.
The Board renews its request that it be informed on a timely basis
of changes in planned use of defense nuclear facilities. In addition,
the Board now wishes to replace Recommendations 90-2 and 92-5. The
schedule agreed to by DOE and the Board for S/RID development and
implementation pursuant to Recommendation 90-2 will be revised and
carried forward as a part of Recommendation 94-5, which is not being
otherwise modified at this time.
Therefore, the Board recommends, that DOE:
1. Institutionalize the process of incorporating into the planning
and execution of every major defense nuclear activity involving
hazardous materials those controls necessary to ensure that
environment, safety and health objectives are achieved.
2. Require the conduct of all operations and activities within the
defense nuclear complex or the former defense nuclear complex that
involve radioactive and other substantially hazardous materials to be
subject to Safety Management Plans that are graded according to the
risk associated with the activity. The Safety Management Plans and the
operations should be structured on the lines discussed in the
referenced documents DNFSB/TECH-5 and DNFSB/TECH-6.
3. Establish a new list of facilities and activities prioritized on
lines of hazard and importance to defense and cleanup programs, to
focus the transition from implementation programs related to 90-2 and
92-5 to this revised development of S/RIDs and associated Safety
Management Plans, following the process of Section I of DNFSB/TECH-6.
4. Promulgate requirements and associated instructions (Orders/
standards) which provide direction and guidance for this process
including responsibilities for carrying it out. The manner of
establishing responsibilities and authorities as currently set forth in
DOE Order 5480.31 (425.1) for Operational Readiness Reviews should
serve as a model for preparing, reviewing, and approving the Safety
Management Programs. The requirement for conformance should be made a
contract term.
5. Take such measures as are required to ensure that DOE itself has
or acquires the technical expertise to effectively implement the
streamlined process recommended.
John T. Conway,
Chairman.
October 11, 1995
The Honorable Hazel R. O'Leary,
Secretary of Energy, Washington, DC 20585
Dear Secretary O'Leary: On October 11, 1995, the Defense Nuclear
Facilities Safety Board, in accordance with 42 U.S.C.
Sec. 2286a(a)(5), unanimously approved Recommendation 95-2 which is
enclosed for your consideration. Recommendation 95-2 deals with
Safety Management.
42 U.S.C. Sec. 2286d(a) requires the Board, after receipt by
you, to promptly make this recommendation available to the public in
the Department of Energy's regional public reading rooms. The Board
believes the recommendation contains no information which is
classified or otherwise restricted. To the extent this
recommendation does not include information restricted by DOE under
the Atomic Energy Act of 1954, 42 U.S.C. Secs. 2161-68, as amended,
please arrange to have this recommendation promptly placed on file
in your regional public reading rooms.
The Board will publish this recommendation in the Federal
Register.
Sincerely,
John T. Conway,
Chairman.
Enclosure
c: Mark Whitaker, EH-9
[FR Doc. 95-25946 Filed 10-18-95; 8:45 am]
BILLING CODE 3670-01-M
