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| NOEMS Safety Basis |
The Safety Basis Program for nuclear facilities within the Department of Energy (DOE) is comprised of safety basis documents and the procESSes and procedures for developing and keeping these documents current. Safety Basis documents define the facilities and their associated operations, define and analyze the hazards and risks associated with these facilities and operations, and identify and establish hazard controls. These hazard controls involve but are not limited to design features; safety structures, systems, and components (SSCs); and technical safety requirements (TSRs). TSRs include safety limits, operating limits, surveillance requirements, and administrative controls (ACs). ACs are comprised of commitments to safety management programs and Specific Administrative Controls (SACs) for specific accident scenarios., These safety basis documents are maintained current through formal change control, safety analysis, and Unreviewed Safety Question (USQ) procESSes. The principal elements generally associated with the suite of Safety Basis documents include the Documented Safety Analysis (DSA), Technical Safety Requirements (TSRs), the Safety Evaluation Report (SER), and the Unreviewed Safety Question (USQ) procedure. When approved and implemented, these Safety Basis documents establish the compliance to Federal Regulations contained in 10 CFR 830.200, NuclearSafety Management, (the rule) and are the cornerstone of the DOE’s basis for authorizing nuclear-related operations.
ESS Systems Solutions, Inc. (ESS) has acquired an experienced staff of engineers and technical specialists who encompass the full range of skills necESSary to develop, analyze, implement, maintain, and assESS the adequacy of the Safety Basis and supporting elements. ESS has an established record of accomplishment in providing support to succESSful Safety Basis management, from a Preliminary DSA development for new activity construction to full DSA/TSR development; DSA / TSR (i.e., hazard controls) implementation; review and approval of safety basis documents; and assESSment of Safety Basis implementation (e.g., ReadinESS AssESSments and Operational ReadinESS Reviews). ESS has been involved with all programmatic elements leading to succESSful authorization to operate under a new Safety Basis. Key individuals associated with ESS have been involved with the DOE in establishing the philosophy, procESSes, requirements, guidance, and training to be used by the DOE nuclear facility complex for succESSful nuclear safety management. ESS continues to provide instructor and client consultation in Safety Basis development, implementation, and maintenance.
ESS has supported several DOE contractor clients in the development and upgrading of their safety basis documentation to meet the requirements of the rule. ESS has a proven understanding of the concept of “graded approach.” We have succESSfully utilized acceptable techniques to ensure that the rigor and sophistication of analysis and the control of hazards is reflective of the overall hazard presented by the related operation. ESS is also very well versed in the “safe harbor” provisions of the rule, and has assisted many clients with execution of those provisions.
ESS personnel have supported the initial development and revision of DOE standards dealing with several DSA safety harbor methodologies, the DOE review and approval procESS, and Specific Administrative Controls. They have also assisted DOE in responding to Defense Nuclear Facilities Safety Board (DNFSB) concerns and recommendations.
The Unreviewed Safety Question (USQ) procESS provides for a systematic and formal method by which the DOE contractor can make operationally necESSary changes in facility structure and administrative controls without seeking DOE approval, as long as the scope of the change does not exceed the boundaries of the existing approved safety basis. ESS has developed site-specific USQ procedures, assisted in the review and updates to these procedures, and provided specialized training for those individuals who qualify and will be responsible for the management of the USQ procESS.
ESS develops and presents specialized training in the areas of USQ, Safety Basis Implementation, Safety Basis Document Review and Approval, Specific Administrative Controls and Configuration Management. ESS staff, involved since program inception, continues to be instrumental in the development and maintenance of this material (USQ training was initially developed in the early 1990’s) and exclusively delivers this training with individuals familiar with the course development.
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