Top Down Analysis of the Department of Energy s Nuclear Safety Framework

1. James O�Brien, Ashley Ruocco, and Chris Chaves DOE / HSS EFCOG Engineering Practices Working Group Workshop April 2010 Top Down Analysis of theDepartment of Energy�sNuclear Safety Framework

2. 2 Presentation Overview Purpose Method of Analysis Current DOE Nuclear Safety Framework NRC�s Regulatory Framework NASA�s Safety Regulatory Framework Comparison of Frameworks Top-down Analysis Summary

3. 3 Purpose This analysis was performed to support an initiative to Evaluate where improvements in the clarity of DOE requirements can be made. To ensure that the necessary requirements are all contained in the appropriate requirements documents (e.g., in Orders and not in Guides).

4. 4 Method of Analysis Reviewed how other agencies structure their safety requirements Nuclear Regulatory Commission National Aeronautics and Space Administration Evaluate flow down of requirements Initial focus on how the top level objective in DOE�s nuclear safety policy (SEN-35-91) is flowed down into DOE�s nuclear safety Rule, Orders, Guides, and Standards.

5. 5 Current DOE Nuclear Safety Framework Defined in DOE Order 251.1C, Departmental Directives Program, and Order 252.1, Technical Standards Program. A hierarchical set that starts with Policies (that include high level expectations and objectives) and ends with guides and standards (which contain implementation details and standard practices).

6. 6 Current DOE Nuclear Safety Framework(continued) DOE Directives and Technical Standards Hierarchy

7. 7 Current DOE Nuclear Safety Framework(continued) > DOE Order 420.1 covers SC and not very well for SS > Both are identified in DOE Std 1189 for �Integration of Safety Into the Design Process� and 1189 describes Chemical and toxic [Appendix C] > DOE G 420.1-1 doesn�t have any codes/standards listed for SS I&C system design other than standard industrial design that might be specified for a warehouse. > The ISA 84.00.01 standard is not prescriptive. It provides a graded approach to design based on acceptable risk (frequency and consequence of event). > The reliability of an SIS is vastly different than for mechanical or structural systems. Active SIS reliability is determined by random hardware failure rates, design configurations, redundancy, functional test frequencies, and diagnostics. > DOE Order 420.1 covers SC and not very well for SS > Both are identified in DOE Std 1189 for �Integration of Safety Into the Design Process� and 1189 describes Chemical and toxic [Appendix C] > DOE G 420.1-1 doesn�t have any codes/standards listed for SS I&C system design other than standard industrial design that might be specified for a warehouse. > The ISA 84.00.01 standard is not prescriptive. It provides a graded approach to design based on acceptable risk (frequency and consequence of event). > The reliability of an SIS is vastly different than for mechanical or structural systems. Active SIS reliability is determined by random hardware failure rates, design configurations, redundancy, functional test frequencies, and diagnostics.

8. 8 NRC�s Regulatory Framework The NRC�s regulatory framework for licensing of the design and operation of nuclear facilities consists of: Policy Statements: Published in the Federal Register Requirements: Contained in Federal Regulations Implementation Guidance: Contained in Regulatory Guides (available on web) Review Guidance and Criteria: Contained in Standard Review Plans (available on web) In addition, the NRC has technical information contained in NUREGs (e.g., analysis and technical data supporting development of requirements).

9. 9 NRC�s Regulatory Framework(continued) The NRC has established sets of requirements that are broadly organized based upon the type of nuclear material utilized and/or its application. Commercial Nuclear Reactors: The requirements are very prescriptive as they relate to the facility design. For DOE, this is more driven by a hazard and safety analysis. Fuel Manufacturing Facilities: Approach is more closely related to the DOE. The NRC requires (as does DOE) safety assessments that guide the resulting safety design, which are very precisely written. They also have guides which provide acceptable means for meeting the requirements.

10. 10 NASA�s Safety Regulatory Framework The NASA safety regulatory framework consists of a hierarchical set of documents that include: Policy Directives Procedural Requirements Standards and Guides

11. 11 NASA�s Safety Regulatory Framework(continued) The top-level NASA safety document is its Safety Policy Directive, NASA Policy for Safety and Mission Success. This is flowed down to safety requirements in its General Safety Program Requirements document. Note: In the General Safety Program Requirements document, each requirement has a �shall� statement and the requirement is numbered and hyperlinked to a Safety and Mission Assurance Requirements Tracking System.

12. 12 NASA�s Safety Regulatory Framework(continued) NASA�s Safety Regulatory Framework

13. 13 Comparison of Frameworks /Requirements Set The NRC�s relatively simple two-level approach (Requirements and Implementation Guidance) has some advantages over the DOE multiple layer approach of Directives, Rules, and Technical Standards. NRC�s regulatory system includes development of �statement of considerations� is developed that serves as the technical basis/rationale for the requirement.

14. 14 Comparison of Frameworks /Requirements Set (continued) One difference between the NRC and DOE is that DOE is both owner and regulator. DOE has established a higher level of detail in some requirements and guidance, such as for Conduct of Operations. The commercial nuclear industry utilizes guidance in this area from the Institute of Nuclear Power Operations.

15. 15 Comparison of Frameworks /Requirements Set (continued) NASA is also both owner and regulator for safety and has established very detailed requirements, guidance, and technical standards. NASA�s process of specifically identified requirements with a unique identifier appears to be particularly beneficial. Similar to DOE, NASA has a hierarchical framework. However, also similar to DOE, the flow down of requirement sets (e.g., general to specific to detailed guidance) is not clear in some cases.

16. Conclusions to the Comparison of Frameworks /Requirements Set Based on this review of NRC�s and NASA�s approaches to safety policy, DOE will examine its nuclear safety framework by refining requirements and guidance within the new Directives reform initiative. A top-down evaluation will be an integral part of this initiative.

17. 17 Top Down Analysis Began with Nuclear Safety Policy (Secretary of Energy Notice [SEN] 35-91) Will continue with 10 CFR 830, Nuclear Safety Management, and DOE�s Orders (e.g., DOE Order 420.1B, Facility Safety)

18. 18 Top Down AnalysisSEN 35-91 Current Top Level Policy Statement � It is the policy of the Department of Energy (DOE) that the general public be protected, such that no individual bears significant additional risk to health and safety from the operation of a DOE nuclear facility above the risks to which members of the general population are normally exposed. The purpose of this document is to establish the basic nuclear safety policy from which specific safety Rules, Orders, Standards, and other requirements shall follow. � DOE facilities will be designed, constructed, operated, and decommissioned to assure the protection of the public, workers, and the environment.

19. 19 Top Down AnalysisSEN 35-91 Questions/Analysis What is the Policy Statement? Is it consistent with the safety objective in the Atomic Energy Act? Does it flow down to lower-tier requirements? Can it be more succinctly stated?

20. 20 Top Down AnalysisSEN 35-91 Key Elements for Implementing the Policy Management Technical Competence Safety Goals Independent Oversight Safety Culture

21. 21 Top Down AnalysisSEN 35-91 Questions/Analysis Are these current? Do they flow down to lower-tier requirements? Can they be more succinctly stated?

22. 22 Summary DOE evaluated its regulatory framework using insights from a review of the NASA and the NRC frameworks DOE is performing a top-down analysis of its nuclear safety requirements Improve clarity/make sure requirements and guidance in right place Start with Nuclear Safety Policy Continue with Nuclear Safety Rule and Orders

23. Contacts Office of Nuclear Safety Policy and Assistance (HS-21) James O�Brien, Director james.o�brien@hq.doe.gov Ashley Ruocco ashley.ruocco@hq.doe.gov Christopher Chaves christopher.chaves@hq.doe.gov 23