Improving DOE Participation in the Voluntary Consensus Process

Improving DOE Participation in the Voluntary Consensus Process Garrett Smith Director Office of Nuclear Safety DOE Standards Executive

Presentation Objectives • • Overview of DOE and Safety Framework Unique DOE Characteristics DOE’s Role as Regulator and The “Law” Improving DOE Participation in the Voluntary Consensus Process Office of Environment, Health, Safety and Security 2

DOE: Massive, Complex, Unique DOE Lab and Site Locations • Eighty-five major laboratories and sites made up of thousands of individual facilities • Varied and complex operations at over 150 Nuclear Facilities • Over 100, 000 Federal and contract employees • Significant quantities of Plutonium and enriched Uranium • Large quantities of radioactive/mixed waste, chemicals and other hazardous materials Legend Operations Offices Production/Cleanup Laboratories Field Offices Site or Project Offices Special Purpose Sites Power Administrations Service Business Center Office of Environment, Health, Safety and Security 3

Nuclear Safety Organization Relationships Facility Owner / Operator Secretary of Energy Nuclear Energy Science Environmental Management Defense Nuclear Facilities Safety Board Enterprise Assessments REGULATOR Environment Health, Safety and Security National Nuclear Security Administration Defense Nuclear Facilities Office of Environment, Health, Safety and Security 4

The Office of Nuclear Safety… …develops and maintains DOE specific Policy, and requirements for nuclear safety basis, facility design, nuclear safety management programs, Quality Assurance and nuclear material packaging. We seek to strengthen cooperation, expand our technical competence, and be a change agent for more effective and efficient nuclear safety and quality assurance policy. Office of Environment, Health, Safety and Security 5

Office of Nuclear Safety Portfolio Nuclear Safety Basis & Facility Design • • • Nuclear Safety Analysis Hazard Categorization Accident Analysis Beyond Design Basis Events Technical Safety Requirements Unreviewed Safety Questions Facility / Safety System Design Fire Protection Natural Phenomena Hazards Conduct of Engineering Quality Assurance & Nuclear Safety Management Programs • • • Quality Assurance Software Quality Assurance HEPA Filter Testing Program Commercial Grade Dedication Suspect/Counterfeit Parts Configuration Management Technical Standards Program Conduct of Operations Operational Readiness Nuclear Material Packaging Office of Environment, Health, Safety and Security 6

Safety Framework Implementation Regulations Directives Technical Standards 10 CFR 820 10 CFR 835 10 CFR 830 10 CFR 851 Over 65 Orders, Policies, Manuals, and Guides that relate to safety and quality assurance Over 145 active DOE Standards and Handbooks and 2000 Voluntary Consensus Standards Office of Environment, Health, Safety and Security 7

Complex Wide Realities § DOE is both the Owner and the Regulator for a large fleet of nuclear facilities. § DOE is building new nuclear facilities. § DOE facilities are often unique and one-of-a-kind (Standardization is a challenge). § Use of Consensus Standards are required as a first choice Office of Environment, Health, Safety and Security 8

DOE Regulator: Inherently Federal Functions • • Establishing Requirements Licensing/Permitting/Authorizations Independent Oversight Enforcement Office of Environment, Health, Safety and Security 9

It’s Not Just a Good Idea – It’s the Law • National Technology Transfer and Advancement Act of 1995 – The Act mandates that all federal agencies use technical standards developed and adopted by voluntary consensus standards bodies, as opposed to using government-unique standards. • OMB Circular No. A-119, “Federal Participation in the Development and Use of Voluntary Consensus Standards and in Conformity Assessment Activities. ” Office of Environment, Health, Safety and Security 10

Key Points OMB Circular No. A-119 • Agency support provided to a voluntary consensus standards activity must be limited to that which clearly furthers agency and departmental missions, authorities, priorities, and is consistent with budget resources. • Agency employees who, at Government expense, participate in standards activities of voluntary consensus standards bodies on behalf of the agency must do so as specifically authorized agency representatives. • Agency Standards Executive -- to the extent possible, ensuring that the agency's participation in voluntary consensus standards bodies is consistent with agency missions, authorities, priorities, and budget resources. Office of Environment, Health, Safety and Security 11

Improving the Way We Interact with Standards Committees v Seek effective use of DOE resources and participation in Standards Developing Organizations (SDOs), like ASME v Develop DOE technical and policy positions that are in the public interest and are coordinated with other Federal participants v Establish procedures to ensure that agency representatives express views and positions that are not inconsistent or in conflict with established agency views and positions Office of Environment, Health, Safety and Security 12

DOE Areas of Interest v Quality Assurance – v. Commercial Grade Dedication (CGD) v. Applying a Graded Approach v CGD of software v. Integrated Safety Assessment – ANS 57. 11 v. Filter Testing and Qualification Approach v. Considering a DOE Endorsement Process similar to NRC Office of Environment, Health, Safety and Security 13

Take Aways • DOE is a Owner and Regulator • DOE Standards Executive responsible to designate the Agency Representative that represents DOE position • DOE is unique, building new facilities and needs quality assurance standards that can be applied throughout the lifecycle of a nuclear facility • DOE is committed to the Voluntary Consensus Standards process Office of Environment, Health, Safety and Security 14