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DOE Regulatory Processes

DOE Regulatory Processes. James O’Brien Office of Nuclear Safety Office of Health, Safety and Security May 9, 2012. Presentation Overview. Overview of DOE Nuclear Safety Regulatory Framework Directives Development, Review, and Approval Processes Directives Reform Initiative

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DOE Regulatory Processes

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  1. DOE Regulatory Processes James O’Brien Office of Nuclear Safety Office of Health, Safety and Security May 9, 2012

  2. Presentation Overview • Overview of DOE Nuclear Safety Regulatory Framework • Directives Development, Review, and Approval Processes • Directives Reform Initiative • Facility Safety Order Note: This presentation does not discuss Federal Regulations development process

  3. Regulatory Infrastructure:Regulations, Orders, Standards, Guides

  4. Directives ProcessInitiation • Order/Guides (controlled per Order 251.1A) : • Justification memo (defines need, scope, schedule) • Approved by Directives Review Board (DRB) • Technical Standards/Handbooks (controlled per Order 252.1A) : • Justification memo • Approved by Office of Primary Interest • Exception – Technical Standards invoked by an Order also go to the DRB

  5. Directives ProcessDevelopment • Establish Working Group • Subject Matter Experts • Contractor and Fed representatives • Red Team Review • Program Office Nuclear Safety Management • Site Office Manager • Field Management Council Representative • Defense Nuclear Facility Safety Board (DNFSB) Briefing/Input

  6. Directives ProcessReview • Orders/Guide: • RevCom Review (durations are the typical times) • 45 day comment period • 30 day comment resolution • 15 day concurrence review* • *DRB has assumed the concurrence review responsibility • Technical Standards/Handbooks • RevCom Review • 60 day comment period • 30 day comment resolution • 10 day concurrence review • Central Technical Authority (CTA) reviews

  7. Directives ProcessIssuance • Orders/Guides: • Orders memo from Office of Primary Interest through Office of Management (MA) to Deputy Secretary (includes concurrence synopsis, rationale for change, DNFSB review feedback) • Guide – same memo but approved by MA • Technical Standards/Handbooks • Senior line manager of approving activity after all concurrences (including CTAs)

  8. Directives Process Example (Facility Safety Order) • Justification Memo (JM) approved by HSS - 9/8/2010 • JM approved by DRB - 9/23/2010 • Draft to red-team/DNFSB review - 2/1/2011 • Draft to RevCom - 4/1/2011 (90 days) • Comments due in RevCom - 7/1/2011

  9. Directives Process Example (Facility Safety Order) • Concurrence Draft released - 9/30/2011 (45 days) • Comments due on Concurrence Draft - 11/18/2011 (DRB meeting) • Second Concurrence Draft released - 3/16/2012 • DRB provided verbal concurrence - 4/5/2012 • DRB updated with status on 1020 and 1066 - April - May 2012 • Will go to DS for approval once 1020 and 1066 approved - May or June 2012

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