EHSS and the DOE’s Technical Standards Program
The American Nuclear Society’s Risk-informed, Performance-based Principles and Policy Committee (RP3C) held another presentation in its monthly Community of Practice (CoP) series. Former RP3C chair N. Prasad Kadambi opened the April 24 meeting with brief introductory remarks about the RP3C and the overall importance of risk-informed, performance-based (RIPB) design principles.
He then introduced this month’s speaker: Larry Perkins, the deputy director of environment, health, and safety within the Department of Energy’s Office of Environment, Health, Safety, and Security (EHSS). Perkins presented an overview of the DOE’s Technical Standards Program.
Some background: RP3C is a special committee created by the ANS Standards Board and currently chaired by Steven Krahn that provides guidance to ANS standards committees on the use of RIPB methods. The CoP is part of RP3C’s charter, which includes training and knowledge-sharing of RIPB principles to exchange ideas outside of the normal management and project processes.
The big picture: Perkins kicked off his presentation by giving a sweeping overview of the extensive, complex, and unique landscape of the DOE network. The DOE oversees 85 major laboratories and sites made up of thousands of individual facilities, including more than 150 nuclear facilities with varied and complicated operations. There are also more than 100,000 federal and contract employees, large quantities of plutonium and enriched uranium, and large quantities of radioactive waste and other hazardous materials.
This network of facilities and resources is managed by numerous offices. Perkins highlighted the DOE’s four major program offices: the Office of Science, which oversees the national laboratories; the Office of Environmental Management, which oversees nuclear waste cleanup; the National Nuclear Security Administration, which works in close collaboration with the Department of Defense; and the Office of Nuclear Energy, which is currently involved in a significant push to get new reactors on line.
Given its volume and variance, Perkins clearly illustrated that the DOE has uniquely extensive breadth of functions.
Where EHSS comes in: With this big picture in mind, Perkins zoomed in on how EHSS fits into the DOE framework. Overall, he described EHSS as a “central organization” providing “corporate leadership” through standards and handbook development as well as through advising to senior departmental leadership across the DOE.
One-third of EHSS is focused on environment, health, and safety. Within this structure is the Office of Nuclear and Facility Safety, EH-22, which manages the DOE’s Technical Standards Program. The remaining two-thirds of EHSS are focused on security.
Perkins explained that the Technical Standards Program covers both standards written by the DOE as well as voluntary consensus standards, which are created by standards-developing organizations like ANS. As a matter of law, he said, “all federal agencies must use voluntary consensus standards in lieu of government-unique standards in their procurement and regulatory activities” in most cases.
However, some unique DOE activities fall outside the scope of voluntary consensus standards. In those cases, he explained, the DOE may need to develop its own standard to address that specific activity.
How a DOE standard is made: With this groundwork laid, Perkins then dove into the particulars of the four (or five) phases of standards development at the DOE.
- Phase 1 is “project justification,” a 15-business-day process in which an author submits a brief statement that argues the merit of creating a new standard or editing or canceling an existing standard. This justification must include an explanation as to why currently available voluntary consensus standards are not sufficient for the relevant need.
- Phase 1.5 is not an official stage in the DOE’s standards development program, however, Perkins argues that it should be considered unique from Phase 1. “Although our program doesn’t call it out, realistically the next phase would be where you develop the document.” Here, the author moves from a justification statement to a full draft standard.
- Phase 2 is “review and comment,” a 90-day process that is kicked off by the submission of the draft. It is then reviewed by subject matter experts (SMEs), after which the author responds to those comments.
- Phase 3 is “response negotiation,” a 30-day process in which the author formally works through each change recommended by the SMEs, after which the SMEs have an opportunity to review and discuss the resolution.
- Phase 4 is “concurrence,” a 10-day process in which the Technical Standards Program managers will review and either approve or reject the standard. Perkins highlighted this phase as one that could potentially be improved. He argued that, because any single program manager’s rejection of a standard halts the concurrence process, it is really more of a “veto process.” He added that the DOE is currently working to reform this issue and is looking at how organizations like ANS handle concurrence for guidance.
Go deeper: After laying out this broad framework, Perkins dove deeper into the details of DOE technical standards, Project Velocity, RevCom, handbooks, and much more. His full presentation is available to view on the American Nuclear Society Standards YouTube channel.
