NA-2018-CSO-01, Approval of Delegations of Nuclear Safety Authorities

Department of Energy National Nuclear Security Administration Washington, DC 20585 May 21, 2018 MEMORANDUM FOR PETER D. RODRIK LIVERMORE FIELD OFFICE THRU: JAMES J. MCCONNELL CENTRAL TECHNICAL AUTHORITY FROM: PATRICK T. CAHALANE COGNIZANT SECRETARIAL OFFICER FOR SAFETY SUBJECT: Approval of Delegations of Nuclear Safety Authorities REFERENCES: (1) Memorandum from Peter D. Rodrik to Patrick Cahalane, “Request for National Nuclear Security Administration Nuclear Safety Delegations for the Livermore Field Office,” March 16, 2018 (2) Memorandum from James J. McConnell to Nicole Nelson- Jean, “Approval of Nuclear Safety Delegations for Livermore Field Office,” July 28, 2014 (3) NNSA Business Operating Procedure 07.01, Delegations of Nuclear Safety Authority, October 28, 2014 By Reference (1), you requested delegations of nuclear safety authorities for yourself and Mr. Douglas Eddy, Senior Technical Safety Advisor (STSA). Your requested delegated authorities are to update and reaffirm the authorities, originally granted in Reference (2), due to your appointment as the Livermore Field Office (LFO) Manager. The requested delegated authorities for Mr. Eddy are to enable him to act in your absence from the office on urgent nuclear safety matters. You also informed me that the delegated nuclear safety authorities to Mr. Samuel D. Brinker are no longer necessary due to his transfer to a non-safety related position. I approve the delegations to yourself and Mr. Eddy. I also rescind the delegated authorities for Mr. Brinker. Although your delegated authorities as specified in Reference (2) remain valid, I consider it prudent to confirm that the bases upon which the delegations were made have not diminished in the period of time since Reference (2) was issued. Therefore, your qualifications and updated experience were re-evaluated and documented per 2 Reference (3). This evaluation determined that you continue to satisfy the requirements for delegation of your nuclear safety authorities. Mr. Eddy qualified as Senior Technical Safety Manager (STSM) in December 2017. He is due for STSM requalification in April 2022. He completed Nuclear Executive Leadership Training in 2017. His experience at LFO is noteworthy. Prior to serving in his present position, Mr. Eddy served for 15 months as Acting STSA/Safety Basis and Engineering Lead, four years as Nuclear Facility Operations Team Leader, nine years as Operations Manager at the National Ignition Facility, and previously for seven years as Senior Facility Representative for Nuclear Facilities. The capabilities, capacities, and framework to perform these delegations were evaluated in the 2016 Biennial Review of LFO. This review resulted in evaluation of Criticality Safety as “Exceeds Expectations” and all other applicable areas as “Meets Expectations.” The review determined that LFO had policies and procedures in effect and sufficient technical staff and resources that would support LFO’s proper execution of these delegated authorities. I delegate the following nuclear safety authorities to you and Mr. Douglas Eddy: Safety Design Basis - Approval Authority for safety design basis documents for Hazard Category 2 and 3 nuclear facilities developed in accordance with DOE-STD-1189-2016. This approval authority covers safety design basis documents prepared in accordance with DOE-STD- 1189-2008 in cases where a project is following that standard.

Safety Basis - Approval Authority for safety basis documents for Hazard Category 2 and 3 nuclear facilities are required by 10 CFR 830 Subpart B, Safety Basis Requirements. This includes Documented Safety Analyses, Technical Safety Requirements, Unreviewed Safety Question (USQ) procedures, documents that result from positive USQ determinations, and revisions to those documents. Startup and Restart - Authorization Authority for startup of Hazard Category 3 nuclear facilities and for restart of Hazard Category 2 and 3 nuclear facilities. These delegations remain valid while you and Mr. Eddy serve in your current positions and maintain STSM qualification. Consistent with Section 3.2 of DOE-STD-1104-2016, Review and Approval of Nuclear Facility Safety basis and Safety Design Basis Documents, the safety basis delegation excludes approval authority for proposed changes to an existing facility safety basis where no viable control strategy exists to prevent or mitigate the offsite dose consequence of an accident scenario from exceeding the Evaluation Guideline. The Central Technical Authority concurs with the delegation of nuclear safety authorities to Mr. Eddy. 3 cc: J. McConnell, NA-50 D. Sigg, NA-51 J. Roberson, NA-51 P. Rhoads, NA-50 D. Schwendenman, NA-512 S. Johnson, NA-512 D. Eddy, LFO -·· .. ~~l/1/1V•~;'i:JIIt'4--_.,.",.- Department of Energy National Nuclear Security Administration Livermore Field Office PO Box 808, L-293 7000 EastAvenue Livermore, California 94551-0808 MAR 16 2018 5481.1.3.5 COR-AMO-2/28/20 18-782614 MEMORANDUM FOR PATRICK T. CAHALANE PRlNCfP AL DEPUTY ASSOCIATE ADMINISTRATOR FOR SAFETY, INFRASTRUCTURE, AND OPERATIONS FROM: PETER D. RODRIK /-) ") Il ~ MANAGER ,~ I/. "&A%~ SUBJECT: Request for National Nuclear Security Administration Nuclear Safety Delegations for the Livermore Field Office REFERENCE: Business Operating Procedure-07.01 (J. McConnell), Delegations oj Nuclear Safety Authority, dated October 28, 2014 Per the delegation procedure in the Reference, attached is my request for delegation of Nuclear Safety Authorities to be re-affirmed due to my appointment as the Livermore Field Office (LFO) Manager. I also request safety authorities be delegated to Mr. Douglas Eddy, LFO Senior Technical Safety Advisor, in the event that I am out of the office and unavailable to act on urgent nuclear safety matters. Completed Delegation Nomination Forms for myself and Mr. Eddy are attached. This memorandum also serves as notification that the delegated approval authority for Mr. Samuel D. Brinker is rescinded due to a change to a different non-safety related position. Should you have any questions, please contact me at (925) 422-6265. Attachments: (1) Peter D. Rodrik, LFO National Nuclear Security Administration (NNSA) Delegation Nomination Form (2) Douglas Eddy, LFO NNSA Delegation Nomination Form cc (wiatt.): J. McConnell, NA-50 D. Sigg, NA-51 D. Bullen, DNFSB Livermore Field Office National Nuclear Security Administration Delegation Nomination Form Delegate Name: Peter D. Rodrik Delegate’s Organization / Position: Livermore Field Office (LFO)/ Manager Delegations Proposed: Safety Design Basis: Approval authority for safety design basis documents developed in accordance with Department of Energy (DOE)-Standard (STD)-1189-2016, Integration of Safety into the Design Process, for Hazard Category 2 and 3 nuclear facilities. This approval authority covers safety design basis documents prepared in accordance with DOE-STD-1189-2008 in cases where a project is following the previous version of the standard.

Safety Basis: Approval authority for safety basis documents for Hazard Category 2 and 3 nuclear facilities required by 10 Code of Federal Regulations (CFR) 830 Subpart B. This includes documented safety analyses, technical safety requirements, Unreviewed Safety Question (USQ) procedures, documents that result from positive USQ determinations, and revisions to these documents. Startup: Authorization authority for startup of Hazard Category 3 nuclear facilities and restart of Hazard Category 2 and 3 nuclear facilities. Delegate’s Education and Experience: • Bachelor of Science in Chemical Engineering (1985), University of Iowa, Iowa City, IA • Biology, Earth Science, Environmental Management/Law, RCRA Post-Graduate Work (1993-1995), University of Denver, Denver, CO • 33 years of Contractor/Federal experience including: o Two months as the Manager, LFO, 1/2018 - Present o 5 months as the Acting Manager, LFO, 8/2017 - 1/2018 o Two years as the Deputy Manager, LFO, 10/2015 - 8/2017 o Nine years as the Senior Technical Safety Advisor (STSA), LFO, 9/2007 - 10/2015 o Seven years as Senior Nuclear Safety Enforcement Specialist, Office of Price Anderson Enforcement, 2/2001 - 9/2007 o Two years as Team Leader for Safeguards, Office of Safeguards and Security Evaluations, 3/1999 - 2/2001 o Seven years as Nuclear Engineer, Office of Environment, Safety, and Health Residents, Rocky Flats Site, 9/1992 -3/1999 o Two years as a Resident Inspector, Nuclear Regulatory Commission, 3/1990 - 9/1992 o Five years as Chief/Shift Refueling Engineer, Mare Island Shipyard, 7/1985 - 3/1990 Delegate’s Qualification: • Senior Technical Safety Manager, 4/2014; re-qualification due 4/2019 • Nuclear Executive Leadership Training, 2009 • National Academy for Nuclear Training, Senior Nuclear Plant Management Course (INPO), 2010 • Federal Executive Institute Leadership for a Democratic Society, 2006 Compensatory Measures: No Compensatory Measures are needed. Organization’s Capabilities / Capacities: Adequate site capabilities and capacities exist and were evidenced in the National Nuclear Security Administration (NNSA) biennial review of the LFO conducted in May 2016. The following are the results from the review: Functional Area Grade Comments Safety Basis Meets Expectations Demonstrates site’s capability/capacity for implementation of safety basis requirements per 10 CFR 830 Subpart B. Startup/Restart Meets Expectations Demonstrates site’s capability/capacity for effective processes to achieve and verify readiness. Criticality Safety Exceeds Expectations Demonstrates site’s capability/capacity of an exceptional level of oversight performance in the criticality safety program. Quality Assurance (QA) Meets Expectations Demonstrates site’s capability/capacity for delegation to approve QA program. Other Conditions to Justify Delegation: Mr. Peter D. Rodrik was granted approval authority as the LFO STSA in July 2014. In the delegation memo, it stated, “These delegations remain valid while Mr. Rodrik maintains STSM qualifications.” This NNSA Delegation Nomination Form re-affirmation request is to ensure that the delegation records accurately reflect Mr. Rodrik’s change of position from the LFO STSA to the LFO Manager. Livermore Field Office National Nuclear Security Administration Delegation Nomination Form Delegate Name: Mr. Douglas Eddy Delegate’s Organization / Position: Livermore Field Office (LFO) / Senior Technical Safety Advisor (STSA) (LFO Manager’s Office)

Delegations Proposed: Safety Design Basis: Approval authority for safety design basis documents developed in accordance with Department of Energy (DOE)-Standard (STD)-1189-2016, Integration of Safety into the Design Process, for Hazard Category 2 and 3 nuclear facilities. This approval authority covers safety design basis documents prepared in accordance with DOE-STD-1189-2008 in cases where a project is following the previous version of the standard. Safety Basis: Approval authority for safety basis documents for Hazard Category 2 and 3 nuclear facilities required by 10 Code of Federal Regulations (CFR) 830 Subpart B. This includes documented safety analyses, technical safety requirements, Unreviewed Safety Question (USQ) procedures, documents that result from positive USQ determinations, and revisions to these documents. Startup: Authorization authority for startup of Hazard Category 3 nuclear facilities and restart of Hazard Category 2 and 3 nuclear facilities. Delegate’s Education and Experience: • Bachelor of Science in Biology (concentration Molecular Biology) with a double major Bachelor of Arts in Chemistry (concentration Biochemistry) (1989), San Jose State University, San Jose, CA • Laser Technology, Vacuum Technology, Engineering, & Occupational Safety Courses (1999 - 2011), Las Positas Community College, Livermore, CA • Graduate of D1G Nuclear Power Prototype, Knolls Atomic Power Laboratory, Ballston Spa, NY (1980) • Graduate of Naval Nuclear Power School, Orlando, FL (1979) • 32 years of Contractor/Federal experience including: o Nine months as the STSA, LFO, 3/2017 - Present o 15 months as Acting STSA/Safety Basis and Engineering Lead, LFO, 12/2015 - 3/2017 o Four years as Nuclear Facility Operations Team Leader, LFO, 6/2011 - 12/2015 o Nine years as Operations Manager, National Nuclear Security Administration (NNSA) Office of the National Ignition Facility, Livermore, CA 3/2002 - 6/2011 o Three years as Operations Team Leader/Inertial Confinement Fusion Program Manager, LFO, 6/1999 - 3/2002 o Seven years Senior Facility Representative for Nuclear Facilities, Livermore Site Office, 4/1992 - 6/1999 o Two years Health Physicist, Lockheed Missiles and Space, Sunnyvale, CA 2/1990 - 4/1992 o Eight months as a Scientific Associate, Kirk Mayer Inc., subcontractor to Lawrence Livermore National Laboratory, Livermore, CA 4/1989 - 2/1990 o Six months as an Analytical Chemist, NWT Corporation, San Jose CA 8/1988 - 4/1989 o Four years Nuclear Electrical Operator/Shutdown Reactor Operator, US Naval Nuclear Power Program, USS South Carolina CGN-37 6/1980 – 6/1984 Delegate’s Qualification: • Senior Technical Safety Manager, 12/2017 • Nuclear Executive Leadership Training, 8/2017 Compensatory Measures: No Compensatory Measures are needed. Organization’s Capabilities / Capacities: Adequate site capabilities and capacities exist and were evidenced in the NNSA biennial review of LFO conducted in May 2016. The following are the results from the review: Functional Area Grade Comments Safety Basis Meets Expectations Demonstrates site’s capability/capacity for implementation of safety basis requirements per 10 CFR 830 Subpart B. Startup/Restart Meets Expectations Demonstrates site’s capability/capacity for effective processes to achieve and verify readiness. Criticality Safety Exceeds Expectations Demonstrates site’s capability/capacity of an exceptional level of oversight performance in the criticality safety program. Quality Assurance (QA) Meets Expectations Demonstrates site’s capability/capacity for delegation to approve QA program.

Other Conditions to Justify Delegation: The LFO STSA position is a part of the LFO Manager’s Office and directly supports and reports to the LFO Manager. This request also meets a May 2016 NNSA biennial review opportunity for improvement, which recommended that LFO obtain approval authority for startup and restart for another qualified Senior Technical Safety Manager as a backup, such as the STSA, to cover cases when the LFO Manager is not available. NA-51 Delegation Review Douglas Eddy Page 1 of 2 Delegated Authorities Requested Criteria for Individuals and Review Results Site Criteria and Review Results Comments 1. Safety Design Basis For new or major modifications to Hazard Category 2 and 3 nuclear facilities, approval authority for the following: (1) Safety Design Strategies and associated approval documentation (2) Conceptual Safety Design Reports, Preliminary Safety Design Reports, and associated safety review letters (3) Preliminary Documented Safety Analyses and associated Safety Evaluation Reports 2. Safety Basis For new or existing Hazard Category 2 and 3 nuclear facilities, approval authority for the following: (1) Documented Safety Analyses (2) Technical Safety Requirements (3) Unreviewed Safety Question procedures (4) Justifications for Continued Operation (5) Evaluations of the Safety of the Situation (as required) BOP 07.01 Criteria: (1) Senior Technical Safety Manager (STSM) qualified. (2) Successful completion of Nuclear Executive Leadership Training (NELT). Review: Mr. Eddy completed NELT in August 2017 and qualified as STSM in December 2017. Mr. Eddy holds a Bachelor of Science in Biology and a Bachelor of Arts in Chemistry, San Jose State University, San Jose, CA. Prior to serving in his current position at Livermore Field Office (LFO), Mr. Eddy served for 15 months as Acting Senior Technical Safety Advisor/Safety Basis and Engineering Lead, four years as Nuclear Facility Operations Team Leader, nine years as Operations Manager at NIF, and previously for seven years as Senior Facility Representative for Nuclear Facilities. BOP 07.01 Criteria: (1) Delegations shall be made only where the candidate’s organization possesses or has access to sufficient staff with the necessary qualifications, experience, and expertise to support the candidate for the authorities being delegated. (2) Delegations shall be made only where the candidate’s organization has the proper framework of processes and procedures, as well as adequate resources and funding, to implement the delegated authorities. Review: The 2016 BR of LFO was conducted in September 2016 and included 11 Functional Areas, including Safety Basis and Startup and Restart of Nuclear Facilities. Objectives were met in all areas. Additionally, a positive trend in performance was noted in multiple functional areas. Mr. Eddy is the Senior Technical Safety Advisor for LFO and has extensive experience with nuclear safety at the site. Since Mr. Eddy is not serving in a Manager or Deputy Manager position, CTA concurrence for the requested delegated authorities is required. LFO currently has a non-technical Acting Deputy Manager. Delegating these authorities to Mr. Eddy provides backup capability to exercise the authorities when the Manager is unavailable. NA-51 Delegation Review Douglas Eddy Page 2 of 2 3. Startup Authorization Authority for startup of

Hazard Category 3 nuclear facilities and restart of Hazard Category 2 and 3 nuclear facilities. Conclusion: Recommend approving the requested delegated authorities. NA-50 Senior Manager Concurrence: Jeffry Roberson Senior Technical Advisor Date Daniel Schwendenman Director, Office of Nuclear Safety Services Date 2018-05-07T11:03:31-0400 Jeffry L. Roberson 2018-05-07T11:05:17-0600 DANIEL SCHWENDENMAN NA-51 Delegation Review Peter D. Rodrik Page 1 of 2 Delegated Authorities Requested Criteria for Individuals and Review Results Site Criteria and Review Results Comments 1. Safety Design Basis For new or major modifications to Hazard Category 2 and 3 nuclear facilities, approval authority for the following: (1) Safety Design Strategies and associated approval documentation (2) Conceptual Safety Design Reports, Preliminary Safety Design Reports, and associated safety review letters (3) Preliminary Documented Safety Analyses and associated Safety Evaluation Reports 2. Safety Basis For new or existing Hazard Category 2 and 3 nuclear facilities, approval authority for the following: (1) Documented Safety Analyses (2) Technical Safety Requirements (3) Unreviewed Safety Question procedures (4) Justifications for Continued Operation (5) Evaluations of the Safety of the Situation (as required) BOP 07.01 Criteria: (1) Senior Technical Safety Manager (STSM) qualified. (2) Successful completion of Nuclear Executive Leadership Training (NELT). Review: Mr. Rodrik completed NELT in July 2009 and requalified as STSM in 2014. He is due for requalification in 2019. Mr. Rodrik currently serves as Manager of the Livermore Field Office (LFO) and is currently responsible for proper execution of these delegated authorities. This delegation updates his authorities. He previously served as Acting Manager, Deputy Manager, and Senior Technical Safety Advisor, LFO, where he held these same authorities in each position. BOP 07.01 Criteria: (1) Delegations shall be made only where the candidate’s organization possesses or has access to sufficient staff with the necessary qualifications, experience, and expertise to support the candidate for the authorities being delegated. (2) Delegations shall be made only where the candidate’s organization has the proper framework of processes and procedures, as well as adequate resources and funding, to implement the delegated authorities. Review: The 2016 BR of LFO was conducted in September 2016 and included 11 Functional Areas, including Safety Basis and Startup and Restart of Nuclear Facilities. Objectives were met in all areas. Additionally, a positive trend in performance was noted in multiple functional areas. Mr. Rodrik is the Manager of LFO, and he and the site meet the criteria for these delegations of authority. CTA concurrence is not required. NA-51 Delegation Review Peter D. Rodrik Page 2 of 2 3. Startup Authorization Authority for startup of Hazard Category 3 nuclear facilities and restart of Hazard Category 2 and 3 nuclear facilities. Conclusion: Mr. Rodrik currently serves as Manager of the Livermore Field Office and exercises these authorities as previously delegated in 2014. This action updates his authorities due to his recent appointment as the Manager. Recommend approving the requested delegated authorities. NA-50 Senior Manager Concurrence: Jeffry Roberson Senior Technical Advisor Date Daniel Schwendenman Director, Office of Nuclear Safety Services Date 2018-05-07T11:04:03-0400 Jeffry L. Roberson 2018-05-07T11:04:24-0600 DANIEL SCHWENDENMAN