SD 410.1A, Implementation of National Nuclear Security Administration Central Technical Authority Responsibilities Regarding Nuclear Safety Requirements

MANUAL NA-1 M 410.1A Approved: 06-02-11 Implementation of National Nuclear Security Administration Central Technical Authority Responsibilities Regarding Nuclear Safety Requirements il mwa’ U.S. DEPARTMENT OF ENERGY National Nuclear Security Administration Office of the Chief of Defense Nuclear Safety AVAILABLE ONLINE AT: http://hq.na.gov link to NNSA Policies/supplemental directives This page intentionally blank. NA-1 M 410.1A Implementation of National Nuclear Security Administration Central Technical Authority Responsibilities Regarding Nuclear Safety Requirements 1. PURPOSE. This supplemental directive is formulated as a manual to supplement DOE O 410.1, Central Technical Authority Responsibilities Regarding Nuclear Safety Requirements. It provides expectations and guidance for the processes by which the National Nuclear Security Administration (NNSA) Central Technical Authority (CTA) and NNSA personnel support CTA functions relating to Department of Energy (DOE) Regulations and Directives with the potential to affect nuclear safety. It also implements related CTA responsibilities that are defined in the DOE and NNSA Functions, Responsibilities and Authorities Manuals (FRAM). 2. CANCELLATIONS. This supplemental directive supersedes and cancels NA-1 M 410.1 Implementation of National Nuclear Security Administration Central Technical Authority Management of Nuclear Safety Requirements, 03/10/2008. 3. APPLICABILITY. a. NNSA Personnel. Except for the exclusion in paragraph 3c, this supplemental directive applies to all NNSA personnel involved in developing, managing, and implementing regulations and directives that affect nuclear safety. b. NNSA Contractors. None. c. Exclusions. This supplemental directive does not apply to: (1) The DOE/NNSA Naval Reactors Program in accordance with Executive Order 12344, as codified at 50 United States Code (U.S.C.) sections 2406 and 2511. (2) Activities regulated through a license by the Nuclear Regulatory Commission (NRC) or a state under an agreement with NRC, including activities certified by NRC under section 1701 of the Atomic Energy Act. 4. SUMMARY. This supplemental directive is composed of two chapters that provide process expectations for conducting the functions assigned to the CTA. Chapter I describes roles and responsibilities. Chapter II provides amplifying guidance and addresses the processes to be followed in executing CTA responsibilities, il NA-1 M 410.1A DEFINITIONS. See DOE O 410.1, Central Technical Authority Responsibilities Regarding Nuclear Safety Requirements, and DOE O 251.1C, Departmental Directives Program, or successor documents. a. REFERENCES. Title XXXII of P.L. 106-65, National Nuclear Security Administration Act, as amended, which established a separately organized agency within the Department of Energy. DOE O 251.1C, Departmental Directives Program. Secretarial Memorandum, Revised Safety Functions, Responsibilities and Authorities, June 22, 2007, from the Secretary of the Department of Energy to Acting Under Secretary for Energy, Acting Under Secretary for Nuclear Security, Under Secretary for Science, and Chief, Health, Safety, and Security Officer. DOE O 252.1A, Technical Standards Program. DOE O 410.1, Central Technical Authority Responsibilities Regarding Nuclear Safety Requirements. DOE M 411.1-1C, Safety Management Functions, Responsibilities and Authorities Manual. NA-1 SD 411.1-1C, NNSA Safety Management Functions, Responsibilities and Authorities Manual.

CONTACT. Questions concerning this supplemental directive should be addressed to the Office of the Chief of Defense Nuclear Safety, at 202-586-8216. os te @ oP P. D’ Sh Administrator National Nuclear Security Administration NA-1 M 410.1A ili CONTENTS CHAPTER I. ROLES AND RESPONSIBILITIES Nr nNnYv FSF YN OD Under Secretary for Nuclear Security/Administrator for NNSA........c:ccccessstessssssesseseseees I-1 Chief of Defense Nuclear Safety 00.0.0... ccscssssessescesssssssesseseesscessessestensescesssecseceesssssseseans 1-5 Senior Advisor for Environment, Safety and Health... cssesecsesssessesessessssscesseees I-4 Site Office Managers ...........ssscssssessssssssesesssscsesseesssseseseeseseseescssesseseseesesseassecaesessessscesensess 1-5 NNSA Headquarters Directives Point of Contact..........ecccsesssesssssssscssssseesssceseseceesneneens I-5 NNSA Headquarters Technical Standards Managet.............c:cssssssssssssscssessereeresseceensseeeees 1-6 NNSA Primary Offices of Responsibility..........ccsssesssssssessssessesesseseeeesseeseesestesssssscseseses 1-7 CHAPTER II. GUIDANCE AND PROCESSES Exemptions and Exceptions Not Requiring CTA Concurrence .........ccscssscsssssesseeseseneees II-1 Requests for Concurrence on Alternate Methodologies for Development of Documented Safety Analyses; Concurrence on Exemptions or Exceptions...........:cccccssscsssesesesesseeee II-3 Expectations and Guidance......... cs ccscsssssessssssessssessascessseessescessssesssseeseesesesessaeseeseneesneses II-5 Operational AWarenesS .........ecesssessesesseeesesseesecescessecessescessesescesaescescensetscescensceeseeseeeees II-7 Attachment 1: Directives (Latest Version) Requiring Central Technical Authority Concurrence Prior to Granting Exemptions or Exceptions Attachment 2: Regulations and Directives (Latest Version) Requiring Central Technical Authority Concurrence Prior to Revision or Cancellation iv This Page Intentionally Blank NA-1 M 410.1A NA-1 M 410.1A I-1 CHAPTER I. ROLES AND RESPONSIBILITIES The roles, responsibilities and requirements of the Central Technical Authority (CTA) are provided in the Departmental and the NNSA Functions, Responsibilities and Authorities Manuals (FRAMs). Requirements for implementing Department-wide responsibilities regarding nuclear safety requirements are provided in DOE O 410.1, Central Technical Authority Responsibilities Regarding Nuclear Safety Requirements. This chapter provides supplemental NNSA roles and responsibilities needed to assure a smooth implementation of the responsibilities in the FRAMs and DOE O 410.1. Roles and responsibilities that are included in the referenced directives will not be duplicated in this document. 1. UNDER SECRETARY FOR NUCLEAR SECURITY/ADMINISTRATOR FOR NNSA a. Approve this supplemental directive. b. Approve a supplemental directive for Biennial Reviews. 2. CHIEF OF DEFENSE NUCLEAR SAFETY (CDNS — NA-SH-10) a. Develop, maintain and distribute this supplemental directive as authorized by DOE 0 251.1C, Departmental Directives Program, and in accordance with applicable NNSA policies and directives. Maintain the lists of directives in attachments to this supplemental directive so that they are inclusive of those included in the attachments to DOE O 410.1 b. Develop, maintain and distribute a supplemental directive for conducting biennial reviews of NNSA Site Offices as authorized by DOE O 251.1C, Departmental Directives Program, and in accordance with applicable NNSA policies and directives.

c. Initiate and coordinate with DOE any changes needed to DOE O 410.1, Central Technical Authority Responsibilities Regarding Nuclear Safety Requirements. d. Coordinating with the Defense Program’s Office of Safety, facilitate the preparation of NNSA expectations and guidance for use by NNSA employees and contractors regarding 10 CFR 830, or Directives listed in DOE O 410.1 that are related to meeting requirements in 10 CFR 830. e. Facilitate preparation and coordination of NNSA inputs to the DOE Office of Health, Safety and Security (HSS) on issues concerning DOE Directives with the potential to affect nuclear safety. NA-1 M 410.1A Identify, on behalf of the CTA, new directives and standards that should be included in Attachment 1 and 2 of DOE O 410.1, including NNSA directives or NNSA supplemental directives that require CTA concurrence. (1) Prepare updates to Attachment 1 and 2 of this supplemental directive as needed to supplement the corresponding Attachment 1 and 2 of DOE O 410.1. To avoid confusion, maintain the lists of directives in attachments to this supplemental directive so that the lists are inclusive of those included in the attachments to DOE O 410.1 (2) Post updated versions of Attachment 1 and 2 with this supplemental directive on the NNSA website, and provide a copy directly to the NNSA Directives Point of Contact or designee, and to the NNSA Technical Standards Manager. (3) Provide updated versions of Attachment 1 and 2 to NNSA personnel and contractors upon request. (4) As needed and in coordination with the Departmental Chief of Nuclear Safety, initiate updates to Attachment 1 and 2 of DOE O 410.1 to incorporate changes to Department-wide directives and regulations. (5) Notify Departmental Offices of Primary Interest or Departmental Preparing Activities when NNSA CTA concurrence is required and the provisions in DOE O 410.1 and/or this supplemental directive apply. Prepare evaluation packages for CTA concurrences on directives and standards listed in Attachment 1 and 2 of this supplemental directive that primarily affect nuclear safety considerations (i.e. compliance with 10 CFR 830 and safety requirements that are designed specifically for nuclear facilities as defined in 10 CFR 830). Coordinate with the Office of Environment, Safety, and Health (NA-SH-20) to determine which directives and standards evaluation packages will be prepared by NA-SH-20 rather than NA-SH-10. Prepare the CTA concurrence package if NA- SH-20 declines to coordinate concurrence on a directive or standard. Maintain electronic records of all CTA concurrence or non-concurrence on directives and standards listed in Attachment 1 and 2 of this supplemental directive. Evaluate and document requests for guidance and expectations regarding nuclear safety, prepare draft responses for CTA consideration, coordinate as appropriate, obtain CTA approval, and disseminate CTA responses. Develop and distribute quarterly NNSA Technical Bulletins to disseminate nuclear safety information of general interest to NNSA personnel and contractors, NA-1 M 410.1A 1-3 including summary information on formal CTA guidance and expectations that have been issued during the quarter. 1. Maintain electronic copies of expectations and guidance issued by the CTA and make complete copies available to NNSA personnel and contractors upon request. m. Maintain (and make available upon request) a listing of CDNS personnel who are assigned to serve as CDNS leads for major technical areas (such as fire protection, safety basis, etc.) and as points of contact for NNSA site offices.

n. Sign on behalf of the CTA and/or the Administrator on nuclear safety matters when the following conditions all apply: i) the matter is not controversial, ii) the signed document does not provide line direction, and iii) CDNS has discussed the matter with the CTA or Administrator in advance and it is agreed that the CDNS will sign for the CTA or Administrator. Areas where the CDNS may sign on behalf of the CTA or Administrator include the following: (1) Concurrence for new and revised directives when the CTA is concurring with the directive and no NNSA organization has non-concurred, or when CTA is non-concurring in support of a non-concurring NNSA organization. A decision for the CTA to concur over the objection of an NNSA organization would be signed out by the CTA personally. (2) | Concurrence on exemptions for which the CTA concurrence memorandum would have no conditions of concurrence and is supported by the responsible Deputy Administrator. A decision to non-concur with an exemption supported by a Deputy Administrator, or to issue conditions of concurrence in the CTA concurrence memorandum would be signed out by the CTA personally. (3) Concurrence with nuclear safety requirements included in contracts. (4) Concurrence with memoranda being provided to the Defense Nuclear Facilities Safety Board when there are no issues with the memoranda. Issues that can not be resolved by CDNS are elevated to the CTA. (5) Concurrence on Active Confinement Ventilation Evaluations for which performance gaps are not identified. (6) Issuance of Nuclear Safety Guidance and Expectations that provide guidance only (i.e. that do not impose requirements) and that the Deputy Administrator for Defense Programs (NA-10) and the Deputy Administrator for Defense Nuclear Nonproliferation (NA-20) have concurred upon. (7) Other Administrator or CTA actions when directed in advance by the Administrator or CTA, respectively. NA-1 M 410.1A When CDNS signs for the Administrator or CTA, the signature block will show the Administrator or CTA name, and CDNS will sign using his or her own name with the word ‘for’ in parenthesis following the CDNS signature. CDNS does not sign for the CTA or Administrator on safety matters involving: (1) Formal guidance and expectations that impose requirements. (2) Resolution of Differing Professional Opinions. (3) | Concurrence on Delegations of Authority. (4) Other matters not authorized in advance by the CTA or Administrator. At the first available opportunity during the CTA biweekly meeting with the CDNS, CDNS will discuss all upcoming actions that CDNS is aware of that will require CTA or Administrator actions, and any actions that CDNS has taken or will take on the CTA or Administrator’s behalf. | OFFICE OF ENVIRONMENT, SAFETY AND HEALTH (NA-SH-20) a. Evaluate and document requests for guidance and expectations regarding environment, health and safety issues that are not related to 10 CFR 830, prepare draft responses for CTA consideration, coordinate as appropriate, obtain CTA approval, and disseminate CTA responses. Facilitate preparation and coordination of NNSA inputs to the HSS on issues concerning DOE Directives with the potential to affect environment, safety and health issues other than compliance with 10 CFR 830.

Prepare evaluation packages for CTA concurrences on directives and standards listed in Attachment 1 and 2 of this supplemental directive that primarily affect environment, safety and health considerations not related to compliance with 10 CFR 830, and elements of the Federal Technical Capability Program. To prevent confusion, the directives listed in attachments to this supplemental directive are inclusive of those included in the attachments to DOE O 410.1. Coordinate with the CDNS (NA-SH-10) to determine which directives and standards CTA concurrence packages will be prepared by NA-SH-20 rather than NA-SH-10. Provide NA-SH-10 with electronic copies of CTA directive and standard concurrence packages once a CTA action has been completed. NA-1 M 410.1A I-5 4. SITE OFFICE MANAGERS a. As needed, submit requests to the CTA through the CDNS for guidance or expectations regarding 10 CFR 830 or the DOE Directives listed in Attachment 1 and 2 of this Supplemental Directive. Support biennial reviews by the CDNS. When a methodology for developing Documented Safety Analyses (DSA) is needed that deviates from those listed in 10 CFR 830, or an exemption or equivalency is needed to 10 CFR 830 or to DOE Directives listed in Attachment lof this supplemental directive: (1) Pre-coordinate with the Defense Programs Office of Safety and with CDNS prior to submission of the formal request to help ensure that the methodology or proposed compensatory measures will result in adequate safety for the proposed operations. (2) Provide copies of alternative methodologies to HSS and request HSS concurrence. (3) Obtain Secretarial Officer approval and CTA concurrence on _ methodologies and/or exemptions or equivalencies before authorizing or directing significant time/resource expenditures to accomplish the work covered (e.g. before development of a DSA covered by the methodology). 5. NNSA HEADQUARTERS DIRECTIVES POINT OF CONTACT a. Identify the Departmental Office of Primary Interest for Directives that are listed in the Attachments to this supplemental directive, or (for new Directives) that are identified as requiring CTA concurrence. To prevent confusion, the directives listed in attachments to this supplemental directive are inclusive of those included in the attachments to DOE O 410.1 Identify and maintain a list of NNSA Primary Offices of Responsibility for each directive listed in the attachments to this supplemental directive. These offices are the NNSA organizations having appropriate subject matter expertise to coordinate the review of the technical content of the directive and the resolution of NNSA comments. When the Departmental Office of Primary Interest is an NNSA organization, that organization should be the NNSA Primary Office of Responsibility. For changes to Directives listed in the attachments to this supplemental directive, notify the Departmental Office of Primary Interest and the NNSA Primary Office of Responsibility of the need for CTA concurrence and that NA-SH-10/20 coordination is available to facilitate the concurrence process. NA-1 M 410.1A Notify the CDNS of new Directives that should be considered for possible inclusion in the attachments to DOE O 410.1. Withhold NNSA concurrence on Directives identified as requiring CTA concurrence until CTA concurrence has been obtained. Provide a copy of CTA concurrence to the Departmental Office of Primary Interest and to the NNSA Primary Office of Responsibility.

Coordinate with CTA staff and request extensions, as needed, to allow for adequate CTA review of new and revised Directives. NNSA HEADQUARTERS TECHNICAL STANDARDS MANAGER a. Identify the Departmental Preparing Activity for Technical Standards that are listed in the attachments to this supplemental directive, or (for new Technical Standards) that are identified as requiring CTA concurrence. To prevent confusion, the directives listed in attachments to this supplemental directive are inclusive of those included in the attachments to DOE O 410.1. Identify and maintain a list of NNSA Primary Offices of Responsibility for each standard listed in the attachments to this supplemental directive, or (for new Technical Standards) that are identified as requiring CTA concurrence. These offices are the NNSA organizations having appropriate subject matter expertise to coordinate the review of the technical content of the standard and the resolution of NNSA comments. When the Departmental Preparing Activity is an NNSA organization, that organization should be the NNSA Primary Office of Responsibility. For changes to Technical Standards listed in the attachments to this supplemental directive, ensure that the Departmental Preparing Activity and NNSA Primary Office of Responsibility are aware of the need for CTA concurrence and that NA-SH-10/20 coordination is available to facilitate the concurrence process. Notify the CDNS of new Technical Standards that should be considered for possible inclusion in the Attachments to DOE O 410.1. Withhold NNSA concurrence on Technical Standards for which CTA concurrence is required until CTA concurrence has been obtained. Provide a copy of CTA concurrence to the Departmental Preparing Activity and the NNSA Primary Office of Responsibility. Coordinate with CTA staff and request extensions, as needed, to allow for adequate CTA review of new and revised Technical Standards. NA-1 M 410.1A 1-7 7. NNSA PRIMARY OFFICES OF RESPONSIBILITY (for Directives and Technical Standards) NNSA Primary Offices of Responsibility are the NNSA organizations having appropriate subject matter expertise to review the technical content of a directive or standard and the resolution of NNSA comments on that directive or standard. They are identified by the NNSA Directives Point of Contact and the NNSA Technical Standards Manager, respectively. a. Review the resolution of NNSA comments on Directives and Technical Standards that are listed in the Attachments to DOE O 410.1 during the final concurrence process for the Directive or Technical Standard. b. Provide the CTA lead with a recommendation on CTA concurrence. c. Assist NA-SH-10/20 in developing the CTA concurrence package. 1-8 This Page Intentionally Blank. NA-1 M 410.1A NA-1 M 410.1A II-1 CHAPTER II. GUIDANCE AND PROCESSES The guidance and processes in this chapter are intended to supplement, and not duplicate, those found in DOE O 410.1. See DOE O 410.1 for additional process description and requirements. 1.

EXEMPTIONS AND EXCEPTIONS NOT REQUIRING CTA CONCURRENCE. DOE O 410.1 describes a number of situations in which CTA concurrence is required prior to award of a contract revision in which an applicable CRD provision from a directive listed in Attachment 1 of DOE O 410.1 is not to be included (i.e. an exception). However, there are some situations that are similar to those described in DOE O 410.1 but that do not require CTA concurrence. These include situations where provisions of nuclear safety directives are omitted from or modified in contracts because they are inapplicable or duplicate requirements. Similarly, DOE O 410.1 describes situations requiring CTA concurrence to exemptions from directives that are listed in Attachment 1 to DOE O 410.1. However, there are some forms of relief that do not require CTA concurrence, even if they involve the directives listed in Attachment 1 of DOE O 410.1, primarily involving an equivalency or requirements for non-nuclear facilities. Each of these situations is discussed in this section. a. Inapplicable Provision in an Applicable Directive during a Contract Revision. A directive may be applicable to a site because of the general nature and coverage of the directive, but a specific Contractor Requirements Document (CRD) provision in the directive might not be applicable to specific situations at that site. CTA concurrence does not have to be requested for exclusion of the inapplicable CRD provision for those situations (per DOE O 410.1, the Site Office Manager is responsible for determining applicability). b. Duplicate Requirements during a Contract Revision. Some CRD provisions duplicate or overlap portions of other requirements, and contract requirements are sometimes written to exclude an applicable CRD provision because its requirement is already included in the contract because of the inclusion of a similar or overlapping requirement. (1) Exclusion of provisions that are already in the contract through other requirements must be documented in accordance with DOE O 410.1, but CTA concurrence does not have to be requested for exclusion of duplicate requirements. (2) Decisions on excluding CRD provisions that are similar but not identical to other included requirements must ensure that all applicable performance expectations are met. If meeting a requirement already included in a contract would not completely meet reasonable performance expectations for a similar CRD provision, CTA concurrence must be obtained if the similar CRD provision is not to be included in the contract. II-2 NA-1 M 410.1A Cc. Equivalencies (as opposed to Exemptions). (1) (2) Revision C to DOE O 251.1, Departmental Directives Program, introduced the term ‘equivalencies’ and, in the context of the Directives program, defined it as: “[A]lternatives to how a requirement in a directive is fulfilled in cases where the “how” is specified. These represent an alternative approach to achieving the goal of the directive.” (a) (b) (c) CTA concurrence is required for relief from requirements that are included in the directives listed in Attachment 1 of this supplemental directive whether the requirement directs the use of a process (a “how” requirement) or requires a specific outcome (a “what” requirement). The process and concurrence criteria for obtaining CTA concurrence are the same for exemptions and equivalencies as defined in DOE O 251.1.

Not all standards invoked in Departmental Directives use the term ‘equivalency’ as defined in DOE O 251.1. CTA concurrence is only required on equivalencies when the relief being sought is to authorize use of an alternative approach to achieving the goal of a directive listed in Attachment 1 of this supplemental directive. See the next subparagraphs for more information on other types of equivalencies. Some codes such as National Fire Protection Association (NFPA) codes include provisions for routinely granting equivalencies with the approval of the Authority Having Jurisdiction (AHJ). In NNSA, the AHJ is usually the Site Office Manager (see, for example, the AHJ requirements for Fire Safety in DOE O 420.1B, Facility Safety). (a) (b) (c) Equivalencies are intended to provide equivalent protection, not to authorize a lower level of protection than specified in the code. Equivalency provisions in a code invoked by a Directive do not take precedence over explicit requirements in an applicable Directive CRD. If an equivalency permitted under a code would violate an explicit requirement in an applicable Directive CRD, use of an equivalency alone to waive the requirement is not appropriate. AH3Js granting routine, appropriate equivalencies do not need to request CTA concurrence. NA-1 M 410.1A II-3 (3) Some directives explicitly include multiple approaches that may be followed to achieve a stated objective, or include provisions for obtaining DOE approval for one of several approaches or of an alternative approach proposed by the contractor. (a) Where directives include these provisions and include specific approval authorities and/or concurrence authorities that do not establish a CTA concurrence role, CTA concurrence is not required. (b) Anexample is a provision in the Training Order that allows the Site Office Manager to approve a contractor procedure for granting ‘equivalencies to training’ on a case-by-case basis. CTA concurrence is not required for the use of such provisions. Exemptions for Non-Nuclear Facilities. Some requirements, such as fire protection and conduct of operations, apply both to nuclear facilities and non- nuclear facilities at the same site. CTA concurrence is not needed for exemptions or exceptions to requirements that are approved exclusively to cover non-nuclear facilities, even if those requirements are found in directives listed in Attachment 1 of DOE O 410.1 or of this supplemental directive. 2. REQUESTS FOR CONCURRENCE ON ALTERNATE METHODOLOGIES FOR DEVELOPMENT OF DOCUMENTED SAFETY ANALYSES; CONCURRENCE ON EXEMPTIONS, OR EXCEPTIONS. a. The same information needed to support an exemption request to the Approval Authority must be submitted to obtain CTA concurrence with an alternate method for developing a documented safety analysis. This information is described in DOE-STD-1083-2009 or successor document for Rules. The same suite of information is generally appropriate for exemptions to Orders, Notices or Manuals. The responsible Site Office Manager must submit requests for CTA concurrence to the CDNS. The CDNS will process and forward the requests to the CTA. (1) _ The Site Office request must include a copy of the concurrence page, if the Site Office uses a concurrence page in evaluating the proposed exception. (2) Any missing signatures or non-concurrences on the concurrence page must be supported by a written minority opinion. (3) Additional information may be requested by the CDNS on a case-by-case basis to support evaluation of a particular request.

(4) Pre-coordination with the CDNS during development of the request and consideration of potential compensatory measures is crucial to a timely resolution. II-4 NA-1 M 410.1A c. If the request involves compliance with 10 CFR 830: (1) Exemptions. (2) (a) (b) (c) (d) (e) The Site Office Manager should comply with responsibilities discussed in DOE-STD-1083-2009 or successor document, which include responsibilities and time limits for provision of information to the NNSA Cognizant Secretarial Officer (CSO) established in the DOE FRAM. The concurrence request should be forwarded to the CDNS at the same time as the approval request is submitted to the NNSA CSO. The focus of CTA concurrence is whether the exemption, with proposed compensatory measures (if any), will provide adequate protection of the environment, public and workers. The CDNS review will take advantage of and not duplicate that performed by safety personnel at the NNSA Site Office and by the NNSA CSO. The CTA does not generally review the legal impacts of the request (this is a responsibility of the approving official); however, the CTA will not concur on requests that would appear to violate the law without obtaining review by the NNSA General Counsel. Alternate Methodologies to those listed in 10 CFR 830 for developing Documented Safety Analyses. (a) (b) (c) Site Office Managers must obtain CTA concurrence on alternate methodologies for developing Documented Safety Analyses before authorizing or directing significant time/resources expenditures for developing the Documented Safety Analysis. Site Office Managers must pre-coordinate requests for concurrence on alternate methodologies with the CDNS to help ensure that the methodology will result in a Documented Safety Analysis that meets 10 CFR 830 requirements. Approval of an alternate methodology for developing a Documented Safety Analysis only satisfies the 10 CFR 830 requirement for DOE approval of the methodology. There are other requirements in 10 CFR 830 that the Documented Safety Analysis must meet. If it is not possible to meet all of the Documented Safety Analysis requirements of 10 CFR 830, an exemption to each requirement not being met must also be obtained. NA-1 M 410.1A II-5 I Multiple exemptions can be combined into a single package and submitted with the request for concurrence with the alternate methodology. 2 Each requirement not being met must be specifically addressed, even when combined into a single request. 3 Potential compensatory measures should be addressed. (d) There is no separate process established for obtaining CTA concurrence on alternate methodologies. Persons seeking CTA concurrence on an alternate methodology for developing a Documented Safety Analysis follow the same process as would be used to obtain CTA concurrence on exemptions to 10 CFR 830. (e) Per the DOE FRAM, HSS must also concur on alternate methodologies. Site Office Managers are responsible for coordinating alternative methodologies with and obtaining HSS concurrence prior to approval of the alternate methodology. (f) Although the DOE FRAM requires HSS review and concurrence for alternate methodologies, HSS review and concurrence are not required for exemptions to 10 CFR 830. d. DOE-STD-1083-2009 provides the NNSA CSO 180 days to review exemptions to 10 CFR 830. (1) The CTA evaluation (through the CDNS) occurs in parallel to the CSO evaluation.

(2) ACTA decision on concurrence is issued to the CSO within 180 days except where special circumstances warrant a delay in the decision. (3) If a delay is warranted, the CTA will provide the reason for the delay and the projected decision date in writing to the requesting contractor, the Site Office Manager, and the CSO within 180 days of the request for concurrence. 3. EXPECTATIONS AND GUIDANCE. a. The CTA provides expectations and guidance related to 10 CFR 830 (the Nuclear Safety Management Rule) and the Directives listed in the attachments to this supplemental directive for use by NNSA employees and contractors. II-6 NA-1 M 410.1A Formal CTA expectations and guidance represent the official NNSA position to resolve disputes regarding NNSA expectations on nuclear safety matters. (1) Site Office or Contractor requests must be submitted through the responsible Site Office Manager, and routed to the CTA through the CDNS. (2) | Headquarters-level requests for expectations and guidance must be submitted through the responsible Associate or Deputy Administrator to the CTA, and routed through the CDNS. (3) The CDNS will coordinate with DOE/HSS, affected site offices, and relevant subject matter experts as needed to develop a position to present to the CTA. (4) The CTA response will be issued through the responsible Associate or Deputy Administrator. (5) A summary of the request and response will be published in a subsequent NNSA Technical Bulletin. Advice obtained through formal or informal discussions with CTA staff members does not represent official NNSA expectations or guidance, and is not authoritative for resolving disputes on nuclear safety requirements. Interpretations. (1) — Ascodified in 10 CFR 820.51, the DOE General Counsel is responsible for interpreting the Atomic Energy Act of 1954, as amended, Nuclear Safety Statutes, and DOE Nuclear Safety Requirements as defined in 10 CFR 820. (2) Ifaregulatory interpretation is required pursuant to 10 CFR 820.51, the CTA, with the assistance of the CDNS, formulates a technical position and coordinates it with the NNSA General Counsel for appropriate review and possible issuance by the DOE General Counsel. (3) Expectations and guidance issued by the CTA are not interpretations. (4) | NNSA expectations and guidance must be consistent with interpretations issued by the DOE General Counsel. (5) Should the DOE General Counsel issue an interpretation that is contrary to previous guidance issued by the NNSA CTA, the interpretation takes precedence. NA-1 M 410.1A Il-7 4. OPERATIONAL AWARENESS. a. The CDNS, on behalf of the Administrator and the CTA, conducts biennial reviews, for cause reviews, and assistance visits to address the implementation of the nuclear safety requirements and directives. CDNS reviews evaluate performance in multiple areas, including the contractual treatment of Directives that affect nuclear safety. (1) Justification of the treatment of nuclear safety directives where tailoring processes are used (as discussed in DOE O 410.1) will be evaluated during CDNS biennial reviews. (2) When a contributing cause to a performance issue relates to the treatment of relevant CRD provisions, the treatment of the CRD provision must be explicitly discussed in the report for the review. CDNS reviews draw upon field and headquarters subject matter experts as available for the actual conduct of the reviews. NA-1 M 410.1 Attachment 1-1

DIRECTIVES (LATEST VERSION) REQUIRING CENTRAL TECHNICAL AUTHORITY CONCURRENCE PRIOR TO GRANTING EXEMPTIONS OR EXCEPTIONS This attachment supplements Attachment 1 of DOE O 410.1, and inclusively lists any directives, including supplemental directives or other NNSA issuances, for which Central Technical Authority concurrence is required prior to granting exemptions or exceptions. The contents of this Attachment are updated by the CDNS and are posted in a Portable Document Format (pdf) online at http://hq.na.gov link to NNSA Policies/supplemental directives, or are available from the CDNS at carl.sykes@nnsa.doe.gov. Attachment 1 Page 2 NA-1 M 410.1 This Page Intentionally Blank. NA-1 M 410.1 Attachment 2-1 REGULATIONS AND DIRECTIVES (LATEST VERSION) REQUIRING CENTRAL TECHNICAL AUTHORITY CONCURRENCE PRIOR TO REVISION OR CANCELLATION This attachment supplements Attachment 2 of DOE O 410.1, and inclusively lists any directives including supplemental directives or other NNSA issuances, for which Central Technical Authority concurrence is required prior to providing NNSA concurrence on revisions or cancellations. The contents of this Attachment are updated by the CDNS and are posted in a Portable Document Format (pdf) online at http://hg.na.gov link to NNSA Policies/supplemental directives, or are available from the CDNS at carl.sykes@nnsa.doe.gov.