GN470105, Identifying, Reporting, and Correcting Nuclear and Worker
Safety Issues and Nonconformances
Sponsor: Michael W. Hazen, 4000

Revision Date: October 13, 2009

This document is no longer a CPR. This document implements the requirements of Corporate procedure ESH100.4.RPT.6, Identify, Report, and Correct Nuclear and Worker Safety Issues and Nonconformances.

IMPORTANT NOTICE: A printed copy of this document may not be the document currently in effect. The official version is the online version located on the Sandia Restricted Network (SRN).

GN470105 – IDENTIFYING, REPORTING, AND CORRECTING NUCLEAR AND WORKER SAFETY ISSUES AND NONCONFORMANCES

Subject Matter Expert: Darlene Moore; CA Counterpart: N/A
GN470105, Issue A
Revision Date: October 13, 2009

Change History

APPLICABILITY

Note: This document describes the mechanisms for identifying, reporting, and correcting nuclear and worker safety issues and nonconformances; and the implementation of the Price-Anderson Amendments Act (PAAA) requirements and reporting process.

This document applies to activities performed by Members of the Workforce for the Department of Energy (DOE)

The nuclear safety requirements apply to activities on either Sandia-controlled premises or non-Sandia-controlled premises.

The worker safety requirements apply to activities that support a DOE mission, on DOE sites which are Sandia-controlled premises, and those non-Sandia-controlled premises owned, leased, or controlled by DOE.

Covered activities include those that have the potential to result in:

A nonconformance with DOE Nuclear Safety Requirements as defined in MN471016, Radiological Protection Procedures Manual (RPPM) or Corporate Governance procedures.
Radiological harm, including activities at facilities where nuclear material is not present, but could potentially cause radiological damage at a later time; such as facilities that prepare the nonnuclear components of nuclear weapons.
An occupational exposure to ionizing radiation or radioactive material.
Occupational injuries and illnesses, or unsafe work conditions.
Specific exclusions to this section are described in the following:

MN471016, Radiological Protection Procedures Manual (RPPM), “Introduction,” Section 2.0, “Applicability.”
10 CFR 830, Subpart A, Quality Assurance Requirements, Exclusions.
10 CFR 851.2, Worker Safety and Health Program, Exclusions.

Note: Questions regarding applicability of the PAAA Nuclear Safety Rules or the Worker Safety and Health Program should be forwarded to the Safety and Security Regulatory Support Office (SSRSO) Program Manager or the ES&H Legal contact (as appropriate), and are addressed on a case-by-case basis.

TRAINING

Requirements

Managers shall be responsible for ensuring that MOW, who are involved in activities that may affect nuclear or worker safety, are provided with appropriate training to recognize hazards and ensure that work is performed in accordance with Sandia processes that implement the Nuclear Safety Rules and Worker Safety and Health Program (hereafter referred to as the Safety Rules).

Department managers, facility managers, and Division ES&H Coordinators shall retain applicable training records according to departmental record retention requirements.

Guidance

Work Activity or Role	Required	Recommended
Activities that may affect nuclear or worker safety such as the following: Design Engineering Maintenance Lab operations Construction Service contract oversight and assessments	N/A	PAAA100, Price Anderson Amendments Act: What It Means to You Price-Anderson Amendments Act As It Applies to Sandia National Laboratories PAAA200, Price Anderson Amendment Act GN470106, Safety and Security Regulatory Compliance Requirements

Work Activity or Role

Required

Recommended

Activities that may affect nuclear or worker safety such as the following:

Design
Engineering
Maintenance
Lab operations
Construction

Service contract oversight and assessments

N/A

PAAA100, Price Anderson Amendments Act: What It Means to You
Price-Anderson Amendments Act As It Applies to Sandia National Laboratories
PAAA200, Price Anderson Amendment Act

GN470106, Safety and Security Regulatory Compliance Requirements

Consult the SSRSO Project Manager for any additional training needs.

Note: Managers of the activities that have a potential to result in radiological harm should also complete RAD250, Management of Radiological Operations.

PROCEDURE REQUIREMENTS

Activity	Responsible Individual	Required Action
Assessing Activity Conditions	Department Managers, Facility Managers, and Division ES&H Coordinators	Assess activities and conditions at their facilities for nuclear safety or worker safety issues and nonconformances. Document the results of the assessment of the activities and conditions identified.
Responding to Nuclear Safety or Worker Safety Non-conformances	Department Managers, Facility Managers, and Division ES&H Coordinators	Ensure one of the following reporting processes is followed, as applicable: ESH100.4.RPT.3, Report Occurrences “Radiological Process Improvement Report (RPIR),” in MN471016, Radiological Protection Procedures Manual (RPPM), Chapter 13, “Feedback and Improvement.” Note: For an event that does not qualify as an occurrence but is an issue or nonconformance with the DOE Nuclear Safety Requirements, or the Worker Safety and Health Program (Safety Rules), notify the Sandia Safety and Security Regulatory Support Office (SSRSO) Program Manager. Ensure that a causal analysis is performed and that corrective actions, as applicable, are sufficiently comprehensive to prevent recurrence. See CG100.6.9, Conduct Root Cause Analysis and Extent of Condition Reviews. Ensure that corrective actions are completed in a timely manner. Periodically recheck the corrective actions to ensure they are still in place and continue to be effective.
Keeping an Evidence File	Department Managers, Facility Managers, and Division ES&H Coordinators	Maintain an evidence file for completed corrective actions, (copies of causal analyses, corrective action plans, and corrective action closure evidence). Forward copies of evidence file documents to the SSRSO Program Manager if there is a Safety Rule noncompliance.
Reporting Nuclear Safety or Worker Safety Issues or Non-conformances	Members of the Workforce	Promptly report to their department manager, or as applicable, all nuclear safety or worker safety issues or nonconformances in accordance with: ES&H Corporate procedures MN471016, Radiological Protection Procedures Manual (RPPM). CG100.5, Ensure Quality. Business rules or processes used to protect against the potential of the following: An exposure to ionizing radiation or radioactive material. Radiological harm, including activities at facilities where nuclear material is not present but could potentially cause radiological damage at a later time, such as facilities that prepare the nonnuclear components of nuclear weapons. Occupational injuries and illnesses or unsafe work conditions. Direct questions or concerns regarding Safety Rules nonconformance to their department manager or as described in ESH100.4, Feedback and Improve.
Reviewing Issues and Non-conformances	Sandia Safety and Security Issues Review Committee	Review issues and nonconformances with corporate requirements to determine if they are also noncompliances with the Safety Rules, as described in GN470106, Safety and Security Regulatory Compliance Requirements. Notify the appropriate members of line management of the issue disposition along with any additional required actions.

Guidance

Department managers, facility managers, and division ES&H coordinators should be familiar with the noncompliance reporting criteria by regulation presented in this section. The criteria described are used by the Sandia Safety and Security Issues Review Committee (SSIRC) to evaluate if an identified Sandia nonconformance is also a potential noncompliance with the requirements, procedures, or regulations, associated with the Nuclear Safety Rules or the Worker Safety and Health Program (hereafter referred to as the Safety Rules).

Members of the Workforce should also use these criteria for assessing activities and facilities to identify potential nonconformances with the Safety Rules.

The following reporting sources should be considered when performing periodic assessments for safety rules compliance:

Occurrence Management reports.
Self-assessment reports and Independent assessments.
Radiological Protection Improvement Reports (RPIRs).
Quality reports.
Nonconformances reported by Members of the Workforce.
Management surveillances.
Other sources, as applicable:

DOE evaluations (e.g., DOE facility representative reviews).
Audits by outside agencies (e.g., Defense Nuclear Facility Safety Board).

Distinction between “Nonconformance” and “Potential Noncompliance"

Although the term ‘nonconformance’ appears to be a replacement for the term ‘potential noncompliance,’ they are not substitutes for one another. The following logic string provides the basis for the distinction between these terms.

The criteria described in this attachment are used by the Sandia Safety and Security Issues Review Committee (SSIRC)to evaluate if an identified Sandia nonconformance is also a potential noncompliance with the requirements, procedures, or regulations, associated with the Nuclear Safety Rules or the Worker Safety and Health Program (hereafter referred to as the Safety Rules).

Members of the Workforce should also use these criteria for assessing activities and facilities to identify potential nonconformances with the Safety Rules.

Step	Required Action
1	Members of the Workforce identify an issue, event, or deficiency that is a deviation from a business rule related to the Safety Rules: MN471016, Radiological Protection Procedures Manual (RPPM) CG100.5, Ensure Quality ES&H Corporate procedures These issues/events or deficiencies are recognized as a nonconformance.
2	The appropriate manager assesses the nonconformance per this document. The nonconformance requires review by the SSIRC for Safety Rules requirements. At this point, the issue, event, or deficiency is still a nonconformance.
3	The SSIRC reviews the nonconformance documentation and determines which one of the following responses is applicable: Not a Safety Rules Noncompliance – This is not a nuclear or worker safety rule nonconformance. A Safety Rules Noncompliance that is reportable to the Safety Rules local tracking system – The nonconformance is below the Department of Energy (DOE) Noncompliance Tracking System (NTS) reporting threshold. The nonconformance is defined as a potential noncompliance with a nuclear or worker safety rule and is recorded in the Sandia local tracking system. A Safety Rules Noncompliance that is reportable to the DOE NTS – The nonconformance meets or exceeds the DOE NTS reporting threshold. The nonconformance represents a potential noncompliance with a nuclear or worker safety rule and is reported to the DOE Office of Enforcement (OE) via the NTS Reporting System.
4	DOE OE reviews the NTS potential noncompliance and decides whether it is either: Not a noncompliance and not a violation of the Safety Rules, or A noncompliance and also a violation of the Safety Rules.

Evaluation Assessment Criteria for the Nuclear Safety Rules and Worker Safety and Health Program

Nuclear Safety Rules

The following criteria should be used to assess potential Sandia nonconformances with PAAA Nuclear Safety Rules. If any of the following criteria is applicable then a Nuclear Safety Rules nonconformance could exist. The potential nonconformance should be reported as described in in this document. Refer to the Safety and Security Regulatory Support Program and DNFSB Coordination Office, Nuclear Safety Regulations (formerly PAAA) website for more information.

Note: All of the following criteria are applicable for assessing activities or facilities for potential nuclear safety nonconformance except where specifically noted.

10 CFR 820, Procedural Rules for DOE Nuclear Activities

Criteria	Citation
Records
Information related to a nuclear activity is incomplete or inaccurate in some respect.	10 CFR 820.11(a)
Information related to a nuclear activity concerning a potential noncompliance was concealed or destroyed.	10 CFR 820.11(b)

10 CFR 830, Subpart A, Quality Assurance Requirements

Note: Title 10 CFR 830.2 contains exclusions to 10 CFR 830, Subpart A, Quality Assurance Requirements.

Criteria	Citation
Management
Program
Inadequate description of organizational structure, responsibilities, or authorities.	10 CFR 830.122(a)(1)
Inadequate management processes, including planning, scheduling, or resource allocation.	10 CFR 830.122(a)(2)
Personnel Training and Qualifications
Members of the Workforce were not trained or did not understand the work activity.	10 CFR 830.122(b)(1)
Failure to verify qualification, training, or certification requirements prior to performing or assigning work.	10 CFR 830.122(b)(1)
Inadequate training plans, instruction, trainer qualification, instructional materials, or training program.	10 CFR 830.122(b)(1)
Members of the Workforce do not satisfy qualification or requalification requirements.	10 CFR 830.122(b)(2)
Quality Improvement
Failure to implement the process to detect and prevent quality problems.	10 CFR 830.122(c)(1)
Failure to identify, control, and correct items, services, or processes that do not meet established criteria.	10 CFR 830.122(c)(2)
Failure to correct items, services, or processes to prevent recurrence.	10 CFR 830.122(c)(3)
Failure to review quality-related information to identify items, services, or processes that require improvement.	10 CFR 830.122(c)(4)
Documents and Records
Failure to prepare, review, approve, issue, use, or revise documents to prescribe processes, specify requirements, or establish designs.	10 CFR 830.122(d)(1)
Failure to specify, prepare, review, approve, or maintain records.	10 CFR 830.122(d)(2)
Performance
Work Processes
Failure to use or comply with applicable procedures or work controls.	10 CFR 830.122(e)(1)
Failure to identify and control items to ensure their proper use.	10 CFR 830.122(e)(2)
Failure to establish procedures or other work controls that are commensurate with the significance of the work processes.	10 CFR 830.122(e)(2)
Failure to inform Members of the Workforce of applicable procedures or work controls.	10 CFR 830.122(e)(2)
Failure to control changes to work control documents.	10 CFR 830.122(e)(2)
Failure to control the configuration of engineered safety features related to nuclear or radiological safety.	10 CFR 830.122(e)(2)
Failure to maintain items or equipment to prevent their damage, loss, or deterioration.	10 CFR 830.122(e)(3)
Failure to calibrate and maintain equipment used for process monitoring or data collection.	10 CFR 830.122(e)(4)
Design
Failure to identify design process requirements (e.g., inputs, outputs, verification, documentation, configuration, change control, records).	10 CFR 830.122(f)(1)
Failure of the design input or output processes or controls (drawings, specifications, test or inspection plans, maintenance requirements, etc.) to incorporate applicable design requirements.	10 CFR 830.122(f)(1)
Failure to implement design configuration and design document change controls in accordance with design specification and applicable design procedures.	10 CFR 830.122(f)(1)
Failure to maintain drawings essential to the safe operation of a nuclear facility during normal and abnormal conditions in the “as-built condition.”	10 CFR 830.122(f)(1)
Failure to incorporate applicable requirements and design bases in the design work and design changes.	10 CFR 830.122(f)(2)
Failure to identify and control design interfaces.	10 CFR 830.122(f)(3)
Failure to verify or validate the adequacy of design products or safety features using individuals or groups other than those who have performed the work.	10 CFR 830.122(f)(4)
Failure to verify or validate work before approval and implementation of the design.	10 CFR 830.122(f)(5)
Procurement
Failure of procurement processes to ensure that items and services meet applicable requirements.	10 CFR 830.122(g)(1)
Failure to evaluate and select prospective suppliers on the basis of specified supplier criteria.	10 CFR 830.122(g)(2)
Failure to establish and implement processes to ensure that approved suppliers continue to provide acceptable items and services.	10 CFR 830.122(g)(3)
Inspection and Acceptance Testing
Failure to identify appropriate inspection requirements in written plans or procedures.	10 CFR 830.122(h)(1)
Failure to perform specified inspections or tests using calibrated equipment in accordance with applicable plans or procedures.	10 CFR 830.122(h)(1)
Failure to ensure that inspections and tests are performed by qualified Members of the Workforce who have not performed or supervised the work.	10 CFR 830.122(h)(1)
Failure to identify inspection status or ensure that failed or untested items are properly controlled to prevent inadvertent use.	10 CFR 830.122(h)(1)
Failure to use calibrated and properly maintained test equipment for inspections or tests.	10 CFR 830.122(h)(2)
Assessment
Management Assessment
Failure to perform management assessments in accordance with applicable procedures.	10 CFR 830.122(i)(c)(1)
Failure to recognize significant process-related issues or problems.	10 CFR 830.122(i)(c)(2)
Failure to analyze the cause or establish appropriate actions to correct an identified problem.	10 CFR 830.122(i)(c)(3)
Failure to schedule, track, or complete corrective actions in a timely manner.	10 CFR 830.122(i)(c)(3)
Independent Assessment
Failure to plan or perform independent assessments of activities affecting nuclear safety.	10 CFR 830.122(j)(1)
Failure to use technically qualified and knowledgeable Members of the Workforce who have sufficient authority and freedom from facility management to conduct an independent assessment.	10 CFR 830.122(j)(2); 10 CFR 830.122(j)(3)

10 CFR 830, Subpart B, Safety Basis Requirements

Note: The following 10 CFR 830, Subpart B, criteria apply to hazard category 1, 2, and 3 nuclear facilities (as defined in DOE-STD-1027-99) only.

Criteria	Citation
Safety Basis Requirements
Performance of Work
Failure to perform work in accordance with the safety basis for a nuclear facility or with hazard controls that ensure adequate protection of Members of the Workforce, the public, and environment.	10 CFR 830.201; 10 CFR 830.122(e)(1)
Safety Basis
Failure to establish and maintain the safety basis for a nuclear facility.	10 CFR 830.202(a); 10 CFR 830.202(c)(1); 10 CFR 830.203(g)
Failure to define the scope of work for a nuclear facility	10 CFR 830.202(b)(1)
Failure to identify all hazards associated with work in a nuclear facility.	10 CFR 830.202(b)(2)
Failure to properly categorize a nuclear facility consistent with DOE requirements.	10 CFR 830.202(b)(3)
Failure to properly prepare a documented safety analysis (DSA) or establish hazard controls for a nuclear facility.	10 CFR 830.202(b)(4); 10 CFR 830.202(b)(5)
Failure to submit either the annual documented safety analysis update to DOE or a letter stating no changes since last submission.	10 CFR 830.202(c)(2); 10 CFR 830.202(c)(3)
Failure to incorporate changes directed by DOE.	10 CFR 830.202(c)(2); 10 CFR 830.202(c)(3)
Unreviewed Safety Question
Failure to perform a USQ Determination (USQD) for a temporary or permanent change in a nuclear facility.	10 CFR 830.203(d)(1)
Failure to perform a USQD for a temporary or permanent procedure change.	10 CFR 830.203(d)(2)
Failure to perform a USQD for a test or experiment not described in the DSA.	10 CFR 830.203(d)(3)
Inadequacy or potential inadequacy of a DSA.	10 CFR 830.203(d)(4)
Failure to obtain DOE approval of a USQD before actions involving a USQD are taken.	10 CFR 830.203(e)
Failure to take appropriate action or maintain a nuclear facility in a safe condition upon iscovery of a potential inadequacy in a DSA.	10 CFR 830.203(g)(1)
Failure to notify DOE of a potential inadequacy in a DSA.	10 CFR 830.203(g)(2)
Failure to promptly perform a USQ or notify DOE of the results of a USQ upon discovery of a potential inadequacy in a DSA.	10 CFR 830.203(g)(3)
Failure to submit a safety evaluation to DOE prior to removing any operational restrictions placed on a nuclear facility.	10 CFR 830.203(g)(4)
Documented Safety Analysis (DSA)
Failure to obtain DOE approval for the methodology used in preparing a DSA for a nuclear facility.	10 CFR 830.204(a)
Failure of the DSA to describe the facility or work to be performed.	10 CFR 830.204(b)(1)
Failure to identify all hazards in the DSA.	10 CFR 830.204(b)(2)
Failure to evaluate normal, abnormal, and accident conditions.	10 CFR 830.204(b)(3)
Failure to derive hazard controls.	10 CFR 830.204(b)(4)
Failure to define characteristics of safety management programs to ensure safe operation of the facility.	10 CFR 830.204(b)(5)
Failure to define a criticality safety program to ensure subcritical operations or failure to identify criticality safety standards.	10 CFR 830.204(b)(6)
Technical Safety Requirements (TSRs)
Failure to develop a TSR from the DSA.	10 CFR 830.205(a)(1)
Failure to obtain DOE approval of TSR and any changes to the TSR prior to use.	10 CFR 830.205(a)(2)
Failure to notify DOE of a violation of a TSR.	10 CFR 830.205(a)(3)
Failure to obtain approval for emergency actions that depart from the TSR or to notify DOE of such actions.	10 CFR 830.205(b)
Failure to develop appropriate hazard controls for an environmental restoration activity in lieu of following the applicable TSR.	10 CFR 830.205(c)
New Nuclear Facility or Major Modification to Existing Facility
Failure to prepare a preliminary DSA for a new or soon to be modified facility.	10 CFR 830.206(a)
Failure to obtain DOE approval of the nuclear safety design criteria and the preliminary DSA before construction or procurement of materials/components.	10 CFR 830.206(b)
Doe Approvals
Failure to submit an existing nuclear facility safety basis to DOE for approval by April 10, 2003.	10 CFR 830.207(a)
Failure to perform work in accordance with the safety basis in effect on October 10, 2000 or prior to the submittal of a safety basis in April 2003.	10 CFR 830.207(b)
Failure to restrict operations or modifications to a nuclear facility prior to DOE issuance of a safety evaluation report approving the safety basis.	10 CFR 830.207(d)

10 CFR 835, Occupational Radiation Protection

Criteria	Citation
Occupational Radiation Protection
Administrative Requirements
Failure to maintain or periodically update the radiation protection program document.	10 CFR 835.101
Failure to perform independent assessments of all radiation protection program elements on a 3-year cycle.	10 CFR 835.102
Failure to establish appropriate radiological procedures.	10 CFR 835.104
Failure to implement or follow radiation protection procedures or technical work documents (TWDs).	10 CFR 835.104
Training
Members of the Workforce with radiation protection roles have inappropriate education, training, and skills to supplement their responsibilities.	10 CFR 835.103
Inadequate or incomplete training of visitors, individuals, or Members of the Workforce within regulated areas.	10 CFR 835.103; 10 CFR 835.901
Radiation protection training records not properly maintained.	10 CFR 835.704
Internal and External Exposure
Failure to perform an adequate ALARA review or to prescribe and implement appropriate administrative or design controls to maintain exposure ALARA.	10 CFR 835.1001; 10 CFR 835.1002; 10 CFR 835.1003
Failure to prescribe or use the appropriate level of personal protective equipment for visitors, individuals, or Members of the Workforce.	10 CFR 835.1003; 10 CFR 835.1102(e)
Occupational exposure resulting in a radiation dose above administrative or regulatory limits – except for emergency exposures.	10 CFR 835.202 – 835.208
Failure to properly manage, authorize, document, or monitor an emergency exposure.	10 CFR 835.1301; 10 CFR 835.1302
Failure to properly authorize a planned special exposure.	10 CFR 835.202; 10 CFR 835.204
Doses from natural background or medical treatment included in occupational dose records or calculations.	10 CFR 835.202
Failure to correctly calculate or use total effective dose equivalent for evaluating or documenting occupational dose exposure.	10 CFR 835.203
Failure to properly assess, document, or record non-uniform exposure of the skin.	10 CFR 835.205
Failure to properly control the occupational exposure of a declared pregnant Member of the Workforce.	10 CFR 835.206
Dose equivalent limits for an embryo/fetus, minor, or member of the public in excess of legal limits (above administrative or regulatory limits).	10 CFR 835.206; 10 CFR 835.207; 10 CFR 835.208
Failure to properly assess or document an internal dose.	10 CFR 835.209
Area Monitoring
Failure to properly perform radiation monitoring of individuals, areas, or items to demonstrate compliance with radiation protection procedures.	10 CFR 835.401(a)
Failure to properly calibrate, select, test, or use appropriate radiation monitoring or air sampling equipment.	10 CFR 835.401(b)
Failure to perform appropriate air monitoring.	10 CFR 835.209; 10 CFR 835.403
Improper package receipt survey of package containing radioactive material.	10 CFR 835.405(a); 10 CFR 835.405(b); 10 CFR 835.405(c)
Failure to complete a package receipt survey as soon as practicable and not later than 8 hours after the beginning of the work activity following receipt of the package.	10 CFR 835.405(d)
Individual Monitoring
Failure to properly specify, issue, or use personal dosimeters for routine operations, an emergency, or accident situation by Members of the Workforce.	10 CFR 835.402(a); 10 CFR 835.1304
Failure to properly implement internal or external dose monitoring to demonstrate compliance with 10 CFR 835 dose limits.	10 CFR 835.402(b); 10 CFR 835.405(c); 10 CFR 835.405(d)
Failure to properly monitor persons exiting radiological areas for radioactive contamination.	10 CFR 835.1102(d)
Entry Control
Failure to properly control entry to a radiological area.	10 CFR 835.501(a); 10 CFR 835.501(b); 10 CFR 835.501(c)
Failure to issue or acquire written authorizations for entry into or work within a radiological area.	10 CFR 835.501(d)
Failure to implement proper entry or emergency evacuation controls for a high or very-high radiation area.	10 CFR 835.502
Posting and Labeling
Postings or labels not clearly marked or conspicuously displayed in accordance with procedures.	10 CFR 835.601; 10 CFR 835.602; 10 CFR 835.603; 10 CFR 835.604
Boundaries of controlled, radiological, or radioactive material areas not clearly identified or properly posted.	10 CFR 835.603
Improperly labeled items or containers.	10 CFR 835.605; 10 CFR 835.606
Records and Reports
Failure to generate, maintain, administer, or retain radiation protection or individual monitoring records in accordance with procedures.	10 CFR 835.701; 10 CFR 835.702; 10 CFR 835.703; 10 CFR 835.704
Failure to properly report or disclose individual exposure or dose information.	10 CFR 835.801
Design and Control
Failure to maintain ALARA radiation exposures through active or passive design features or administrative controls.	10 CFR 835.1001
Failure to consider, specify, implement, or document appropriate ALARA objectives when designing new facilities or modifying existing facilities.	10 CFR 835.1002
Failure of active or passive design features or administrative controls to maintain ALARA individual exposures during routine operations.	10 CFR 835.1003
Contamination Control
Contamination spread from a radiological area to a controlled or uncontrolled area.	10 CFR 835.1101; 10 CFR 835.1102
Contamination or contaminated item discovered outside of a controlled area or at an off-site location.	10 CFR 835.1101; 10 CFR 835.1102
Failure to control a fixed contamination area in accordance with procedures.	10 CFR 835.1102(b); 10 CFR 835.1102(c)
Failure to specify or use adequate personal protective equipment for entry into or work within a radiological area.	10 CFR 835.1102(e)
Discovery of skin or clothing contamination.	10 CFR 835.1102
Sealed Source Control
Source not controlled (e.g., stored, used, handled) in a manner that commensurate with its hazard.	10 CFR 835.1201
Accountable sealed source not inventoried at least once every 6 months.	10 CFR 835.1202(a)
Leak test for accountable sealed source neither performed initially, during suspected damage, nor at least once every 6 months with the exception of sources made of solely gaseous radioactive material or tritium.	10 CFR 835.1202(b)
Leak test not adequate or capable of testing radiological material at or below the acceptable range.	10 CFR 835.1202(b)
Accountable sealed source lost or misplaced.	10 CFR 835.1202(a)
Leaking source not controlled in a manner that prevents the spread of contamination.	10 CFR 835.1202(e)

Worker Safety and Health Program

The following criteria should be used to assess potential Sandia nonconformances with the Worker Safety and Health Program requirements (criteria listed below is a modified excerpt from 10 CFR 851). If any of the 10 CFR 851 criteria, as described below, is applicable then a nonconformance could exist. The potential nonconformance should be reported as described in this document.

10 CFR 851, Worker Safety and Health Program

Criteria	Citation
General Requirements
With respect to a covered workplace for which a contractor is responsible, the contractor does not: provide a place of employment that is free from recognized hazards that are causing or have the potential to cause death or serious physical harm to workers	10 CFR 851.10 (a)(1)
Hazard Identification and Assessment
Contractors has not established procedures to identify existing and potential workplace hazards and assessed the risk of associated workers injury and illness.	10 CFR 851.21 (a)
Hazard Prevention and Assessment
Contractors has not established and implemented a hazard prevention and abatement process to ensure that all identified and potential hazards are prevented or abated in a timely manner.	10 CFR 851.22 (a)
Safety and Health Standards
Contractors does not comply with the following safety and health standards that are applicable to the hazards at their covered workplace: ( 1) Title 10 Code of Federal Regulations (CFR) 850, “Chronic Beryllium Disease Prevention Program.” (2) Title 29 CFR, Parts 1904.4 through 1904.11, 1904.29 through 1904.33; 1904.44, and 1904.46, “Recording and Reporting Occupational Injuries and Illnesses.” (3) Title 29 CFR, Part 1910, “Occupational Safety and Health Standards,” excluding 29 CFR 1910.1096, “Ionizing Radiation.” (4) Title 29 CFR, Part 1915, “Shipyard Employment.” (5) Title 29 CFR, Part 1917, “Marine Terminals.” (6) Title 29 CFR, Part 1918, “Safety and Health Regulations for Longshoring.” (7) Title 29 CFR, Part 1926, “Safety and Health Regulations for Construction.” (8) Title 29 CFR, Part 1928, “Occupational Safety and Health Standards for Agriculture.” (9) American Conference of Governmental Industrial Hygienists (ACGIH), “Threshold Limit Values for Chemical Substances and Physical Agents and Biological Exposure Indices,” (2005) (incorporated by reference, see § 851.27) when the ACGIH Threshold Limit Values (TLVs) are lower (more protective) than permissible exposure limits in 29 CFR 1910. When the ACGIH TLVs are used as exposure limits, contractors must nonetheless comply with the other provisions of any applicable expanded health standard found in 29 CFR 1910. (10) American National Standards Institute (ANSI) Z88.2, “American National Standard for Respiratory Protection,” (1992) (incorporated by reference, see § 851.27). (11) ANSI Z136.1, “Safe Use of Lasers,” (2000) (incorporated by reference, see § 851.27). (12) ANSI Z49.1, “Safety in Welding, Cutting and Allied Processes,” sections 4.3 and E4.3 (1999) (incorporated by reference, see § 851.27). (13) National Fire Protection Association (NFPA) 70, “National Electrical Code,” (2005) (incorporated by reference, see § 851.27). (14) NFPA 70E, “Standard for Electrical Safety in the Workplace,” (2004) (incorporated by reference, see § 851.27).	10 CFR 851.23 (a) (1-14)
Functional Area
Contractor does not have a structured approach to their worker safety and health program which at a minimum, includes provisions for the following applicable functional areas in their worker safety and health program: construction safety; fire protection; firearms safety; explosives safety; pressure safety; electrical safety; industrial hygiene; occupational medicine; biological safety; and motor vehicle safety.	10 CFR 851.24 (a)
Contractor does not comply with the applicable standards and provisions in Appendix A of this part, entitled “Worker Safety and Health Functional Areas.”	10 CFR 851.24 (b)
Worker Safety and Health Functional Areas
Contractor does not comply with the appendix that establishes the mandatory requirements for implementing the applicable functional areas required by § 851.24. Construction Safety Fire Protection Explosives Safety Pressure Safety Firearms Safety Industrial Hygiene Biological Safety Occupational Medicine Motor Vehicle Safety Electrical Safety Nanotechnology Safety Workplace Violence Prevention	Appendix A to Part 851

RELATED HAZARDS & ACTIVITIES

Hazards and activities related to reporting Safety Rules nonconformances include:

Hazard/Activity	Reference
Activities at nuclear facilities or that have the potential to result in an occupational exposure to ionizing radiation or radioactive material	GN470080, Implementing the Unreviewed Safety Question (USQ) Process for Nuclear Facilities. GN470101, Preparation and Review of Documented Safety Analyses (DSAs) and Technical Safety Requirements (TSRs) to Meet 10 CFR 830, Subpart B. MN471016, Radiological Protection Procedures Manual.
Worker Safety and Health	ES&H Corporate Procedures
Causal analysis and corrective actions	CG100.6.6, Perform Corrective Actions CG100.6.9, Conduct Root Cause Analysis and Extent of Condition Reviews MN471016, Radiological Protection Procedures Manual (RPPM), Chapter 13, “Feedback and Improvement.”
Reporting ES&H concerns	ESH100.4, Feedback and Improve MN471016, Radiological Protection Procedures Manual (RPPM), Chapter 13, “Feedback and Improvement.”
Reporting Quality concerns	CG100.5, Ensure Quality

REFERENCES

Requirements Source Documents

10 CFR 708, DOE Contractor Employee Protection Program.

10 CFR 820, Procedural Rules for DOE Nuclear Activities.

10 CFR 830, Nuclear Safety Management.

10 CFR 835, Occupational Radiation Protection.

10 CFR 851, Worker Safety and Health Program.

Implementing Documents

PG470246, Sandia National Laboratories 10 CFR 851 Worker Safety and Health Protection Program (WSHPP).

PG470208, Nuclear and Worker Safety Requirements Program Plan.

GN470105 – IDENTIFYING, REPORTING, AND CORRECTING NUCLEAR AND WORKER SAFETY ISSUES AND NONCONFORMANCES

Contents

APPLICABILITY

TRAINING

Requirements

Guidance

PROCEDURE REQUIREMENTS

Guidance

Distinction between “Nonconformance” and “Potential Noncompliance"

Evaluation Assessment Criteria for the Nuclear Safety Rules and Worker Safety and Health Program

Nuclear Safety Rules

Worker Safety and Health Program

RELATED HAZARDS & ACTIVITIES

REFERENCES

Requirements Source Documents

Implementing Documents

Related Documents