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the successful completion of a PSC's scope of work. These assessments are conducted as
necessary and often take the form of readiness demonstrations or activity oversight.
Management assessments are also performed. The SIOM contains requirements for
performing management assessments and the Management Assessment Program (MAP),
procedure 3-W24-MA-002 (Ref. Z), establishes the method and processes for plannmg,
scheduling, and performing management assessments by KH. PSCs may use the KH MAP
procedure or develop their own that meets the requirements of the KH procedure. Issues
identified through MAP assessments are recorded, tracked, trended, and corrected in accordance
with the Site Corrective Action Process as discussed below.
Both intennal and external assessments provide assurance that the SMPs are healthy at the
building, project, and Site level with respect to implementation of programmatic requirements.
Issues identified through assessments are managed as described below in Section 3.1.2, Program
Mmuzgement. Facility management is responsible for assuring issues identified during
assessments are screened against this authorization basis (AB), if appropriate.
3.1.2 Program Management
Program owners are responsible for maintaining SMPs in compliance with DOE Orders
contained in the K;H contract. Issues identified regarding lack of compliance at the SMP level
with DOE Order requirements are corrected or a formal exemption request is submitted
Exemptjon requests will be screened through the Unreviewed Safety Question Determination
(USQD) process to determine significance with respect to this AB.
Issues of non-compliances with Site programs are evaluated as issues through the Site
Corrective Action Process, procedure 3-x3 1-CAP-001 (Ref. 3) and the Plant Action Trackzng
System, procedure 1-P04-PATS-16.00 (Ref. 4) or other Quality Program approved alternatlve
deficiency and corrective action tracking systems as defined in the Site Corrective Action
Requirements Mmaal, I-MAN-012-SCARM (Ref. 5). This infrastructure provides for tracking
and trending of individual non-compliances and evaluations of significance. Characterization
information is ideneied for documented deficiencies. These data are recorded and tracked at
the Site level since individual deficiencies may be assigned a low level of significance or risk but
when viewed collectively they may be highly significant. Issues occurring in this facility and
characterized as having high significance through the Corrective Action Process should be
reviewed through the USQD process (Ref. 6) to determine impact on this AB.
The Price-Anderson Amenhents Acts (PAAA) Program Mmd,
l-MAN-022-PAAAPROG (Ref. 7) provides a consistent process for screening and reporting
PAAA applicability for issues associated with nuclear facilities and activities. The PAAA IS
applicable to issues in nuclear facilities if there is a potential noncompliance with a Nuclear
Safety Rule Requirement or if it can be shown that a process used in a nuclear facility IS
deficient and is the: cause of the issue. The mechanisms for identifying items for the PAA4
organization to evaluate include various assessment programs - both internal and external - and
the occurrence reporting process. A screen is performed and significance of individual issues, as
Revision 1
Swtcmher 1999
3-2 Building 99 1 Complex FS.-\R