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Enforcement Guidance Supplement 99-01: Enforcement of 10 CFR Part 830.120 (Quality Assurance Rule) for Facilities below Hazard Category III

Section 1.3 of the Operational Procedures for Enforcement, published in June 1998, provides the opportunity for the Office of Enforcement and Investigation (EH Enforcement) periodically to issue clarifying guidance regarding the processes used in its enforcement activities.

During the past 18 months, EH Enforcement has identified a number of examples in which both DOE and contractor organizations have incorrectly exempted activities from applicability of the DOE Quality Assurance Rule 10 CFR 830.120 (QA Rule). The contractors excluded these activities on the basis that the QA Rule did not apply if the activity was classified as less than a Hazard Category III under DOE Standard 1027-92 (Hazard Categorization and Accident Analysis Techniques for Compliance with DOE Order 5480.23, Nuclear Safety Analysis Reports). Standard 1027 provides guidance for determining whether a facility, activity or area requires a Safety Analysis Report but it does not provide a basis for exclusion from the provisions of the QA Rule.