D-_10_(15_of_18)_N3B-AP-ER-0002,_r.0_Peer_Review_of_Documents.Deliverables.pdf

N3B-AP-ER-0002, R0

Peer Review of Documents/Deliverables

Effective Date: 2/13/19

Next Review Date: 2/13/22

Hazard Class: Low Moderate High/Complex Usage Mode: Reference UET Both UET & Reference

The Responsible Manager has determined that the following organizations’ review is required for initial procedure release as well as subsequent major revisions. Review documentation is contained in the Document History File.

RCRA Remediation, Regulatory Documentation Group RCRA Remediation, Remediation Science and Engineering Regulatory and Stakeholder Interface, Regulatory Compliance Quality Assurance

Classification Review: Unclassified UCNI Classified

Tracy Drake / 140891 / Signature on File / 1/28/19 Name (print) Z# Signature Date

Responsible Manager, Division and Title

Pamela Maestas / 112829 / Signature on File / 2/5/19 Name (print) Z# Signature Date

Working Copy / Information Only (circle one) Initials / Date: /

RFP-0000300

Document No.: N3B-AP-ER-0002 Peer Review of Documents/Deliverables Revision: 0 Effective Date: 2/13/19 Reference Page: 2 of 13

REVISION HISTORY

Document No./Revision No. Effective Date Action Description EP-DIR-AP-10070, R0 6/13/2013 New procedure

This procedure supersedes SOP-4005.

This procedure defines the process for review of documents generated by Environmental Programs Directorate organizations.

Updated title and procedure number; added specific instructions for decision reviews;

and tied this procedure to the communication record procedure.

Incorporated DOE findings in its analysis of the EP FY2013 Peer Review and Support Documents.

EM-AP-10088, R0 12/21/2016 New procedure This procedure was cancelled in the ADEM system and is being reissued as a new procedure with a new number. Major changes include clarifying the length of the peer reviews and incorporating the relationship of communication records to the decision peer review process.

EM-AP-10088, R1 2/13/17 Major Revision Revised Attachment 2, Review, Approval, and Signature Matrix.

N3B-AP-ER-0002, R0 2/13/19 New procedure This procedure is being reissued as a new N3B procedure with a new number. Major changes include clarifications on work flow and terminology to reflect N3B practices in support of the LLCC. This document supercedes Blue Sheeted EM-AP-10088.

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TABLE OF CONTENTS

Section Page

TITLE PAGE

REVISION HISTORY

TABLE OF CONTENTS

1. PURPOSE

2. SCOPE

3. APPLICABILITY

4. REFERENCES

5. RESPONSIBILITIES

6. PRECAUTIONS AND LIMITATIONS

7. PREREQUISITE ACTIONS

7.1 Training

7.2 Planning and Coordination

7.3 Materials and Equipment

8. REVIEW PROCESS

8.1 Review Request

8.2 Review Notification

8.3 Review Proceedings

8.4 Comment Resolution

9. RECORDS

10. APPENDICES

Appendices

Appendix A, Peer Review Process Flow Chart Appendix B, Review, Approval, and Signature Requirements for Document Reviews Appendix C, Example Regulatory Documentation Comment/Resolution Form

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1. PURPOSE

This procedure describes the process for reviewing documents prepared by Newport News Nuclear

BWXT–Los Alamos, LLC (N3B) in support of the Los Alamos Legacy Cleanup Contract (LLCC).

This procedure applies to, but is not limited to, regulatory documents prepared by the Environmental Remediation (ER) Program and submitted to the New Mexico Environment Department (NMED), U.S. Department of Energy (DOE), or the U.S. Environmental Protection Agency (EPA) or documents submitted to local and tribal governments or any other outside entity.

This process guides staff in conducting peer reviews and identifying review requirements and reviewer responsibilities (see Appendices A and B). The review process ensures that management is in alignment with key decisions, such as readiness for work or submittal of critical documents.

Reviews are performed by qualified technical personnel with sufficient independence to ensure that criteria, assumptions, methodology, and conclusions are appropriate for a given document.

2. SCOPE

A peer review is a mandatory review of a 95% complete draft of a document that focuses on clarity of presentation and approach and on consistent, appropriate format and content.

The peer review draft should receive a pre-review edit and composite. This draft includes all pertinent sections for a formal review and indicates “Peer Review Draft” on the document cover.

The peer review requires, at a minimum, technical subject matter experts (SMEs), Regulatory and Stakeholder Interface (R&SI) staff, applicable N3B management, and DOE staff. Other reviewers are required as applicable, such as N3B legal counsel, geographic information system (GIS) staff, data stewards, risk assessors, and staff from Quality Assurance and Transformation. Appendix B outlines the review, approval, and signature requirements for documents.

Reviewers are given up to 5 business days to review and comment on smaller documents (i.e., fewer than 20 pages of text), at least 5 business days to review and comment on midsize documents, and 10 business days to review larger, more complex documents (i.e., more than 50 pages of text). Documents on an expedited schedule may require a shorter review period and fewer reviewers.

Correspondence (other than cover letters) is given a 1- to 2-day review by technical SMEs, N3B management, DOE, and N3B legal (if applicable).

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3. APPLICABILITY

Peer review is part of the document development for environmental deliverables process (N3B-AP-

ER-0001) and is mandatory for deliverables due to NMED and EPA, reports and plans for local and tribal governments, and any other document being delivered to an outside entity. It is recommended for products to DOE (e.g., contract deliverables). Appendix B provides the review, approval, and signature requirements for various document types.

Peer review includes a review notification request from the Regulatory Documentation Manager to reviewers via email and will include a PDF of the draft document along with the comment/resolution form. Large files will be transferred using a common drive or other means.

The reviewer must use the form to provide any comments unless otherwise indicated in the request.

The author must respond to all reviewer comments, meet with the reviewers to obtain their signatures, and return the completed forms to the Regulatory Documentation Manager. Review is complete only when all required comments from reviewers have been resolved and documented on N3B-Form-6124, Regulatory Documentation Comment/Resolution Form, and the form is signed (see Appendix C for an example).

NOTE A completed N3B-Form-6124 for the associated document contains the reviewer comments, author resolution, and reviewer signature. Completed comment/resolution forms end the review process.

4. REFERENCES

N3B-AP-ER-0001, Document Development for Environmental Deliverables

N3B-Form-6123, Document Services Request Form

N3B-Form-6124, Regulatory Documentation Comment/Resolution Form

5. RESPONSIBILITIES

Project Manager/Author/Designee

• Completes N3B-Form-6123, Document Services Request Form, using the matrix in Appendix B to help identify reviewers, and requests a peer review in accordance with N3B- AP-ER-0001, Document Development for Environmental Deliverables.

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• Provides the review draft to Regulatory Documentation team for editing and compositing.

• Reconciles reviewer comments via N3B-Form-6124, Regulatory Documentation Comment/Resolution Form, and obtains reviewer signature to complete the review process.

• Returns completed and signed comment/resolution forms to the Regulatory Documentation Manager.

Regulatory Documentation Manager

• Sends out the review notification via email, sends out reminders when comments are due, and maintains all reviewer-completed comment/resolution forms.

Subject Matter Experts

• Provide comments in their areas of expertise on the comment/resolution form for each document/deliverable assigned.

6. PRECAUTIONS AND LIMITATIONS

Comments provided after the required review date will not be considered part of the formal review process without advance notification to the author/designee. If the schedule permits, the author/designee will be encouraged to incorporate late comments as appropriate and follow the formal comment resolution process.

7. PREREQUISITE ACTIONS

7.1 Training

Personnel using this procedure are expected to have completed basic site and job function training.

No additional training is required to execute this procedure.

7.2 Planning and Coordination

The project manager/author/designee must include time in the document schedule to conduct the peer review and resolve comments.

7.3 Materials and Equipment

No materials or equipment are required for this procedure beyond standard office equipment.

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8. REVIEW PROCESS

8.1 Review Request

Project Manager/Author/Designee [1] REQUESTS the appropriate review by completing and submitting N3B-Form-6123, Document Services Request Form, to the Regulatory Documentation Manager in accordance with N3B-AP-ER-0001, Document Development for Environmental Deliverables.

NOTE See Appendix B for the document review, approval, and signature requirements to determine who must be included in the peer review.

[2] LISTS appropriate reviewers on N3B-Form-6123, Document Services Request Form (e.g., SMEs, R&SI staff, applicable N3B management, and DOE staff).

[3] If necessary, INDICATES the section(s) reviewers should focus and comment on, if not the entire document.

[4] PROVIDES the Regulatory Documentation Manager with an electronic version of the 95% draft of the document, including appendixes and attachments.

NOTE Reviewers receive N3B-Form-6124, Regulatory Documentation Comment/Resolution

Form (see example in Appendix C) when they receive the peer review email notification from the Regulatory Documentation Manager.

8.2 Review Notification

Regulatory Documentation Manager [1] RECEIVES a completed N3B-Form-6123, Document Services Request Form, and the 95% draft document.

[2] SETS UP the electronic folder that includes the review request and comment/resolution form.

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[3] DRAFTS the email to the reviewers transmitting the 95% draft document and the associated

N3B-Form-6124, Regulatory Documentation Comment/Resolution Form, and INCLUDES the following information:

• Title of the document to be reviewed

• Person receiving and reconciling comments

• Due date for comments to be received

• Any special review requirements provided by the project manager/author on the associated N3B-Form-6123, Document Services Request Form.

[4] EMAILS the review notification, 95% draft document, and comment/resolution form to reviewers.

8.3 Review Proceedings

Reviewer [1] FOLLOWS the guidance in the Regulatory Documentation Manager’s email review notification.

[2] READS the original document in its entirety (unless otherwise instructed) to ensure technical accuracy and consistency with previous approaches and document types.

[3] CONCENTRATES on the technical content of the document, focusing on area of expertise.

[4] RECORDS all comments on the N3B-Form-6124, Regulatory Documentation Comment/Resolution Form, that was provided with the draft document or as otherwise indicated. INCLUDES entries that are informative and that address the issues completely to encourage an effective response to comment(s).

NOTE Only comments entered on N3B-Form-6124, Regulatory Documentation

Comment/Resolution Form, or as specified by the review notification are considered mandatory; therefore, the author is not required to address comments transmitted by other means. If previously agreed upon, tracked changes in documents reviewed electronically may be acceptable, or comments may be recorded in the margins of the hard copy document and returned, along with N3B-Form-6124, to the project manager/author/designee.

[5] ENSURES comments are incorporated and/or addressed.

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[6] SUBMITS the completed N3B-Form-6124 to the project manager/author/designee and the

Regulatory Documentation Manager.

8.4 Comment Resolution

Project Manager/Author/Designee

NOTE Comments require resolution acceptable to the reviewer or elevation to management, as in 8.4 [4] below. Recommendations as they appear on the associated N3B-Form-6124 are incorporated as appropriate.

[1] RESOLVES all comments as indicated on the submitted comment/resolution forms

(N3B-Form-6124).

[2] DOCUMENTS the resolution on each associated comment/resolution form

(N3B-Form-6124) and RETURNS them to the reviewers for concurrence and signature.

Reviewer [3] CONCURS with the project manager’s/author’s responses by signing the associated

N3B-Form-6124.

Reviewer/Project Manager/Author/Designee [4] IF an issue cannot be resolved between a reviewer and the project manager/author/designee, THEN BRINGS the issue to the attention of the program director.

[5] WORKS with the program director to discuss and resolve the issue(s), and COMPLETES the associated N3B-Form-6124.

Project Manager/Author/Designee [6] REQUESTS document files from the Regulatory Documentation team to incorporate changes based on comments. USES tracked changes in Microsoft Word files.

[7] TRANSMITS the completed and signed N3B-Form-6124 comment/resolution forms to the Regulatory Documentation Manager.

NOTE Completed forms include reviewer comments, the project manager’s/author’s resolutions to the comments, and the signature of each reviewer if the standard peer review process is used.

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[8] SUBMITS peer-reviewed document with changes incorporated to the Regulatory

Documentation team for final editing and compositing.

Regulatory Documentation Manager [9] SCANS the completed N3B-Form-6124 comment/resolution forms, and ARCHIVES each reviewer’s form as a PDF in the document folder.

9. RECORDS

The completed N3B-Form-6124, Regulatory Documentation Comment/Resolution Forms, that are generated as a result of this procedure are archived by the Regulatory Documentation team, but they are not submitted to Records Management.

Record Identification Record Type

Determination Protection/Storage

Methods Processing

Information None

10. APPENDICES

Appendix A: Peer Review Process Flow Chart Appendix B: Review, Approval, and Signature Requirements for Document Reviews Appendix C: Example Regulatory Documentation Comment/Resolution Form

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APPENDIX A

Peer Review Process Flow Chart

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APPENDIX B

Review, Approval, and Signature Requirements for Document Reviews

Editing and Composition

Peer Review Da ta S te wa rd

(a s a pp lic ab le)

Ge og ra ph ic In fo rm at io n Sy st em pp lic

Re gu lat or y Co m pl ian ce

En gi ne er in g

(a s a pp lic

Qu ali ty A ss ur an ce pp lic

Le ga l C ou ns el

(a s a pp lic

DO

E

Re vie we r

Pr oj ec t

Ma na ge r

Pr og ra m

Di re ct or

Un re vie we d Sa fe ty

Qu es tio n Re vie we r (a s a pp lic

Signatures Required

Document Type

N3B ER Program

Manager

N3B RS&I/Other

Program Manager

N3B Program Manager

Owner/ Operatora and Engineering Certification

Program/ Permitting Manager

DOE

Deliverables under the Compliance Order on Consent

(NMED) or the Individual Permit for Storm Water (EPA) X X X X X X — X X X X — X — — — X

Other deliverables and products to NMED and EPA X X X X X X — X X X X — X X — — X Deliverables and products to DOE X R X X — X — X — X X — — X X — — Access agreement X X — X X X — X X X X — X — — — X Correspondence (external, notification) X X — — X X — X X X X — Xb Xb Xb — Xb Memorandum of understanding X X — — X — X X X X X — — X X — X Remedy completion or closure plan/report X X X X X X — X X X X — X X X X X Risk assessment methodology X X — — X — X — X X — — X — — — X Safety and security plan/report — X — — — — X — X X — — — X — — — Statement of work/task order R X — — — — X — — X — — — — — — Waste characterization strategy form and amendmentsc R X — — — — — — — X — X — — — — —

Notes: X = Required. — = Not required. R = Recommended. Some authorizations do not appear on the blue folder signature form. Author review and approval are required for all documents. All documents to NMED require editing and composition by the Regulatory Documentation team. All final documents must be submitted to Records Management.

a Owner/operator certification pursuant to 20.4.1.900 New Mexico Administrative Code, 270.11(b–d) is required for final remedy completion reports and closure plans/reports. An engineering certification is also required.

b As applicable.

c Technical reviewers for waste characterization strategy forms/amendments are also the waste management coordinators. Note: Other waste/field documents such as integrated work documents, site-specific health and safety plans, and field implementation plans may be completed by subcontractors but should be peer-reviewed. Waste profile forms are completed using the N3B Waste Compliance and Tracking System.

Peer Review of Documents Revision: 0

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APPENDIX C

Example Regulatory Documentation Comment/Resolution Form

(Obtain the current version of N3B-Form-6124 from the Regulatory Documentation Manager or Document Control)