APPROVAL BASES FOR DOCUMENTED SAFETY ANALYSES
DOE evaluates the DSA by considering the extent to which the DSA (1) adequately addresses
the criteria set forth in 10 CFR 830.202 and 10 CFR 830.204 and (2) satisfies the provisions of
the methodology used to prepare the DSA. DSA review and approval focuses on the adequacy
of the following approval bases:
Hazard and accident analyses;
Safety structures, systems, and components;
Derivation of technical safety requirements ; and
Safety management program characteristics.
Once technical justification exists to support conclusions that the DSA adequately describes how
the facility is satisfactory with respect to the approval bases, the DSA may generally be
considered adequate. These approval bases also form the foundation for documenting DSA
approval in a SER.
Base information is the first of the approval bases that should be reviewed and
encompasses elements of DSA preparation, completeness, and general content. Base
information is not reviewed for accuracy in and of itself but for sufficiency to allow
assessment of the other approval bases that rely on this inform ation. The review for
sufficiency can range from a simple screening effort to more detailed discussions,
depending on the complexity of the DSA.
Insufficient or incomplete base information in a DSA may prevent further review of the
DSA. Reviewers should require resolution of major discrepancies in base information
(e.g., incomplete site characteristics) before evaluation of the more specific aspects (e.g.,
hazard and accident analyses) of the safety basis proceeds. It is for this reason that the
SER nee d only provide a brief statement as to the adequacy of base information.
For example, for DSAs adhering to DOE-STD -3009 Change Notice No. 2 format, the
review of base information primarily determines the sufficiency of the information
provided in the Exec utive Summary, Site Characteristics (Chapter 1), Facility Description
(Chapter 2), and to some extent material generic to all DSA chapters (e.g., statutes,
rules, Orders, and principal health and safety criteria). Determining the adequacy of base
information generally entails being able to conclude that the DSA contains sufficient
documentation and basis to arrive at the following conclusions:
The facility contractor development and approval processes (e.g.,
personnel involvement in developing the DSA, ma nagement cognizance
and acceptance, internal reviews, etc.) demonstrate sufficient
commitment to establish the facility safety basis.
The facility mission(s) and scope of operations (i.e., the scope of work to
be performed) for which safety basis approval is being sought are clearly
stated and reflected in the type and scope of operations analyzed in the
DSA. For example, a DSA documenting the safety basis of a spent fuel
storage facility whose mission includes size reduction of spent fuel
elements would be unacceptable if the DSA omitted safety analysis of
size reduction operations.