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Safety Management Program Commitments
Preparation Guide for U
Technical safety requirements - doe-std-3009-94_cn3_3-30-060035

DOE-STD -3009-94
of the summary invalid.
By virtue of application of the graded approach, the majority of the engineered feat ures in
a facility will not be identified in the categories of safety-class or safety-significant SSCs
even though they may perform some safety functions. However, such controls noted as a
barrier or preventive or mitigative feature in the hazard and accident analyses must not be
ignored in managing operations. Such a gross discrepancy would violate the safety basis
documented in the DSA even if the controls are not designated safety-class or
safety-significant, because programmatic commitments extend to these SSCs as well. For
example, the commitment to a maintenance program means that the preventive and
mitigative equipment noted as such in the DSA hazard analysis is included in the facility
maintenance program. As a minimum, all aspects of defense in depth identified must be
covered within the relevant safety management programs (e.g., maintenance, quality
assurance) committed to in the DSA. The details of that coverage, however, are developed
in the maintenance program as opposed to in the DSA. Facility operators are expected to
have noted the relative significance of these engineered features and have provided for
them in programs, in keeping with standard industrial practice, based on the importance of
the equipment. It is the fact of coverage that is relevant to the facility safety basis. The
details of this programmatic coverage (i.e., exact type of maintenance items and associated
periodicities) are not developed in or part of the DSA.
An overall commitment made in a DSA is that the contractor will not change the facility
configuration underlying the documented safety basis without implementing and
completing the unreviewed safety question (USQ) process. However, situations do occur
where a USQ process is not necessary. For example, a stipulat ion to have a radiation
protection program in the administrative control section of the TSR is a commitment;
however, changes to specific program provisions do not require going through the USQ
process. Further clarification of such interpretations can be found in DOE G 424.1-1,
"Implementation Guide for Use in Addressing Unreviewed Safety Question (USQ)
DOE facilities that use and rely on site-wide, safety support services, organizations, and
procedures, may summarize the applicable site-wide documentation provided its interface
with the facility is made clear. The DSA then notes whether the reference applies to a
specific commitment in a portion of the referenced documentation or is a global
commitment to maintaining a program for which a number of details may vary without
affecting the global commitment. Any documents referenced in the DSA are to be made
available upon request.
TSR and SSC Commitments
In order to comply with 10 CFR 830, specific safety controls are to be developed in the
DSA. In keeping with the graded-approach principle, distinctions are made to avoid
wasting effort by providing detailed descriptions of all facility SSCs. While a basic
descriptive model of the facility and its equipment must be provided in Chapter 2,
"Facility Description," highly detailed descriptions are reserved for two categories of
SSCs comprising the most crucial aspects of facility safety. These two categories are
safety-class SSCs and safety-significant SSCs.
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