Worker Safety - doe-std-3009-94_cn3

DOE-STD -3009-94

The process of developing a DSA is a process that may require numerous iterations

depending on the complexity of the facility and the level of detail required. The hazard

and accident analyses (hazard analysis is adequate for Category 3 facilities) are the central

elements of this process. The results of the hazard analysis form the basis for grading the

level of detail necessary to ensure an acceptable DSA. The hazard analysis specifically

identifies safety-significant SSCs and SACs for defense in depth and worker safety, and

TSR controls. The results of the accident analysis form the basis for determining

additional safety controls imposed on the facility (e.g., safety-class SSCs and TSRs) as a

function of the Evaluation Guideline. These specific controls are then factored into overall

safety management programs that ensure the operational discipline required by the hazards

identified is maintained.

Several specific topics are directly relevant to understanding the conceptual basis of this

Standard. These topics are worker safety, defense in depth, programmatic commitment s,

SSC and TSR commitments, and correlation of this Standard to 10 CFR 830 requirements.

The remainder of this section discusses each of these topics in discrete subsections.

Worker Safety

Workers, typically those in close proximity to operations, are the population principally at

risk from potential consequences associated with Hazard Category 2 and 3 facilities. The

DOE recognizes, via 10 CFR 830, the importance of including worker safety in safety

analyses by specifically noting the worker as a populat ion of concern. Developing a

conceptual basis for the methodology used in this Standard requires answering the

fundamental question of how worker safety is most appropriately addressed in the DSA.

The Occupational Health and Safety Administration (OSHA) has published 29 CFR

1910.119, "Process Safety Management of Highly Hazardous Chemicals." OSHA defines

the purpose of this regulation in summary fashion as, "Employees have been and continue

to be exposed to the hazards of toxicity, fires, and explosions from catastrophic releases of

highly hazardous chemicals in their workplaces. The requirements in this standard are

intended to eliminate or mitigate the consequences of such releases." Many of the topics

requiring coverage in this federal regulation, such as design codes and standards, process

hazard analysis, human factors, training, etc., are directly parallel to the requirements in 10

CFR 830.

DOE O 440.1 and the OSHA standard address the issue of worker safety from process

accidents by requiring the per formance of hazards analyses for processes (exclusive of

standard industrial hazards) in conjunction with implementation of basic safety programs

that discipline operations and ensure judgments made in hazard analyses are supported by

actual operating cond itions. These requirements effectively integrate programs and

analyses into an overall safety management structure without requiring quantitative risk

assessment. This integration and the basic concepts of Process Safety Management (PSM)

described by OSHA regulations and the manuals and codes of practice described in DOE

O 440.1 are philosophically accepted as appropriate for DSAs. This Standard effectively

merges PSM principles with traditional DSA precepts.

Page 6