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Formulation of SACs - Continued - std118620040017
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Specific Administrative Controls - index
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Configuration Management - std118620040019


DOE-STD-1186-2004
will need to be performed to substantiate the available time interval necessary to accomplish
the task. Consequences of incorrect implementation of the control should be evaluated and
measures to prevent control failure should be factored into the control formulation.
If SACs require operator action and perform a function similar to a SC SSC, a human
reliability assessment (HRA) should be performed as part of the Specific AC formulation.
The HRA validates the dependability of an SAC and can identify weaknesses in the
proposed procedures to implement an SAC and suggest additional measures to improve the
overall dependability.
Verification: SACs implemented by TSRs must be initially (prior to operation) and
periodically verified to perform their intended safety function. In the context of SACs, this
may involve "dry runs," procedure walk-downs, tabletop exercises, or actual hazard/casualty
exercises. Additionally, the verification process should be performed by knowledgeable
individuals who were not part of the formulation of the control to assure an unbiased
assessment of the effectiveness of the control. In addition, the control should be formulated
so that it is easily and readily verifiable through appropriate and ongoing testing,
examination or surveillance activities. Periodic re-verification that SACs are performing, or
capable of performing, their intended safety function should be addressed through Limiting
Conditions for Operation (LCO) Surveillance Requirements (SR) for SACs written as LCOs,
or through facility operations and maintenance procedures if the Specific AC is incorporated
into the AC section of the TSRs.
2.3
Implementation and Maintenance of SACs
SACs are generally procedures. These procedures should include specifications for
implementation such as qualifications of involved personnel, steps involved, verification of
identified limits, frequency of verification, requirements for any independent verifications,
interfaces with measuring equipment, and the required accuracy of the equipment, etc. TSRs
are the formal requirements that implement those procedures and recovery actions in the case
of breakdown of the control. SACs are addressed through the TSRs generally by two forms as
identified below.
a. LCO/Surveillance Requirement
14


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