Relationship of DOE-STD-1186-2004 to 10 CFR Part 830

DOE-STD-1186-2004

1.5

Relationship of DOE-STD-1186-2004 to 10 CFR Part 830, DOE G 423.1-1,

DOE G 421.1-2 and Safe Harbor Methods for DSAs under 10 CFR Part 830

Subpart B of 10 CFR Part 830, "Safety Bases" requires contractors responsible for hazard

category 1, 2, and 3 nuclear facilities to develop safety bases for those facilities. The safety

bases consist of DSAs and hazard controls in TSRs derived from the DSA hazard analyses.

Various guides and technical standards, such as this document, provide guidance to help

interpret and implement requirements, including the DSA safe harbor methodologies listed in

10 CFR Part 830, Appendix A, Table 2.

The methodology in DOE-STD-3009-94, CN2, Preparation Guide for U.S Department of Energy

Nonreactor Nuclear Facility Documented Safety Analyses, is an acceptable method for

preparation of a DSA for nonreactor nuclear facilities. STD-3009 CN2 provides detailed

guidance for preparation of SARs (DSAs), including the derivation of TSRs. The general

guidance of STD-3009 in methodologies for hazard analysis and specification of hazard controls

and their classification is applicable to all the safe harbor methodologies (see DOE G 421.1-2,

Section 5.3, Hierarchy and Selection of Safety Items (Hazard Controls), as is the guidance for

SACs in this Standard.

Dispositioning activities such as decommissioning and environmental restoration provide unique

challenges. In these types of activities, it is common that the hazards and the hazard control

sets change as the work progresses. More application-specific guidance for dispositioning

activities can be found in DOE-STD-1120, Integration of Environment, Safety, and Health into

Facility Dispositioning Activities.

STD-3009 addresses derivation of ACs relative to the anticipated application of ACs with major

significance to defense in depth, or worker safety. These ACs are typically implemented

through safety management programs. Inclusion of these ACs in the TSRs formally

acknowledges the importance of programmatic commitments (e.g., radiation protection,

maintenance, quality assurance) to overall facility safety, but usually do not specify key aspects

of each program as providing specific safety functions. The cumulative effect of these safety

management programs is recognized as being important to overall facility safety, as opposed to

specific accident risk reduction.