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Establishing a Safety Culture - Continued
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Specific Administrative Controls - index
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Considerations In Developing a Material at Risk (MAR) TSR Control:


DOE-STD-1186-2004
4.
TREATMENT OF SACs IN TSRS
The TSR derivation section in the DSA provides a link between the identified hazards, safety
SSCs, and ACs necessary to ensure safety.
4.1
TSR Treatment of Safety Controls Covered by Safety Management Programs
The traditional type of TSR ACs are the provisions relating to organization and management,
procedures, record keeping, reviews, audits governing safe operations, and safety management
program commitments. Existing DOE directives (References b. and d.) specify that the AC
section of the TSR document will contain commitments to establish, maintain, and implement
these programs at the facility and, as appropriate, facility organizational and administrative
requirements.
Programmatic ACs are credited in safety basis documents with a significantly lower level of
specificity than are SACs. Absent in their selection are specific limits or discernible operator
actions relating to specific hazard or accident analysis conditions. Rather, these ACs contain
basic program elements or features that constitute the viability of the safety management
program to support safe operations.
These ACs typically flow down as performance requirements contained in organizational or
company-level procedures. Prior to implementation of DOE approved TSR ACs, contractors
should first take appropriate actions to ensure a control's availability and readiness. These
actions may include programmatic assessments, development or modification of facility
procedures, and training of facility personnel. Continuing implementation of the programmatic
control is typically verified through continuing assessment and performance monitoring (trend
analysis).
4.2
Implementing SACs in TSRs
When SACs are identified, they shall be controlled through the TSR. Two methodologies are
acceptable for the appropriate treatment of SACs in TSRs. The first involves using the
conventions for LCOs and associated SRs. Placement of the LCO and SR for an SAC should
be in the Operating Limits and SR section of the TSR. This format should be used when the
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