Introduction - std301120020007

DOE-STD-3011-2002

1. INTRODUCTION

1.1

Scope. This Standard provides a Department of Energy (DOE) approved

methodology for preparing a Basis for Interim Operation (BIO) document. The BIO

is an acceptable form of Documented Safety Analysis (DSA) in accordance with

Table 2 of Appendix A, General Statement of Safety Policy, to Title 10 of the Code of

Federal Regulations (CFR) Part 830, Nuclear Safety Management, Subpart B, Safety

Basis Requirements (hereafter, in this Standard referred to as the "Rule"). It

supplements the information in DOE Guide (G) 421.1-2, Implementation Guide for

Use in Developing Documented Safety Analyses to Meet Subpart B of 10 CFR 830.

Contractors with facilities having existing DOE-approved BIOs may wish to continue

operations under those BIOs. In evaluating the viability of this approach, contractors

must assess whether or not those BIOs reflect the current facility status and

operations and whether the guidance of DOE-STD-3011-94, Guidance for

Preparation of DOE 5480.22 (TSR) and DOE 5480.23 (SAR) Implementation Plans,

was followed in their development. In doing so, contractors should consider the

following:

Item 5 of the Forward of DOE-STD-3011-94 has the statement: "It is noted that,

in any event, the Rules will govern." This referred to the planned (at that time)

Rule safety basis requirements as related to Order requirements. In other words, a

BIO prepared in accordance with DOE-STD-3011-94 must also comply with the

Rule requirements. The Standard is consistent with DOE Order 5480.23, and the

Rule is consistent with the Order in the scope of requirements.

Paragraphs 3 and 4 of section 4.2.1 of DOE-STD-3011-94 provide the guidance

that if an upgrade of a Safety Analysis Report to full compliance with DOE Order

5480.23 (read, now, the Rule) is not warranted, then an exemption from the

requirements is the route to take. It follows that, if the existing BIO is not fully

compliant with DOE-STD-3011-94 and a contractor chooses not to upgrade it to

current Rule requirements, then a Rule exemption should be prepared and

submitted.

It is clear from the guidance of DOE-STD-3011-94 that worker safety must be

addressed in a BIO (see Section 4.2.4.2 and sections A.2 and A.4. In addition,

Integrated Safety Management Systems must include provisions for worker safety

at the facility level (as well as the site and task levels). At the facility level this is

done as part of the safety basis (BIO and TSR). Many existing BIOs are based on

decades old bounding accidents and do not reflect consideration of work

processes that is necessary for assurance of worker safety. If a BIO does not treat

worker safety by hazard analysis and identification of appropriate safety controls,

then it is not compliant with either the Rule or DOE-STD-3011-94.

DOE-STD-3011 is a safe harbor for the DSA requirements of 10 CFR 830. TSR

requirements of the Rule must separately be satisfied. Under DOE-STD-3011-94,

safety controls were integral to the BIO. The ability of the BIO to support

development of a Rule-compliant TSR document should be assessed.

A BIO developed under the nuclear safety Order DOE 5480.23 was a bridge

between safety documentation that existed prior to the Order and a fully Order-