Specific Administrative Controls cont'd

DOE-STD-1120-2005/Vol. 1

environmental restoration activities. The nature of these activities is such that engineered safety

features may not be available, reliable or comprehensive in controlling many worker hazards. In

some cases, a particular facility safety system may physically interfere with further project

activities and require removal before hazardous materials can be fully removed.

In cases where safety SSCs are either unavailable or unreliable because of aging or degradation,

facility safety and operations personnel must weigh the potential safety benefit of installing or

upgrading safety SSCs versus reliance on specific administrative controls. Primary

consideration should be given to the duration of a facility disposition activity (e.g., it may be

acceptable to conduct short duration tasks using a fire watch rather than upgrading an unreliable

sprinkler system or installing a new system), and the capability of existing SSCs in preventing or

mitigating hazards (e.g., would the SSC have a dramatic effect on reducing worker or public

risk). Costs associated with the SSC installation, upgrade, operation, and maintenance are also a

valid consideration, but shouldn't be the primary determining factor. The reliability and

effectiveness of candidate SACs being considered in lieu of safety SSCs is also an important

consideration that should be explained in the DSA along with the rationale for its selection (i.e.,

TSR derivation information on which accidents are being prevented or mitigated by the SAC,

how does the SAC prevent or mitigate hazards, and how will its effectiveness be assured).

Functioning safety SSCs should not be retired prematurely from service in favour of SACs

simply to eliminate the need to maintain the control. SACs should only be considered when

safety SSCs are not reliable or cannot be maintained. Appropriate subject matter experts should

be involved in these determinations.

Some administrative controls may take on prominence during specific project tasks, because of

the nature of the work. For example, tasks that involve hot work to dismantle equipment or

flammable solvents to decontaminate equipment may increase fire hazards, which can be

compensated through additional administrative controls, such as more rigorous combustible

controls, or increased fire response capabilities. Another example is the increased risk of worker

exposure during intrusive radiological/hazardous material removal, which may necessitate

additional radiation protection and industrial hygiene measures such as PPE, site controls, or

increased air monitoring.

The specificity of administrative controls (e.g., operator actions, limits) can vary depending on

the severity of hazards, the level of importance given to the administrative control and the

availability of other controls. Administrative controls may also be needed to protect important

initial conditions assumed in the hazard analysis (e.g., assumption on combustible loading).

Figure 1 provides guidelines for determining the appropriate level of specificity needed for

administrative controls.

Administrative controls should ensure that safety management programs emphasize key

elements that are relied on for controlling hazards. As the severity of hazards increases and the

availability or reliability of safety SSCs decrease, it is important to emphasize specific attributes

such as administrative limits and specific actions that will be controlled through the limits,

controls and conditions. Additionally, where safety management programs are relied on as the

primary means of controlling significant hazards, the defense in depth considerations built into

these programs should be discussed (e.g., management of uncertainties, redundant samples or

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