Approval Bases for Documented Safety Analyses

DOE-STD-1104-96

APPROVAL BASES FOR DOCUMENTED SAFETY ANALYSES

DOE evaluates the DSA by considering the extent to which the DSA (1) adequately addresses

the criteria set forth in 10 CFR 830.202 and 10 CFR 830.204 and (2) satisfies the provisions of

the methodology used to prepare the DSA. DSA review and approval focuses on the adequacy

of the following approval bases:

Base information;

Hazard and accident analyses;

Safety structures, systems, and components;

Derivation of technical safety requirements ; and

Safety management program characteristics.

Once technical justification exists to support conclusions that the DSA adequately describes how

the facility is satisfactory with respect to the approval bases, the DSA may generally be

considered adequate. These approval bases also form the foundation for documenting DSA

approval in a SER.

2.1

Base Information

Base information is the first of the approval bases that should be reviewed and

encompasses elements of DSA preparation, completeness, and general content. Base

information is not reviewed for accuracy in and of itself but for sufficiency to allow

assessment of the other approval bases that rely on this inform ation. The review for

sufficiency can range from a simple screening effort to more detailed discussions,

depending on the complexity of the DSA.

Insufficient or incomplete base information in a DSA may prevent further review of the

DSA. Reviewers should require resolution of major discrepancies in base information

(e.g., incomplete site characteristics) before evaluation of the more specific aspects (e.g.,

hazard and accident analyses) of the safety basis proceeds. It is for this reason that the

SER nee d only provide a brief statement as to the adequacy of base information.

For example, for DSAs adhering to DOE-STD -3009 Change Notice No. 2 format, the

review of base information primarily determines the sufficiency of the information

provided in the Exec utive Summary, Site Characteristics (Chapter 1), Facility Description

(Chapter 2), and to some extent material generic to all DSA chapters (e.g., statutes,

rules, Orders, and principal health and safety criteria). Determining the adequacy of base

information generally entails being able to conclude that the DSA contains sufficient

documentation and basis to arrive at the following conclusions:

The facility contractor development and approval processes (e.g.,

personnel involvement in developing the DSA, ma nagement cognizance

and acceptance, internal reviews, etc.) demonstrate sufficient

commitment to establish the facility safety basis.

The facility mission(s) and scope of operations (i.e., the scope of work to

be performed) for which safety basis approval is being sought are clearly

stated and reflected in the type and scope of operations analyzed in the

DSA. For example, a DSA documenting the safety basis of a spent fuel

storage facility whose mission includes size reduction of spent fuel

elements would be unacceptable if the DSA omitted safety analysis of

size reduction operations.