Safety Management Program Commitments

DOE-STD -3009-94

management programs goes beyond merely supporting the assumptions identified in the

hazard analysis and is an integral part of defense in depth.

Administrative Controls (AC) that are major contributors to defense in depth are

designated as Specific Administrative Controls (SAC) that are required for safety because

they are the basis for validity of the hazard or accident analyses, or they provide the main

mechanisms for hazard control. This Standard, along with DOE-STD-1186, "Specific

Administrative Controls," provides guidance applicable to these types of controls. SACs

provide preventive and/or mitigative functions for specific potential accident scenarios,

which also have safety importance equivalent to engineered controls that would be

classified as safety-class or safety-significant if the engineered controls were available

and selected. The established hierarchy of hazard controls requires that engineering

controls with an emphasis on safety-related SSCs be preferable to ACs or SACs due to

the inherent uncertainty of human performance. SACs may be used to help implement a

specific aspect of a program AC that is credited in the safety analysis and therefore has a

higher level of importance.

In accordance with nuclear safety precepts, a special level of control is provided through

use of TSRs. DOE Guide 423.1-1, "Implementation Guide for Use in Developing

Technical Safety Requirements," provides screening criteria for converting existing

Technical Specifications and Operational Safety Requirements (OSRs) into TSRs. For the

purposes of this Standard, the screening criteria are considered a generally reasonable set

of criteria to designate TSRs for defense in depth. The safety items identified in the

hazard analysis are examined against those criteria to identify a subset of the most

significant controls that prevent uncontrolled release of hazardous materials and nuclear

criticality. These TSR controls may be captured in operational limits or in administrative

controls, including those on safety management programs. This collection of TSRs

formally acknowledges features that are of major significance to defense in depth.

Safety Management Program Commitments

Sections 10 CFR 830.204(b)(5) and 830.204(b)(6) of the Rule require that the DSA define

the characteristics of the safety management programs necessary to ensure the safe

operation of the facility. Program commitments (e.g., radiation protection, maintenance,

quality assurance) encompass a large number of details that are more appropriately

covered in specific program documents (e.g., plans and procedures) external to the DSA.

The cumulative effect of these details, however, are recognized as being important to

facility safety, which is the rationale for a top level program commitment becoming part

of the safety basis.

As appropriate to the hazard, the safety basis may identify specific controls (e.g.,

hazardous material inventory limits) that are required for safety. These controls should be

considered for designation as a SAC as discussed in this Standard and DOE-STD-1186.

The importance of the program commitments, which can be incorporated in TSRs as

administrative controls, cannot be overestimated. The safety basis, however, includes

only the top- level summary of program elements, not the details of the program or its

governing documents. Inspection discrepancies in a program would not constitute

violation of the safety basis unless the discrepancies were so gross as to render premises

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