TSR and SSC Commitments

DOE-STD -3009-94

of the summary invalid.

By virtue of application of the graded approach, the majority of the engineered feat ures in

a facility will not be identified in the categories of safety-class or safety-significant SSCs

even though they may perform some safety functions. However, such controls noted as a

barrier or preventive or mitigative feature in the hazard and accident analyses must not be

ignored in managing operations. Such a gross discrepancy would violate the safety basis

documented in the DSA even if the controls are not designated safety-class or

safety-significant, because programmatic commitments extend to these SSCs as well. For

example, the commitment to a maintenance program means that the preventive and

mitigative equipment noted as such in the DSA hazard analysis is included in the facility

maintenance program. As a minimum, all aspects of defense in depth identified must be

covered within the relevant safety management programs (e.g., maintenance, quality

assurance) committed to in the DSA. The details of that coverage, however, are developed

in the maintenance program as opposed to in the DSA. Facility operators are expected to

have noted the relative significance of these engineered features and have provided for

them in programs, in keeping with standard industrial practice, based on the importance of

the equipment. It is the fact of coverage that is relevant to the facility safety basis. The

details of this programmatic coverage (i.e., exact type of maintenance items and associated

periodicities) are not developed in or part of the DSA.

An overall commitment made in a DSA is that the contractor will not change the facility

configuration underlying the documented safety basis without implementing and

completing the unreviewed safety question (USQ) process. However, situations do occur

where a USQ process is not necessary. For example, a stipulat ion to have a radiation

protection program in the administrative control section of the TSR is a commitment;

however, changes to specific program provisions do not require going through the USQ

process. Further clarification of such interpretations can be found in DOE G 424.1-1,

"Implementation Guide for Use in Addressing Unreviewed Safety Question (USQ)

Requirements".

DOE facilities that use and rely on site-wide, safety support services, organizations, and

procedures, may summarize the applicable site-wide documentation provided its interface

with the facility is made clear. The DSA then notes whether the reference applies to a

specific commitment in a portion of the referenced documentation or is a global

commitment to maintaining a program for which a number of details may vary without

affecting the global commitment. Any documents referenced in the DSA are to be made

available upon request.

TSR and SSC Commitments

In order to comply with 10 CFR 830, specific safety controls are to be developed in the

DSA. In keeping with the graded-approach principle, distinctions are made to avoid

wasting effort by providing detailed descriptions of all facility SSCs. While a basic

descriptive model of the facility and its equipment must be provided in Chapter 2,

"Facility Description," highly detailed descriptions are reserved for two categories of

SSCs comprising the most crucial aspects of facility safety. These two categories are

safety-class SSCs and safety-significant SSCs.

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