Coordination of Annual Updates to Hazard Analysis Documents

DOE-HDBK-1163-2003

DOE G-151-1, "Emergency Management Guide: Hazards Surveys and Hazards

Assessments"

4.5 Coordination of Annual Updates to Hazard Analysis Documents

Hazard analyses should be maintained to ensure they are reflective of the current facility work

scope and hazards. This can be important as operations, facility configuration, work activities, or

hazardous material inventories may change. Many of these changes are controlled through

formal change control processes and mechanisms that are applied to DOE nuclear operations.

Nuclear facilities are required to use the Unreviewed Safety Question (USQ) process (10 CFR

830.203) that provides a level of review and control for safety basis documents; however, the

USQ process will not maintain current the safety basis documents and those supporting

documents (such as FHAs, process descriptions, etc.) upon which the safety basis is founded. A

comprehensive change control process that incorporates the USQ process is still needed. These

same concepts must also be applied to non-nuclear facilities to maintain accurate hazard analysis

and supporting facility documents.

Several DOE directives require that hazard analyses and associated documents be updated and

submitted to DOE on an annual basis. Primarily affected are Documented Safety Analyses

required by 10 CFR 830, Emergency Planning Hazard Analyses required by DOE O 151.1, and

Fire Hazards Analysis required by DOE O 420.1. Since all of these documents are closely related

for a particular facility, they are similarly affected by facility changes.

Resource utilization can be improved through the coordination of annual updates for these hazard

analysis documents. Participants responsible for each hazard analysis should work together on

the potential changes that need to be reflected within annual updates. There should be

consistency in how changes are noted and addressed and a collective agreement on their

significance. This can best be achieved by scheduling updates on the same annual basis and the

institution of a comprehensive and integrated change control process within the plant or facility.

[NOTE: Significant changes such as a proposed new activity or a positive USQ are considered to

be outside of this recommended practice and would potentially require a new hazard analysis that

is irrespective of the annual update.]

Sources of Information on Annual Updates:

DOE G 421.1-2, "Implementation Guide for Use in Developing Documented Safety

Analyses to Meet Subpart B of 10 CFR 830"

DOE G-151-1, "Emergency Management Guide: Hazards Surveys and Hazards

Assessments"