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Page Title: Coordination of Annual Updates to Hazard Analysis Documents
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DOE G-151-1, "Emergency Management Guide: Hazards Surveys and Hazards
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

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