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| DOE-STD-1082-94
activities reflected in facility-specific procedures. However, the information
provided shall be specific enough to allow clear interpretations of the intent of
the commitment. Examples of the appropriate level of detail for additional
activities are 1) "development and implementation of a recordkeeping
program," and 2) "development and implementation of a revised lockout and
tagout program."
The additional activities identified in the plan shall include not only the
development of programs to meet the requirements, but also the actions
necessary to implement those programs, such as procedure development and
training. During the development of the additional activities list, the
implementing organization is expected to consider adopting alternate
implementation activities which may be more cost-efficient ways to meet the
requirements.
3.7 Graded Approach. The complete set of activities necessary to
meet the nuclear safety requirements, as well as the level of depth, rigor, and
thoroughness in applying them to a given facility, are determined by applying
a graded approach. The graded approach is defined in 10 CFR Part 830.3 as
"a process by which the level of analysis, documentation, and actions
necessary to comply with a requirement ... are commensurate with the
following: (1) the relative importance to safety, safeguards, and security [risk];
(2) the magnitude of any hazard involved; (3) the life cycle stage of a facility;
(4) the programmatic mission of a facility; (5) the particular characteristics of a
facility; and, (6) any other relevant factor." The graded approach will permit
the implementing organization to tailor the implementing activities for each
facility or activity to appropriately address these considerations.
Consideration of the risks and hazards of the facility [items (1) and (2) in the
definition] will allow the implementing organization to focus resources on
those activities most likely to reduce the associated risks and hazards by
tailoring the implementing actions to the specific risks and hazards at the
individual facilities and activities.
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