Expectations for the Formulation, Implementation, and Maintenance of Specific Administrative Controls

DOE-STD-1186-2004

DOE Guide 423.1-1, Implementation Guide For Use In Developing Technical Safety

Requirements, provides detailed guidance for developing TSR content, including ACs.

Section 4.10.7 of the guide recognizes that ACs may be applied for risk reduction of individual

accident scenarios. When ACs specifically state a limit or specific requirement rather than a

generic programmatic reliance, failure to meet such statements can result in a TSR violation. In

contrast, a TSR violation of a safety management program can only result from a gross program

failure, significant enough to render the DSA assumptions invalid.

DOE G 423.1-1 and DOE STD-3009 continue to provide relevant guidance on the application of

ACs as part of the DSA-required controls. However, this document provides additional

amplification and clarification for the appropriate development and implementation of ACs.

1.6

Expectations for the Formulation, Implementation, and Maintenance of Specific

Administrative Controls

The development, selection, and implementation of an effective set of hazard controls are

among the most important elements of nuclear safety. DOE has established a priority process

that favors preventive over mitigative measures, passive design features over active controls,

and engineered controls over ACs. The approved process recognizes that, where necessary or

practical, ACs may play an important role in hazard prevention and mitigation.

This Standard consolidates and clarifies existing DOE rule guidance and standards so that

contractors may formulate, implement, and maintain ACs consistent with their importance to

safety. This Standard also provides expectations for the formulation, implementation, and

maintenance of ACs when relied on to provide specific safety functions of SS/SC importance,

and to ensure existing ACs of this nature are evaluated and improved.

1.6.1

Formulation (Design), of Specific Administrative Controls

The general approach to formulating SACs, as described in this Standard, parallels existing

guidance for designing safety SSCs. Primary guidance for nuclear safety design criteria is

found in DOE O 420.1A, Section 4.1, and its associated implementation guide, DOE G 420.1-1,

Nonreactor Nuclear Safety Design Criteria and Explosive Safety Criteria Guide for use with

DOE O 420.1., Facility Safety. These documents contain requirements and guidance for safety

SSCs that have been adapted for SACs as follows: