Indentification,Formulation, Implemenation, and Maintenance of SACs

DOE-STD-1186-2004

IDENTIFICATION, FORMULATION, IMPLEMENTATION, AND MAINTENANCE OF

SACs

2.1

Identification of SACs

The specificity of ACs within the DSA/TSR will vary depending on the severity of hazards, the

complexity of the facility, and the administrative control's overall contribution to controlling

potential accident consequences (i.e., primary or supplemental control). SACs may also be

needed to protect important initial conditions assumed in the hazard analysis (e.g., the

assumption on combustible inventory limits).

Depending on the situation, some ACs that perform specific preventive or mitigative functions

for accident scenarios may be identified in hazards analyses. These are more specific functions

than implied by general commitments to safety management programs, and they may need to

be raised to a higher importance level. Some of these ACs may have critical importance similar

to or the same as those that would be classified as SC or SS, if the safety functions or

objectives were performed by engineered safety systems. These types of ACs shall be

classified as SACs in accordance with the criteria provided below:

If an administrative control:

a. is identified in the DSA as a control needed to prevent or mitigate an accident scenario,

and

b. has a safety function that would be safety significant or safety class if the function were

provided by an SSC,

then the AC shall be designated as an SAC. Identification as a control in a hazard analysis

is a necessary criterion for an SAC. It may be explicitly specified as a control in the DSA

(item a), or it may be a discrete attribute of a safety management program that was not

specifically called out in the hazard analysis (item b).

Other factors that may be useful to designate an AC, identified as a control in a hazard analysis,

as an SAC include:

a. The AC is the basis for validity of the hazard or accident analyses (e.g., a hazardous

material inventory, such as combustible materials or Material-at-Risk (MAR) limit)

b. ACs provide the main mechanisms for hazard control (e.g., Safety SSCs are degraded,

out of service, too costly to implement, or are impractical for a limited-life facility)