Treatment of SACs In TSRS

DOE-STD-1186-2004

TREATMENT OF SACs IN TSRS

The TSR derivation section in the DSA provides a link between the identified hazards, safety

SSCs, and ACs necessary to ensure safety.

4.1

TSR Treatment of Safety Controls Covered by Safety Management Programs

The traditional type of TSR ACs are the provisions relating to organization and management,

procedures, record keeping, reviews, audits governing safe operations, and safety management

program commitments. Existing DOE directives (References b. and d.) specify that the AC

section of the TSR document will contain commitments to establish, maintain, and implement

these programs at the facility and, as appropriate, facility organizational and administrative

requirements.

Programmatic ACs are credited in safety basis documents with a significantly lower level of

specificity than are SACs. Absent in their selection are specific limits or discernible operator

actions relating to specific hazard or accident analysis conditions. Rather, these ACs contain

basic program elements or features that constitute the viability of the safety management

program to support safe operations.

These ACs typically flow down as performance requirements contained in organizational or

company-level procedures. Prior to implementation of DOE approved TSR ACs, contractors

should first take appropriate actions to ensure a control's availability and readiness. These

actions may include programmatic assessments, development or modification of facility

procedures, and training of facility personnel. Continuing implementation of the programmatic

control is typically verified through continuing assessment and performance monitoring (trend

analysis).

4.2

Implementing SACs in TSRs

When SACs are identified, they shall be controlled through the TSR. Two methodologies are

acceptable for the appropriate treatment of SACs in TSRs. The first involves using the

conventions for LCOs and associated SRs. Placement of the LCO and SR for an SAC should

be in the Operating Limits and SR section of the TSR. This format should be used when the