Background - std301120020009

DOE-STD-3011-2002

must be paid to hazards that may develop over the extended period of time. For

example, the importance of consideration of natural phenomenon hazards is increased

as the time spent in a particular mode (limited operational life, transitions surveillance

and maintenance, or deactivation) is extended.

Background. All of the guidance in the previous version of this Standard, pertaining

1.3

to implementation plans, has been deleted since the 10 CFR 830 Rule does not

require an implementation plan. The methodology in the previous version of this

Standard for development of BIOs has been updated to assure compliance with the

Rule and its associated Implementation Guides.

As its name implies, the BIO establishes for the types of interim operations described

in the preceding section, the interim safety basis for the facility. The contractor must

also develop a Technical Safety Requirements (TSRs) document as part of the safety

basis to satisfy the requirements of 10 CFR 830.205, Technical safety requirements.

An existing DSA for operational activities, a Safety Analysis Report (SAR), or an

Operational Safety Requirements (OSR) document may be helpful supporting

documentation to the degree that they are current and correct. Due to the wide variety

of facilities and activities within the DOE complex, and the broad spectrum of

existing safety documentation among the facilities, it is expected that the contents of

the BIOs and the efforts required to prepare them will vary.

1.4

Alternative Methodology or Significant Deviations. In accordance with 10 CFR 830

DSAs for these types of interim operations may also be prepared utilizing the safe

harbor methodology in DOE-STD-3009, Preparation Guide for U.S. Department of

Energy Nonreactor Nuclear Facility Safety Analysis Reports.

If a contractor uses a method other than a safe harbor method, it must obtain DOE

approval of the method before developing the DSA. Likewise, if a contractor uses a

safe harbor method to develop the DSA, but does not follow the method completely,

the contractor should request DOE approval of the method with the specific

deviations noted. The use of alternative methods or specific deviations from the safe

harbor methods must have (1) for NNSA facilities the approval of the Deputy

Administrator or for non-NNSA facilities, the approval of the Cognizant Secretarial

Officer (CSO) as specified in paragraph 9.3.1 of DOE Manual 411.1-1B, Safety

Management Functions, Responsibilities, and Authorities Manual (FRAM), and (2)

the review and concurrence (or comment if an NNSA facility is involved) of the DOE

Headquarters Office of Environment, Safety, and Health (DOE HQ / EH) as specified

in paragraph 9.4.1.6 of the FRAM. Generally, in order to approve an alternative

methodology, the DOE responsible organizations would need to find that the

alternative methodology was sufficiently rigorous to provide an equivalent level of

safety in the alternative DSA and resulting controls. Refer to Section 5 of DOE G

421.1-2 for additional guidance.