Bio For Transition Surveillance and Maintanance of a Nuclear Facility

DOE-STD-3011-2002

requirements of the Rule would no longer apply; the appropriate contractual provisions for a

radiological facility would need to be implemented.

Identification of hazards, evaluation of normal, abnormal, and accident conditions, and

derivation of hazard controls will be a function of the step in the plan. If the steps were to be

conducted sequentially the process would be straightforward. However, if steps are

conducted in parallel, then the possibility of interactions between concurrent steps must also

be considered. The simplest hazard analysis technique that is consistent with the magnitude

and complexity of the process step and its associated hazards should be used (preliminary

hazard analysis, what-if analysis, Hazards and Operability Study [HAZOP], etc.).

The identification and classification of hazard controls will also be a function of step in the

plan. Usually facility safety SSCs will all be appropriate controls at the beginning of the

deactivation process. However, as hazardous materials are removed, the accident scenarios

for which they were originally designed for prevention or mitigation may no longer be

possible, and the controls may be removed. The plan, supported by a hazard analysis, should

provide identification of when in the deactivation steps existing controls may be removed

(and when other controls may be necessary) and the criteria that must be satisfied before they

are removed. In this way, once DOE approves the BIO, with the criteria that must be

satisfied, further DOE DSA reviews and approvals, other than verification that the criteria

have been met, are not required.

The format of presentation of BIO material may be different than that in a DOE-STD-3009

DSA. For example, it may add clarity if, beyond facility description and deactivation plan

description in a BIO chapter 2, the balance of DSA information is organized by major step,

or activity, in the deactivation plan. That is, for each major activity, the hazards are

identified and analyzed, and hazard controls, including safety management programs are

described and classified. Association with a timeline or schedule may be useful.

The Rule (10 CFR 830.205) requires Technical Safety Requirements. These are derived

from the DSA (BIO). A TSR may be constructed as a function of major step in the

deactivation plan. That is, each major step can be defined as an operational mode, and the

controls specified appropriate to each mode. As with Category 3 DSAs, the basis for safety

management programs, and any facility-specific characteristics of them that are necessary, is

through hazards analyses. A listing of these programs, with references to site-wide programs

and the facility-specific characteristics should be presented in summary table form.

5. BIO FOR TRANSITION SURVEILLANCE AND MAINTENANCE OF A NUCLEAR

FACILITY

Transition surveillance and maintenance means activities conducted when a facility is not

operating and not during deactivation, decontamination, and decommissioning activities.

Ideally, deactivation would precede transition surveillance and maintenance, but often it does

not. That is, mission related operations may have been terminated and the facility placed into

a surveillance and maintenance mode, possibly with the expectation of resuming operations

at a later date, without removal of hazardous materials. During this phase surveillance and