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Documented Safety Analysis
NUCLEAR SAFETY BASIS
DSA Contacts: Richard
Englehart or Richard Stark
Subpart B of 10 CFR Part 830, Nuclear Safety Management,
requires contractors and operators of hazard category 1, 2, and 3 DOE nuclear facilities
to develop and maintain a Safety Basis and to perform work in accordance with that Safety
Basis. The major components of the safety basis for a nuclear facility include the DSA and
the Technical Safety Requirements (TSRs).
| DSA Requirements |
The DSA is the safety analysis for a hazard category 1, 2, or 3 DOE nuclear facility. Section 830.204 of 10 CFR Part 830 requires that DSAs:
- Describe the facility and the work to be performed; and the facility;
- Categorize the facility in accordance with DOE-STD-1027;
- Evaluate all accident conditions that are presented by natural and/or manmade hazards;
- Derive the hazard controls, including technical safety requirements, to eliminate, limit, or mitigate identified hazards, and define the process for maintaining the hazard controls current at all times and controlling their use;
- Define the characteristics of the safety management programs necessary to ensure the safe operation of the facility, including a criticality safety program, where applicable.
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| DSA Formats & Methodologies |
Depending upon the type of nuclear facility and where it is in its life cycle, the DSA format will typically be one or more of the following:
- SAR (Safety Analysis Report)
- BIO (Basis for Interim Operation)
- HASP (Health and Safety Plan)
- HAR (Hazard Analysis Report)
DOE contractors for hazard category 1, 2, and 3 DOE nuclear facilities must use DOE-approved methods to develop their DSAs. These methods will be either:
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| DSA Guidance |
DOE G 421.1-2, Implementation Guide for Use in Developing Documented Safety Analyses to Meet Subpart B of 10 CFR Part 830 on our Directives Web Page for guidance on how to apply the rule requirements for DSAs. |
Safe Harbor Methodologies for DSAs
"Safe Harbor methodologies" are methods for developing a DSA that have already been approved by DOE for use in
the specific circumstances described. Read Table 2 in Appendix A to Subpart B of 10 CFR Part 830 for the list of Safe Harbor methodologies. These methodologies will allow you to develop your DSA by a method that is appropriately graded for the work and the hazards.
The Safe Harbors methodologies are methods identified
in standards developed by DOE or the Nuclear Regulatory Commission (NRC), or defined in regulations promulgated by the Occupational, Safety and Health Administration (OSHA). These standards are based on many years of experience with the types of facilities and activities to which they may be applied. You do not need to get prior DOE approval to use the Safe Harbors methods in accordance with the stated provisions in 10 CFR Part 830. You will need DOE approval to use a method other than the Safe Harbor methods. In addition, whether or not you use a Safe Harbor method to develop your DSA, you must get approval from DOE for the final DSA before you use it. You should consult the rule and the guide for the specific provisions and limitations for each Safe Harbor method.
This web page provides general information on the DSA methodologies, but you may not use it in lieu of the requirements in 10 CFR Part 830. Click on one of the following for a discussion of the Safe Harbor methodology for that type of facility or activity. Note that some of these categories overlap, for instance, Nonreactor nuclear facilities and environmental restoration activities. In cases where two or more safe harbors are applicable, the contractor should choose the method that is cost-effective for the particular facility.
Reactors
The Safe Harbor method listed in Table 2 of Appendix A to Subpart B of Part 830 for DOE reactors is:
- Nuclear Regulatory Commission (NRC) Regulatory Guide 1.70, Standard Format and Content of Safety Analysis Reports for Nuclear Power Plants.
This is the method used for nuclear reactors licensed by the NRC and is acceptable for DOE reactors regulated by DOE. Read the rule and the DOE G 421.2-1, Implementation Guide for Use in Developing Documented Safety Analyses to Meet Subpart B of 10 CFR Part 830 on our Directives Web Page for detailed information on developing safety bases for DOE-regulated reactors.
Nonreactor Nuclear Facilities
The Safe Harbor method that you may use to develop the DSA for any DOE nuclear facility other than a reactor
is:
- DOE STD 3009-2000, Preparation Guide for U.S. Department of Energy Nonreactor Nuclear Facility Safety Analysis Reports.
This Standard can be viewed on our Technical Standards Web Page.
See the rule and DOE G 421.2-1,
Implementation Guide for Use in Developing Documented Safety Analyses to Meet Subpart B of 10 CFR Part 830 on our Directives Web Page for detailed information on developing safety bases for nonreactor nuclear facilities.
Nuclear Facilities with Limited Operational Life
The Safe Harbor methods that you may use to develop the DSA for a nuclear facility with a limited operational
life are either:
- DOE STD 3009-2000, Preparation Guide for US Department of Energy Nonreactor Nuclear Facility Safety Analysis Reports; or
- DOE STD 3011-94, Guidance for Preparation of DOE 5480.22 (TSR) and DOE 5480.23 (SAR) Implementation Plans.
A DSA prepared in accordance with DOE STD 3009-2000 will be in the form of a Safety Analysis Report (SAR). The
DSA prepared in accordance with DOE STD 3011-94 will be in the form of a Basis of Interim Operation (BIO).
These Standards can be viewed on our Technical Standards Web Page.
See the rule and DOE G 421.2-1, Implementation Guide for Use in Developing Documented Safety Analyses to Meet Subpart B of 10 CFR Part 830 on our Directives Web Page for detailed information on developing safety
bases for nuclear facilities with a limited operational life.
Environmental Restoration Activities
Table 2 of Appendix A of Subpart B to 10 CFR Part 830 provides specific Safe Harbor provisions for certain environmental restoration activities. The rule states that you may prepare DSAs for environmental restoration activities by following the provisions of OSHA regulation 29 CFR 1910.120 (or 29 CFR 1926.65 for construction activities) in conjunction with the methodology of DOE STD 1120-98, Integration of Environment, Safety, and Health into Facility Disposition Activities, if the activity involves either:
- Work not done within a permanent structure, or
- The decommissioning of a facility with only low-level residual fixed radioactivity.
DOE STD 1120-98 can be viewed on our Technical Standards Web Page.
You may also use 29 CFR 1910.120 (or 1926.65, for construction activities) to develop the appropriate hazard controls for your environmental restoration activities, rather than the provisions for TSRs in section 830.205 of the rule.
See the rule and DOE G 421.2-1,
Implementation Guide for Use in Developing Documented Safety Analyses to Meet Subpart B of 10 CFR Part 830 on our Directives Web Page for detailed information on developing safety bases for environmental restoration activities.
Deactivation and Decommissioning Activities
Table 2 of Appendix A of Subpart B to 10 CFR Part 830 provides specific Safe Harbor provisions for deactivation
and decommissioning activities.
As defined in the rule, you may develop your DSAs for deactivation or transition surveillance and maintenance
activities by following the method in either:
- DOE STD 3009-2000, Change Notice No. 1, Preparation Guide for US Department of Energy Nonreactor Nuclear Facility Safety Analysis Reports for Nuclear Power Plants, January 2000, or
- DOE STD 3011-94,
Guidance for Preparation of DOE 5480.22 (TSR) and 5480.23 (SAR) Implementation Plans, November 1994.
You may develop your DSAs for decommissioning of a DOE nuclear facility (or activity) by following the methods
in:
- DOE STD 1120-98,
Integration of Environment, Safety, and Health into Facility Disposition Activities,
May 1998, and
- 29 CFR 1910.120 (or 29 CFR 1926.65 for construction activities)
DOE STD 1120-98, DOE STD 3009, and DOE STD 3011 can be viewed on our Technical Standards Web Page.
You may also use 29 CFR 1910.120 (or 1926.65, for construction activities) to develop the appropriate hazard controls for your deactivation and decommissioning activities, rather than the provisions for TSRs in section 830.205 of the rule.
See the rule and DOE G 421.2-1, Implementation Guide for Use in Developing Documented Safety Analyses to Meet Subpart B of 10 CFR Part 830 on our Directives Web Page for detailed information on developing safety bases for deactivation and decommissioning activities.
Weapons Activities
The amendment to 10 CFR Part 830 issued in October 2000 included specific methods by which nuclear explosive operations and their associated activities may meet the rule that are consistent with nuclear explosives safety. The rule makes clear that it applies to nuclear explosives facilities and their associated nuclear explosive operations and activities.
The Subpart B to 10 CFR Part 830 requires contractors and operators of DOE hazard category 1, 2, and 3 nuclear
facilities to develop and maintain a Safety Basis for each facility and to perform work in accordance with that
Safety Basis. Nuclear Explosive and Weapons Surety requirements are established in DOE Orders 452.1A and 452.2A, and they contain both nuclear and weapons safety requirements.
Table 2 in Appendix A to Subpart B of 10 CFR Part 830 states that you may use the following two methods in conjunction as the safe harbor method for nuclear explosives operations:
- DOE STD 3016-99, Hazards Analysis Reports for Nuclear Explosive Operations, and
- DOE STD 3009-2000, Preparation Guide for US Department of Energy Nonreactor Nuclear Facility Safety Analysis Reports.
These Standards can be viewed on our Technical Standards Web Page.
See the rule and DOE G 421.2-1, Implementation Guide for Use in Developing Documented Safety Analyses to Meet Subpart B of 10 CFR Part 830 on our Directives Web Page for detailed information on developing safety bases for weapons activities.
Transportation Activities
Table 2 of Appendix A of Subpart B to 10 CFR Part 830 provides specific Safe Harbor provisions for transportation activities. The rule states that you may prepare your DSAs for transportation activities using certain specified provisions of:
- DOE O 460.1A, Packaging and Transportation Safety, and
- DOE G 460.1-1, Implementation Guide for Use with DOE O 460.1A, Packaging and Transportation Safety
to prepare their documented safety analyses (DSA).
You may prepare your DSAs for transportation and transfer of nuclear explosives, Naval nuclear fuel elements, Category 1 and 2 special nuclear material, special assemblies and other materials of national security using certain specified provisions of
- DOE O 461.1, Packaging and Transportation for Materials of National Security Interest, and
- DOE M 461.1-1, Packaging and Transfer of Materials
of National Security Interest Manual.
DOE O 460.1A, DOE G 460.1-1, DOE O 461.1, and DOE M 461.1-1 can be viewed on our Directives Web Page.
See the rule and DOE G 421.2-1, Implementation Guide for Use in Developing Documented Safety Analyses to Meet Subpart B of 10 CFR Part 830 on our Directives Web Page for detailed information on developing safety
bases for transportation activities.
Alternate Methodologies for DSAs
You may also propose "alternate methods" which you consider to be more effective than the Safe Harbor methods to be used to prepare your DSAs. You must first get DOE approval for the specific circumstances for which you will use the alternate method.
This page was last updated on January 05, 2007
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