Safety technical requirements

The inspection of process vessels and storage tanks represent examples of closed-space inspection. It is necessary for the management to define the closed-space inspection and provide a set of regulations for inspection. The chosen inspector must be aware of all the regulations defined by the management for inspection, along with the permission for inspection. Before entry all the technical safety requirements must be met. It is also necessary that the inspector in the closed-space process vessel must be in constant communication with other personnel outside during the entire duration of inspection. It is also possible to use mechanical robotic systems in some cases to avoid the hazards involved in closed-space entry for inspection. 

Structures, systems, and components (SSCs) that are important to safety and that are identified as Safety SSCs are based on criteria contained in DOE-STD-3009 (p. xix) and the results of safety analyses, which determine the safety contributions of specific SSCs. The degree of consequence mitigation is the basis for identification of Safety SSCs and associated Safety Functions". These Safety Functions are the essential performance requirements that are imposed on Safety SSC s which maintain the consequences of accident scenarios within bounds that are described in the SAR accident analysis. The use of the term Safety Function will be limited to these essential performance requirements in this SAR. While many SSCs provide a material safety benefit and could be considered to perform a safety function, SSCs that are not relied upon to effect an acceptable outcome will not have an associated Safety Function as the term is used in this S/VR. Safety SSCs and associated Safety Functions are based on the results of hazard evaluation and accident analysis described in Chapter 3, and are specifically identified in Section 3.3.2.3. The specific safety functions important to safety are described in Chapter 4, and form the basis of the derivation of Technical Safety Requirements presented in Chapter 5. 

DOE Order 5480.22, Technical Safety Requirements (DOE 1992a), specifies the criteria, content, scope, format, approval process, revision process, and reporting requirements for DOE nuclear facility Technical Safety Requirements. 

This chapter provides the bases for the Technical Safety Requirements (TSRs), derived from the safety analyses presented throughout this SAR, which, when Implemented, will ensure the safe operation of the HCF. The content of this chapter provides the iink between the assumptions made in the hazard/accident analysis, operational safety commitments, plant configuration, and the TSR document as required by DOE Order 5480.22, Technical Safety Requirements (DOE 1992a). 

DOE Order 5480.21, Unreviewed Safety Questions (DOE 1991), This order specifies the applicable conditions and basis for determining the existence of an Unreviewed Safety Question (USQ) for proposed changes or modifications to the facility design or operation. More specifically, implementation of this order requires consideration of whether a proposed activity involves a conflict with the facility Technical Safety Requirements. 

DOE 1997), This order requires a system for reporting of operations information on unusual occurrences. Section 7, "Occurrence Categorization, Notification, and Reporting Requirements," Part (2) defines a violation of a technical safety requirement as an Unusual Occurrence, which requires DOE notification Mthin two hours of categorization (i.e., identification of the occurrence as an Unusual Occurrence), followed by written notification within 24 hours utilizing a Notification Report. 

Technical Safety Requirements shall define the operating limits and surveillance requirements, the basis thereof, safety boundaries, and management or administrative controls necessary to protect the health and safety of the public and to minimize the potential risk to workers from the uncontrolled release of radioactive or other hazardous materials and from radiation exposure due to inadvertent criticality. 

On Page 4 of Attachment I (Guidelines for Technical Safety Requirements) to DOE Order 5480.22 appears the following discussion. 

U.S. Department of Energy (DOE), 1992a, Technical Safety Requirements, DOE Order 5480.22, U.S. Department of Energy, Washington, D.C., February 25,1992. 

Initial startup testing procedures have been prepared and implemented to demonstrate that structures, systems, and components (SSCs) and processes will perform as intended. Initial testing includes, as appropriate, bench tests and proof tests prior to installation, mockup tests, pre-operational tests, post-maintenance tests, post-modification tests, and operational startup tests. Safety-related items are subject to the quality-assurance requirements of SNL/NM Research Reactor and Experimental Programs (RREP) Quality Assurance Program Plan (SNL 1998a), as implemented by the facility Project/Experiment Quality Plan (PEQP). Testing inciudes those initial tests mandated by applicable Technical Safety Requirement (TSR) surveiilance requirements (see Chapter 5.0, "Derivation of Technical Safety Requirements") and Operational Readiness Review (ORR) requirements (see DOE O 425.1 and DOE-STD-3006-93). 

Job responsibilities of the HCF Operations Facility Supervisor involve the direction of radiation workers to maintain hot ceil facility operability in accordance with regulatory and ES H requirements. This includes monitoring facility performance, work planning and control, facility maintenance, operation in accordance with Technical Safety Requirements, maintenance of facility records, logs and associated documentation, and the support of production operations. 

Operational compliance with Technical Safety Requirements and... 

To accommodate HCF experimental capabilities, a defined process for the preparation, review, and approval of experiments is established as an important element of facility safety. Experiment control is exercised through a system of administrative procedures that are applied to classify experiments into three broad categories (Class I, II, or III) in accordance with the RCSC charter. In addition, all experiments must be conducted in accordance with the approved Technical Safety Requirements, and potential consequences of conducting the experiment must be bounded by the safety analysis in Chapter 3 of this SAR. Proposed experiments that would exceed either of these constraints must be submitted to the SNL Nuclear Facilities Safety Committee (NFSC) and to DOE/AL for review and approval. 

The requirements that define the conditions, safe boundaries, and the management of administrative controls necessary to ensure the safe operation of a nuclear facility are contained in the Technical Safety Requirements for the facility. Figure 17.3-1 is an organization chart delineating the line of authority for HCF operations. Position descriptions defining the duties and responsibilities of each management and supervisory position are maintained and are readily available. 

TA-V Standard Operating Procedure (TA-V SOP) Operations procedure which implement the Technical Safety Requirements (TSR), to address specific topics (e.g. isotope processing, maintenance, normal operations), or required by the SNL ES H manual to address special hazard categories. TA-V SOPs are reviewed by the appropriate HCF safety committee and are approved by line management prior to implementation. 

The unmitigated consequences at the exclusion area boundary for credible HCF accidents are well within the off-site Evaluation Guideline of 25 Rem. Since the HCF had no Technical Safety Requirement (TSR) related safety limits, there have been no past safety limit wolations. Furthermore, there have been no significant violations of OSR-related surveillances or administrative controls In the HCF historical record. 

DOE Order 5480.22 (DOE 1992a), Derivation of Technical Safety Requirements. DOE Order 5480.23 (DOE 1992b), Derivation of a facility Safety Analysis Report. DOE O 151.1, Chg. 2 (DOE 1995a), Comprehensive Emergency Management. 

Safety is a line responsibility that is shared by the operators, facility supervisor, facility manager. Director, and Vice President. The staff is procedurally trained to understand and obey the Technical Safety Requirements (TSRs) of the facility. If plant conditions change such that TSRs are threatened by operations, experiments, equipment failures or external forces, then operations are immediately terminated to minimize the possibilify of a TSR violation and a potential unanalyzed or unsafe condition. The Hot Cell Facility Periodic Maintenance/ Surveillance Operating Procedure (SNL 1997c) requires periodic inspection and checkout of important safety equipment and safety system settings to minimize the chance of "undetected" degradation of safety equipment that could lead to a safety function failure. 

The RCSC is the basic internal safety review committee for HCF activities, providing an independent safety review of proposed activities and facility modifications. The committee acts in a advisory capacity to line management, and conducts reviews as set forth in an operational committee charter approved by the SNL Depufy Director, Nudear Facility Operations. The RCSC ensures HCF operations are based on sound engineering prindples and are maintained within the approved Technical Safety Requirements (TSRs). 

Administrative Controls. Appropriate administrative controls are used for personnel selection, training, documentation of plans and procedures, quality assurance, rigid enforcement of Technical Safety Requirements, and independent safety controls. 

WSRC has submitted a K-Reactor Compliance Assesanent and Enplementation Report (Ref 4-20) for compliance with DOE Order 5480.22 (Ref 4 21) discussing Technical Safety Requirements. 

To support this enforcement process, DOE developed several DOE orders, guides, and manuals. These documents were to be used by the contractors to prepare documented safety analysis (DSA) and technical safety requirements (TSRs). 

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