Title:
Safety Basis Supplement -
SBS White Paper Attachment to BP82
Facility:
Multiple Sites
Points of Contact:
SAWG Steering Committee Chair, Brad Evans, 509-371-7386,
Brad.Evans@pnl.gov
Brief Description of Best Practice:
The Safety Basis Supplement (SBS) provides an efficient
mechanism for temporarily revising safety basis
documentation, i.e., the documented safety analysis (DSA)
and technical safety requirements (TSR) to support a planned
activity or evolution that introduces temporary conditions
into a facility that the original safety basis documentation
or hazard controls were not developed to support.
DOE review and approval of the SBS assures that
appropriate regulatory oversight is maintained. The SBS
White Paper details the application, development,
implementation, and management of the SBS.
Why
the best practice was used:
The SBS was formally referred to as a
Justification for Continued Operations (JCO).
The use of a JCO was determined to be acceptable for
unplanned situations resulting from a potentially inadequate
safety analysis (PISA) leading to an Unreviewed Safety
Question (USQ).
Outside of a PISA/USQ situation, the use of a JCO was deemed
inappropriate. For a
planned activity, additional rigor is necessary, and this is
built in to the SDS.
What are the benefits of the
best practice:
The process of development, review and approval,
implementation, and eventual retirement of an SBS is much
more efficient than the process of revising the DSA and TSR
documentation, getting it reviewed and approved,
implemented, then repeating the process when the temporary
activity or evolution has been completed.
Not only are there fewer process steps, each one can
be executed more efficiently.
What
problems/issues were associated with the best practice:
The
SBS White Paper describes necessary considerations and
constraints in using the SBS for temporary activities.
How the success of the Best Practice was measured:
Use of the SBS is measured in terms of reducing
cycle time in safety basis revision, implementation, and
management. Site
specific data may be requested via the POC.
Description of process experience using the Best Practice:
See Benefits above.
Site specific data may be requested via the POC.
