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well as the collective significance <strong>of</strong> other related non-compliances, is determined. If the P AM<br />

screen considers a programmatic deficiency to be a potential concern, the Condition <strong>of</strong> the<br />

program should also be reviewed against this AT3 to determine whether there is a potential for an<br />

Unreviewed Safety Question (USQ).<br />

Data related to issues identified and reported through the Site Corrective Action Process<br />

or other approved alternative deficiency and corrective action tracking systems are analyzed and<br />

trending is performed in accordance with the Data Analysis and Trending for Performance<br />

Improvement, procedure 1-E93-ADM-16.18 (Ref. 8). High significance issues, and any other<br />

issues a responsible <strong>manager</strong> identifks, will have a formal cause analysis performed in<br />

accordance will the Cause Analysis Requirements Mmal, MAN-O6ZCAUSE ANALYSIS<br />

(Ref. 9). The results <strong>of</strong> this analysis should include corrective actions that may require<br />

modifications to this AB. Any modifications to this AB will be managed in accordance with the<br />

Nuclear Safety Mmal, 1 -MAN-OI 8-NSM (Ref. 10).<br />

These programs and processes require DOE notification for significant individual issues<br />

and notification for cases where potential or confirmed programmatic deficiencies exist<br />

Notification <strong>of</strong> DOE may OCCUT through various channels depending on the program or process<br />

that was being followed when an issue was identified. E the issue is determined to have<br />

significance with respect to this AB, additional notification to DOE specifically identifying the<br />

AB issue is required as well.<br />

3.2 INTEGRATED SAFETY MANAGEMENT<br />

The Building 991 Complex implements Integrated Safety Management (ISM) by the<br />

systematic integration <strong>of</strong> safety and environmental standardshquirements into the work<br />

planning and execution processes. This systematic integration <strong>of</strong> safety and environmental<br />

considerations into all complex activities results in the successfi~I accomplishment <strong>of</strong> the<br />

activities while protecting the workers, the public, and the environment. The SMPs described in<br />

this chapter provide the necessary programmatic infrastructure and formalized'discipline to meet<br />

the primary goal <strong>of</strong> ISM - "DO WORK SAFELY". Complex management requires specific<br />

activities to ensure work is performed safely. These activities include definition <strong>of</strong> work scope,<br />

identifying and analyzing hazards; development and implementation <strong>of</strong> operational contro Is,<br />

performance <strong>of</strong> work or operation; and feedback and improvement.<br />

Defintion <strong>of</strong> any given scope <strong>of</strong> work is accomplished predominately through the Work<br />

Control and Maintenance programs. The engineering documentation defines the technical work<br />

scope for any given maintenance activity, and the Integrated Work Control Program (IWCP)<br />

work package or operating procedures define the specific planned work scope. Chapter 1 <strong>of</strong> this<br />

FSAR identifies the activities authorized for planning or performance in the Building 991<br />

Complex.<br />

The identification and analysis <strong>of</strong> hazards involved in a work scope primarily falls within<br />

the domain <strong>of</strong> the Safety and Industrial Hygiene; Radiation Protection; Nuclear Safety,<br />

Criticality Safety, Fire Protection, and Work Control programs. The IWCP process defines the<br />

Revision<br />

Scptcmher I999<br />

3-3 Building 991 Complex FSAR<br />

.

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