All nuclear safety requirements and facility nuclear safety design features and procedures should be considered in terms of their support of one or more nuclear safety principles. As the starting point in the development of the new approach, we identified the 17 most significant (but broadly generic) nuclear safety principles from a comprehensive paper on this subject, a paper that was recently developed by Brookhaven National Laboratory at the request of DOE Headquarters (EH). We then developed a systematic (but simple) surveillance framework within which each of these fundamental nuclear safety principles can be addressed.

This specific surveillance document provides oversight teams as well as facility managers with a specific approach to addressing each of 17 nuclear safety principles from the different perspectives of 12 nuclear facility functional areas, focusing primarily on those facilities that have reached the decontamination and decommissioning (D&D) phase of their life cycle. While this document is specifically intended for use in oversight of D&D facilities, the approach could be applied to any nuclear facility. Since the costs of initial development (about $150K) have already been paid by DOE Headquarters, a complementary or site specific document could be produced quite readily and at significantly less expense. We can also assist in the performance of self-assessments, providing independent evaluations of all of a site’s functional areas relative to the 17 nuclear safety standards.

Page through the introductory sections (Purpose and Scope), noting that the introduction explains how important nuclear safety continues to be even for a shutdown facility. A contaminated, unmanned, and poorly maintained facility is more hazardous than one that is operating to design specs.

Page through sections 3.0 to 6.0, noting the list of 12 functional areas and that the approach is summarized and DOE responsibilities assigned, much like other oversight guides that they have seen. Note in the Attachment 1 Definitions the terms "Nuclear Hazards of Concern" and "Radiological Hazards of Concern," as these are important in understanding how many of the nuclear safety principles apply to the specific facility.

Attachment 2, Format and Content of Surveillance Report, suggests a quantitative approach to the Executive Summary, and a similar quantitative approach to the main body of the report (Results by Nuclear Safety Principle and Results by Functional Area, Strengths, Weaknesses, Interim Corrective Actions, and Permanent Corrective Actions).

In Appendix A, Nuclear Safety Principles, note that the 17 principles are divided between those that apply to all nuclear facilities (xA to xG) and those that fall under the category of having a "Nuclear of Radiological Hazard of Concern," (xH to xQ). Note that each applicable principle is addressed for each functional area. The numbering system makes inter-functional area "crosswalks" easy, so the surveillance team can communicate internally in a meaningful way!

In Appendix B, each section starts off with an Introduction to explain why the functional area is important to nuclear safety, perhaps even more so during D&D. Page through the Question Set sections, noting that each principle is supported by general questions that serve as the starting point for the surveillance and that the surveillance or assessment team could delve farther into requirements where this might be appropriate.

The final part of each functional area section provides guidance on how to perform the surveillance, normally done in three distinct parts: document reviews, interviews, and facility inspections. Each of these areas is further subdivided, and each question in that functional area is listed to indicate which of the three parts and subparts might involve that question. Note that interviews with the senior person in each functional area include all of the questions, since those who are in charge of an area should be able to answer all of the questions.

Since this is a new approach, the quantification scheme has not been tested in detail. Nevertheless, scaled and weighted approaches are not new. Although it is possible to use a double-weighting process (weight each principle and each functional area), this is not necessary and might overly complicate the process.

The objective of the new approach is to understand how well each of the 12 functional areas (or a selected smaller number of functional areas) is related to and supports meeting each of the nuclear safety principles, quantifying the level of support on a percentage basis (0 to 100). By evaluating the level of support for the fundamental nuclear safety principles subjectively but quantitatively, a powerful communication tool is created for use by oversight groups as well as site managers. With a principle-based surveillance framework, it is possible to significantly increase the focus of assessments, use nuclear safety resources more efficiently, and prioritize corrective actions in a graded manner. From a requirements-exemption perspective, a more powerful case can be developed and communicated for approval.

The quantification approach is outlined in the document as part of the suggested report format. The basis for the quantification is that there are three fundamental segments of nuclear safety support for each principle in each applicable functional area: resources, training, and implementation. That is, the quantification process is standardized in general terms by assigning a maximum of one-third of the 100 points each for resources being available, training being conducted, and implementation being effective. The scores for the 17 principles can be averaged to obtain an overall functional area score. The scores for the 12 functional areas (or a lesser number of functional areas, as desired) can be averaged for the entire facility.

It is important to understand that the quantification process is only intended to be a communication tool, and differences among inspectors and with facility managers are expected. Quantification communicates perspectives, which are almost always initially different. Indeed, if it were possible to agree on the relative nuclear safety values of the many different contributing elements (requirements) for each facility, the nuclear safety oversight process could be automated.

This approach allows quantitative comparisons of facilities; supports understanding and implementation of the "graded approach;" and allows facility managers to determine their own scores, with or without oversight from DOE Headquarters. Moreover, self-assessments against the 17 nuclear safety principles will provide DOE Field Element managers and site contractors with a resource prioritization rationale as well as substantial justification for implementing or not implementing certain detailed requirements.

1.0 PURPOSE 1

2.0 SCOPE 2

3.0 SURVEILLANCE PLAN DESCRIPTION 2

4.0 RESPONSIBILITIES 5

5.0 SURVEILLANCE PLAN APPROACH 7

6.0 ORGANIZATION AND ANALYSIS OF SURVEILLANCE RESULTS 10

ATTACHMENT 1, DEFINITIONS 12

ATTACHMENT 2, FORMAT AND CONTENT OF SURVEILLANCE REPORT 14

APPENDIX A, NUCLEAR SAFETY PRINCIPLES 19

APPENDIX B, FUNCTIONAL AREA QUESTION SETS 21

INDEX 156

This surveillance plan establishes responsibilities and methods for conducting reviews of DOE nuclear facilities during post-operational periods such as mission transition (includes deactivation and surveillance and maintenance phases), decontamination and decommissioning (D&D), and environmental restoration. The surveillance plan is intended to provide a systematic but high-level approach to assessing fundamental radiological and nuclear safety aspects of post-operational activities. The plan incorporates a new assessment approach that focuses on meeting a limited number of fundamental safety principles in each of several functional areas, allowing increased efficiency in assessment planning and execution.

The approach is to address each principle from the perspective of the different functional areas. This provides a focused, purposeful approach with relevant questions that are also organized to support the three components of the surveillance process – document reviews, facility inspections, and personnel interviews. This approach is intended to allow a reasonably detailed assessment using limited personnel resources. It is also intended to minimize the need for surveillance team members checking off compliance with specific DOE Order requirements and standards that often apply inconsistently to a specific facility, especially during significant and rapid changes that may occur in the post-operational period.

The guidance provided is organized under familiar functional areas, but surveillance coordination and planning is facilitated through principle-based questions in each functional area. Using a set of basic principles, each functional area selected for a specific surveillance is systematically evaluated. The information and data collected in each functional area can then be readily used for cross-cutting observations because they are based on a common set of principles, which are listed in generic form in Appendix A. The functional area question sets are provided in Appendix B, with an introductory discussion of each functional area in terms of how it may be impacted by the post-operational environment.

This surveillance plan applies to all DOE post-operational facilities that contain nuclear or radiological hazards. The surveillance plan covers only those activities that are necessary to protect the health and safety of the public and workers against nuclear hazards or radiological hazards. The surveillance plan does not address activities that are necessary for environmental protection or protection against non-radiological hazards, such as chemical hazards or industrial hazards.

The surveillance plan distinguishes between surveillance activities that are appropriate for facilities involving nuclear and radiological hazards of concern, and facilities involving lesser nuclear and radiological hazards. The level of effort and sophistication of each surveillance should be based on the type and status of the facility being reviewed, the type and magnitude of the facility hazards, and the complexity of the facility. The plan is also written in a modular fashion so that specific functional areas or safety principles can be individually evaluated.

Once the EH Office of Independent Oversight and Appraisals has determined that the principles are being met in an effective manner or that no nuclear or radiological hazards of concern (see definitions, Attachment 1) remain at the facility, nuclear safety-related oversight activities at the facility may be significantly reduced or terminated.

This surveillance plan describes the responsibilities and procedures for performing post-operational surveillances and examining results (Sections 1.0 through 6.0), lists the post-operational nuclear safety principles on which the surveillance plan is based (Appendix A), and provides the functional area question sets (Appendix B) to be used in the conduct of surveillances. Each of the 12 functional area question sets is based on the post-operational nuclear safety principles .

The fundamental safety objective for post operational activities is to establish and sustain a comprehensive and effective safety envelope throughout the facility during changing conditions, requirements, and personnel. This objective can only be met if fundamental nuclear safety principles are met on a continuing basis. The 17 nuclear safety principles listed in Appendix A are stated in general terms and are not intended to be restrictive. Indeed, each principle stated in Appendix A provides only the starting point for exploring many aspects of that principle. Also, the principles may require adaptation and focused application for unique facilities and activities.

The post-operational nuclear safety principles applicable to a facility depend on the level of the nuclear or radiological hazards present. For facilities where a nuclear hazard of concern or a radiological hazard of concern exists, nuclear safety principles similar to those applicable to operating facilities will apply. For facilities where lesser hazards exist, fewer and less demanding nuclear safety principles will normally apply, often involving less costly implementation. In either case, the implementation of the nuclear safety principles may be graded to be consistent with the nature and magnitude of the hazard present.

In general, the nuclear safety principles will apply to nuclear facilities in any life-cycle phase. Although deactivation will usually remove all nuclear and radiological hazards of concern, and at some subsequent point the facility may be declared non-nuclear, it is the current condition of the facility and not the current life-cycle phase that determines the applicability of the nuclear safety principles. It should be emphasized that there are often many more non-nuclear (e.g., industrial) safety concerns and hazards that must also be addressed to ensure adequate worker and public safety. Non-nuclear safety programs are not specifically addressed under this plan, but each surveillance team member should identify and raise safety issues and questions whether they are nuclear or non-nuclear.

These nuclear safety principles must be understood and addressed in a systematic manner in order to focus attention on and anticipate safety vulnerabilities that may exist during post-operational activities. Due to the significant additional costs associated with meeting nuclear safety objectives in the post operational phases of a nuclear facility, it is prudent to re-evaluate the status of the facility and the applicable safety principles on a continuing basis as the features and status continue to change. If the current facility status is clear, then this plan provides additional cost savings by facilitating planning and focusing surveillance resources on specific nuclear safety principles. While all standards and requirements may continue to apply, the approach provided in this plan places them in a more realistic framework of nuclear safety principles. This also allows facility managers and contractors to focus their upgrade efforts and provides a format for continued discussion and corrective actions.

Surveillance planning includes the early definition of the scope and focus of the surveillance, identifying the functional areas to be formally addressed. The surveillance may address only selected functional areas, selected nuclear safety principles, or selected portions of the assessment (e.g., document reviews, facility inspections, or interviews). Flexibility in the emphasis of different functional areas should be maintained throughout the process, allowing mid-course corrections where the need for changes in the approach becomes evident. This surveillance plan is intended to facilitate this high-level of flexibility.

Principle-based question sets are provided in Appendix B for each of the following functional areas:

Depending on the specific surveillance situation and the experience of the surveillance team member, the planning level of effort can be minimized due to the logical organization of the question sets by functional area, the 17 fundamental nuclear safety principles, and the three basic surveillance activities. Each of the 12 functional area guidance documents in Appendix B is divided into three sections: an introduction, functional area related questions for each of the applicable nuclear safety principles, and a numeric listing that suggests which questions may be most useful in planning the approach to specific surveillance activities.

The introduction section in each functional area guide describes the applicability of the functional area to nuclear or radiological safety for post-operational activities and describes the basic differences, if any, relative to normal operations. The introduction also states the basic objectives for evaluating site performance in the functional area and provides comments on key coordination activities that may be required with other functional areas.

The question set section of each functional area guide provides suggested questions that may help to evaluate whether the facility meets each of the applicable nuclear safety principles from the perspective of that functional area. The questions are intended to be generic and to provide an experienced assessor already familiar with the detailed requirements and expectations in the functional area with specific questions that will facilitate developing an understanding of how well that functional area supports the related principle. This section of the functional area document also allows efficient team coordination on the scope, approach, and emphasis of the surveillance. For example, different members of the surveillance team might be assigned responsibility for coordinating and integrating the evaluations of specific nuclear safety principles.

The section relating individual questions to the three surveillance activities - document review, inspection, and interview - organizes the questions for each functional area in a manner that clearly indicates which of the surveillance activities can contribute to answering the questions. Similar questions from the different functional areas can then be identified, and it can be determined whether they should be addressed collectively or individually. Thus, this systematic organization of the question sets facilitates surveillance planning, execution, and report development.

The Deputy Assistant Secretary for Independent Oversight and Appraisals is responsible for:

The Project Coordinator for EH D&D Oversight and Technology Review Activities is responsible for:

Residents are responsible for:

As stated in the Purpose, the objective of this surveillance plan is to provide a means for systematically collecting fundamental nuclear safety information on DOE post-operational facilities. The plan is intended to be used by EH Residents and EH Headquarters personnel at post-operational facilities throughout the DOE Complex. The plan may be adapted to the needs and resources of the EH organization conducting the surveillance. This may include performing the surveillance as a large scale activity using a large team of personnel or performing the surveillance on a small scale basis, such as having a couple of personnel conduct document reviews or facility walk-throughs that focus on a particular problem area. Regardless of the scale or level of effort, the consistent use of the guidance in Appendix B will allow the results of surveillances at various facilities in various life cycle phases to be analyzed to determine how DOE can best upgrade post-operational facility safety. The Project Coordinator for EH D&D Oversight and Technology Review Activities will plan surveillances to ensure that appropriate priority is given to high-risk facilities and that representative information on nuclear safety-related areas is being generated.

The Project Coordinator will develop an annual surveillance plan that will identify the specific surveillances to be performed, their schedule, and estimates of personnel and resources required.

Prior to each surveillance, a facility-specific surveillance plan will be developed. The plan should define the scope and focus of the surveillance, the schedule, the names of the personnel conducting the surveillance, the names of the organizations requiring notification, a list of specific documents that will be reviewed in advance of the facility visit, and the individual questions to be addressed by the surveillance. The documentation requirements and questions should be derived from or related to those contained in Appendix B. The question selection, the organization of the selected questions in support of the surveillance objectives, and assignment of responsibilities for integrating the results of the surveillance should be accomplished as early in the planning process as feasible. This early planning at the detailed level may allow comparisons and synergy in planning surveillances for different facilities. Nevertheless, each set of questions should be selected, integrated, and organized in a manner consistent with the site-specific objectives, the time available, and the personnel available to support the surveillance.

For onsite surveillances that will be conducted by EH Headquarters personnel, a letter will be sent notifying the facility manager of the planned surveillance. This letter will include the proposed dates for the on site portion of the surveillance, the names of the personnel conducting the surveillance, the draft agenda for the onsite portion of the surveillance, and a documentation request. The documentation request should indicate the documents to be sent to EH prior to the onsite portion of the surveillance and the date these documents will be needed. The letter will normally identify additional documents required for review during the onsite portion of the surveillance. The notification letter also should request at least one knowledgeable point of contact for assessment coordination.

Document reviews will be performed as needed to respond to documentation-related questions provided for each functional area. The questions are not to be considered as all inclusive, inflexible, or as limiting. Some questions will naturally lead to more detailed questions that occur to the assessor, and each should be pursued as needed to assess whether the associated principle is being met for the functional area and, eventually, across the entire facility being assessed. Pre-arrival document reviews should be used to refine plans for the onsite portion of the surveillance. This will involve adapting questions to make them facility specific. The document review should also be used to compile a list of additional documents for review during the onsite part of the surveillance, and the questions to be addressed by that review.

During the onsite document review, the quality of the information in the facility documentation should be assessed and a determination should be made as to whether additional facility documents need to be reviewed after the facility visit. Any documentation not available during the facility visit should be requested and forwarded to EH.

Interviews are conducted to elicit answers to the selected questions and to determine the documents and facility locations where other relevant information may be found. In order to limit the number of interviews and the time spent with one individual, interviews should be planned to address relevant questions from as many functional areas as feasible. Interviews conducted early in the surveillance help to sharpen the focus of the document review and inspection activities. However, interviews later in the surveillance can explain and supplement information gathered during the document review and inspection activities. The scheduling of the interviews should take these conflicting factors into account.

Inspection involves first hand observation of actions and conditions at the facility, including configuration of structures, systems, and components; reviews of the actual operating procedures used; and observation of actual operations, including storage of materials and radioactive waste. Inspection can provide answers to questions or point to problem areas for further inquiry. Locations in the facility should be selected for inspection based on their potential for providing information helpful in answering the questions selected for the surveillance. In particular, first hand observation should be used to confirm the implementation of the policies, programs, and procedures contained in the facility documentation.

When safety program weaknesses are found, surveillance personnel should ensure that site or facility managers are notified and that facility personnel take the initiative to determine and implement corrective measures, including compensatory and mitigation measures needed to meet potentially short-term needs.

Formal EH guidance (e.g., ONS/AP-0.0-04, "Assessment Report Preparation") is in place that details the process for preparing nuclear safety assessment reports. A draft surveillance review report will be prepared in accordance with the currently approved guidance or, if resources and time are limited, in the format provided below in Attachment 2. The draft surveillance report will be submitted for comment to the Project Coordinator for EH D&D Oversight and Technology Review Activities, to all personnel involved in conducting the surveillance, and to the responsible DOE facility representative and facility managers. The final surveillance report should take into account the comments received on the draft report. Any requested documentation received after the facility visit should be reviewed before completing the final surveillance report. The final surveillance report will be signed by the personnel conducting the surveillance, approved by the Project Coordinator for EH D&D Oversight and Technology Review Activities, and transmitted to appropriate organizations and personnel.

To the extent practical, the report should provide quantitative performance indicators that facilitate clear communication, analysis, and prioritization of problem areas. It is not necessary to achieve exacting agreement or consensus on quantitative values assigned. Not only is total agreement not a practical objective, it would also mask legitimate differences of opinion regarding issues of potentially great uncertainty. Further discussion of the suggested quantitative approach is provided below.

Nuclear safety program information generated by the post-operational facility surveillances (both positive and negative observations and findings) will normally be divided into discrete units of information and assessed in relative terms, using quantitative weighting to indicate relative significance in terms of the nuclear safety principles. For example, each of the applicable 17 nuclear safety principles could be assigned a value between 0 and 100, with a 100 rating reflecting a facility with programs that fully meet the intent of the associated principle, and a zero rating reflecting a complete lack of indication that the associated principle is implemented and maintained systematically in the facility programs. Each significant observation or finding should have a quantitative (although most likely subjective) impact on one or more of the nuclear safety principles.

There are three fundamental components associated with most problems and their resolution. These fundamental components are (1) the presence and ready availability of appropriate resources, (2) the training and readiness of personnel to use those resources, and (3) the effectiveness of the implementation process. Note that these components build on each other, so (2) and (3) are not credible in the absence of (1). These components should be kept in mind in the assignment of quantitative values since poor implementation is generally not as significant a problem as a lack of proper implementation coupled with a lack of proper training and adequate resources. It is appropriate to assign each of these components one-third of the weighting factors for issues associated with each nuclear safety principle. It should be kept in mind that the quantification process is only intended to provide a means of communication, so agreement among stakeholders is not expected or even desired.

In addition to the above general quantification, each discrete unit of information will be assigned various codes to facilitate the integration and analysis of all of DOE’s nuclear safety surveillance data. This coding will normally be an administrative function and will not necessarily impact or reflect the final quantitative nuclear safety indicators developed during the analysis of surveillance results. Codes will be assigned to characterize information in terms of:

Each data unit will be entered into an electronic database to facilitate retrieval and analysis of information in a manner that allows general comparisons among different facilities. Thus, the surveillance report should include enough information to support this objective. Nevertheless, it is not intended that the collection, refinement, and presentation of this simplified, limited set of information detract from the more important and detailed determinations required to assess the nuclear safety posture of the facility. If necessary, this limited database information will be developed separately.

The findings and observations resulting from nuclear safety surveillances will be analyzed to the extent feasible to identify trends, generic issues, and opportunities for program improvements. Such analysis is expected to take place at Headquarters and in Field Elements, with the objective of identifying, prioritizing, and implementing improvements. Status keeping and adjustments to quantitative assessment results are of secondary importance.

It is also important to emphasize that this approach to nuclear safety surveillances is intended to promote the sharing of both positive and negative information regarding DOE nuclear facility safety status. While there may be deficiencies that cause a facility to be less than 100 percent in meeting a specific nuclear safety principle, there may also be a number of positive programs and attributes in place that support the principle. It is important to identify these positive elements as well as the negative, and it is important for such good practices to be considered for implementation at other facilities that are having difficulty meeting the intent of the associated nuclear safety principles.

Surveillance information will be analyzed by EH to identify DOE-wide generic strengths and weaknesses. Information about these strengths and weaknesses will be disseminated to appropriate organizations to support further program development and improvements for all aspects of post-operational activities within the DOE complex. Where appropriate, this information will include reference to the applicable nuclear safety principles. Information on the need for adding or deleting standards or requirements impacting specific technical areas will be provided to the DOE Technical Standards Program, again with emphasis on the specific nuclear safety principles supported by the proposed changes to standards and requirements.

Deactivation: The process of removing a facility from DOE operations, with the intent of conversion to another use or permanent shutdown; by the removal of fuel, draining and/or de-energizing of systems, removal of stored radioactive and hazardous materials and other actions to place the facility in a safe and stable condition so that a Surveillance and Maintenance program will prevent any unacceptable risk to persons or the environment until ultimate disposition of the facility.

Decommissioning: Decommissioning occurs at the end of the useful life of a nuclear facility. It involves the removal of sufficient radioactive and hazardous material to allow the restricted or unrestricted release of the facility. For unrestricted release, this activity reduces the risk to human health and the environment to negligible levels.

Decontamination: Those activities employed to reduce the levels of radioactive and/or hazardous contamination in or on material, structures, and equipment.

Dismantlement: Those actions required to remove material, including radioactive or contaminated material, from the facility.

Entombment: The encasement of radioactive materials in concrete or other structural material sufficiently strong and structurally long-lived to ensure retention of the radioactivity until it has decayed to levels that permit restricted release of the site.

Facility: A plant, building, structure, complex, or activity contiguously located on the same site, defined by a single geographical perimeter (usually determined by a fence or other barrier that surrounds and limits uncontrolled access), and used by the DOE or its contractors for the performance of work under the jurisdiction of the DOE. The term "facility" includes the land (soil), surface water, and groundwater contained within its geographical perimeter.

Hazard: A source of danger (i.e., material, energy source, or operation) with the potential to cause illness, injury, or death to personnel or damage to a facility or to the environment (without regard for the likelihood or credibility of accident scenarios or consequence mitigation).

Nuclear Hazards of Concern: Those hazards associated with processing, storage, transferring, or handling of significant quantities of fissionable material. (See the definition for "Significant Quantity of Radioactive Material.")

Pathway: A route and sequence of processes by which radioactive material may move through the environment to humans or other organisms.

Radioactive Material: Any material or combination of materials that spontaneously emits ionizing radiation.

Radioactive Waste: Any material containing or contaminated with radionuclides at concentrations greater than the values that competent authorities would consider acceptable in materials suitable for unrestricted use or release and for which there is no foreseen use.

Radiological Hazards of Concern: Those hazards associated with the radiation emitted by significant quantities of radioactive materials. (See the definition for "Significant Quantity of Radioactive Material.")

Safe Storage: Those actions required to place and maintain a nuclear facility in such a condition that future risk to public safety from the facility is within acceptable bounds and that the facility can be safely stored for as long a time as desired.

Significant Quantity of Fissionable Material: The minimum mass of fissionable material for which control of at least one parameter is required to ensure subcriticality under all normal and credible abnormal conditions.

Significant Quantity of Radioactive Material: An amount of radioactive material which, if released, would produce greater than 10 rem doses at 30 meters based on 24 hour exposure. Additionally, 1000 curies of tritium is defined as a significant quantity of radioactive material. (For threshold values of radionuclides considered to be a significant quantity of radioactive material, see the Category 3 heading of Table A.1 in DOE Standard 1027, Hazard Categorization and Accident Analysis Techniques for Compliance with DOE Order 5480.23, Nuclear Safety Analysis Reports.)

Surveillance and Maintenance: Those activities necessary to ensure that the facility remains in a safe condition, including periodic inspection and monitoring of the facility, maintenance of barriers that prevent access to radioactive materials left on the facility site, and prevention of activities on the facility site that might impair these barriers.

Note: This attachment provides guidance regarding the expected information to be provided in the surveillance report. Additional documentation information and guidance is available in ONS/AP-0.0-04, "Assessment Report Preparation" and should be used where resources allow.

A nuclear safety program surveillance has been completed at the Site for the __________ Facility. This facility provides the Department of Energy (DOE) with necessary support to meet DOE responsibilities for ______________ . The facility was built in 19 and is scheduled for final decontamination and decommissioning (D&D) by 19/20 . Following D&D, the facility will be , as specified in agreements with .

The results of this independent surveillance indicate that the facility nuclear safety program is currently percent effective in meeting the intent of the 17 [or less] nuclear safety principles in the functional areas considered by the surveillance team, with a range of percent to percent for the individual principles. Facility management has performed a self assessment and considers their nuclear safety program to be effective, with a range of to for the individual principles.

Significant strengths were found in the resources, training programs, and implementation of principles involving , particularly in the functional areas .

Significant weaknesses were found in the resources, training programs, and implementation of principles involving , particularly in the functional areas .

Interim corrective actions have been implemented to minimize nuclear safety vulnerabilities in the areas of .

Permanent, long-term corrective actions are needed to . These corrective actions, when completed, will potentially improve the overall nuclear safety effectiveness to 100 percent.

The report provides a similar summary for each of the 17 nuclear safety principles and a cross-cutting assessment of the principles in terms of each of the 12 functional areas considered by the surveillance team. A more detailed and prioritized listing of interim and permanent corrective actions is also provided.

Executive Summary i

Summary of Significant Strengths

Summary of Significant Weaknesses

Interim Corrective Actions (identified to date)

Permanent Corrective Actions (identified to date)

xA Facilities will meet applicable federal, state, and local safety requirements.

xB The exposure of any person to radiation will be kept as low as is reasonably achievable (ALARA), managed and controlled under a systematic program.

xC No person will receive doses of ionizing radiation in excess of the statutory dose limits during post operational activities.

xD All practical steps will be taken to prevent accidents during post operational activities.

xE Post operational activities will each result in benefits commensurate with the safety risks resulting from those activities.

xF Post operational activities and systems will be adequate to compensate for safety vulnerabilities resulting from age-related degradations, including an appropriate margin to accommodate uncertainties in material status.

xG The generation of radioactive waste will be minimized to the extent feasible.

xH Operations will be performed in a formal and controlled manner on a continuing basis.

xI The configuration and status of the physical plant will be documented and controlled on a continuing basis.

xJ Positive control of nuclear facilities and their safety systems, including communications and instrumentation systems, will be maintained.

xK A comprehensive and approved Safety Analysis or Hazards Analysis document applicable to the facility during post-operational activities will be in place in advance of the initiation or performance of the post operational activities addressed in the document.

xL Defense-in-depth will be provided for all nuclear accidents; no single failure or set of common-cause failures will result in a nuclear accident or the spread of radioactive contamination beyond containment boundaries.

xM All structures, systems, and components integral to post operational activities should be assigned a safety categorization that takes into account the nuclear or radiological consequences of failure as defined and assessed in the applicable Safety Analysis or Hazards Analysis document; operational reliability during the needed period of service will be ensured in a manner consistent with the safety categorization.

xN A program to identify and address unreviewed safety questions will be maintained on a continuing basis.

xO Personnel training and qualifications will be maintained on a continuing basis.

xP All practical steps will be taken to minimize the radiological consequences of accidents occurring as a result of post operational activities, including the maintenance of established containment barriers where feasible.

xQ Emergency response capabilities commensurate with the potential accidents that could reasonably occur at the facility will be available on a continuing basis.

Management of post-operational nuclear facilities will normally be significantly more difficult than normal operations due to the transient and one-time nature of many post-operational activities. The level of D&D management difficulty can easily exceed that of new construction and startup, since there are likely to be many different or unusual hazards to deal with and less margin for error. There are also could be a significant number of additional personnel and contractors to manage.

To address such a challenge, the facility management organization may have to be changed significantly from its normal operations mode of doing business. A close look must be taken at the applicability and effectiveness of the management programs, the abilities of post-operational period managers to deal with potentially complex technical and nonroutine matters, and whether the range of special personnel technical skills required for post-operational activities has been understood and is being met.

Many of the fundamental facility management processes in place during normal operations must continue to be applied effectively in controlling and optimizing post-operational activities. The basic management functions are setting objectives, assigning responsibilities, allocating resources, and monitoring performance relative to the objectives. Feedback within these management processes is a necessary element for optimizing those processes. For a nuclear facility, such feedback should be as expeditious and circumspect as possible, optimizing overall facility performance by facilitating the effective performance of personnel in all of the functional areas. Changes in old activities and the addition of new activities unique to the post-operational period need to be recognized and incorporated into the facility’s basic management processes. Properly managed, facility post-operational activities will continue to meet the highest nuclear safety principles and goals.

The purpose of surveillance in the management functional area is to review the performance of the facility or site management processes from an overall perspective, supplementing the narrower reviews of management processes in the other functional areas. The expected overlap suggests that preparations for and coordination of assessment team activities across the several, complex functional area and management interfaces will be a significant challenge. Nevertheless, this management overview component of the assessment should be effective in determining how well the broader management processes are contributing to the safe and efficient performance of post-operational activities.

The nuclear safety principles applicable to a facility depend on the nuclear or radiological hazards present. For facilities where a significant nuclear hazard of concern (e.g., the potential for a criticality accident) or a radiological hazard of concern (e.g., the potential for a major release to the environment) exists, nuclear safety principles similar to those applicable to operating facilities continue to apply. For post-operational facilities where major nuclear and radiological safety hazards no longer exist, some of the nuclear safety principles will often not apply. For example, systems and procedures that provide defense-in-depth for accident prevention may no longer be needed. In either case, the actual implementation of the nuclear safety principles applicable to the facility should be consistent with the level of the hazard.

In general, the nuclear safety principles will apply to nuclear facilities in any life-cycle phase. Although facility shutdown and deactivation may remove all nuclear and radiological hazards of concern, it is the current condition of the facility and not the life-cycle phase that determines the applicability of each of the nuclear safety principles. For coordination purposes, the principles are identified by the letters A through Q, and the principles and their associated questions have the same designation letter for all of the functional areas. To better focus the assessment process, the principles most applicable to facilities having safety and environmental hazards of concern are listed last (i.e., principles H though Q). While this separation of the nuclear safety principles into two groups adds some clarity to the nuclear safety assessment process, it should be understood that all of the principles apply to some degree to all of the facilities and should be considered. For example, operational formality (principle H) is appropriate at all times; it is mandatory for high-hazard facilities.

DOE post-operational nuclear facility assessments will normally include three complementary components: document reviews, physical plant inspections, and personnel interviews. Each of the functional area questions above is listed below under one or more of the three assessment components. Specifically, this section organizes the questions identified in Section 1.2 to suggest how document reviews, site inspections, and personnel interviews can be used to answer the questions, providing a basis for assessing whether the associated principles have been met. This question numbering system used in Section 1.2 is truncated below, with each question being listed under one or more specific assessment activities in a manner intended to facilitate surveillance preparations and performance.

The evaluator should keep in mind that these listings are only suggestions, intended to minimize administrative preparation for the various assessment activities. If the evaluator uses additional generic or functional area questions under a specific principle, the questions and related answers should be identified in a manner consistent with the numbering system. For example, if the next question number in the functional area would be 66, an additional question should be entered under the applicable principle, and the number 66 should be added to the assessment activities in which the question was used. The answer to each question should be obtained and documented for record purposes, including indicating those questions that are not applicable or that were not asked.

The actual questions used during an assessment should be coordinated by the assessment team under each of the three surveillance activities, using the most relevant site- related questions and perspectives from the various functional areas. This coordination will permit the surveillance activities to elicit the greatest amount of useful information with minimal duplication of effort. For example, each interview with an individual should be planned in a manner designed to address all questions that may apply to that individual, without regard to the functional areas. Likewise, visits to a plant location should attempt to address all questions relevant to the location with one visit, again minimizing redundancy and avoiding interference with ongoing facility activities. It is intended that assessment activity redundancy be limited to follow-up for safety principles or goals not fully satisfied.

1.3.1.1 Safety Analysis and Hazard Analysis Reports

1.3.1.2 Organizational Information, Procedures, and Plans

1.3.1.3 Records

1.3.2.1 Senior Managers

1.3.2.2 Facility Managers and Subcontractor Liaison

1.3.2.3 Staff Personnel

1.3.2.4 Facility Stakeholders

1.3.3.1 Containment Barriers and Boundaries

1.3.3.2 Alarm, Indication, and Communications Systems

1.3.3.3 Process and Safety Systems

1.3.4.4 Support Facilities

Radiological controls must be maintained throughout plant life, especially during the post-operational activities, which often involve built-up quantities of radioactive materials in the forms of waste and holdup. Control of exposure to radiation during the post-operational period is particularly difficult when the physical plant is being modified or disassembled. Even when it is determined that a facility is fully decontaminated, this is a threshold-related end point that is subject to revised criteria and to newly discovered contamination at any time.

Moreover, while significant quantities of fissile materials remain in the facility, special precautions are needed to protect against, detect, and respond to criticality accidents. Likewise, it is likely that any remaining radioactive wastes will continue to present risks to plant workers and to the public until removed to a permanent repository. Thus, while most nuclear facilities can be built without strenuous radiological protection programs, such programs are almost always required throughout the post-operational period. Plant managers must ensure that their post-operational plans include increased attention to radiological controls, with a positive plan and process to determine where such controls are needed and to apply the necessary resources in a timely manner.

Independent oversight of a post-operational nuclear facility radiological controls program will normally involve comparing operational and post-operational program resources, plans, and daily activities and determining whether an adequate radiological controls program is in place and planned for the rest of the facility life cycle. Where such a comparison with the operational program is not practical, it is likely that a much more detailed evaluation will be needed in order to identify or validate the level of effort needed and the framework for managing that effort. In either case, plant managers must demonstrate that they have a protection program in place that ensures continued control of all radiological hazards.

Question sets related to assessing radiological controls in the post-operational period are presented below for each of the Nuclear Safety Principles. The evaluator should determine that a principle is understood and being implemented in a positive manner from the radiological controls perspective. It is particularly important that the principle will be met throughout the post-operational period and that plans are in place to ensure this.

DOE post-operational nuclear facility assessments will normally include three complementary components: document reviews, physical plant inspections, and personnel interviews. Each of the functional area questions above is listed below under one or more of the three assessment components. The evaluator should keep in mind that these listings are only suggestions, intended to facilitate preparation for the various assessment activities. If the evaluator uses additional generic or functional area questions under a specific principle, the questions and related answers should be identified in a manner consistent with the numbering system. For example, if the next question number in the functional area would be 49, an additional question should be entered under the applicable principle, and the number 49 should be added to the assessment activities in which the question was used. The answer to each question should be obtained and documented for record purposes, including indicating those questions that are not applicable or that were not asked.

2.3.1.1 Safety Analysis Reports

2.3.1.2 Post-operational Radiological Control Procedures and Plans

2.3.1.3 Radiological Controls Records

2.3.2.1 Health Physics Manager/Supervisor

2.3.2.2 Facility Manager/Control Room Manager

2.3.2.3 Radiation Workers

2.3.2.4 Facility Stakeholders

2.3.3.1 Containment Barriers and Boundaries

2.3.3.2 Radiation Alarm and Indication Systems

2.3.4.3 Support Facilities

Safe nuclear facility operations require constant attention throughout plant life, including during plant retirement activities where many operations will be performed for the first time. New procedures and temporary systems are required, and the level of training and time available for preparation are often severely limited. Under such difficult conditions, it is increasingly important for operating personnel to ensure a continuous understanding and control of all plant equipment and activities.

Until the facility is completely deactivated, decontaminated, and decommissioned, operations personnel are relied on to monitor and control all plant activities. This is likely to be a particularly difficult task due to the large number of new or untrained people who may be involved with those activities. Also, there may be a reduced level of operational flexibility and defense-in-depth available for dealing with accidents and incidents. In this challenging environment, the operators and supporting plant staff must maintain a clear picture of the remaining plant safety vulnerabilities, the resources available to deal with them, and the proper procedures for doing so.

Independent oversight of the post-operational phase of the plant life cycle will often involve identifying the status of and verifying plant safe shutdown and deactivation activities. No assumptions can be made that the facility operational phase was properly or fully terminated. In many cases, adequate documentation of the termination process will not be available, and there will be no remaining facility operating staff available. Establishing operational control of such a facility could be a significant undertaking requiring extensive physical plant inspections and the generation of documents certifying the plant condition and remaining hazards. The nuclear safety principles and key questions provided below are intended to provide oversight personnel guidance regarding verifying operational control of the post-operational facility.

Question sets for assessing continued operator control during the post-operational period are presented below for each of the Nuclear Safety Principles. The evaluator should determine that a principle is understood and being implemented in a positive manner from a safe operations perspective. It is particularly important that the principle be met throughout the post-operational period and that plans and resources are in place to ensure this.

DOE post-operational nuclear facility assessments will normally include three complementary components: document reviews, physical plant inspections, and personnel interviews. Each of the functional area questions above is listed below under one or more of the three assessment components. The evaluator should keep in mind that these listings are only suggestions, intended to facilitate preparation for the various assessment activities. If the evaluator uses additional generic or functional area questions under a specific principle, the questions and related answers should be identified in a manner consistent with the numbering system. For example, if the next question number in the functional area would be 72, an additional question should be entered under the applicable principle, and the number 72 should be added to the assessment activities in which the question was used. The answer to each question should be obtained and documented for record purposes, including indicating those questions that are not applicable or that were not asked.

3.3.1.1 Safety Analysis Reports

3.3.1.2 Post-Operational Procedures and Plans

3.3.1.3 Operational Records

3.3.2.1 Operations Manager/Supervisor

3.3.2.2 Facility Manager/Control Room Manager

3.3.2.3 Facility Operators

3.3.2.4 Facility Stakeholders

3.3.3.1 Containment Barriers and Boundaries

3.3.3.2 Alarm, Indication, and Communications Systems

3.3.3.3 Process and Safety Systems

3.3.4.5 Support Facilities

The packaging and transportation activities conducted by post-operational facility organizations include some of the most difficult safety challenges in the nuclear industry. These challenges result from the fact that the post-operational period often involves highly radioactive and poorly characterized materials, and the materials are likely to be confined within the most degraded containers and least controlled containment boundaries. It is not likely that post-operational nuclear facility managers will be able to meet these challenges without significantly upgrading resources in the packaging and transportation technical disciplines.

Besides having to deal with the worst types of radioactive and hazardous materials under poor conditions, managers are often faced with having to retrieve large quantities of these materials from a variety of locations, pretreat and process the materials to a stable or less hazardous form, store the treated materials while awaiting final disposal, and then provide transportation to different locations using a variety of transportation modes and containers. There is also a significantly increased risk for the public when the materials are being transported, often resulting in a great deal of interagency and stakeholder involvement in the packaging and transportation area.

These same factors result in oversight difficulties for nuclear facility post-operational packaging and transportation functions. In addition, since DOE has a number of facilities with increased treatment and cleanup programs, there are many intra-site packaging and transportation issues that might need to be addressed. Unfortunately, due to the relatively small packaging and transportation requirements for such materials in the past and the newness of some of the emergent post-operational requirements, there may be a transitional period while contractors and DOE Field Elements identify and resolve these evolving issues.

Such a proactive management effort will require a clear commitment to developing a packaging and transportation upgrade program and a specific assignment of organizational advocacy to achieve adequate results. The oversight activity described in this section of the plan focuses primarily on ensuring that post-operational facility managers have established a capable packaging and transportation organization and integrated it with the several plant customers requiring its services.

Question sets related to assessing operations in the post-operational period are presented below for each of the Nuclear Safety Principles. The evaluator should determine that a principle is understood and being implemented in a positive manner from the packaging and transportation perspective. It is particularly important that the principle will be met throughout the post-operational period and that plans are in place to ensure this.