Nuclear Safety Principle-Based Assessments
(Decontamination and Decommissioning Example)
This is a new, principle-based nuclear safety assessment approach developed under a support services contract for DOE Headquarters. This new approach provides a framework within which each DOE nuclear facility can be assessed for its overall approach to nuclear safety in 12 functional areas. Since this framework is principle-based rather than requirements-based, all standards and requirements can be assessed for their specific nuclear safety relevance and value on a site-specific or facility specific basis. Thus, assessment and corrective action resources may be applied more efficiently.
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 sites 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.
Quantification
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.
TABLE OF CONTENTS
(Note: The numbers that follow each topic here and in the
Index at the end of the document are the
page numbers in the original hardcopy document.)
1.0 PURPOSE 1
2.0 SCOPE 2
3.0 SURVEILLANCE PLAN DESCRIPTION 2
3.1 Post-Operational Nuclear Safety Principles 2
3.2 Functional Area Question Sets 3
4.0 RESPONSIBILITIES 5
4.1 EH Deputy Assistant Secretary for Independent Oversight and Appraisals 5
4.2 Project Coordinator for EH D&D Oversight and Technology Review Activities 5
4.3 EH Residents 6
4.4 Individuals Conducting Post-Operational Surveillances 6
5.0 SURVEILLANCE PLAN APPROACH 7
5.1 General 7
5.2 Surveillance Planning 7
5.3 Conducting a Surveillance 8
5.4 Surveillance Report 9
6.0 ORGANIZATION AND ANALYSIS OF SURVEILLANCE RESULTS 10
6.1 Organization of Information Collected 10
6.2 Data Analysis 11
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
1.0 MANAGEMENT 22
2.0 RADIOLOGICAL CONTROLS 34
3.0 OPERATIONS 43
4.0 PACKAGING AND TRANSPORTATION 54
5.0 MAINTENANCE AND SURVEILLANCE 67
6.0 ENGINEERING 81
7.0 TRAINING 93
8.0 CONFIGURATION MANAGEMENT 103
9.0 QUALITY ASSURANCE 112
10.0 EMERGENCY PLANNING 126
11.0 FIRE PROTECTION 136
12.0 SAFEGUARDS AND SECURITY 146
INDEX 156
SURVEILLANCE PLAN FOR DEPARTMENT OF ENERGY
NUCLEAR FACILITY POST-OPERATIONAL FACILITY PHASES
1.0 PURPOSE
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.
2.0 SCOPE
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.
3.0 Surveillance Plan Description
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 .
3.1 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.
3.2 Functional Area Question Sets
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:
1. Management
2. Radiological Controls
3. Operations
4. Packaging and Transportation
5. Maintenance
6. Engineering
7. Training
8. Configuration Management
9. Quality Assurance
10. Emergency Planning
11. Fire Protection
12. Safeguards and Security
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.
4.0 RESPONSIBILITIES
4.1 EH Deputy Assistant Secretary for Independent Oversight and Appraisals
The Deputy Assistant Secretary for Independent Oversight and Appraisals is responsible for:
approving this surveillance plan and any subsequent revisions; and
ensuring that adequate staff are available to support the conduct of post-operational surveillances.
4.2 Project Coordinator for EH D&D Oversight and Technology Review Activities
The Project Coordinator for EH D&D Oversight and Technology Review Activities is responsible for:
preparing and maintaining this surveillance plan;
determining the facilities to be surveilled;
establishing the overall schedule for conducting post-operational surveillances;
coordinating with the EH Residents regarding post-operational surveillance activities
analyzing and trending data generated from post-operational surveillances;
approving surveillance reports; and
ensuring that surveillance reports are distributed to appropriate organizations/personnel.
4.3 EH Residents
Residents are responsible for:
planning and performing surveillances of post-operational facilities at their site; and
forwarding results of post-operational surveillances to the Project Coordinator for EH D&D Oversight and Technology Review Activities.
4.4 Individuals Conducting Post-Operational Surveillances
Individuals conducting post-operational surveillances are responsible for:
assisting with surveillance planning and preparation activities;
performing document reviews of applicable facility documentation;
conducting facility inspections and interviews; and
preparing assigned portions of surveillance reports.
5.0 SURVEILLANCE PLAN APPROACH
5.1 General
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.
5.2 Surveillance Planning
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.
5.3 Conducting a Surveillance
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.
5.4 Surveillance Report
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.
6.0 ORGANIZATION AND ANALYSIS OF SURVEILLANCE RESULTS
6.1 Organization of Information Collected
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 DOEs 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:
Facility type
Post-operational life-cycle phase of the facility
Post-operational nuclear safety principles impacted
Significance (relative or quantitative)
Functional areas impacted
Specific subject matter
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.
6.2 Data Analysis
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.
Attachment 1
Definitions
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.
Attachment 2
Format and Content of Surveillance Report
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.
Executive Summary
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.
Table of Contents
Executive Summary i
Introduction and Approach 1
Results by Nuclear Safety Principle 2
A. Facilities will meet applicable federal, state, and local safety requirements.
B. The exposure of any person to radiation will be kept as low as is reasonably achievable (ALARA), managed and controlled under a systematic program.
C. No person will receive doses of ionizing radiation in excess of the statutory dose limits during post operational activities.
D. All practical steps will be taken to prevent accidents during post operational activities.
E. Post operational activities will each result in benefits commensurate with the safety risks resulting from those activities.
F. 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.
G. The generation of radioactive waste will be minimized to the extent feasible.
H. Operations will be performed in a formal and controlled manner on a continuing basis.
I. The configuration and status of the physical plant will be documented and controlled on a continuing basis.
J. Positive control of nuclear facilities and their safety systems, including communications and instrumentation systems, will be maintained.
K. 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.
L. 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.
M. 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.
N. A program to identify and address unreviewed safety questions will be maintained on a continuing basis.
O. Personnel training and qualifications will be maintained on a continuing basis.
P. 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.
Q. Emergency response capabilities commensurate with the potential accidents that could reasonably occur at the facility will be available on a continuing basis.
Results by Functional Area
1. Management
2. Radiological Controls
3. Operations
4. Packaging and Transportation
5. Maintenance
6. Engineering
7. Training
8. Configuration Management
9. Quality Assurance
10. Emergency Planning
11. Fire Protection
12. Safeguards and Security
Summary of Significant Strengths
Summary of Significant Weaknesses
Interim Corrective Actions (identified to date)
Permanent Corrective Actions (identified to date)
Appendix A
NUCLEAR SAFETY PRINCIPLES
Nuclear Safety Principles for Post-Operational Activities at All Nuclear Facilities
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.
Nuclear Safety Principles for Post-Operational Activities at Nuclear Facilities
Where a Nuclear or Radiological Hazard of Concern Exists
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.
Appendix B
Functional Area Question Sets
1. Management
2. Radiological Controls
3. Operations
4. Packaging and Transportation
5. Maintenance
6. Engineering
7. Training
8. Configuration Management
9. Quality Assurance
10. Emergency Planning
11. Fire Protection
12. Safeguards and Security
1.0 MANAGEMENT
1.1 Introduction
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 facilitys 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.
Questions related to individual nuclear safety principles are presented in Section 1.2. These questions are reorganized in Section 1.3 to indicate which of the surveillance activities
document reviews, inspections, and interviews can contribute to answering the questions and, thus, determining how well the associated nuclear safety principles are satisfied at the facility.1.2 Management-Related Nuclear Safety Principles and Questions Sets
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.
1.2.1 Nuclear Safety Principles for Management of Post-Operational Activities at All Nuclear Facilities
1A Facilities will meet applicable federal, state, and local health and safety laws and regulations, including requirements identified by contract or other form of agreement.
1A-1 Have the applicable federal, state, and local laws and regulations, and other requirements been formally identified and documented as applicable to the facility? Is the documentation available for inspection?
1A-2 Have the responsibilities for identifying, managing, and meeting the full range of regulatory and other external requirements been assigned? Do managers and other appropriate personnel know where these responsibilities reside?
1A-3 How does the process for developing and implementing management controls explicitly address the need to satisfy external requirements?
1A-4 What deficiencies have been identified in meeting external requirements? Have the root causes been identified and corrected?
1A-5 What management process is used to identify deficiencies in the implementation of external requirements?
1B The exposure of any person to radiation will be kept as low as is reasonably achievable (ALARA) under a systematic program.
1B-6 How does management assure themselves that individual workers are aware of the facility ALARA program goals, are implementing them and have made ALARA part of the facility safety culture?
1B-7 Does the facility have a centrally managed ALARA program? What process actually results in radiation exposure reductions?
1B-8 Which managers are specifically assigned ALARA program responsibilities? How are they held accountable?
1B-9 How is the information needed for the application of the ALARA concept systematically developed, documented, analyzed, communicated, and used? Are the documents available for inspection?
1B-10 Are there documented examples where the cost of reducing radiation exposure has been calculated and this information has been used for management decisions? Are the documents available for inspection?
1B-11 Is there a quantitative policy for assessing or limiting resource commitments to minimizing radiation exposure (e.g., dollars/man-rem)? What has performance been relative to the goals?
1B-12 How do managers in their management planning and guidance documents explicitly support and encourage the application of ALARA in post-operational activities? Are there examples of such documents? Are the documents available for inspection?
1B-13 How are radiation exposures routinely reported to management? Are radiation exposures and environmental releases of radioactive materials documented, and analyzed for patterns and trends? Are the documents available for inspection?
1C No person will receive doses of ionizing radiation in excess of the statutory dose limits during post-operational activities.
1C-14 Is the responsibility for the worker radiation monitoring and dosimetry program clearly assigned to a specific manager and organization? Who is it? Does that person acknowledge that responsibility?
1C-15 What management controls and guidance are in place to identify and respond to actual or potential excessive radiation exposures?
1C-16 What formal procedures are used for reassignment of personnel who are approaching or have reached an administrative or statutory exposure limit? Has this occurred?
1C-17 Is there a periodic backlog in radiation monitoring, dosimetry processing, or reporting paperwork? What is it? Are resources consistent with the workload?
1C-18 Have the radiation exposure control responsibilities of supervisors and workers been clearly defined and accepted? What evidence is there that the responsibilities have been accepted and are being exercised?
1D All practical steps will be taken to prevent radiological accidents during post-operational activities.
1D-19 Who is the manager responsible for determining what practical steps will be taken to minimize the probability of radiological accidents?
1D-20 What program (e.g., Process Safety Management) formally assesses the potential for radiological and other accidents during planning for post-operational activities? What types of potential problems have been found and addressed?
1D-21 What radiological and other accidents have occurred during the post-operational period? What might have prevented them? What corrective actions has management put in place?
1D-22 What changes have been made since the operating period to the safety program with regard to accident prevention? What was the reason for those changes?
1E Post-operational activities will result in benefits commensurate with the safety risks resulting from those activities.
1E-23 Are decisions on post-operational activities based in part on the comparison of risks and benefits, with the objective of finding the best overall alternative? Are these decisions and their bases documented? Are the documents available for inspection?
1E-24 Do guidelines exist regarding the way risks, benefits, and costs are to be evaluated during the decision and planning process? Are they documented? Are the documents available for inspection?
1E-25 What individuals are responsible for deciding among alternatives clearly identified? Do they know who they are? Do they acknowledge responsibility?
1F Post-operational activities and systems will be adequate to compensate for safety vulnerabilities resulting from age-related degradation, including an appropriate margin to accommodate uncertainties in material status.
1F-26 How does the guidance for performing hazards analysis explicitly identify age-related degradation as an issue to be addressed in hazards analysis and in the planning for the conduct of post-operational activities?
1F-27 Do the facility documents identify the individual(s) responsible for ensuring that hazards analysis and activity planning are done in accordance with existing guidance? Do they know who they are? Do they acknowledge responsibility?
1G The generation of radioactive waste will be minimized to the extent feasible.
1G-28 Where Is waste minimization clearly stated as a continuing facility policy and objective? Is the document available for inspection?
1G-29 For activities that generate radioactive wastes, how is the planning process required to assess optional activities as a means to minimize waste generation?
1G-30 Is waste generation a value that is documented, tracked or trended by management? Are the documents available for inspection?
1.2.2 Nuclear Safety Principles for Post-Operational Activities at Nuclear Facilities Where a Nuclear or Radiological Hazard of Concern Exists
1H Operations will be performed in a formal and controlled manner on a continuing basis.
1H-31 Are written plans and procedures required prior to the initiation of a post-operational activity? Where is the requirement stated?
1H-32 What written guidance is used for the format and content of plans and procedures?
1H-33 Are plans and procedures controlled documents?
1H-34 Is the responsibility for preparing and controlling the plans and procedures clearly defined in writing? Are these documents available for inspection?
1H-35 What is the internal review or assessment process to ensure the adequacy of the required plans and procedures?
1I The configuration and status of the physical plant will be documented and controlled on a continuing basis.
1I-36 Is there a written requirement that drawings and other documents that define the current configuration of the plant be baselined and maintained current within a document control system? Where is the requirement documented? Is the documentation available for inspection? Is a phase out plan needed? Has it been prepared?
1I-37 Who are the individuals responsible for configuration baselining and control during the post-operational period? Are they clearly identified in facility documents? Is the documentation available for inspection? Do the responsible individuals acknowledge that they are responsible?
1I-38 Where is the authority for approving configuration changes clearly defined?
1I-39 Do procedures prohibit facility configuration changes by unauthorized persons and describe the process for obtaining approval of such changes?
1J Positive control of nuclear processes and safety systems, including communications and instrumentation systems, will be maintained.
1J-40 Is there a) a written requirement that Technical Safety Requirements be established for the post-operational activity (e.g., a contractual requirement to implement DOE 5480.22), or b) a written determination by a Secretarial Officer that Technical Safety Requirements are not necessary or appropriate for the activity? Are these requirements documented and available for inspection?
1J-41 Who are the individuals responsible for approval and implementation of Technical Safety Requirements? Is this clearly identified in facility documents? Do the individuals acknowledge responsibility?
1K 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.
1K-42 How is the need for a Safety Analysis Report or a Hazard Analysis Report identified and managed in the post-operational period? Is the individual responsible for approving the Safety Analysis Report or Hazards Analysis Report clearly identified in the facility documentation? How frequently will these reports be updated?
1K-43 What safety and hazards analysis documents are currently in place or being developed? Are they available for inspection?
1K-44 How are post-operational safety and hazards analysis requirements implemented and monitored? Are managers and other key personnel responsible for performing activities covered in a Safety Analysis Report or Hazards Analysis Report aware of these responsibilities?
1L 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.
1L-45 Where is the defense-in-depth concept stated as continuing facility policy during the post-operational period? Will the policy be phased out? How? Who is responsible for approving changes?
1L-46 How does the Safety Analysis Report or Hazards Analysis Report explicitly address the need for defense-in-depth as part of preventing accidents caused by single failures and common-cause failures? What management process provides risk-based decision making in the post-operational period?
1L-47 Please cite examples of defense-in-depth or risk-based decisions that have been made by managers in the post-operational period. Are they documented? Is the documentation available for inspection?
1M The operational reliability of structures, systems, and components integral to post-operational activities should be maintained at levels consistent with the nuclear or radiological consequences of failure as defined and assessed in the applicable Safety Analysis or Hazards Analysis document.
1M-48 How is the reliability of structures, systems, and components integral to post-operational activities being monitored and controlled by facility management? Is there a written requirement that the safety significance of changes in structures, systems, and components be assessed by management in terms of the consequences of failure prior to implementing the changes?
1M-49 Is there a requirement that the operational reliability of structures, systems, and components needed in the post-operational period be established, approved by facility management, and maintained at levels that are consistent with their safety significance? Where is this documented? Are the documents available for inspection?
1M-50 Are the managers and other personnel who are responsible for establishing and maintaining the operational reliability of the structures, systems, and components in the post-operational period clearly identified in the facility documents? Are the documents available for inspection? Do the individuals acknowledge their responsibilities?
1M-51 Is there a record of the structures, systems, and components for which requirements related to operational reliability have been established and approved by facility management? Is this record available for inspection?
1N A program to identify and address unreviewed safety questions will be maintained on a continuing basis.
1N-52 What facility documents identify the need for continuing review and re-evaluation of safety in the light of ongoing activities and changing plant conditions during the post-operational period? What is the formal process for management review and resolution of unreviewed safety questions?
1N-53 What facility documents clearly identify the individual(s) responsible for screening safety issues, including safety concerns raised by workers or members of the public, to identify unreviewed safety questions?
1O Personnel training and qualifications will be maintained on a continuing basis.
1O-54 Is there a formal, documented program for qualifying management and supervisory personnel to perform key management and supervisory functions required by post-operational activities? Are manager train in the skills needed in case of a worker work stoppage? Is the documentation available for inspection?
1O-55 Are manager and supervisor job qualifications established through formal analysis of skill requirements for key functions required by post-operational activities? Please provide examples.
1O-56 How is the use of unqualified personnel to perform safety functions explicitly prohibited?
1O-57 Which facility organization and management documents clearly identify the individual(s) responsible for recruitment, training, and qualification/certification of personnel during the post-operational period, especially for new or unique technical requirements? Are these documents available for inspection?
1O-58 What management process ensures or verifies the continued qualification of personnel performing key functions in the post-operational period?
1P 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.
1P-59 What management process causes the review of proposed activities on a coordinated or integrated basis for opportunities to minimize the potential radiological consequences of accidents?
1P-60 What managers and management controls ensure the continued integrity of containment barriers during post-operational activities?
1Q Emergency response capabilities commensurate with the potential accidents that could reasonably occur at the facility will be available on a continuing basis.
1Q-61 Where are all of the required emergency response capabilities described in safety and hazard assessment documents? Are they in place and functional for the post-operational period? What major emergency response resource changes are needed for post-operational period?
1Q-62 What forward-looking management process provides planning for changing emergency response needs during post-operational activities? What required emergency response capabilities will not be implemented at the facility in a timely manner due to inadequate budget support or availability of resources?
1Q-63 What contingency procedures for accidents or events have included emergency response capabilities that have been degraded?
1Q-64 What individuals are responsible for implementing and controlling emergency response capabilities during actual events? Are they clearly identified in the facility planning documents? What emergency response functions do not have specific individuals assigned?
1Q-65 Are emergency response drills and exercises conducted in accordance with the requirements and schedules defined in facility documents? Are the drills and exercises adequate as performed? What records provide evidence of emergency response program adequacy? How many individuals are assigned to each emergency response management function?
1.3 Surveillance Activities
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 Management-Related Document Review
1.3.1.1 Safety Analysis and Hazard Analysis Reports
Questions: 1 15 22 23 33 37 38 39 40 42 43 44 45 46 47 48 51 52 53 58 60 62
1.3.1.2 Organizational Information, Procedures, and Plans
Questions: 1 2 3 5 6 7 8 9 11 12 13 14 15 16 17 18 19 20 22 26 27 28 29 30 31 32 33 34 35 36 37 38 39 40 41 42 44 43 46 48 49 50 51 52 53 54 55 56 57 58 59 60 62 63 64 65
1.3.1.3 Records
Questions: 4 7 10 13 17 20 30 48 51 54 55 57 58 65
1.3.2 Management-Related Interviews
1.3.2.1 Senior Managers
Questions: 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 34 35 36 37 38 39 40 41 42 43 44 45 46 47 48 49 50 51 52 53 54 55 56 57 58 59 60 61 62 63 64 65
1.3.2.2 Facility Managers and Subcontractor Liaison
Questions: 2 3 6 7 8 9 10 11 12 13 14 15 16 18 19 20 23 24 25 26 27 28 29 31 32 33 35 36 38 42 44 45 47 48 49 50 51 54 55 56 58 59 61 64 65
1.3.2.3 Staff Personnel
Questions: 2 4 6 7 9 10 12 17 18 19 20 24 25 28 31 32 33 36 38 42 44 45 48 50 52 54 56 58 59 61 62 64 65
1.3.2.4 Facility Stakeholders
Questions: 1 4 19 61 65
1.3.3 Management-Related Facility Inspections
1.3.3.1 Containment Barriers and Boundaries
Questions: None
1.3.3.2 Alarm, Indication, and Communications Systems
Questions: 61
1.3.3.3 Process and Safety Systems
Questions: None
1.3.4.4 Support Facilities
Questions: 17 61
2.0 RADIOLOGICAL CONTROLS
2.1 Introduction
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.
2.2 Radiological Controls Nuclear Safety Principles and Questions Sets
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.
2.2.1 Nuclear Safety Principles and Key Questions for Post-Operational Radiological Controls Activities at All Nuclear Facilities
2A Facilities will meet applicable federal, state, and local health and safety laws and regulations related to radiological hazards, including those identified by contract or other form of agreement.
2A-1 Have applicable federal, state, local laws and regulations, and other standards been reviewed to determine specific radiological controls and cleanup requirements to be met by the facility throughout the post-operational period?
2A-2 Are these radiological controls requirements documented and promulgated specifically for use in post-operational planning and management?
2A-3 Have the post-operational radiological requirements been assessed for completeness and effectively integrated with each other and with project planning to eliminate conflicts and ambiguities?
2A-4 Do managers, supervisors, and workers know who is responsible for providing guidance on radiological controls requirements and how to obtain that guidance in their areas of responsibility?
2A-5 Is there buy in by the plant or facility stakeholders that the post-operational radiological protection program is (or will be) effective?
2A-6 Is there a process established that ensures radiological protection requirements will be met on a continuing basis throughout the post-operational period?
2B The exposure of any person to radiation will be kept as low as is reasonably achievable (ALARA) under a systematic program for radiological controls.
2B-7 Do radiation exposure records provide separate information for (1) operational exposures, (2) maintenance-related exposures, (3) surveillance activity exposures, (4) training program exposures, (5) and radiation survey exposures? Are exposures from these activities tracked and/or trended separately to determine which activities require more attention to reduce exposures?
2B-8 Is there a process that systematically identifies post-operational activities to which ALARA is applicable?
2B-9 Is there remotely controlled equipment in place or planned to help implement ALARA during post-operational activities?
2B-10 What are the differences that exist in the ALARA procedures used during the post-operational period relative to those previously used during normal plant operations and maintenance periods (or between this facility and other facilities at the site)? Why are these differences appropriate?
2B-11 Does each individual know the facility radiation levels and understand his or her personal role in maintaining radiation exposure ALARA? Is the facility safety culture oriented toward ALARA? What examples demonstrate that there is an effective ALARA program in place and working?
2B-12 Is there a management process that ensures effective ALARA reviews, planning, and implementation?
2C No person will receive doses of ionizing radiation in excess of the statutory dose limits during post-operational activities.
2C-13 Have the various types of dosimetry needed been identified, and are radiation exposures being properly monitored and controlled on a daily basis?
2C-14 Have reviews and plans been completed that forecast and manage the expected level of individual exposures to be received during post-operational activities?
2C-15 For those activities involving the most radiological exposure, have options been identified and assessed to ensure that exposures are minimized and that they do not unnecessarily become the controlling consideration?
2C-16 Is the radiation monitoring and dosimetry laboratory work or paperwork backlog minimal?
2C-17 Are processes and controls in place to identify and control radiation hot spots during post-operational activities.
2D All practical steps will be taken to prevent radiological accidents during post-operational activities.
2D-18 What reviews of radiological events at other facilities have been conducted to determine what should be done to prevent similar events at the facility?
2D-19 What radiological accidents are possible during post-operational activities been identified? What has been or will be done to prevent these events?
2D-20 What new physical and procedural barriers have been established to prevent or minimize radiological accidents?
2D-21 What process is in place for systematically identifying and addressing emergent radiological accident risks?
2E Post-operational activities involving exposure or potential exposure to ionizing radiation will result in benefits commensurate with the safety risks resulting from that exposure.
2E-22 Are there review processes and criteria through which a determination might be made that a post-operational activity would result in unnecessary radiation exposures or significant uncertainty as to the level of those exposures?
2E-23 Are there specific examples where a determination has been made that an activity should be modified in order to achieve benefits commensurate with the associated safety risks?
2F Post-operational radiological protection activities and related systems will be adequate to compensate for safety vulnerabilities resulting from age-related degradation, including an appropriate margin to accommodate uncertainties in material status.
2F-24 Have daily radiation protection activities been changed due to increased radiological vulnerabilities caused by post-operational activities involving potentially degraded equipment and systems?
2F-25 Are there processes in place to identify and address the principal areas of radiological uncertainty for post-operational projects involving potentially degraded equipment and systems?
2G The generation of radioactive waste will be minimized to the extent feasible.
2G-26 Have plans been developed and implemented to minimize radioactive waste generation?
2G-27 Does the radiation protection organization play a role in supporting the waste minimization principle?
2G-28 Are there specific examples where the generation of unnecessary radioactive waste has been avoided?
2.2.2 Nuclear Safety Radiological Controls-Related Principles for Post-Operational Activities at Nuclear Facilities Where a Nuclear or Radiological Hazard of Concern Exists
2H Operations will be performed in a formal and controlled manner on a continuing basis.
2H-29 Do facility post-operational procedures (including those for routine tours and inspections) as documented and used by the responsible contractor organization include allowances for relaxation of formality when required to minimize personnel exposure to ionizing radiation?
2I The configuration and status of the physical plant will be documented and controlled on a continuing basis.
2I-30 Is there a process in place to ensure that radiation survey point maps (onsite and offsite) and related documents are updated during post-operational periods in a manner consistent with identifying new release pathways and detecting radiological control problems?
2I-31 Are there plans and procedures to ensure that the status of the facility shielding system is updated and meets design requirements on a continuing basis during the post-operational period?
2J Positive control of nuclear processes and their safety systems, including communications and instrumentation systems, will be maintained.
2J-32 Are there plans and procedures in place to ensure the availability, operability, and continued operation of radiation detection systems on a continuing basis during the post-operational period?
2J-33 Have organizational elements been assigned to monitor and review radiation protection exposure and instrumentation data on a continuing basis during the post-operational period?
2K 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.
2K-34 Has the worst-case radiological consequence that could result during post-operational activities been identified and addressed?
2K-35 Have actions to reduce radiological consequences been taken or planned as part of safety and hazards analysis follow-up actions?
2L 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.
2L-36 Are there systems and procedures in place to detect contamination on or in equipment and personnel if the primary instrumentation or protective clothing used at individual work sites is not effective?
2L-37 Are there systems and backup systems in place to prevent, detect, measure, and warn personnel of significant accidents such as an inadvertent criticality?
2L-38 Have agreements and procedures been developed and implemented to identify, train, and use radiological control resources that are available in the local community or nearby population centers?
2M 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.
2M-39 Is there a process or plan to ensure that plant systems important to safety will be maintained at a level of reliability consistent with applicable safety categorizations?
2N A program to identify and address unreviewed safety questions will be maintained on a continuing basis.
2N-40 Is there a process in place to systematically look for and address emergent unreviewed safety questions on a continuing basis during the post-operational period?
2N-41 Have unreviewed safety questions been identified that impact radiological controls?
2O Personnel training and qualifications will be maintained on a continuing basis.
2O-42 Is there a process for identifying radiological controls training requirements and conducting the associated training on a continuing basis during the post-operational period?
2O-43 Is the training and qualification status adequate for plant personnel working in radiation areas?
2O-44 Is there a process that ensures the continued qualification of radiation control personnel and radiation detection equipment technicians?
2P 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.
2P-45 Has a program been established that ensures appropriate active and passive radiological containment barriers are in place and maintained in a reliable condition on a continuing basis during the post-operational period?
2P-46 Is the level of effectiveness of facility radiological containment barriers adequate?
2P-47 Are there radiation detection systems in place to control each radioactive isotope present and to detect releases caused by barrier failures?
2Q Emergency response capabilities commensurate with the potential accidents that could reasonably occur at the facility will be available on a continuing basis.
2Q-48 Have upgrades in plant and local community radiological controls and emergency response programs been planned or implemented to meet contingencies on a continuing basis during the post-operational period?
2.3 Surveillance Activities
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 Radiological Controls-Related Document Review
2.3.1.1 Safety Analysis Reports
Questions: 1 6 19 20 31 34 35 36 37 39 40 47 48
2.3.1.2 Post-operational Radiological Control Procedures and Plans
Questions: 2 3 4 6 7 8 9 10 12 13 14 15 16 17 18 19 20 21 22 24 25 26 27 29 30 31 32 33 34 35 36 37 38 39 40 42 43 44 45 46 47 48
2.3.1.3 Radiological Controls Records
Questions: 1 2 3 5 7 8 13 14 16 17 23 24 25 26 28 30 31 32 33 35
2.3.2 Radiological Controls-Related Interviews
2.3.2.1 Health Physics Manager/Supervisor
Questions: 1 2 4 3 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 34 35 36 37 38 39 40 41 42 43 44 45 46 47 48
2.3.2.2 Facility Manager/Control Room Manager
Questions: 2 3 4 5 6 7 8 9 11 12 13 15 17 18 19 20 21 22 23 24 26 28 29 30 34 36 37 38 39 40 41 43 44 45 46 48
2.3.2.3 Radiation Workers
Questions: 4 5 7 9 11 12 13 17 18 19 20 23 24 26 28 29 34 36 37 40 43 44 45 46
2.3.2.4 Facility Stakeholders
Questions: 1 2 5 6 19 20 22 23 26 34 37 38 40 41 45 46 48
2.3.3 Radiological Controls-Related Facility Inspections
2.3.3.1 Containment Barriers and Boundaries
Questions: 19 20 30 31 33 39 45 46
2.3.3.2 Radiation Alarm and Indication Systems
Questions: 13 17 19 20 32 34 37 39 45 47
2.3.4.3 Support Facilities
Questions: 13 16 20 26 32 33 36
3.0 OPERATIONS
3.1 Introduction
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.
3.2 Operations-Related Nuclear Safety Principles and Questions Sets
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.
3.2.1 Nuclear Safety Principles and Key Questions for Post-Operational Activity Control at All Nuclear Facilities
3A Facilities will meet applicable federal, state, and local health and safety laws and regulations related to operations, including those identified by contract or other form of agreement.
3A-1 Has a formal assessment determined which current and future safety system, process operations, and other activities at the post-operational facility are impacted by federal, state, and local requirements?
3A-2 Is there an administrative procedure that ensures conformance with these requirements on a continuing basis during the post-operational period?
3B The exposure of any person to radiation will be kept as low as is reasonably achievable (ALARA) under a systematic program.
3B-3 Are there ALARA-related policies and procedures in place for plant personnel participating in post-operational activities?
3B-4 How does operations management include ALARA program considerations in operational activities?
3B-5 Does the facility and contractor safety culture place importance on identifying dose reduction opportunities and implementing them?
3B-6 Are there examples that demonstrate the presence of an effective ALARA program? For example, is remotely operated equipment provided to help avoid, or reduce, radiation exposures?
3B-7 Where operational procedures require personnel access to equipment that may be radioactive or contaminated, how are ALARA concerns addressed in the procedures?
3B-8 What evidence is there that facility operators are aware of ALARA policies and are implementing them?
3C No person will receive doses of ionizing radiation in excess of the statutory dose limits during post-operational activities.
3C-9 Have personnel exceeded administrative control limits or a statutory dose limit?
3C-10 For personnel that have reached or are likely to reach administrative radiation exposure limits, are there plans for replacing them with other qualified personnel?
3C-11 Are operators and other potentially affected personnel aware of plant radiation levels and their own cumulative radiation exposure level?
3D All practical steps will be taken to prevent radiological accidents during post-operational activities.
3D-12 How are radiological accidents considered in the planning of post-operational activities?
3D-13 What radiological accidents occurred (or could occur) due to operations performed at this facility during the post-operational period?
3D-14 What specific steps are taken during post-operational activities to look for and prevent radiological accidents, especially when changes in procedures or the way evolutions are conducted are involved?
3D-15 Who are the managers responsible for determining what practical steps will be taken to minimize the probability of a radiological accident?
3E Post-operational activities involving exposure or potential exposure to ionizing radiation will result in benefits commensurate with the safety risks resulting from that exposure.
3E-16 Who is the manager assigned the responsibility for deciding whether the radiation doses expected to be received during a post-operational activity are worth the associated benefits from that activity?
3E-17 Are there specific examples where a determination has been made (or would be made) that an activity should be modified in order to achieve benefits commensurate with the associated safety risks? What are they?
3F Post-operational radiological protection activities and related systems will be adequate to compensate for safety vulnerabilities resulting from age-related degradation, including an appropriate margin to accommodate uncertainties in material status.
3F-18 Have compensations been applied to post-operational activities to address material degradation and uncertainties regarding material degradation? What are they?
3F-19 Have the types of material or equipment age-related uncertainties that could impact personnel safety or environmental safety been identified? What are they?
3F-20 Are there plant degradations that require workarounds in order to ensure adequate personnel and environmental safety? What are they?
3G The generation of radioactive waste will be minimized to the extent feasible.
3G-21 Have post-operational activities that result in the production of radioactive waste been identified? What are they?
3G-22 Have actions been taken or planned to minimize the production of radioactive waste? What are they?
3G-23 What coordination is required with waste management personnel regarding the generation of radioactive waste?
3.2.2 Nuclear Safety Principles and Key Questions for Post-Operational Activities at Nuclear Facilities Where a Nuclear or Radiological Hazard of Concern Exists
3H Operations will be performed in a formal and controlled manner on a continuing basis.
3H-24 What is the process to determine the applicability of conduct of operations requirements to post-operational activities?
3H-25 How are operating procedures formally controlled and validated under changing post operating conditions?
3H-26 Does the operator and contractor safety culture fully support the use of formal communications and procedures?
3H-27 Have changes to communications and plant status information displays occurred since the facility was shutdown? What are they?
3H-28 Are there plant status documents and procedures in place to ensure a complete watchstander turnover and comprehensive shift turnover? What are they?
3H-29 Under what conditions it will be possible to terminate formal and controlled operations?
3I The configuration and status of the physical plant will be documented and controlled on a continuing basis.
3I-30 Are activities that affect the status of plant equipment and decisions that could result in restrictions affecting operations authorized by appropriate operations personnel?
3I-31 Is there adequate validated information available to ensure that post-operational activities can be performed safely?
3I-32 Is there an efficient process in place to ensure that a change in the physical plant is reflected in the documentation used to develop and control continuing activities?
3I-33 Are sufficient data and information being collected for permanent records?
3I-34 Are activities affecting equipment status formally controlled using lockout/tagout devices and labels?
3I-35 Have problems occurred or are problems expected as a result of a lack of accurate plant configuration or status information?
3J Positive control of nuclear processes and their safety systems, including communications and instrumentation systems, will be maintained.
3J-36 Have the nuclear processes that are possible in the facility during post-operational activities been defined and documented? What are they?
3J-37 Have safety system requirements associated with each of those processes been identified? If so, what are they?
3J-38 Have communications and instrumentation systems that are needed for controlling nuclear processes and safety systems been identified?
3J-39 What controls are in place to ensure that operating stations and other areas of the facility have and will continue to have adequate lighting and ventilation during the post-operational period?
3J-40 What program will ensure the continued availability of qualified personnel to operate, maintain, or deactivate plant process and safety equipment in a reliable and controlled manner?
3J-41 Why is the overall level of process and safety system reliability and redundancy adequate in terms of what is needed to proceed with post-operational activities?
3K 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.
3K-42 How are post-operational plant activities addressed in the facility safety and hazard analysis documentation?
3K-43 What post-operational plant activities are not addressed in the facility safety and hazard analysis documentation?
3K-44 What process is used to ensure that future activities will be assessed for safety and that adequate protection is available for personnel and for the environment before the initiation of activities?
3K-45 What events have occurred that indicate the level of adequacy of the facility safety and hazard assessments?
3L 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.
3L-46 Are there operational controls in place or planned that provide or contribute to defense-in-depth for postulated accidents on a continuing basis during the post-operational period? What are they?
3L-47 Have the post-operational activities that require independent verifications been identified? What are they?
3L-48 What nuclear accident scenarios do not have adequate levels of prevention and defense-in-depth?
3L-49 Are adjustments in operator routines in place or planned to ensure continued effectiveness of the passive and active elements of the facility containment barriers? What are they?
3L-50 What safety systems are no longer needed to provide defense-in-depth?
3M 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.
3M-51 Have the technical safety requirements that apply to the facility during the post-operational period been identified? What are they?
3M-52 What surveillance activities are in place and scheduled to support meeting the technical safety requirements on a continuing basis?
3M-53 How is the operability of safety related equipment verified and controlled at a level that ensures continued safety?
3M-54 What chemistry and lay-up requirements have been identified and implemented for the preservation of plant equipment?
3M-55 What procedures or controls are in place to formally take safety related equipment out of service on a permanent basis?
3M-56 What safety related equipment has already been taken out of service?
3N A program to identify and address unreviewed safety questions will be maintained on a continuing basis.
3N-57 What process is in place to systematically look for and address emergent unreviewed safety questions on a continuing basis during the post-operational period?
3N-58 What unreviewed safety questions been identified that could impact plant post-operational activities?
3N-59 What evidence is there that a facility operator would be able to recognize an unreviewed safety question in the course of post-operational activities?
3O Personnel training and qualifications will be maintained on a continuing basis.
3O-60 What current and future operator training and qualification requirements been identified and implemented?
3O-61 What training and qualification requirements are unique to the post-operational period?
3O-62 Have new training and qualification requirements for facility and other contractor personnel been identified and implemented in a timely manner? What are they?
3O-63 Is there a required-reading or lessons learned program in effect for personnel participating in post-operational activities? What is included?
3P 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.
3P-64 What control and instrumentation systems are in place for continued monitoring and maintenance of containment integrity?
3P-65 Have the operators responsibilities regarding ensuring the integrity of containment boundaries been identified and implemented? What are they?
3P-66 What documentation records the day-to-day status of containment barriers?
3P-67 What improvements could be implemented to increase containment barrier effectiveness?
3Q Emergency response capabilities commensurate with the potential accidents that could reasonably occur at the facility will be available on a continuing basis.
3Q-68 What upgrades in plant and local community emergency response programs have been planned or implemented to meet contingencies on a continuing basis during the post-operational period?
3Q-69 What emergency response training is provided to personnel involved with post-operational activities?
3Q-70 What special equipment is in place or needed to support early response to potential emergencies?
3Q-71 What evacuation and personnel accounting procedures in place?
3.3 Surveillance Activities
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 Operations-Related Document Review
3.3.1.1 Safety Analysis Reports
Questions: 1 2 13 14 18 24 25 31 33 36 37 38 39 42 43 46 47 48 49 50 51 58 64 68 70 71
3.3.1.2 Post-Operational Procedures and Plans
Questions: 1 2 3 4 7 12 14 15 16 18 19 20 21 22 24 25 27 28 29 30 31 32 33 34 36 38 39 40 44 46 47 49 50 51 52 53 54 55 56 58 60 61 62 63 64 68 69 70 71
3.3.1.3 Operational Records
Questions: 4 6 9 13 14 17 18 19 20 21 25 27 28 29 30 31 32 33 34 36 45 47 51 52 53 54 56 57 58 64 65 66 69
3.3.2 Operations-Related Interviews
3.3.2.1 Operations Manager/Supervisor
Questions: 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 34 35 36 37 38 39 40 41 42 43 44 45 46 47 48 49 50 51 52 53 54 55 56 57 58 59 60 61 62 63 64 65 66 67 68 69 70 71
3.3.2.2 Facility Manager/Control Room Manager
Questions: 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 23 24 25 26 27 28 29 30 31 32 33 34 36 37 38 41 42 43 45 46 47 48 49 50 51 52 53 55 56 57 58 59 60 62 63 64 66 67 68 69 70 71
3.3.2.3 Facility Operators
Questions: 3 4 5 6 7 8 11 12 13 14 15 16 18 20 21 23 24 25 26 27 28 29 30 31 34 35 36 37 38 41 42 43 45 46 47 48 49 50 51 52 53 56 57 58 59 60 62 63 64 65 66 67 69 70 71
3.3.2.4 Facility Stakeholders
Questions: 1 2 13 14 21 29 36 42 48 56 58 68
3.3.3 Operations-Related Facility Inspections
3.3.3.1 Containment Barriers and Boundaries
Questions: 13 18 20 34 39 48 49 54 56 64 67
3.3.3.2 Alarm, Indication, and Communications Systems
Questions: 13 18 20 26 27 33 34 38 48 56 64
3.3.3.3 Process and Safety Systems
Questions: 13 18 20 30 32 34 35 36 37 38 39 40 41 48 50 54 56 64 70
3.3.3.4 Control Room and Operating Station Logs and Reference Material
Questions: 11 13 20 30 31 33 34 35 56 64 70
3.3.4.5 Support Facilities
Questions: 13 18 21 23 39 54 70 71
4.0 PACKAGING AND TRANSPORTATION
4.1 Introduction
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.
4.2 Packaging and Transportation Nuclear Safety Principles and Questions Sets
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.
4.2.1 Nuclear Safety Principles and Key Questions for Post-Operational Packaging and Transportation Activities at All Nuclear Facilities
4A Facilities will meet applicable federal, state, and local health and safety laws and regulations related to or potentially impacting packaging and transportation of hazardous and radioactive materials, including those identified by contract or other form of agreement.
4A-1 Have applicable federal, state, local laws and regulations, and other standards been reviewed to determine specific packaging and transportation requirements to be met by the facility throughout the post-operational period? What are they?
4A-2 How are these packaging and transportation requirements documented and promulgated specifically for use in post-operational planning and management?
4A-3 Have the post-operational packaging and transportation requirements been assessed for completeness and effectively integrated with each other and with project planning to eliminate conflicts and ambiguities? Where is this assessment documented?
4A-4 What managers, supervisors, and workers are responsible for providing or obtaining guidance on packaging and transportation requirements? Do they know how to obtain that guidance in their areas of responsibility?
4A-5 Does the facility have a lowlevel waste certification program to provide assurance that the waste acceptance criteria for any low-level waste treatment, storage, or disposal facility used by the facility are met? Where is the program documented?
4A-6 Is there buy in by the plant or facility stakeholders that the post-operational packaging and transportation program is (or will be) effective? Where is stakeholder agreement documented?
4A-7 What is the process that ensures packaging and transportation requirements will be met on a continuing basis throughout the post-operational period?
4B The exposure of any person to radiation will be kept as low as is reasonably achievable (ALARA) under a systematic Packaging and Transportation program.
4B-8 What process systematically identifies post-operational packaging and transportation activities in which ALARA is applicable?
4B-9 What remotely controlled equipment is in place or planned to implement ALARA during post-operational packaging and transportation activities?
4B-10 How is access to storage areas marked and controlled? What are the related procedures?
4B-11 How are vehicles checked for residual radiological contamination at site entry, before loading, and before release offsite following a delivery?
4B-12 What are the differences between these procedures and those previously used for packaging and transportation either for this facility or relative to other facilities at the site?
4B-13 How does each individual involved with packaging and transportation know the related radiation levels, and how does management know individual workers understand their personal role in maintaining radiation exposure ALARA?
4B-14 What is the management process that ensures effective ALARA reviews, planning, and implementation in the packaging and transportation program?
4B-15 How does the facility and contractor packaging and transportation safety culture place importance on identifying dose reduction opportunities and implementing them?
4B-16 What examples will demonstrate the presence of an effective packaging and transportation ALARA program?
4C No person will receive doses of ionizing radiation in excess of the statutory dose limits during post-operational activities.
4C-17 What special dosimetry is in use by packaging and transportation workers, and how are radiation exposures monitored and controlled on a daily basis?
4C-18 What reviews and plans are used to forecast and manage the expected level of individual exposures that will be received during packaging and transportation activities?
4C-19 For those packaging and transportation activities involving the most radiological exposure, what options have been identified and assessed to ensure that exposures are minimized and that they do not unnecessarily become the controlling consideration?
4C-20 What processes or controls are in place to identify and control radiation hot spots during packaging and transportation activities?
4C-21 What packaging and transportation personnel have exceeded administrative control limits or a statutory dose limit?
4C-22 For personnel that have reached or are likely to reach administrative radiation exposure limits, what plans are in place for replacing them with other qualified personnel?
4C-23 How are packaging and transportation workers and other potentially affected personnel made aware of material radiation levels and their own total radiation exposure levels?
4D All practical steps will be taken to prevent radiological accidents during post-operational packaging and transportation activities.
4D-24 What radiological accidents have occurred (or could occur) due to packaging or transportation activities performed at this facility during the post-operational period?
4D-25 How are requirements for intra-building movement, onsite transfers, and enroute storage of packages addressed in the local onsite Transportation Safety Manual?
4D-26 How do packaging procedures ensure that, prior to initial use, packaging for the shipment of more than a Type A quantity of radioactive material is inspected for defects and given a containment pressure test, if applicable?
4D-27 How are radiological accidents considered in planning for post-operational packaging and transportation activities?
4D-28 How is the need for new physical and procedural barriers to prevent or minimize packaging and transportation radiological accidents considered and implemented?
4D-29 Who is the manager responsible for determining what practical steps will be taken to minimize the probability of a radiological accident during packaging and transportation activities?
4D-30 If more resources were available for packaging and transportation activities, what else could be done to protect against radiological accidents?
4E Post-operational packaging and transportation activities involving exposure or potential exposure to ionizing radiation will result in benefits commensurate with the safety risks resulting from that exposure.
4E-31 Are there review processes and criteria through which a determination might be made that a post-operational packaging and transportation activity will result in unnecessary radiation exposures or significant uncertainty as to the level of those exposures? What are they?
4E-32 Are there specific examples where a determination has been made that a packaging and transportation activity should be modified in order to achieve benefits commensurate with the associated safety risks? What are they?
4E-33 For transportation of radioactive materials offsite, how are the potentially affected offsite stakeholders involved with assessing the hazards and making recommendations for improvements?
4E-34 What stakeholder recommendations have been implemented in the packaging and transportation area?
4F Post-operational packaging and transportation activities and related systems will be adequate to compensate for safety vulnerabilities resulting from age-related degradation, including an appropriate margin to accommodate uncertainties in material status.
4F-35 How have daily packaging and transportation radiation protection activities been upgraded due to increased radiological vulnerabilities caused by degraded equipment and systems unique to the post-operational phase?
4F-36 What processes and plans have been used to identify and address the principal areas of radiological uncertainty for packaging and transportation post-operational projects involving potentially degraded materials and equipment?
4F-37 What material or equipment degradations require work arounds in order to ensure adequate personnel and environmental safety during packaging and transportation activities?
4F-38 What storage container corrosion and fire protection issues need to be addressed during post-operational packaging and transportation activities?
4G The generation of radioactive waste during post-operational packaging and transportation activities will be minimized to the extent feasible.
4G-39 What plans are in place to minimize radioactive waste volume during post-operational packaging and transportation activities?
4G-40 How does the packaging and transportation organization play a role in supporting the waste minimization principle?
4G-41 Are there specific examples where the generation of unnecessary radioactive waste has been avoided during packaging and transportation activities? What are they?
4G-42 How is the appropriate level of coordination identified and established with other post-operational personnel regarding the packaging of radioactive and hazardous wastes?
4.2.2 Nuclear Safety Packaging and Transportation-Related Principles for Post-Operational Activities at Nuclear Facilities Where a Nuclear or Radiological Hazard of Concern Exists
4H Packaging and transportation activities will be performed in a formal and controlled manner on a continuing basis.
4H-43 How do facility post-operational packaging and transportation procedures include allowances for relaxation of formality when required to minimize personnel exposure to ionizing radiation?
4H-44 What aspects of Conduct of Operations requirements have been identified and routinely applied to post-operational packaging and transportation activities?
4H-45 Do material storage procedures include administrative controls and verifications for material movements to and from storage, including verifying the amount of material, the radioisotopes present, chemical composition, and the degree of neutron moderation? What are they?
4H-46 How are waste characterization needs and the handling and storage of mixed wastes addressed?
4H-47 Does interim storage for solidified high-level waste awaiting transport to the designated geologic repository comply with permanent high level waste storage requirements? If not, why not?
4H-48 In what manner does the contractor packaging and transportation safety culture include the routine use of formal communications and procedures?
4H-49 How are data and information collection requirements identified and implemented for record purposes?
4H-50 Where in the record keeping system are the data maintained that are necessary to show that radioactive and hazardous waste was properly classified, treated, stored, shipped, and permanently dispositioned?
4H-51 Under what conditions will it be possible to terminate formal and controlled packaging and transportation activities?
4I The configuration and status of the physical plant will be documented and controlled on a continuing basis.
4I-52 How is major packaging and transportation equipment included in controlled design documentation and configuration control?
4I-53 What design controls and safety features (e.g., fire protection and radiation shielding) associated with storage and work areas are used by the packaging and transportation organization?
4I-54 How are design controls and safety features for packaging and transportation facilities being maintained during the post-operational period?
4J Positive control of nuclear processes and their safety systems, including communications and instrumentation systems, will be maintained.
This principle does not apply to the packaging and transportation functional area.
4K 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.
4K-55 How are expected dispositions of radioactive and hazardous materials identified with respect to treatment, packaging, interim storage, transportation, and disposal?
4K-56 What is the worst-case radiological consequence that could result during post-operational packaging and transportation activities? How was it identified and addressed?
4K-57 What detailed criticality safety analyses have been performed as to how fissionable materials are handled, stored, and transported?
4K-58 What transportation-related safety and hazards analyses have been issued for the facility?
4K-59 What is the approval process for onsite and offsite transportation related safety and hazards analyses?
4K-60 What actions to reduce radiological consequences have been taken or planned as part of safety and hazards analysis followup actions?
4K-61 What post-operational packaging and transportation activities are not addressed in the facility safety and hazard analysis documentation?
4K-62 What process ensures future packaging and transportation activities will be assessed in a timely manner to meet facility needs?
4K-63 What packaging and transportation successes and problems have been reviewed to evaluate the level of adequacy of the facility safety and hazard assessments?
4L 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.
4L-64 What systems and backup systems are in place to prevent, detect, measure, and warn personnel of an uncontrolled release of radioactive contamination during post-operational packaging and transportation activities?
4L-65 How have post-operational packaging and transportation activities that require independent verifications been identified?
4L-66 Have packaging and transportation accident scenarios that do not have adequate levels of prevention and defense-in-depth been identified and addressed? What were the results?
4L-67 What routine inspections and surveillances are used to ensure the continued effectiveness of the passive and active elements of waste containers and protective or alarm systems?
4L-68 What procedures or systems are no longer needed in the post-operational period to provide defense-in-depth?
4M 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.
4M-69 What technical safety requirements apply to packaging and transportation systems and procedures?
4M-70 What surveillance activities are in place and scheduled to support meeting the technical safety requirements on a continuing basis?
4N A program to identify and address unreviewed safety questions will be maintained on a continuing basis.
4N-71 What process is in place to systematically look for and address emergent unreviewed safety questions in the packaging and transportation area?
4N-72 What unreviewed safety questions that impact packaging and transportation have been identified?
4O Personnel training and qualifications will be maintained on a continuing basis.
4O-73 What is the process for identifying packaging and transportation training requirements and conducting the associated training during the post-operational period?
4O-74 What training and qualification requirements are unique to the post-operational period?
4O-75 Why is the current training and qualification status adequate for plant personnel working in the packaging and transportation area?
4O-76 What formal program ensures the continued qualification of packaging and transportation equipment workers and support technicians?
4P All practical steps will be taken to minimize the radiological consequences of accidents occurring as a result of post-operational packaging and transportation activities, including the maintenance of established containment barriers where feasible.
4P-77 How have the packaging and transportation organizational responsibilities regarding ensuring the integrity of waste storage facility containment boundaries been identified and implemented?
4P-78 What is the current condition of the waste storage facility radiological containment barriers?
4P-79 What radiation detection systems are in place to detect releases caused by barrier failures?
4P-80 What program ensures the use of appropriate active and passive radiological containment barriers for packaging and transportation facilities, and are they maintained in a reliable condition on a continuing basis during the post-operational period?
4Q Emergency response capabilities commensurate with potential packaging and transportation accidents that could reasonably occur at the facility will be available on a continuing basis.
4Q-81 What special design and engineering features are provided for fire fighting, flooding, and other emergencies in areas where fissile and radioactive materials are stored?
4Q-82 What upgrades in plant and local community radiological controls and emergency response programs have been identified, planned, and implemented to meet packaging and transportation contingencies?
4Q-83 What special equipment is in place or needed to support early response to potential packaging and transportation emergencies?
4Q-84 What emergency response training is provided to personnel involved with post-operational packaging and transportation activities?
4.3 Surveillance Activities
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 is listed under one or more of the three assessment components. The evaluator should keep in mind that these listings are only suggestions, intended only 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 85, an additional question should be entered under the applicable principle, and the number 85 should be added to the assessment components where 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.
4.3.1 Packaging and Transportation-Related Document Review
4.3.1.1 Safety and Hazards Analysis Reports
Questions: 1 5 8 9 10 17 19 24 25 26 27 28 31 35 36 37 38 39 42 43 44 45 46 47 49 50 51 52 53 54 55 56 57 58 59 60 61 64 65 66 67 68 70 71 73 74 76 77 78 79 80 81 82 83 84
4.3.1.2 Packaging and Transportation Procedures and Plans
Questions: 1 2 3 4 5 6 7 8 9 10 11 12 13 14 16 17 18 19 20 22 23 24 25 26 27 28 29 31 33 34 35 36 37 38 39 40 42 43 44 45 46 47 49 50 51 52 54 55 57 59 60 61 62 64 65 66 67 68 69 70 71 72 73 74 76 77 79 80 82 83 84
4.3.1.3 Packaging and Transportation Records
Questions: 1 5 8 11 14 16 17 18 19 20 21 24 26 31 32 33 34 35 39 45 47 49 50 52 55 59 61 63 65 67 68 72 73 75 76 78 80 84
4.3.2 Packaging and Transportation-Related Interviews
4.3.2.1 Packaging and Transportation Manager/Supervisor
Questions: 1 2 4 3 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 34 35 36 37 38 39 40 41 42 43 44 45 46 47 48 49 50 51 52 53 54 55 56 57 58 59 60 61 62 63 64 65 66 67 68 69 70 71 72 73 74 75 76 77 78 79 80 81 82 83 84
4.3.2.2 Facility Managers
Questions: 2 4 5 8 9 10 13 14 15 16 17 18 19 21 22 24 25 28 29 30 31 32 33 35 36 37 38 39 42 43 44 45 51 53 55 56 57 58 59 61 62 63 64 65 66 67 68 69 71 72 73 77 78 79 80 81 82 83
4.3.2.3 Qualified Packaging and Shipping Personnel
Questions: 1 2 4 5 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 35 36 37 38 39 40 41 42 43 44 45 46 47 48 49 50 51 52 53 54 55 56 57 58 59 60 61 63 64 65 66 67 68 69 70 71 72 73 74 75 76 77 78 79 80 81 82 83 84
4.3.2.4 Facility Stakeholders
Questions: 1 5 6 27 28 31 33 34 51 56 58 59 64 65 66 72 79 82
4.3.3 Packaging and Transportation-Related Facility Inspections
4.3.3.1 Containment Boundaries
Questions: 10 11 26 27 28 38 52 53 56 60 64 66 68 78 79 80 81
4.3.3.2 Packaging and Storage-Related Structures, Systems, and Components
Questions: 9 10 11 19 24 26 28 35 38 52 53 56 60 64 66 68 78 79 80 81
4.3.3.3 Support Facilities
Questions: 5 9 10 11 17 19 28 38 52 53 60 64 68 79 81 82 83
5.0 MAINTENANCE AND SURVEILLANCE
5.1 Introduction
Nuclear facility maintenance requires constant attention throughout plant life, including during post-operational activities, where many maintenance activities will be performed for the first time. New procedures and temporary systems are often required, and the level of training and time available for preparation are often severely limited. Under such difficult conditions, it is increasingly important for maintenance personnel to ensure the continuing operability and reliability of safety related equipment.
It is particularly important facility managers to understand that nuclear facility post-operational maintenance and surveillance programs can be more demanding than the normal operational programs. During post-operational periods, equipment may be idle for long periods, resulting in accelerated rates of corrosion; spare parts are often no longer available from vendors and are expensive to make locally; power supplies and other auxiliary systems are often disconnected or (worse) simply abandoned; and experienced technical personnel are often no longer available to identify and correct equipment problems. In addition, idle facilities will often be used for spare parts for any remaining operating facilities, a process that can significantly increase post-operational problems if not managed within a well-established post-operational plan. Without establishing such controls and plans, safe and efficient deactivation, decontamination, and decommissioning processes can become quite difficult to achieve.
Thus, it is important to have a comprehensive and systematic path forward through these processes for each part of the physical plant. This path forward should be established immediately at the conclusion of facility operations. The instrumentation and control systems that will be needed for monitoring and controlling the remaining inventories of process materials, the pumps and valves that may be needed during remediation, and the ventilation systems that provide radiation containment and filtering must all continue to be maintained at a high level of reliability. Also, there are many passive barriers or containment boundaries required to be maintained to ensure safety in the post-operational period. Each plant structure, system, and plant component should have a clearly defined post-operational role, and its condition and reliability should be controlled under a continuing maintenance and surveillance plan.
In addition to continuing to maintain facility equipment having a defined post-operational role, there will often be new equipment or facilities required for remediation. Ideally, the necessary support systems for remediation facilities would be identified early, and current plant support system capabilities would be maintained rather than be replaced with new systems at a later date. Such forward-looking planning is seldom possible, so other management strategies may be needed. For example, it may be easier to identify those items that could not possibly be needed for post-operational and remediation activities, terminating maintenance and surveillance of such items. Even then, items no longer needed are often connected to remaining safety-related systems and require a thoughtful plan for their isolation and removal, including deactivation of electrical power supplies, fluid systems, instrumentation, and control systems.
All of these concerns indicate the continuing need to maintain and control the physical plant in the post-operational period, but this surveillance plan focuses on safety concerns. Thus, a post-operational facility meeting all of the Nuclear Safety Principles and associated maintenance and surveillance questions presented below must still have broader capabilities and plans in order to be considered adequate to meet post-operational requirements.
5.2 Maintenance-Related Nuclear Safety Principles and Questions Sets
Question sets for assessing the safety related aspects of maintenance and control programs 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 maintenance and surveillance 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.
5.2.1 Nuclear Safety Principles and Key Questions for Post-Operational Activity Control at All Nuclear Facilities
5A Facilities will meet applicable federal, state, and local health and safety laws and regulations, including those identified by contract or other form of agreement.
5A-1 Has a formal assessment determined which current and future safety system maintenance and surveillance requirements and activities at the post-operational facility are impacted by federal, state, and local requirements? What are they?
5A-2 What administrative procedure ensures conformance with these requirements on a continuing basis during the post-operational period?
5A-3 Have post-operational maintenance requirements been assessed for completeness, and have they been effectively integrated with each other and with project planning to eliminate conflicts and ambiguities? What was the result?
5A-4 What process ensures maintenance and surveillance requirements will be met on a continuing basis throughout the post-operational period?
5A-5 Do managers, supervisors, and workers know who is responsible for providing guidance on maintenance and surveillance requirements? How do they obtain that guidance in their areas of responsibility?
5B The exposure of any person to radiation will be kept as low as is reasonably achievable (ALARA) under a systematic program.
5B-6 What process systematically identifies post-operational maintenance and surveillance activities in which ALARA is applicable?
5B-7 What ALARA-related policies and procedures are in place for plant personnel participating in post-operational maintenance and surveillance activities?
5B-8 What evidence is there that facility maintenance and surveillance personnel are aware of ALARA policies and are implementing them?
5B-9 What differences exist in these procedures relative to those previously used during normal plant operations and maintenance periods (or between this facility and other facilities at the site)? Are the differences appropriate?
5B-10 What remotely controlled equipment is in place or planned to implement ALARA during post-operational maintenance and surveillance activities?
5B-11 How does each individual involved with maintenance and surveillance know the facility radiation levels and understand his or her personal role in maintaining radiation exposure ALARA?
5B-12 What examples are there that demonstrate the presence of an effective ALARA program in the maintenance and surveillance area (e.g., extent of equipment mockups used to practice maintenance procedures)?
5B-13 What management process ensures effective ALARA reviews, planning, and implementation in the maintenance and surveillance program?
5B-14 Does the facility and contractor safety culture place importance on identifying dose reduction opportunities in the maintenance and surveillance area and implementing them? How is this importance demonstrated?
5B-15 What protective coatings (with planned periodic renewal) are used to control residual levels of contamination in surfaces?
5C No person will receive doses of ionizing radiation in excess of the statutory dose limits during post-operational maintenance and surveillance activities.
5C-16 Which maintenance and surveillance personnel have exceeded administrative control limits or a statutory dose limit?
5C-17 Which personnel have reached or are likely to reach administrative radiation exposure limits? What plans are in place for replacing them with other qualified personnel?
5C-18 How are maintenance and surveillance personnel made aware of plant radiation levels and their own cumulative radiation exposure level?
5C-19 What special dosimetry is in use by maintenance and surveillance workers, and how are radiation exposures monitored and controlled on a daily basis?
5C-20 What reviews and plans have been completed that forecast and manage the expected level of individual exposures that will be received during maintenance and surveillance activities?
5C-21 For those maintenance and surveillance activities involving the most radiological exposure, what options have been identified and assessed to ensure that exposures are minimized and that they do not unnecessarily become the controlling consideration?
5C-22 What process or controls are in place to identify and control radiation hot spots during maintenance and surveillance activities?
5D All practical steps will be taken to prevent radiological accidents during post-operational maintenance and surveillance activities.
5D-23 What radiological accidents have been considered as potential events to be avoided during maintenance and surveillance activities?
5D-24 What radiological accidents have occurred (or could occur) as a result of accomplishing or not accomplishing maintenance and surveillance activities at this facility?
5D-25 What steps are taken during post-operational maintenance and surveillance activities to prevent radiological accidents, particularly when changes in procedures or changes in the way activities are conducted are involved?
5D-26 How is the need for new physical and procedural barriers to prevent or minimize maintenance and surveillance related radiological accidents considered and appropriately addressed?
5D-27 Who is the manager responsible for determining what practical steps will be taken to minimize the probability of a radiological accident during maintenance and surveillance activities?
5D-28 If more resources were available for maintenance and surveillance activities, what else could be done to protect against radiological accidents?
5E Post-operational activities involving exposure or potential exposure to ionizing radiation will result in benefits commensurate with the safety risks resulting from that exposure.
5E-29 Which manager is responsible for deciding whether the radiation doses expected to be received during a maintenance and surveillance activity are worth the associated benefits?
5E-30 Which criteria will be used to determine whether a post-operational maintenance and surveillance activity will result in unnecessary radiation exposures or significant uncertainty as to the level of those exposures?
5E-31 Please cite specific examples where a determination has been made (or would be made) that a maintenance and surveillance activity should be modified in order to achieve benefits commensurate with the associated safety risks?
5F Post-operational activities and related systems will be adequate to compensate for safety vulnerabilities resulting from age-related degradation, including an appropriate margin to accommodate uncertainties in material status.
5F-32 What compensations been identified and applied to post-operational maintenance and surveillance activities to address the potential impacts of material degradation and related uncertainties?
5F-33 What maintenance and surveillance upgrades are in place or planned that will reduce the material or equipment age-related uncertainties impacting personnel safety or environmental safety?
5F-34 When and how are periodic inspections of facility structural members, walls, floors, and roofs performed?
5F-35 Which plant degradations require work arounds in order to ensure adequate personnel and environmental safety?
5F-36 What facility or equipment corrosion and fire protection issues need to be addressed during post-operational maintenance and surveillance activities?
5F-37 Which cathodic protection systems are still needed? Are those that are still in service being calibrated and inspected periodically?
5G The generation of radioactive waste during maintenance and surveillance activities will be minimized to the extent feasible.
5G-38 Which post-operational maintenance and surveillance activities result in the production of radioactive waste? How is radioactive waste generation minimized?
5G-39 How are contaminated tools and test equipment kept separate from those that are not contaminated?
5G-40 What actions have been taken or are actions planned to minimize the production of radioactive waste?
5G-41 Please cite specific examples where the generation of unnecessary radioactive waste has been avoided during maintenance and surveillance activities?
5G-42 What coordination is required with waste management, packaging, and transportation personnel regarding the generation of radioactive waste from maintenance and surveillance activities?
5.2.2 Nuclear Safety Principles and Key Questions for Post-Operational Activities at Nuclear Facilities Where a Nuclear or Radiological Hazard of Concern Exists
5H Maintenance and surveillance activities will be performed in a formal and controlled manner on a continuing basis.
5H-43 How is the master equipment list kept up-to-date and used to ensure a comprehensive maintenance and surveillance program?
5H-44 Which process is used to determine and manage the application of Conduct of Operations requirements to post-operational maintenance and surveillance activities?
5H-45 How do facility post-operational maintenance and surveillance procedures allow for relaxation of formality when required to minimize personnel exposure to ionizing radiation?
5H-46 How are maintenance, surveillance, and repair procedures formally controlled and validated under changing post operating conditions?
5H-47 To what extent does the worker safety culture support the use of formal communications and procedures as an integral part of maintenance, surveillance, and repair activities?
5H-48 What documentation and procedures ensure a comprehensive shift turnover for ongoing maintenance and surveillance activities?
5H-49 What maintenance and surveillance data and information are being collected for permanent records?
5H-50 What conditions have been identified under which it will be possible to terminate formal and controlled maintenance and surveillances?
5H-51 What controls are used to keep contaminated and uncontaminated tools and test equipment separate?
5I The configuration and status of the physical plant will be documented and controlled on a continuing basis.
5I-52 How are activities that affect the status of plant equipment and decisions that could result in maintenance restrictions reviewed and authorized? Are appropriate maintenance managers involved?
5I-53 What system and component information is available to ensure that post-operational maintenance and surveillance activities can be performed safely?
5I-54 How does a change in the physical plant get reflected accurately and promptly in the documentation used to develop and control plant work activities?
5I-55 How is facility modification information being collected and drawings and other records controlled and updated to support maintenance and surveillance activities?
5I-56 How are maintenance and surveillance activities affecting equipment status formally controlled? How are lockout/tagout devices and labels used in post-operational maintenance and surveillance activities? What differences are there in this regard relative to the procedures used during normal operations?
5I-57 What maintenance and surveillance activity problems have occurred (or are expected) as a result of a lack of accurate plant configuration or status information?
5J Positive control of nuclear processes and their safety systems, including communications and instrumentation systems, will be maintained.
5J-58 How are nuclear process systems and safety systems kept under positive control during post-operational period maintenance and surveillance activities?
5J-59 What communication and instrumentation systems are available for controlling nuclear processes and safety systems during maintenance and surveillance activities?
5J-60 What formal calibration program is in place for safety related instrumentation?
5J-61 What routine maintenance is performed to ensure that the various areas of the facility have and will continue to have adequate lighting and ventilation during the post-operational period?
5J-62 What operating personnel are used to operate or deactivate plant process and safety equipment during maintenance and surveillance activities?
5J-63 What is the overall level of process and safety system reliability and redundancy compared to that which is needed to proceed safely with post-operational activities?
5K 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 maintenance and surveillance activities potentially impacting the safety risks addressed in the document.
5K-64 Have the post-operational equipment and system requirements and activities identified in the facility safety and hazard analysis documentation been assessed for potential impacts from maintenance and surveillance activities? What were the assessment results?
5K-65 What process ensures future maintenance and surveillance activities will be assessed for safety and that adequate protection will be available for personnel and for the environment?
5K-66 What is the worst-case radiological consequence that could result during post-operational maintenance and surveillance activities?
5K-67 What actions to reduce maintenance and surveillance related consequences have been taken or planned?
5K-68 What events have occurred due to maintenance and surveillance activities that indicate inadequacies in the facility safety and hazard assessments?
5L 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.
5L-69 What maintenance and surveillance activity controls are in place or planned that will contribute to defense-in-depth for postulated accidents?
5L-70 Which systems and backup systems are in place to prevent, detect, measure, and warn personnel of an uncontrolled release of radioactive contamination during maintenance and surveillance activities?
5L-71 Are there maintenance and surveillance accident scenarios that do not have adequate levels of prevention and defense-in-depth? What are they?
5L-72 Which maintenance and surveillance activities require independent verifications?
5L-73 Which maintenance and surveillance program changes are in place or planned to ensure the continued effectiveness of passive and active elements of the facility containment barriers?
5M 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.
5M-74 Which technical safety requirements could be impacted by maintenance and surveillance activities?
5M-75 Which technical safety requirement surveillance activities are in place and scheduled for performance during the post-operational period?
5M-76 How does the surveillance program verify the operability of all of the required safety related equipment?
5M-77 Which safety related components are controlled under a formal and periodically updated preventive maintenance program?
5M-78 Which chemistry and lay-up requirements have been identified and implemented for the preservation of plant safety related equipment, including spare parts in storage?
5M-79 What procedures or controls are in place to formally take safety related equipment out of service on a permanent basis?
5M-80 What safety related equipment has been taken out of service permanently?
5N A program to identify and address unreviewed safety questions will be maintained on a continuing basis.
5N-81 What process is in place to look for and address emergent unreviewed safety questions that might be uncovered during maintenance and surveillance activities?
5N-82 How are unreviewed safety questions identified that could impact plant post-operational maintenance and surveillance activities?
5N-83 How would a worker be able to recognize an emergent unreviewed safety question in the course of maintenance and surveillance activities?
5O Personnel training and qualifications will be maintained on a continuing basis.
5O-84 What is the process for identifying maintenance and surveillance training requirements and conducting the associated training on a continuing basis during the post-operational period?
5O-85 What are the current and planned maintenance and surveillance worker training and qualification requirements?
5O-86 What are the maintenance and surveillance training and qualification requirements for the post-operational period?
5O-87 What new training and qualification requirements have been identified and implemented for facility and other contractor personnel?
5O-88 What is the current training and qualification status for plant personnel working in the maintenance and surveillance area?
5O-89 What required-reading and lessons-learned program is in effect for personnel participating in post-operational maintenance and surveillance activities?
5O-90 What formal program ensures the continued qualification of maintenance and surveillance workers and support technicians?
P 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.
5P-91 What controls and instrumentation for continued monitoring and maintenance of containment integrity are included in the maintenance and surveillance program?
5P-92 What specific worker responsibilities are identified and implemented regarding ensuring the continued integrity of containment boundaries?
5P-93 How is the day-to-day status of containment barriers and the impacts of maintenance and surveillance activities on the barriers documented?
5P-94 What maintenance and surveillance program improvements have been or will be implemented to increase containment barrier effectiveness?
5Q Emergency response capabilities commensurate with the potential accidents that could reasonably occur at the facility will be available on a continuing basis.
5Q-95 What special equipment is in place or needed to support early response to potential emergencies?
5Q-96 What emergency response equipment is covered by the maintenance and surveillance program?
5.3 Surveillance Activities
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 97, an additional question should be entered under the applicable principle, and the number 97 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.
5.3.1 Maintenance and Surveillance -Related Document Review
5.3.1.1 Safety Analysis Reports
Questions: 1 2 3 6 9 10 13 15 21 22 23 25 26 28 30 32 33 34 36 37 39 40 42 43 44 45 46 48 49 50 51 53 54 56 58 59 60 61 63 64 65 66 67 69 70 71 72 73 74 75 76 77 78 79 81 84 86 89 90 91 94 95 96
5.3.1.2 Maintenance and Surveillance Procedures and Plans
Questions: 1 2 3 4 5 6 7 10 11 12 13 15 17 19 20 21 22 25 27 29 30 32 33 34 35 36 37 38 39 40 42 43 44 45 46 48 49 50 51 52 53 54 55 56 58 59 60 61 62 63 64 65 67 69 70 72 73 74 75 76 77 78 79 80 81 84 86 87 89 90 91 92 93 94
5.3.1.3 Maintenance and Surveillance Records
Questions: 1 3 4 6 7 8 11 13 15 16 19 20 22 24 25 27 29 30 31 32 34 35 36 37 38 39 40 41 43 46 48 49 53 54 55 56 57 60 61 68 72 75 76 77 78 79 80 82 87 89 90 91 92 93 94 96
5.3.2 Maintenance-Related Interviews
5.3.2.1 Maintenance Manager/Supervisor
Questions: 1 2 4 3 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 34 35 36 37 38 39 40 41 42 43 44 45 46 47 48 49 50 51 52 53 54 55 56 57 58 59 60 61 62 63 64 65 66 67 68 69 70 71 72 73 74 75 76 77 78 79 80 81 82 83 84 85 86 87 88 89 90 91 92 93 94 95 96
5.3.2.2 Facility Manager
Questions: 1 2 4 5 6 7 8 9 10 11 12 13 15 16 17 19 20 21 22 23 24 25 26 27 28 29 32 33 34 35 36 37 40 42 43 44 45 46 47 48 50 52 53 54 55 56 58 59 62 63 64 65 66 67 68 69 70 71 73 74 76 77 78 79 80 81 82 85 87 89 91 92 93 94 95
5.3.2.3 Facility Maintenance Workers
Questions: 3 4 5 6 7 8 9 10 11 12 14 15 16 17 18 19 20 21 22 23 24 25 26 28 29 30 31 32 34 35 36 37 38 39 40 41 42 43 44 45 46 47 48 49 50 51 52 53 54 55 56 57 58 59 60 61 62 63 64 68 69 70 71 72 73 74 75 76 77 78 79 80 81 82 83 84 85 86 87 88 89 90 91 92 93 94 95 96
5.3.2.4 Facility Stakeholders
Questions: 1 70
5.3.3 Maintenance-Related Facility Inspections
5.3.3.1 Containment Barriers and Boundaries
Questions: 22 23 26 34 35 36 37 39 56 61 70 73 79 80
5.3.3.2 Alarm, Indication, and Communications Systems
Questions: 22 26 35 36 37 56 59 60 70 79 80 95
5.3.3.3 Process and Safety Systems
Questions: 35 36 56 61 79 80
5.3.4.4 Support Facilities
Questions: 10 12 34 35 36 37 38 39 43 51 53 56 60 61 70 79 95
6.0 ENGINEERING
6.1 Introduction
Post-operational nuclear facility engineering support is a significant challenge and impacts all functional areas. Besides routinely touching all of the ongoing facility programs, the engineering support organization may be involved with design, construction, and testing of major waste treatment facilities and providing technical guidance on retiring facilities being transitioned to safe shutdown conditions, decontaminated, decommissioned, and dismantled. In each case, during the time frame that the risk of a nuclear or radioactive contamination accident exists, additional effort is required to identify, evaluate, document, and resolve a range of safety and environmental issues, many of which are unique to facility end-of-life conditions and involve greater risks due to increased radiation levels and other hazards. To be successful in such a broad range of tasks, the engineering support organization may require significantly increased resources and management foresight.
The technical engineering work applicable to the post-operational period started when the initial design decisions were made prior to facility construction, in many cases 40 or 50 years ago. To the extent that this initial engineering work resulted in design features important to the post-operational period, it is important for the facility engineering design records to be reviewed and such features identified. Such records may not be available or may not have been updated over the years to reflect modifications.
Another concern in the engineering support area is that, in contrast to other functional areas, well-experienced personnel may not be available to address specific facilities or issues efficiently. For example, even if 50 year-old installation procedures and the related component handling equipment are found, none of the original design or construction staff would be available, and some of the originally installed equipment will likely have been replaced or significantly modified over the years. Without a reliable configuration management program, a significant amount of research and plant walk downs may be required to provide adequate post-operational engineering support.
The original design documents and installation procedures may also include important safety considerations. In some cases the original equipment vendors can not provide post-operational support, but such possibilities may need to be investigated. Regardless of the situation, each aspect of the post-operational engineering effort must be formally developed, documented, approved, and implemented, and the current engineering organization must assume full responsibility for the results.
During the oversight process, each applicable engineering support activity and product must be assessed relative to the nuclear safety principles. Since many of the engineering support activities are services to the other functional areas, the associated interfaces must be assessed for effectiveness. In most cases, this effectiveness is dependent on the accuracy, completeness, and timely flow of information in both directions across the interface.
6.2 Engineering-Related Nuclear Safety Principles and Questions Sets
Question sets for assessing the safety related aspects of engineering programs 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 engineering 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.
6.2.1 Nuclear Safety Principles and Key Questions for Post-Operational Engineering at All Nuclear Facilities
6A Facilities will meet applicable federal, state, and local health and safety laws and regulations, including those identified by contract or other form of agreement.
6A-1 Has a formal assessment determined which current and future safety system engineering requirements and activities at the post-operational facility are impacted by federal, state, and local requirements? What were the results of the assessment?
6A-2 Which engineering administrative procedure ensures conformance with these requirements on a continuing basis during the post-operational period?
6A-3 Have the post-operational engineering requirements been assessed for completeness and effectively integrated with each other and with project planning to eliminate conflicts and ambiguities (i.e., a systems approach)? What were the results of the assessment?
6A-4 What process ensures that general engineering requirements will be met on a continuing basis throughout the post-operational period?
6A-5 What ventilation and filtration systems are provided to control radionuclides and keep any necessary releases within limits?
6A-6 How do managers, supervisors, and workers know who is responsible for providing guidance on engineering requirements? How do they obtain that guidance in their areas of responsibility?
6B The exposure of any person to radiation will be kept as low as is reasonably achievable (ALARA) under a systematic program.
6B-7 What process is used to systematically identify post-operational activities in which engineering support for ALARA requirements is applicable?
6B-8 Describe the platforms, doors, passageways, cranes, portable hoist supports or rails, lighting, and power supplies (pneumatic and electrical) provided in potentially high dose rate areas?
6B-9 What engineering analysis has been performed to determine whether remotely controlled equipment is needed to implement ALARA during post-operational activities?
6B-10 How does each individual involved with engineering support work know the facility radiation levels and understand his or her personal role in developing design guidance and information that supports the ALARA objective?
6B-11 What examples are there that demonstrate the presence of an effective ALARA engineering support program (e.g., equipment mockups used to practice radiation area procedures).
6B-12 Does the facility and contractor safety culture place importance on identifying dose reduction opportunities and implementing them through the design process (e.g., providing shielding systems)?
6C No person will receive doses of ionizing radiation in excess of the statutory dose limits during post-operational engineering activities.
6C-13 Which engineering personnel have exceeded administrative control limits or a statutory dose limit?
6C-14 For personnel that have reached or are likely to reach administrative radiation exposure limits, what are the plans for replacing them with other qualified personnel?
6C-15 How are engineering personnel made aware of plant radiation levels and their own cumulative radiation exposure level?
6D All practical steps will be taken to prevent radiological accidents during post-operational activities.
6D-16 What radiological accidents have occurred (or could occur) as a result of inadequate engineering reviews?
6D-17 How are engineering reviews used to identify project safety vulnerabilities and to identify ways to prevent radiological accidents, particularly when changes to the facility are being made? What results have been achieved?
6D-18 If more resources were available for engineering activities, what could be done to better protect against radiological accidents?
6E Post-operational activities involving exposure or potential exposure to ionizing radiation will result in benefits commensurate with the safety risks resulting from that exposure.
6E-19 Who is the manager responsible for deciding whether the worker radiation doses expected to be received during an engineering support activity or project are worth the associated benefits?
6E-20 What are the criteria under which a determination might be made that an engineering related activity or requirement will result in unnecessary radiation exposures or significant uncertainty as to the level of those exposures?
6E-21 Please cite specific examples where a determination has been made (or would be made) that an engineering design should be modified in order to achieve benefits commensurate with the associated safety risks?
6F Post-operational activities and related systems will be adequate to compensate for safety vulnerabilities resulting from age-related degradation, including an appropriate margin to accommodate uncertainties in material status.
6F-22 What engineering upgrades are in place or planned that will reduce the material or equipment age-related uncertainties impacting personnel safety or environmental safety?
6F-23 What periodic technical engineering inspections of facility structural members, walls, floors, and roofs are performed?
6F-24 Which plant design problems require workarounds in order to ensure adequate personnel and environmental safety?
6F-25 Which facility and equipment corrosion and fire protection issues are being investigated and addressed as part of the post-operational engineering activities?
6F-26 Which cathodic protection systems and other corrosion prevention methods have been identified as part of routine post-operational engineering activities?
6G The generation of radioactive waste during post-operational activities will be minimized to the extent feasible.
6G-27 What analysis program ensures that radioactive treatment systems are capable of handling all of the decommissioning wastes?
6G-28 What segregated sumps and similar design features are provided to isolate clean liquids, mildly radioactive liquids, and highly radioactive liquids?
6G-29 How do post-operational engineering activities include consideration of technical approaches or methods for reducing the production of radioactive waste?
6G-30 Please cite specific examples where the generation of unnecessary radioactive waste has been avoided through engineering insights?
6G-31 How has engineering design been coordinated with waste management, packaging, and transportation personnel in order to reduce the generation of radioactive waste or reduce the packaging volume resulting from post-operational activities?
6.2.2 Nuclear Safety Principles and Key Questions for Post-Operational Activities at Nuclear Facilities Where a Nuclear or Radiological Hazard of Concern Exists
6H Engineering work activities will be performed in a formal and controlled manner on a continuing basis.
6H-32 Is there an up-to-date and comprehensive master equipment list available to the engineering organization staff? Is it available for review?
6H-33 In what way do engineering installation and removal procedures include provisions for relaxation of formality when required to minimize personnel exposure to ionizing radiation?
6H-34 What engineering data and information are being collected for permanent records?
6I The configuration and status of the physical plant will be documented and controlled on a continuing basis.
6I-35 How are engineering support activities that affect the status of plant equipment safety being reviewed and authorized? Are the appropriate engineering personnel involved?
6I-36 What system and component information is available to ensure that post-operational engineering activities can be performed without adversely impacting safety?
6I-37 How is facility modification information being collected and drawings and other records controlled and updated to support engineering activities?
6I-38 What engineering support problems have occurred or are expected as a result of a lack of accurate plant configuration or status information?
6J Positive control of nuclear processes and their safety systems, including communications and instrumentation systems, will be maintained.
6J-39 How was the availability of communication systems considered during engineering project development activities?
6J-40 How are new instrumentation system requirements coordinated with calibration facility capabilities for safety related instrumentation?
6J-41 How do engineering projects include provisions for ensuring that the affected areas of the facility have and will continue to have adequate lighting and ventilation?
6K 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 activities potentially impacting the safety risks addressed in the document.
6K-42 How are equipment and system requirements and activities identified in the facility safety and hazard analysis documentation assessed for changes needed during post-operational activities?
6K-43 What engineering process ensures future activities will be assessed for safety and that adequate protection will be available for personnel and for the environment?
6K-44 What are the worst-case radiological consequence that could result during post-operational activities?
6K-45 What actions have been taken to reduce safety related consequences of post-operational activities?
6K-46 Have events occurred during post-operational activities that indicate inadequacies in the facility safety and hazard assessments? Please describe them.
6L 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.
6L-47 What engineered safety systems and non-safety automatic controls have been put in place or planned that will provide for defense-in-depth for postulated accidents?
6L-48 Describe the double walled containments used or planned for pipes and tanks containing radioactive liquid?
6L-49 What systems and backup systems are in place to prevent, detect, measure, and warn personnel of an uncontrolled release of radioactive contamination during post-operational activities?
6L-50 Which accident scenarios do not have adequate levels of prevention and defense-in-depth?
6L-51 Upon loss and subsequent recovery of normal electrical power, what waste transfer equipment is inhibited from restarting without active operator action?
6L-52 Are criticality controls based on equipment designs in which dimensions of the contained fissionable material and spacing between equipment are limited through passive engineering controls? Which are not?
6L-53 Which storage facilities and structures are designed to preclude an accidental criticality in the event of natural calamities such as seismic events, fires, or floods?
6L-54 Where sprinkler systems are installed, are storage areas designed to prevent the accumulation of water? Which are not?
6L-55 Which instruments and controls important to safety are provided with backup power to ensure operability under emergency conditions?
6L-56 Which engineering design and other support activities require independent verifications?
6L-57 What engineering management changes have been put in place or planned to ensure the continued effectiveness of passive and active elements of the facility containment barriers during planned facility transitions?
6M 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.
6M-58 Which technical safety requirements could be impacted by engineering support activities?
6M-59 Which surveillance activities are in place and scheduled for performance during the post-operational period?
6M-60 Which chemistry and lay-up requirements have been identified and implemented for the preservation of plant safety related equipment, including spare parts in storage?
6M-61 Which procedures or controls are in place to formally take safety related equipment out of service on a permanent basis?
6N A program to identify and address unreviewed safety questions will be maintained on a continuing basis.
6N-62 What process is in place to look for and address emergent unreviewed safety questions that might be uncovered during engineering activities?
6N-63 What unreviewed safety questions have been identified that could impact plant post-operational activities?
6O Personnel training and qualifications will be maintained on a continuing basis.
6O-64 What is the process for identifying engineering staff training requirements and conducting the associated training on a continuing basis during the post-operational period?
6O-65 What are the current and planned engineering staff training requirements?
6O-66 What are the unique engineering technical staff requirements for the post-operational period?
6O-67 Is there a required-reading and lessons-learned program in effect for personnel participating in post-operational engineering activities? What are the contents of the program?
6O-68 Is there a systematic process for identifying technical information needed in the facility training program? Please describe it.
6P 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.
6P-69 What controls and instrumentation are provided for continued monitoring and maintenance of containment integrity?
6P-70 Is there complete and up-to-date documentation on containment barriers, and are the impacts of the planned activities on the barriers identified and addressed systematically? Are these documents available for inspection?
6P-71 What engineering improvements have been or will be implemented to increase containment barrier effectiveness?
6Q Emergency response capabilities commensurate with the potential accidents that could reasonably occur at the facility will be available on a continuing basis.
6Q-72 What special equipment is needed to support early response to potential emergencies during post-operational activities?
6.3 Surveillance Activities
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 73, an additional question should be entered under the applicable principle, and the number 73 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.
6.3.1 Engineering -Related Document Review
6.3.1.1 Safety Analysis Reports
Questions: 1 5 7 12 16 17 22 23 24 26 27 28 29 32 34 36 40 41 42 44 47 48 50 51 52 53 54 55 56 58 59 60 61 62 64 66 67 69 70 71 72
6.3.1.2 Engineering Procedures and Plans
Questions: 2 3 4 5 6 7 10 11 12 14 16 17 18 19 20 22 23 24 25 26 27 28 29 31 32 33 34 35 36 37 39 40 41 42 43 44 45 47 48 51 53 54 55 56 57 58 59 60 61 62 64 65 67 68 70 71 72
6.3.1.3 Engineering Records
Questions: 5 10 11 13 16 17 20 21 22 23 24 30 32 34 35 36 37 38 40 46 53 59 60 61 63 64 67 68 70
6.3.2 Engineering-Related Interviews
6.3.2.1 Engineering Manager
Questions: 1 2 4 3 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 34 35 36 37 38 39 40 41 42 43 44 45 46 47 48 49 50 51 52 53 54 55 56 57 58 59 60 61 62 63 64 65 66 67 68 69 70 71 72
6.3.2.2 Facility Manager
Questions: 3 5 6 7 10 11 12 16 17 18 22 23 24 25 28 30 31 32 36 37 38 39 41 42 44 45 46 47 48 50 51 52 53 54 55 57 58 59 60 61 63 65 66 67 68 69 70 71 72
6.3.2.3 Engineering Staff
Questions: 1 3 5 6 7 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 34 35 36 37 38 39 40 41 42 43 44 45 46 47 48 49 50 51 52 53 54 55 56 57 58 60 61 62 63 64 65 66 67 68 69 70 71 72
6.3.2.4 Facility Stakeholders
Questions: 149
6.3.3 Engineering-Related Facility Inspections
6.3.3.1 Containment Barriers and Boundaries
Questions: 5 22 23 24 25 28 41 42 47 48 49 61 69 70 71
6.3.3.2 Alarm, Indication, and Communications Systems
Questions: 24 25 39 40 41 42 47 48 49 55 61 69 71
6.3.3.3 Process and Safety Systems
Questions: 5 12 22 24 25 28 42 48 49 51 52 54 55 60 61
6.3.4.4 Support Facilities
Questions: 5 23 24 28 31 32 37 40 41 48 49 51 53 54 55 60 72
7.0 TRAINING
7.1 Introduction
Although major training program responsibilities are eliminated at the time a nuclear facility is shut down for the last time, they are often replaced by new ones. Also, it is likely that the training program will require significant changes and upgrades long before plant shutdown, depending upon how much preparation is required to be ready for post-operational activities. Training program preparations can be inhibited by a lack of technical information, the emergent nature of many of the post-operational activities, and the short amount of time available for training program planning.
Post-operational nuclear facility training is a significant challenge and impacts all functional areas. Besides routinely touching all of the ongoing facility programs, the training organization will need to anticipate training requirements for design, construction, and testing of major waste treatment facilities while continuing training on the post-operational facilities. In each case, during the time frame that the risk of a nuclear or radioactive contamination accident exists, additional effort is required to identify, evaluate, document, and resolve a range training requirements, many of which are unique to facility end-of-life conditions. To be successful in such a broad range of tasks, the training organization may require significantly increased resources and management coordination among the various organizations.
During the oversight process, each applicable training activity and product must be assessed relative to the nuclear safety principles. Since many of the training activities are services to the other functional areas, the associated interfaces must be assessed for effectiveness. In most cases, this effectiveness is dependent on the accuracy, completeness, and timely flow of information across the interface.
7.2 Operations-Related Nuclear Safety Principles and Questions Sets
Question sets for assessing training program effectiveness 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 training program 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.
7.2.1 Nuclear Safety Principles and Key Questions for Post-Operational Activity Control at All Nuclear Facilities
7A Facilities will meet applicable federal, state, and local health and safety laws and regulations related to operations, including those identified by contract or other form of agreement.
7A-1 Has a formal assessment determined which current and future safety system, process operations, and other activities at the post-operational facility are impacted by federal, state, and local requirements? What were the results of the assessment?
7A-2 How does the facility training program systematically incorporate these requirements in appropriate lesson plans for initial training and retraining programs?
7A-3 Does the training program include all of the subcontractors involved with post-operational activities? Which are not included?
7A-4 What process ensures technical qualification requirements conform with state and local laws as well as applicable federal agency requirements?
7A-5 What changes in lesson plans have occurred as a result of newly identified safety requirements?
7B The exposure of any person to radiation will be kept as low as is reasonably achievable (ALARA) under a systematic program.
7B-6 How are published ALARA-related policies and procedures used in training plant personnel on minimizing radiation exposures?
7B-7 Does the facility worker's (operators, maintenance & surveillance personnel) training program support a safety culture that places importance on identifying dose reduction opportunities and implementing them?
7B-8 Does training include facility-specific examples that demonstrate the actual application of the ALARA policy? Where can remote operated equipment be used to minimize exposures in the performance of necessary training?
7B-9 How does training include the use of mockups and models to practice complex activities before attempting them in radiation areas?
7C No person will receive doses of ionizing radiation in excess of the statutory dose limits during post-operational activities.
7C-10 What training is given on administrative control limits and on statutory dose limits, including individual responsibility for staying below these limits?
7C-11 How does training address actions to be taken if it is likely that someone will reach administrative radiation exposure limits, including replacing them with other qualified personnel?
7C-12 To what extent does the training program include guidance on determining plant radiation levels and the individual workers cumulative radiation exposure level?
7D All practical steps will be taken to prevent radiological accidents during post-operational activities.
7D-13 How does the training program cover the radiological accidents that have occurred (or that could occur) due to post-operational activities?
7D-14 How does the training program address the specific steps to be taken during post-operational activities to look for and prevent radiological accidents?
7E Post-operational activities involving exposure or potential exposure to ionizing radiation will result in benefits commensurate with the safety risks resulting from that exposure.
7E-15 Are there specific examples used in the training program where a determination has been made (or would be made) that an activity should be modified in order to achieve benefits commensurate with the associated safety risks? Please discuss those examples.
7F Post-operational radiological protection activities and related systems will be adequate to compensate for safety vulnerabilities resulting from age-related degradation, including an appropriate margin to accommodate uncertainties in material status.
7F-16 What portion of the training program covers the types of material or equipment age-related uncertainties that could impact personnel safety or environmental safety included in the training program?
7F-17 What portion of the training program covers the compensations that have been applied to post-operational activities to address material degradation and uncertainties regarding material degradation?
7F-18 What portion of the training program covers plant degradations that require workarounds in order to ensure adequate personnel and environmental safety and, also, how to cope with such degradations?
7G The generation of radioactive waste will be minimized to the extent feasible.
7G-19 What portion of the training program covers required actions to minimize the production of radioactive waste?
7.2.2 Nuclear Safety Principles and Key Questions for Post-Operational Activities at Nuclear Facilities Where a Nuclear or Radiological Hazard of Concern Exists
7H Operations will be performed in a formal and controlled manner on a continuing basis.
7H-20 Are personnel formally trained on conduct of operations requirements as they relate to post-operational activities?
7H-21 Are special training and examinations/demonstrations completed prior to assigning personnel to tasks which require special knowledge and skills?
7H-22 Does the training program include a process for incorporating lessons learned from in-house and industry operating experience?
7H-23 Are personnel familiarized with administrative controls such as those for modifications to operating procedures under changing post operating conditions?
7H-24 Does the safety culture reflected by instructors fully support the use of formal communications and procedures?
7H-25 Are personnel trained on the changes to communications and plant status information displays that have occurred since the facility was shutdown?
7H-26 Are personnel trained on the plant status documents and procedures that are used to ensure a complete watchstander turnover and comprehensive shift turnover?
7H-27 Are records of each individual's training participation and performance maintained in an auditable form?
7I The configuration and status of the physical plant will be documented and controlled on a continuing basis.
7I-28 What portion of the training program covers the proper way to control activities that affect the status or configuration of plant equipment?
7I-29 What portion of the training program covers the process that ensures a change in the physical plant is reflected in the documentation used to develop and control continuing activities?
7I-30 What portion of the training program covers the data and information being collected for permanent records?
7I-31 What portion of the training program covers on the lockout/tagout procedures, devices, and labels?
7I-32 What problems have occurred or are problems expected as a result of a lack of adequate training on control and use of plant configuration and status information?
7J Positive control of nuclear processes and their safety systems, including communications and instrumentation systems, will be maintained.
7J-33 What portion of the training program covers the nuclear processes expected to be active in the facility during the post-operational period?
7J-34 What portion of the training program covers the safety system requirements associated with each of those processes?
7J-35 What portion of the training program covers the communications and instrumentation systems used for controlling the nuclear processes and safety systems?
7J-36 How does the training program ensure the continued availability of qualified personnel to operate, maintain, and deactivate plant process and safety equipment in a reliable and controlled manner?
7K 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.
7K-37 Does the training program cover all of the post-operational plant activities addressed in the facility safety and hazard analysis documentation? Which are omitted?
7K-38 What portion of the training program covers the level of adequacy of the facility safety and hazard assessments?
7L 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.
7L-39 What portion of the training program covers the operational controls that provide or contribute to defense-in-depth for postulated accidents?
7L-40 What portion of the training program covers the post-operational activities that require independent verifications?
7L-41 What portion of the training program covers the nuclear accident scenarios that may not have adequate levels of prevention and defense-in-depth?
7L-42 What portion of the training program covers the operator routines in place or planned to ensure continued effectiveness of the passive and active elements of the facility containment barriers?
7L-43 What portion of the training program covers the safety systems that are no longer needed to provide defense-in-depth?
7M 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.
7M-44 What portion of the training program covers the technical safety requirements that apply to the facility during the post-operational period?
7M-45 What portion of the training program covers surveillance activities that support meeting each of the technical safety requirements?
7M-46 What portion of the training program covers the chemistry and lay-up requirements for the preservation of plant equipment?
7M-47 What portion of the training program covers the procedures or controls in place to formally take safety related equipment out of service on a permanent basis?
7M-48 What portion of the training program covers the safety impacts of safety related equipment already taken out of service?
7N A program to identify and address unreviewed safety questions will be maintained on a continuing basis.
7N-49 What portion of the training program covers the concept of unreviewed safety questions and what their related responsibilities are during the post-operational period?
7N-50 What portion of the training program covers the unreviewed safety questions that have already been identified?
7O Personnel training and qualifications will be maintained on a continuing basis.
7O-51 How have current and future training and qualification requirements been identified and implemented for all of the facility personnel involved with post-operational activities?
7O-52 What are the training and qualification requirements that are unique to the post-operational period?
7O-53 How are new training and qualification requirements for facility and other contractor personnel identified and implemented in a timely manner?
7O-54 Is there a required-reading or lessons-learned program in effect for personnel participating in post-operational activities? How is it administered?
7P 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.
7P-55 What portion of the training program covers the control and instrumentation systems that are in place for continued monitoring and maintenance of containment integrity?
7P-56 What portion of the training program covers workers' responsibilities regarding ensuring the integrity of containment boundaries?
7Q Emergency response capabilities commensurate with the potential accidents that could reasonably occur at the facility will be available on a continuing basis.
7Q-57 What portion of the training program covers the upgrades in plant and local community emergency response programs that have been planned or implemented?
7Q-58 Is emergency response training provided to all personnel involved with post-operational activities? What personnel are excused from attending training?
7Q-59 What portion of the training program covers the special equipment used to support early response to potential emergencies?
7Q-60 What portion of the training program covers evacuation and personnel accounting procedures?
7.3 Surveillance Activities
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 61, an additional question should be entered under the applicable principle, and the number 61 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.
7.3.1 Training-Related Document Review
7.3.1.1 Safety Analysis Reports
Questions: 1 4 6 10 12 13 16 17 18 25 28 33 34 37 39 40 41 42 43 44 45 46 47 48 49 50 52 53 55 57 59
7.3.1.2 Training Procedures and Plans
Questions: 2 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 25 27 28 29 30 31 33 34 35 36 37 38 39 40 41 42 43 44 45 46 47 48 49 51 53 54 55 56 57 58 59 60
7.3.1.3 Training Records
Questions: 3 4 5 8 10 21 22 27 32 51 53 54
7.3.2 Training-Related Interviews
7.3.2.1 Training Manager/Supervisor
Questions: 1 2 4 3 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 34 35 36 37 38 39 40 41 42 43 44 45 46 47 48 49 50 51 52 53 54 55 56 57 58 59 60
7.3.2.2 Facility Manager
Questions: 1 3 4 5 7 8 12 13 15 16 17 18 19 20 21 22 23 24 25 26 28 29 30 31 32 33 35 36 37 39 40 41 42 43 44 46 47 49 50 51 52 53 54 56 57 58 59 60
7.3.2.3 Training Staff
Questions: 1 3 4 5 6 7 8 9 10 11 12 14 15 18 19 20 24 27 34 35 38 40 42 43 44 45 47 48 49 50 54 55 56 60
7.3.2.4 Facility Stakeholders
Questions: 1 4 57
7.3.3 Operations-Related Facility Inspections
7.3.3.1 Support Facilities
Questions: 9
8.0 CONFIGURATION MANAGEMENT
8.1 Introduction
Configuration management (CM) is applicable to many post-operational activities. The basic function of CM is to maintain accurate information describing the facility, its systems, and functions, in a form that is current and available for use. CM information is used by other functional areas for planning and performing plant operations, repairs, and modifications and for determining what physical plant changes have occurred in the past. Ideally, the CM information would be traceable to the original design intent of each item, which would indicate that the physical plant still provides safety and environmental protection at a level (and with margins for uncertainties) consistent with approved design safety calculations.
The basic CM functions that applied during normal operations remain applicable for post-operational activities, although its application within the facility will be dependent on the number and types of activities (old and new) in which CM provides continued assurance of safety and environmental protection. Additionally, information concerning facility conditions resulting from operations that involved or were likely to involve unintentional release of radioactive or other hazardous material takes on increased importance in the post-operational phase. With the knowledge of where past operations have or are likely to have resulted in uncontrolled release of radioactive or hazardous material, managers can best develop proper plans for mission transition, decontamination, decommissioning, and environmental restoration of the facility.
Many of the nuclear and environmental safety goals and the related CM questions apply during any part of a facilitys life cycle, at least up to the point that the original design intent of an item is formally verified to be no longer applicable. The CM assessor should be familiar with formal document control procedures, the facility safety analyses, the facility systems and operating modes, and planned modifications, including the CM-related aspects of the post-operational maintenance program.
CM program evaluations should be performed on a continuing basis, but particularly just prior to key changes in facility status. They should be performed frequently during the operational phase of the facility and upon shutdown and transition to post-operational activities. In most cases, it is not cost effective to reestablish a comprehensive backward-looking CM program if one does not already exist at the start of the post-operational period, especially for systems being taken out of service. Nevertheless, new systems and processes required during the post-operational period should be incorporated into the CM program as provided for in the related safety analyses.
CM during the post-operational period may require as much or more day-to-day attention as it did during normal plant operations. CM is needed to ensure facility design information is accurately captured in the facility documentation (e.g., system descriptions and drawings) for use in the continued deliberate control of the facility, including changes that may result in reductions in the hazard associated with the facility. A periodic review of the appropriateness of the CM programs requirements and level of effort will be needed during the post-operational period, as the facility complexity changes and as the hazards associated with the facility are addressed and eliminated.
8.2 Configuration Management Question Sets Related to Nuclear Safety Principles
The CM questions which follow are listed under their corresponding safety principle. Given the nature of CM as an element of a safety program, the CM related questions are not widely dispersed among the safety principles. Instead they are concentrated primarily under the safety principles related to requirements, configuration of the physical plant, and control of the facility (principles 8A, 8.I, and 8.J). CM basically provides support for maintaining control of the facilitys safety basis. The three broad categories of CM questions deal with the facilitys safety design basis, document change control program, and material history.
8.2.1 Nuclear Safety Principles and Key Questions for Post-Operational Control at All Nuclear Facilities
8A Facilities will meet applicable federal, state, and local health and safety laws and regulations, including those identified by contract or other form of agreement.
8A-1 Have applicable federal, state, local laws and regulations, and other standards been reviewed to determine specific CM requirements that should be changed or that should be met by the facility during the post-operational period? What changes in the CM program have occurred since the operating period?
8A-2 If the CM program in use during the operational period was not in compliance with the applicable federal, state, local laws and regulations, and other standards (or was otherwise unsatisfactory), what problems are expected and how is the actual physical plant condition determined in post-operational activity planning?
8A-3 Please identify the set of CM requirements that has been documented and promulgated specifically for use in post-operational planning and management? Which of these requirements are not yet being met?
8A-4 Have the post-operational CM requirements been assessed for completeness and effectively integrated with each other and with project planning to eliminate conflicts and ambiguities? What was the result of that assessment?
8A-5 How do managers, supervisors, and workers know who is responsible for providing guidance on understanding and applying CM requirements and how to obtain that guidance in their areas of responsibility? Have the individuals who are responsible for implementing the CM program recognized and accepted that responsibility? Who are they?
8A-6 What are the organizational assignments of responsibility for generation, retention, and maintenance of CM documentation?
8A-7 Is there agreement among the plant or facility stakeholders that the post-operational CM program is (or will be) effective? How was this determined?
8A-8 What process ensures that CM requirements will be met on a continuing basis throughout the post-operational period?
8A-9 What criteria will be used to implement reductions in the CM programs requirements as the facility approaches the end of decommissioning?
8B The exposure of any person to radiation will be kept as low as is reasonably achievable (ALARA), managed and controlled under a systematic program.
8B-10 What requirements are in place and what procedures are used to verify that structural, system, and component configurations are as described in facility documents prior to initiating work?
8B-11 If the exposure reporting program relies on the CM program for disseminating personnel exposure information, what evidence is there that shows that the CM program is adequately supporting this function?
8B-12 Do long-term archived records contain adequate documentation of the prior use and mission of the facility, the radiological hazards once present in the facility, post decontamination survey records, and the restrictions on use of the decommissioned portions of the site? Are these records available for review?
8C No person will receive doses of ionizing radiation in excess of the statutory dose limits during post-operational activities.
See questions 8B-10 and 11.
8D All practical steps will be taken to prevent accidents during post-operational activities.
8D-13 Do the drawings, procedures, and the Safety Analysis Report in place at the facility accurately describe the present configuration of the structures, systems, and components important to safety and the prevention of accidents? What structures, systems or components are not adequately described?
8E Post-operational activities will each result in benefits commensurate with the safety risks resulting from those activities.
8E-14 How have configuration management program controls or validation procedures been modified to limit the possibility of personnel receiving unnecessary exposure to radiation and to other hazards? What process removes retired equipment from the CM program?
8F 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
This principle is not impacted by CM.
8G The generation of radioactive waste will be minimized to the extent feasible.
This principle is not impacted by CM.
8.2.2 Nuclear Safety Principles and Key Questions for Post-Operational Activities at Nuclear Facilities Where a Nuclear or Radiological Hazard of Concern Exists
8H Operations will be performed in a formal and controlled manner on a continuing basis.
8H-15 Does the CM program include adequate provisions for configuration control of operational procedures? What are those provisions?
8H-16 Under what process are changes in structures, systems, and components reflected in related operating procedures? How is an inconsistency between a procedure and the physical plant resolved?
8I The configuration and status of the physical plant will be documented and controlled on a continuing basis.
8I-17 How does the CM program identify what information must be included in the program (such as design requirements, the initial design and all subsequent modifications; change controls to ensure that facility changes are properly identified, screened, designed, evaluated, implemented, and documented; and document controls to identify, store, update, and retrieve important documents throughout the life of a facility)?
8I-18 Did the operators of the facility keep good records of information generation during the design, construction, and operation of the facility which would be important to decommissioning? Examples of this information includes locations of radioactive material work, processing, or storage areas and events involving uncontrolled spread of contamination. Please provide samples of the records.
8I-19 What uncertainties in the past design basis, document change control process or facility material history have been identified to management so that compensatory measures can be prescribed when planning work?
8I-20 Is the present facility configuration accurately described by the current versions of the controlled drawings and the Safety Analysis Report? Do the current versions of the facility procedures accurately reflect the present facility configuration? If not, when will the present facility configuration be accurately reflected, and what hazards are added by the documents not being accurate?
8I-21 Does the CM program publish a listing of the current versions of controlled documents and is this list used by personnel when using controlled documents? Please provide sample listings.
8I-22 Describe how discrepancies are resolved between as-built configurations and the description in approved design documents, in the Safety Analysis Report, or as assumed in procedures?
8I-23 For facilities that have been decommissioned, has the following documentation been collected and archived to provide a detailed record?
A. Drawings showing "as left" structures, systems, and components.
B. Environmental Assessment
C. Environmental Impact Statement (if needed)
D. Decommissioning Plan
E. Activity Specifications
F. Project Management Plan
G. Funding Plan
H. Cost and Schedule Estimates
I. Detailed Work Procedures
J. Safety Analysis Report(s)
K. Periodic Status Reports
L. Final Site Radiation Survey Report
M. Final Program Report
Where can the above information be found?
8I-24 How often does the responsible DOE field office periodically review the adequacy of the CM program? What were the results of the most recent review? Were identified problems and weaknesses corrected?
8J Positive control of nuclear facilities and their safety systems, including communications and instrumentation systems, will be maintained.
8I-25 How do supervisors and management use the equipment status control program to ensure compliance with Technical Safety Requirements?
8I-26 Does the maintenance program require a record of work performed, collection of associated data, a description of the as-found condition, and the results of testing for the post maintenance operability of the equipment? Are samples of these records available for review?
8I-27 Are maintenance records for lifting and handling equipment maintained (e.g., load testing records for cranes)? Are samples of these records available for review?
8I-28 Are calibration records for systems and equipment that are relied on in the approved safety or hazard analysis incorporated into the CM program? Are samples of these records available for review?
8I-29 How will long term archive records be maintained for facilities which have been, or are being, decommissioned?
8I-30 How long will archived records be required to be preserved? Where will they be kept?
8I-31 How will archived material be identified for ease of retrieval and how will identified material actually be retrieved?
8I-32 What arrangements been made to ensure that DOE will maintain control of relevant working and archived records (e.g., after M &O Contractor changes or turnover)?
8K 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.
8K-33 How is the approved safety analysis or hazards analysis document supported (controlled) by the CM program? Are these documents being changed as D&D progresses?
8K-34 Is the supporting information used as the underlying basis for the analyses in the approved safety analysis or hazards analysis document controlled by the CM program such that changes in these documents are reviewed for impact to the analyses? Are these reviews available for inspection?
8K-35 Does the approved safety analysis or hazards analysis document specify the elements of the CM program which must be implemented during the D&D of the facility? What are they? (Also see question 20)
8L 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.
This principle is not applicable to CM.
8M 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.
8M-36 How is the safety classification of structures, systems, and components controlled over the facility life cycle? Specifically, what criteria are used to change a classification to non-safety related during the post-operational period when it was safety related during the operational phase of the facility? Is this process controlled by the CM program?
8N A program to identify and address unreviewed safety questions will be maintained on a continuing basis.
8N-37 What process coordinates or involves the CM program in the identification, review, and processing of unreviewed safety questions and follow-up activities during the facility post-operational period?
8O Personnel training and qualifications will be maintained on a continuing basis.
8O-38 How frequent are the personnel who are responsible for implementing and using the CM program trained and given periodic refresher training incorporating lessons learned?
8P 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.
This principle does not apply to CM.
8Q Emergency response capabilities commensurate with the potential accidents that could reasonably occur at the facility will be available on a continuing basis.
8Q-39 Are emergency response facilities accurately described in the drawings and in procedures? Are appropriate changes made as D&D progresses? Please provide examples of changes made to date.
8.3 Surveillance Activities
DOE post operational nuclear facility assessments will normally include three complementary components: document reviews, physical plant inspections, and personnel interviews. Each of the fire protection 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 51, an additional question should be entered under the applicable principle, and the number 51 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.
8.3.1 Configuration Management - Related Document Review
8.3.1.1 Safety Analysis Reports
Questions: 1 3 8 9 12 13 14 16 18 19 20 21 22 23 29 30 31 32 33 34 35 37 39
8.3.1.2 Plans and Procedures
Questions: 1 2 3 4 5 6 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 26 27 28 29 30 31 32 33 34 37 39
8.3.1.4 Drawings and Other CM Records
Questions: 12 13 18 19 20 21 22 23 24 27 28 29 30 31 32 36 39
8.3.2 Configuration Management-Related Interviews
8.3.2.1 Configuration Management Personnel
Questions: 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 34 35 36 37 38 39
8.3.2.2 Facility Managers
Questions: 1 2 3 4 5 6 7 8 10 12 13 14 15 17 18 19 20 21 23 24 25 29 30 31 32 33 34 35 36 37 39
8.3.2.3 Facility Supervisors
Questions: 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 25 26 27 28 33 34 36 37 38 39
8.3.2.4 Facility Workers
Questions: 5 6 7 10 11 12 13 14 15 16 18 19 20 21 22 26 27 28 36 37 38 39
8.3.2.5 Facility Stakeholders
Questions: 1 2 7
8.3.3 Configuration Management-Related Facility Inspections
8.3.3.1 Radiation Containment Barriers and Boundaries
Questions: 10 22
8.3.3.2 Alarm, Indication, and Communications Systems
Questions: 10 22
8.3.3.3 Process and Safety Systems
Questions: 10 22
8.3.4.4 Support Facilities
Questions: 22 39
9.0 QUALITY ASSURANCE
9.1 Introduction
The post-operational period presents several quality assurance program (QAP) challenges. The control and assurance of quality work and results for a facility that is no longer needed may become trivial, or they can become major problems. For most DOE facilities, the QAP will continue to require significant attention until the various functional requirements and closure activities are completed formally. QAP activities should continue and should be directed toward independent validation of line management decisions and post-operational activities in general.
As for most DOE Orders, DOE 5700.6C, Quality Assurance, is not tailored to meet the potentially rapidly changing needs of post-operational facilities. Also, there may be additional QAP functions that derive from EPA and NRC requirements, activities that may be totally new to the facility. Nevertheless, the primary QAP issues or problems in the post-operational period are expected to result from the transitional nature and one-time job environment that can easily cause managers and technicians to compromise on facility safety and control. EH oversight of QAP activities is likewise made more difficult during the transition. In many cases, this oversight will be limited to verifying that the site or facility QAP is continuing to assess the safety and environmental implications of the various line organization activities.
It can be anticipated that the effectiveness of quality assurance-related activities in the post-operational period will be particularly dependent on managements understanding of the continuing need to maintain formal control of the facility and its administration, even while dismantling the physical plant and reducing staff. It is particularly important to develop and maintain detailed, accurate disposition records and reports so that any issues that emerge later can be addressed. Some records and reports may continue to be useful for centuries after the site has been restored. The site QAP should be verifying the adequacy of such site-closure objectives.
Post-operational nuclear facility quality assurance may impact all functional areas, requiring line managers to be sensitive to identifying the need for new QAP activities and the possibility of modifying or closing out other QAP activities. Besides routinely touching all of the ongoing facility programs, the quality assurance organization may be involved with design, construction, and testing of new facilities and processes, while concurrently controlling those retiring facilities being transitioned to safe shutdown conditions, decontaminated, decommissioned, and dismantled. In each case, during the time frame that the risk of a nuclear or radioactive contamination accident exists, additional effort is expected to be required to identify, evaluate, document, and resolve a range of safety and environmental issues, many of which are unique to facility end-of-life conditions and involve greater risks due to increased radiation levels and other hazards. To be successful in such a broad range of tasks, the quality assurance organization may require significantly increased resources and management foresight, rather than less. Also, the level of cooperation between the line organization and the QAP processes during the post-operational period must be high, regardless of the oversight nature of QAP.
It should be emphasized that many of the QAP oversight perspectives reflected in this chapter will initially appear to overlap those found in some of the other chapters, especially the management chapter. The difference in this chapter is that a much more technical and risk-based approach is being undertaken, but here we are also primarily focused on the effectiveness of the site QAP in providing independent oversight of key activities. In the other chapters the intent is to generally determine whether the post-operational activity is being done. In this chapter we attempt to determine whether the activities are being performed at a level sufficient to ensure that design safety criteria are being met as intended, and whether the site QAP is capable of monitoring and assessing this.
During the EH oversight process, each applicable quality assurance activity and product must be assessed relative to the nuclear safety principles. Since many quality assurance activities are services to the other functional areas, the associated interfaces must be assessed for effectiveness. In most cases, this effectiveness is dependent on the accuracy, completeness, and timely flow of information in both directions across the interface.
9.2 Quality Assurance-Related Nuclear Safety Principles and Questions Sets
Question sets for assessing the safety related aspects of the QAP 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 quality awareness and control 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 without continuous oversight from outside organizations such as EH.
9.2.1 Nuclear Safety Principles and Key Questions for Post-Operational Engineering at All Nuclear Facilities
9A Facilities will meet applicable federal, state, and local health and safety laws and regulations, including those identified by contract or other form of agreement.
9A-1 Has a formal assessment determined which current and planned QAP requirements and activities at the post-operational facility are in support of or impacted by federal, state, and local requirements, especially as reflected in DOE 5700.6C for EPA? Was this reviewed under the QAP? What were the results of the assessment?
9A-2 What administrative procedure ensures conformance with these requirements on a continuing basis during the post-operational period? How is this activity monitored under the QAP?
9A-3 Have the post-operational QAP requirements been assessed for regulatory completeness and effectively integrated with each other and with project planning to eliminate conflicts and ambiguities (i.e., a systems approach)? What were the results of the assessment? Was this reviewed or monitored under the QAP?
9A-4 How do managers, supervisors, and workers know who is responsible for providing guidance on changing quality assurance requirements and how to obtain that guidance in their areas of responsibility?
9A-5 Is there a regulatory path forward to a site final condition that is acceptable to all of the stakeholders? Was this reviewed under the QAP? What were the results of the review?
9A-6 Has it been determined and documented as to which of the site stakeholders (or groups of stakeholders) has the authority and responsibility to stop work when problems occur? Was this reviewed under the QAP? What were the results of the review?
9A-7 Have remediation studies and agreements addressed non-radioactive hazardous material disposition as well as radioactive material dispositions, both for waste materials and for excess materials? Was this activity monitored under the QAP? What was found?
9A-8 What permanent records are being developed and maintained to demonstrate and record regulatory and agreement compliance? Is this activity monitored under the QAP?
9B The exposure of any person to radiation will be kept as low as is reasonably achievable (ALARA) under a systematic program.
9B-9 Is there a process to systematically identify post-operational quality assurance activities that need to be modified to be consistent with ALARA requirements? Where is this process described? Is it available for review?
9B-10 In what way does the QAP provide internal oversight of the ALARA program for contractors and subcontractors?
9B-11 How does each worker know the facility radiation levels and understand his or her personal role in supporting the ALARA objective? Is this monitored under the QAP? Does the QAP include an evaluation of the facility worker's safety culture?
9B-12 How are the potential risks of personnel and environmental exposures or contamination during post-operational activities minimized, and are these minimized risks acceptable? How is this determined and recorded? How is this activity monitored under the QAP?
9B-13 Who has the authority and responsibility to stop work when ALARA issues, questions, or problems occur?
9C No person will receive doses of ionizing radiation in excess of the statutory dose limits during post-operational engineering activities.
9C-14 Have any personnel (including site contractors and subcontractors) exceeded administrative control limits or a statutory dose limit? How is this monitored under the QAP?
9C-15 For personnel that have reached or are likely to reach administrative radiation exposure limits, what plans in place for replacing them with other qualified personnel? How is this monitored under the QAP?
9C-16 How are personnel made aware of plant radiation levels and their own cumulative radiation exposure level? Is this monitored under the QAP?
9C-17 In what ways does the QAP provide oversight of radiation monitoring programs, including calibration of monitoring instruments and dosimetry readers?
9C-18 What records and reports will provide a comprehensive and permanent description of personnel exposures received during plant normal operations and during the post-operational period? Is this monitored under the QAP?
9D All practical steps will be taken to prevent radiological accidents during post-operational activities.
9D-19 How are QAP and management-supported assessments used to identify potential radiological accidents?
9D-20 What radiological accidents have occurred (or could occur) as a result of inadequate QAP design reviews and procedural oversight or reviews? What action(s) have been or will be taken to prevent these events in the future?
9D-21 What personnel are receiving current and continuing training regarding accident prevention and response? How is this monitored under the QAP?
9D-22 What is the overall level of risk associated with post-operational activities? How is this monitored under the QAP?
9D-23 If more resources were available for QAP activities, what more could be done to protect against radiological accidents?
9E Post-operational activities involving exposure or potential exposure to ionizing radiation will result in benefits commensurate with the safety risks resulting from that exposure.
9E-24 Where are exposure risks and the associated benefits for post-operational activities described in approved safety documentation? Is this activity monitored under the QAP? What are the findings to date?
9E-25 How is oversight provided for site contractor and subcontractor exposures? How is this activity monitored under the QAP?
9E-26 Who is the manager responsible for deciding whether the worker radiation doses expected to be received during a quality assurance activity or other post-operational activity are worth the associated benefits? How is this function monitored under the QAP?
9E-27 Other than ALARA, what is the administrative limit or criterion that provides clear guidance as to what exposure levels are acceptable and expected? How is meeting this criterion monitored under the QAP?
9E-28 What inspections, inventory checks, or test procedures should be terminated? What is the process for identifying equipment that has been abandoned in place? How is this activity monitored under the QAP?
9E-29 What permanent records will indicate that individual and collective exposures received during post-operational activities are consistent with the resulting benefits or work progress? How is this monitored under the QAP?
9F Post-operational activities and related systems will be adequate to compensate for safety vulnerabilities resulting from age-related degradation, including an appropriate margin to accommodate uncertainties in material status.
9F-30 How are age-related vulnerabilities and risks addressed in approved safety documentation for the post-operational period? How is this monitored under the QAP?
9F-31 In what manner does the QAP include monitoring material or equipment age-related uncertainties impacting personnel safety or environmental safety?
9F-32 How often are quality assurance inspections of facility structural members, walls, floors, and roofs performed? What additional surveillances are appropriate? How is this monitored under the QAP?
9F-33 What are the design features that are most critical in terms of process and support systems and structures, particularly with regard to design safety margins for post-operational activities? Was this assessed independently under the QAP? What were the results of the assessment?
9G The generation of radioactive waste during post-operational activities will be minimized to the extent feasible.
9G-34 Have adequate waste-related records been properly produced, validated, and conveyed in conjunction with facility custody transfers? Was this reviewed under the QAP? What were the results of the review?
9G-35 Are there specific examples where the generation of unnecessary radioactive waste has been avoided through QAP oversight activities? What are they?
9G-36 What QAP activities are in place or could be implemented to identify opportunities to reduce the generation of radioactive waste by workers, including site contractors and subcontractors?
9G-37 How are procurement actions routinely screened for opportunities to minimize radioactive waste volume? How is this activity monitored under the QAP?
9G-38 What permanent records are being developed of the waste minimization studies and efforts undertaken during post-operational activities in this regard? How is this monitored under the QAP?
9.2.2 Nuclear Safety Principles and Key Questions for Post-Operational Activities at Nuclear Facilities Where a Nuclear or Radiological Hazard of Concern Exists
9H Post-operational facility activities will be performed in a formal and controlled manner on a continuing basis.
9H-39 In what ways are post-operational activities different in terms of formality and control relative to facility normal or production operations? How is this monitored under the QAP?
9H-40 What QAP activities monitor, record, and promote the application of appropriate levels of formality and control, including those of the site contractor and subcontractors?
9H-41 Are personnel receiving current and continuing training regarding communication and procedural formality? How is this activity monitored under the QAP?
9H-42 Does the instrument calibration program continue to provide current instrumentation calibration information to workers and operators, as modified to meet post-operational conditions and activities? How is this activity monitored under the QAP?
9H-43 Are the procurement and receipt inspection practices of site contractors and subcontractors consistent with continuing control of safety systems? How is this activity monitored under the QAP?
9H-44 What quality assurance and environmental data and information are being collected for permanent records? How is this activity monitored under the QAP?
9I The configuration and status of the physical plant will be documented and controlled on a continuing basis.
9I-45 What QAP activities support or monitor configuration control of the physical plant safety and environmental systems that are still operational?
9I-46 Is there adequate, validated system and component information available to ensure that post-operational activities can continue to be performed without adversely impacting safety? How is this monitored under the QAP?
9I-47 Is facility modification information being collected and drawings and other records controlled and updated in a timely manner to support formal control of post-operational activities, including procurement activities? How is this monitored under the QAP?
9I-48 Are environmental data updated and assimilated such that a valid final site radiological characterization will be available? How is this activity monitored under the QAP?
9I-49 Are all of the appropriate personnel trained regarding plant configuration management controls needed to ensure safety? What differences are there for training of site subcontractors in this regard? How is this process monitored under the QAP?
9I-50 What plans are in place for the gradual termination of configuration management requirements for the facility? How is this activity monitored under the QAP?
9J Positive control of nuclear processes and their safety systems, including communications and instrumentation systems, will be maintained.
9J-51 What QAP activity monitors the continued effectiveness of facility support equipment such as communications and instrumentation?
9J-52 What is the status of the instrumentation calibration program? Are instruments and gages that are still in use properly calibrated? How is this monitored under the QAP?
9J-53 What is the status of the lockout/tagout program? How is it monitored under the QAP?
9J-54 Is obsolete plant equipment being removed with safety-related tags or locks still in place? Are disconnections from other systems (e.g., electrical and steam) rendered safe in a formal manner? How are these activities monitored under the QAP?
9J-55 Are systems and components that are no longer in use or operable systematically labeled as retired, abandoned-in-place, or otherwise identified in a manner that prevents confusion? How is this activity monitored under the QAP?
9K 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 activities potentially impacting the safety risks addressed in the document.
9K-56 Have equipment and system requirements and activities identified in the facility safety and hazard analysis documentation been assessed for changes needed to ensure continued control and minimization of safety and environmental risks and the protection of the associated design safety margins during the post-operational period? What were the results of these assessments? How are these activities monitored under the QAP?
9K-57 What management control process ensures future activities will be assessed for safety and environmental concerns and that adequate management controls will be established, as needed? What differences are there for management of site subcontractors in this regard? How is this monitored under the QAP?
9K-58 What events have occurred during post-operational activities that indicate QAP inadequacies in ensuring facility safety and environmental protection?
9K-59 Has the final level of site overall risk and material condition been determined, documented, and approved? What is it? How is the process of determining this being monitored under the QAP?
9L 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.
9L-60 What are the various levels of hardware-based protection currently in place or planned, including engineered safety systems and automatic controls, that will provide adequate defense-in-depth for postulated accidents? How is this monitored under the QAP?
9L-61 Are double-walled containments used routinely for pipes and tanks containing radioactive liquid used such that leakage can be detected and remedial action taken, including for temporary systems? How has the decision making process in this regard been monitored by the QAP?
9L-62 What procedural and human monitoring controls are in place that provide additional assurance against nuclear accidents or the spread of radioactive contamination? What accident scenarios do not have adequate levels of prevention and defense-in-depth? How has this topic been assessed under the QAP?
9L-63 What QAP activities in place or planned to ensure the continued effectiveness of passive and active elements of the facility containment barriers during planned facility transitions?
9L-64 Are personnel receiving current and continuing training regarding the various supporting elements of the safety program? How is this activity monitored under the QAP?
9M 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.
9M-65 Are safety categorizations for the post-operational period included in approved safety documents? At what point do these categorizations become not-applicable in the post-operational period? How is this monitored under the QAP?
9M-66 How is it established that all of the appropriate surveillance or management oversight activities are in place and scheduled for performance during the post-operational period? Are site contractors and subcontractors assessed for safety-related management practices? How is this monitored under the QAP?
9M-67 What areas of concern regarding safety-related equipment reliability remain? What are the worst-case consequences of the failure of key components or systems? How is this monitored under the QAP?
9M-68 Are there procedures or controls in place to formally take safety related equipment out of service on a permanent basis? What design-life limits apply to safety systems still in use? How is this monitored under the QAP?
9M-69 Is the data collection or log taking being performed in the post-operational period adequate to record proper equipment performance? How is this activity monitored under the QAP?
9N A program to identify and address unreviewed safety questions will be maintained on a continuing basis.
9N-70 Is there a process in place to look for and address emergent unreviewed safety questions for each post-operational project? How is this activity monitored under the QAP?
9N-71 What unreviewed safety questions have been identified that could impact plant post-operational activities? What level of risk is associated with each? When does the concern for each terminate in the post-operational period? How is this monitored under the QAP?
9N-72 In the event that an unreviewed safety question arises, who has the authority and responsibility to identify and stop the related work or activities? How is this monitored under the QAP?
9O Personnel training and qualifications will be maintained on a continuing basis.
9O-73 Is there a process for identifying training requirements and conducting the associated training on a continuing basis during the post-operational period? How is this activity monitored under the QAP?
9O-74 Is there a required-reading and lessons-learned program in effect for personnel participating in post-operational activities? How is this monitored under the QAP?
9O-75 Is there adequate safety documentation and a systematic process for identifying safety margin and control system technical information needed in the facility training program? How is this monitored under the QAP?
9P 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.
9P-76 Are the controls and instrumentation for continued monitoring and maintenance of containment integrity adequate, including for unique conditions anticipated in the post-operational period? How is this monitored under the QAP?
9P-77 Is there complete and up-to-date documentation on containment barriers, and are the impacts of the planned activities on the barriers identified and addressed systematically through design change documentation? How is this monitored under the QAP?
9P-78 Are contractor and subcontractor personnel trained on radiological protection and the current status of barriers? How is this monitored under the QAP?
9Q Emergency response capabilities commensurate with the potential accidents that could reasonably occur at the facility will be available on a continuing basis.
9Q-79 Have potential accidents been determined and documented for the post-operational period, and have the associated emergency response capabilities been acquired and validated? How is this monitored under the QAP?
9Q-80 Are periodic inspections conducted of the special equipment needed to support early response to potential emergencies during post-operational activities? How is this activity monitored under the QAP?
9Q-81 Are emergency response capabilities being maintained and exercised in a manner that reasonably ensures that the potential risks of personnel and environmental exposures or contamination during post-operational activities are minimized? How is this activity monitored under the QAP?
9.3 Surveillance Activities
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 82, an additional question should be entered under the applicable principle, and the number 82 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.
9.3.1 Engineering -Related Document Review
9.3.1.1 Safety Analysis Reports
Questions: 1 7 12 22 24 30 33 56 59 60 61 62 65 67 75 76 77 79
9.3.1.2 Procedures and Plans
Questions: 2 3 5 6 7 8 9 10 11 13 15 17 18 19 20 21 24 25 26 27 28 29 31 32 35 36 37 39 40 41 42 43 44 45 47 48 49 50 51 52 53 54 55 56 57 61 62 63 65 66 68 69 70 71 72 73 74 75 76 77 78 80 81
9.3.1.3 Records
Questions: 8 10 12 14 18 20 21 29 34 38 43 44 46 47 48 49 54 55 58 69 74
9.3.2 Quality Assurance-Related Interviews
9.3.2.1 Quality Assurance Manager
Questions: 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 34 35 36 37 38 39 40 41 42 43 44 45 46 47 48 49 50 51 52 53 54 55 56 57 58 59 60 61 62 63 64 65 66 67 68 69 70 71 72 73 74 75 76 77 78 79 80 81
9.3.2.2 Facility Manager/Subcontractor Liaison
Questions: 3 4 6 7 10 12 13 14 15 16 18 19 20 21 22 25 27 28 29 33 34 37 39 40 41 43 46 47 49 52 53 54 55 58 59 60 61 62 64 66 67 68 69 70 71 72 73 74 75 76 77 78 79 80 81
9.3.2.3 Quality Assurance Program Staff
Questions: 2 4 6 8 9 11 12 13 14 15 16 17 18 19 20 21 22 23 25 26 27 28 29 30 32 33 35 36 37 39 40 41 42 43 44 45 46 47 49 51 52 53 54 55 58 60 61 62 64 69 70 74 75 76 79 80 81
9.3.2.4 Facility Stakeholders
Questions: 1 5 6 12 22 71
9.3.3 Quality Assurance-Related Facility Inspections
9.3.3.1 Containment Barriers and Boundaries
Questions: 12 30 32 39 54 60 61 63 68 76 77 78
9.3.3.2 Alarm, Indication, and Communications Systems
Questions: 17 32 39 42 51 52 54 55 60 76
9.3.3.3 Process and Safety Systems
Questions: 17 30 32 33 39 42 54 55 60 67 68
9.3.4.4 Support Facilities
Questions: 17 30 32 33 39 42 43 46 51 52 53 54 55 79 80 81
10.0 EMERGENCY PLANNING
10.1 Introduction
For many post-operational nuclear facilities, emergency preparedness and readiness require more planning and resources than during normal operations. This is particularly true for non-reactor facilities having accumulations of a range of poorly characterized waste materials. Post-operational activities can result in criticality accidents, explosions, fires, releases due to containment barrier degradations, and a range of industrial accidents. These vulnerabilities result largely from the transitional nature of many post-operational facilities, in which it is often difficult to anticipate emergency response needs.
In contrast to practice during normal operations, emergency preparedness activities must be incorporated as an integral part of the planning for each post-operational activity, addressing a wide range of "what-if" scenarios, often with very little time for planning, resource upgrades, and training. Although helpful, worst-case response planning will not be adequate to ensure that the onsite and national offsite emergency response resources will be applied promptly and efficiently where they are needed. By definition, when emergency response is required, something has already failed in spite of all of the measures taken to ensure industrial, nuclear, and environmental safety. Once an emergency has been declared, there is no guarantee that further planning and preparation time will be available. Thus, it is not appropriate to proceed with any post-operational activity having a questionable emergency response requirement.
DOE has an extraordinary nuclear and radiological emergency response and management capability that must continue to be available throughout the post-operational period. This is particularly important for post-operational activities where the potential exists for radiological Protective Action Guides (PAG) to be exceeded onsite or offsite. The basic functions of emergency planning are to develop emergency plans and procedures, to identify and train the necessary personnel, to acquire and maintain the necessary resources, and to maintain effective public and interagency communications, as needed to minimize the consequences to workers and the public from nuclear and radiological incidents involving DOE operations.
Questions related to individual nuclear safety principles are presented in Section 10.2. These questions are reorganized in Section 10.3 to indicate which of the basic surveillance activities document reviews, facility inspections, and personnel interviews can contribute to answering the questions and, in turn, determining whether the fundamental nuclear safety principles are being met in terms of emergency planning program effectiveness.
10.2 Emergency Planning-Related Nuclear Safety Principles and Questions Sets
The 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 those hazards do not exist, less rigorous Nuclear Safety Principles involving less costly implementation will apply. In either case, the implementation of the Nuclear Safety Principles may be graded to 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 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 condition of the facility and not the life-cycle phase that determines the applicability of the Nuclear Safety Principles. Question sets related to emergency response are presented below for each of the Nuclear Safety Principles.
10.2.1 Nuclear Safety Principles for Post-Operational Activities at All Nuclear Facilities
10A Facilities will meet applicable federal, state, and local health and safety laws and regulations, including requirements identified by contract or other form of agreement.
10A-1 Are the applicable federal, state and local requirements for emergency planning and response implemented? What exceptions are there to meeting DOE emergency planning requirements contained in DOE 5500 series Orders?
10B The exposure of any person to radiation will be kept as low as is reasonably achievable (ALARA) under a systematic program for management and control.
10B-2 What limitations do emergency plans and procedures place on access to potentially contaminated or otherwise radioactive equipment in order to maintain exposures to facility emergency workers ALARA? What security or other remotely operated equipment is available to help keep exposures down during emergency response activities?
10B-3 Given an accident or potential accident, do emergency plans and procedures provide guidance for systematically limiting worker and public radiation exposure to the lowest levels that are reasonably achievable? Does the Safety Analysis Report or Hazards Analysis Report describe how this is achieved? Is remotely operated equipment provided for this purpose?
10B-4 Do the emergency plans and procedures use the EPA PAGs as the basis for a graduated implementation of protective responses?
10B-5 Are emergency procedures and monitoring instruments available that can be used to determine the source term and projected dose for actual and potential releases and impacts onsite and offsite? Are they described in the Safety Analysis Report or Hazards Analysis Report?
10B-6 What guidance is provided to workers in emergency procedures for preventing escalation or worsening of an emergency event in progress, particularly with regard to keeping exposures as low as reasonably achievable?
10C No person will receive doses of ionizing radiation in excess of the statutory dose limits during post-operational activities.
10C-7 How do emergency procedures provide for monitoring and controlling emergency exposures?
10D All practical steps will be taken to prevent radiological accidents during post operational activities.
[This principle is not applicable to this functional area.]
10E Post operational activities will result in benefits commensurate with the safety risks resulting from those activities.
[This principle is not applicable to this functional area.]
10F Post operational activities and systems will be adequate to compensate for safety vulnerabilities resulting from age-related degradation, including an appropriate margin to accommodate uncertainties in material status.
10F-8 How do the emergency plans and procedures take into account the higher probability of structure, system, and component failure, and consequent accident propagation, as a result of age-related degradation, including impacts of unique post-operational activities that may challenge them?
10F-9 Have assessments been conducted and are personnel trained in the types of behavior and performance that can be expected of structures, systems, and components as a result of age and long term exposure to the conditions of the operational facility? For example, which roofs no longer can support the weight of emergency personnel? Are the assessments available for review?
10G The generation of radioactive waste will be minimized to the extent feasible.
10G-10 What facility and emergency response equipment design features are intended to avoid unnecessary production of waste volume in the event of an accident?
10.2.2 Nuclear Safety Principles for Post-Operational Activities at Nuclear Facilities Where a Nuclear or Radiological Hazard of Concern Exists
10H Work activities will be performed in a formal and controlled manner on a continuing basis.
10H-11 Is the responsibility for each action required by the emergency plans and procedures appropriately assigned to one or more individuals? Do those individuals acknowledge their responsibilities in this regard? Who are they?
10H-12 In what manner do the emergency plans and procedures reflect the importance of discipline and control in the implementation of emergency response?
10H-13 Does training of emergency response personnel reflect the importance of individual and organizational discipline and compliance with authorized procedures, even when organizational structure or communication cannot be maintained? How is this accomplished?
10H-14 Are procedures for public and interagency communications clearly a part of the formal emergency response structure, so that communications will be maintained even under severe emergency conditions? What is the basis for your conclusion?
10I The configuration and status of the physical plant will be documented and controlled on a continuing basis.
10I-15 Is the documented plant, system, and component configuration and status information referenced by the emergency plans and procedures correct? How recently was it updated?
10I-16 Does the training of emergency response personnel reflect the importance of plant configuration and status information in determining the nature and severity of the emergency? What is the basis for your conclusion?
10I-17 Are emergency response personnel trained to understand and use the facility configuration status and control system information available to the emergency response team? What evidence is there that the training was effective?
10J Positive control of nuclear processes and safety systems, including communications and instrumentation systems, will be maintained.
10J-18 Do the emergency plans and procedures provide direction and guidance on how facility personnel should regain control when control of facility processes fails, unanticipated events occur, and/or one or more safety systems have failed? When was the last practice drill that tested this skill? What were the results?
10J-19 Do the facility's Safety Analysis Report, Hazards Analysis Report, and emergency plans and procedures identify back-up safety systems, non-safety manual and automatic controls, instruments, and communications systems that can be used in the event of the failure of one or more safety systems? Please identify the applicable sections of these documents.
10J-20 Do the facility's Safety Analysis Report, Hazards Analysis Report, and emergency plans and procedures identify the instruments, controls, and communications devices that are qualified for a severe natural or accident environment and are powered by a reliable emergency power supply? Please identify the applicable sections of these documents.
10J-21 How are the accident-conditions qualified instruments, controls, and communications devices uniquely identified on the instrument, on drawings, and in procedures so that facility personnel can locate these controls and instruments?
10J-22 What process ensures that the minimum number of skilled individuals required at the facility are available from onsite and offsite locations in a timely manner, as needed to deal with potential emergencies?
10J-23 How does facility management plan for and maintain the required emergency response resources, such as providing sufficient numbers of trained individuals to ensure that the necessary technical skills will be available when required?
10J-24 Does the facility's Safety Analysis, Hazards Analysis, or the facility's emergency plans and procedures identify the necessary emergency response equipment? Please identify the applicable sections of these documents.
10J-25 Is sufficient emergency response equipment available on site in locations near where it may be needed? Where is a list of this equipment kept?
10J-26 How is emergency response equipment that is used for routine operations controlled in such a manner that it will be readily available for use in an emergency?
10J-27 How frequent is emergency response equipment tested to ensure that it will function as needed when required?
10J-28 How are emergency response procedures controlled and modified as emergency response requirements change in the post-operational period?
10J-29 What onsite and offsite communications systems and devices will be used during an emergency?
10J-30 How will communications be provided in the event of loss of onsite or offsite electric power or the telephone system?
10J-31 How will emergency response personnel be summoned to the site in the event of a failure of the telephone system?
10J-32 How will on site personnel communicate with offsite agencies, fire, medical, local, state and federal officials during an emergency?
10K 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.
10K-33 Does the safety analysis or hazards analysis document describe the facility's emergency planning policies, needs, and assumptions for the post-operational period? Please identify the applicable sections of each document.
10L 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.
10L-34 Does the facility's Safety Analysis Report or Hazards Analysis Report describe (e.g., technical safety requirements) and do the emergency plans and procedures include provisions for actions to be taken in the event the facility no longer meets single or common cause failure requirements, particularly as a result of post-operational activities? Please identify the applicable sections of each document.
10L-35 How are facility operations and maintenance personnel made aware of changes in facility vulnerability to single or common cause failures as a result of post-operational activities?
10M The operational reliability of structures, systems, and components integral to post operational activities should be maintained at levels consistent with the nuclear or radiological consequences of failure as defined and assessed in the applicable Safety Analysis or Hazards Analysis document.
10M-36 Is there a reliability goal for emergency response equipment? What is it?
10N A program to identify and address unreviewed safety questions will be maintained on a continuing basis.
This principle is not applicable to this functional area.
10O Personnel training and qualifications will be maintained on a continuing basis.
10O-37 Are there adequate numbers of trained personnel to implement each of the established emergency plans and procedures? What is the priority for filling each position?
10O-38 Has each person with assigned responsibilities for emergency preparedness or response received training in the implementation of those responsibilities? What evidence is there that the training was effective?
10O-39 Are emergency drills conducted periodically using realistic designbasis as well as beyonddesign-basis scenarios at unannounced and non-routine times? When were the last two drills conducted and what were the scenarios?
10O-40 Are periodic emergency drills and exercises conducted that involve offsite local, state, and federal agencies for post-operational activities? When was the last such drill or exercise and who participated?
10P 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.
10P-41 What else could be done to minimize the radiological consequences of accidents occurring as a result of post-operational activities?
10Q Emergency response capabilities commensurate with the potential accidents that could reasonably occur at the facility will be available on a continuing basis.
10B-42 Are the available onsite and offsite resources consistent with the requirements for effective implementation of emergency plans and procedures? What is the basis for your conclusion?
10B-43 Have arrangements been made, including specified points of contact, to coordinate response to emergencies with all relevant and interested federal, state, and local emergency response organizations? Where are the arrangements documented, and when were responses lasted tested? What were the results?
10B-44 Have arrangements been made for dissemination of information concerning emergencies to state and local governments and to the public? When was the last time such information was distributed? What was distributed?
10.3 Surveillance Activities
DOE post operational nuclear facility assessments will normally include three complementary components: document reviews, physical plant inspections, and personnel interviews. Each of the fire protection 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 45, an additional question should be entered under the applicable principle, and the number 45 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.
10.3.1 Emergency Planning-Related Document Review
10.3.1.1 Safety Analysis Reports and Hazards Analysis Reports
Questions: 1 3 5 8 10 19 20 24 25 27 29 30 32 33 34
10.3.1.2 Emergency Preparedness Policies, Plans, and Procedures
Questions: 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 34 36 37 38 39 40 42 43 44
10.3.2 Emergency Response-Related Interviews
10.3.2.1 Emergency Response Manager
Questions: 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 34 35 36 37 38 39 40 41 42 43 44
10.3.2.2 Operations Managers
Questions: 2 3 4 6 7 10 11 13 16 17 18 19 21 22 23 26 27 28 29 30 32 34 35 37 38 41 42
10.3.2.3 Radiological Safety Managers
Questions: 2 3 5 7 8 10 11 13 16 19 22 23 26 27 28 29 32 36 37 38 41 42
10.3.2.4 Maintenance Managers
Questions: 2 6 7 8 9 10 11 13 16 22 23 26 27 28 34 35 36 37 38 41 42
10.3.2.5 Facility Stakeholders
Questions: 1 3 5 10 14 22 31 32 40 41 42 44
10.3.3 Facility Inspection
10.3.3.1 Security Boundaries, Fire Barriers, Radiation Containment Barriers
Questions: 2 3 5 8 9 15 25 41
10.3.3.2 Alarm, Indication, and Communications Systems
Questions: 5 7 17 19 21 25 27 29 30 31 32 36 41 44
10.3.3.3 Process and Safety Systems
Questions: 2 17 18 19 21 26 35 41
10.3.4.4 Emergency Response Equipment and Support Facilities
Questions: 2 3 5 7 16 17 18 19 21 24 25 26 27 29 30 31 32 36 41 42
11.0 FIRE PROTECTION
11.1 Introduction
Post-operational nuclear facility fire hazards will generally increase, depending on the types of activities or processes required for decontamination, decommissioning, and dismantlement. While it is expected that nuclear safety will be significantly less dependent on fire protection capabilities in the post-operational environment, industrial or life-safety risks will likely increase. The increase in fire protection risk may be caused by several factors, including reductions in the number of personnel present in the facility who are able to identify potential fire hazards, fewer systematic facility inspections, the possible presence of additional hazardous materials needed for to support post-operational activities such as decontamination, and increases in high-risk activities (e.g., use of cutting torches) during the dismantlement process. Continued awareness of fire protection vulnerabilities and capabilities is needed in the post-operational environment.
In the event of a fire, one of the unique concerns at a nuclear facility even in the post-operational period is the presence of radioactive contamination. Fires can result in the breach of containment and a fire-induced spread of radioactive contamination. Thus, fire department response issues will continue as long as radioactive materials are present in the facility. Continued training on how to access radioactive contamination control areas and how to deal with contaminated personnel is needed.
Physical plant degradation and inadvertent interference with fire protection systems and access routes may also impact fire protection readiness. Resources needed to ensure the availability and operability of fire protection systems in the post-operational period may also decline, so opportunities to remove or consolidate fire protection risks should be identified early and appropriate actions taken. Post-operational activity planning should include consideration of fire protection and emergency response capabilities and the need for general and specific fire protection upgrades.
11.2 Fire protection-Related Nuclear Safety Principles and Questions Sets
Question sets for assessing the safety related aspects of fire protection programs 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 fire protection 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.
11.2.1 Nuclear Safety Principles and Key Questions for Post-Operational Fire Protection at All Nuclear Facilities
11A Facilities will meet applicable federal, state, and local health and safety laws and regulations, including those identified by contract or other form of agreement.
11A-1 Has a formal assessment determined which current and planned activities at the post-operational facility are impacted by federal, state, and local fire protection requirements, including DOE5480.7 (series) on fire protection? What were the results of the assessment?
11A-2 What administrative procedure ensures continuing reviews of conformance with fire protection requirements during the post-operational period, such as standards for portable structures (DOE/EV-0043)?
11A-3 Are the post-operational fire protection system requirements formally identified by a qualified fire protection engineer, and have the actual systems been verified to meet those requirements? Is this verification documented and available for review?
11A-4 What unique fire protection requirements are due to nuclear or radiation safety concerns?
11A-5 Which radiation protection barriers are dependent on the integrity of flammable materials such as ventilation filters? How are these barriers protected?
11A-6 How do managers, supervisors, and workers know who is responsible for providing guidance on fire protection requirements for post-operational activities and how to obtain that guidance in their areas of responsibility?
11A-7 Is there a phased plan and budget to increase or decrease fire protection capabilities as needed to meet changing requirements in post-operational environment? What are the plan's contents? What is the current and planned staffing of the fire protection organization. On what basis is it sufficient to keep up with work requirements?
11B The exposure of any person to radiation will be kept as low as is reasonably achievable (ALARA) under a systematic program.
11B-8 During fire protection emergency response activities, how will personnel exposures to potential airborne and surface contamination be minimized? What protective equipment is provided? What remotely operated equipment is available to help keep exposures down during fire fighting activities?
11B-9 How does each individual involved with fire protection response know the facility radiation levels and understand his or her personal role in minimizing exposure? What evidence supports the response?
11B-10 What routine radiation exposures are associated with inspecting and maintaining fire protection systems and equipment? How can such exposures be reduced?
11C No person will receive doses of ionizing radiation in excess of the statutory dose limits during post-operational fire protection activities.
11C-11 Have fire protection personnel exceeded administrative control limits or a statutory dose limit? Under what conditions did this occur?
11C-12 How are fire protection personnel made aware of plant radiation levels and their own cumulative radiation exposure level?
11D All practical steps will be taken to prevent radiological accidents during post-operational activities.
11D-13 What has been done to assess the potential impacts of fire protection activities and emergency response actions in terms of planned post-operational activities involving radioactive materials?
11D-14 Are fire protection response plans and training assessed in terms of the possibility that they may contribute to increases in the severity of accidents, such as through the unnecessary spread of contamination by fire fighting water? What were the results of these assessments?
11D-15 What radiological accidents have occurred (or could occur) at this or similar facilities as a result of inadequate fire protection procedures? What action(s) have or will be taken to prevent these event(s) at this facility?
11D-16 If more resources were available for fire protection programs, what could be done to protect against radiological accidents resulting from fire protection activities?
11E Post-operational activities involving exposure or potential exposure to ionizing radiation will result in benefits commensurate with the safety risks resulting from that exposure.
11E-17 What criteria are in place to determine whether a fire protection system inspection or response activity should be terminated due to the potential for receiving high levels of exposure to ionizing radiation? Who is responsible for making this decision?
11F Post-operational activities and related systems will be adequate to compensate for safety vulnerabilities resulting from age-related degradation, including an appropriate margin to accommodate uncertainties in material status.
11F-18 Have the current, new, and planned process controls and safety systems been assessed for continuing fire protection requirements? What were the results of the assessment?
11F-19 What fire protection compensatory actions or system upgrades are planned to support operating and safe-shutdown availability and reliability during the post-operational period?
11F-20 How frequent are fire protection inspections of facilities performed and do the inspections include assessments of the effects of age-related degradation? What were the results of the assessments performed to date?
11F-21 What plant design problems or temporary conditions require workarounds in order to ensure adequate fire protection?
11F-22 Are cathodic protection systems and other corrosion prevention methods needed to ensure the availability of fire fighting water sources and the fire main distribution system? How was this determined?
11G The generation of radioactive waste during post-operational activities will be minimized to the extent feasible.
This principle is not related to the fire protection program.
11.2.2 Nuclear Safety Principles and Key Questions for Post-Operational Activities at Nuclear Facilities Where a Nuclear or Radiological Hazard of Concern Exists
11H Fire protection work activities will be performed in a formal and controlled manner on a continuing basis.
11H-23 Is there an up-to-date and comprehensive fire protection system and equipment list available to the fire protection staff? Where is it located?
11H-24 Are fire protection system modifications and maintenance procedures that impact system or fire barrier availability included as part of the centrally controlled maintenance program? Which maintenance procedures apply to fire protection structures, systems, and components?
11H-25 What process ensures the adequacy of fire watches for post-operational hot work and activities not specifically covered by fire protection systems?
11I The configuration and status of the physical plant will be documented and controlled on a continuing basis.
11I-26 How are fire protection system configuration changes and temporary modifications reviewed and authorized by appropriate fire protection personnel?
11I-27 How are other process and safety system work packages and system configuration changes formally coordinated with regard to changing fire protection needs?
11J Positive control of nuclear processes and their safety systems, including communications and instrumentation systems, will be maintained.
11J-28 How is the availability of appropriate communication systems considered during fire protection and emergency planning activities?
11J-29 How are post-operational safety-related instrumentation, alarm, and video system requirements coordinated with fire protection personnel?
11J-30 Do fire protection and emergency response plans include ensuring that affected areas of the facility have adequate lighting and ventilation under emergency conditions, including instrumentation visibility and cooling of electronics? Are these plans available for review?
11K 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 activities potentially impacting the safety risks addressed in the document.
11K-31 Is there an up-to-date safety or hazards analysis document that has been approved for addressing fire protection and life safety requirements and procedures during the post-operational period? Is it available for review?
11K-32 Have fire protection and life safety equipment and system requirements and related procedures been assessed for changes needed during post-operational activities? Is this assessment available for review?
11K-33 What actions to identify and reduce emergent fire protection and life safety related risks have been taken or planned?
11L 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.
11L-34 What redundant fire protection and related safety systems and automatic controls are in place or planned to provide defense-in-depth for postulated accidents?
11L-35 What fire protection resources been identified and arranged in the local community to provide backup fire protection and rescue support?
11L-36 What fire fighting scenarios do not have adequate or timely levels of prevention and defense-in-depth?
11L-37 Where sprinkler systems are installed, what design features are present to prevent the accumulation of water?
11L-38 Which instruments, communications systems, and controls important to fire protection and life safety are provided with backup power to ensure operability under emergency conditions?
11L-39 What fire protection management or control procedures are in place or planned to ensure the continued effectiveness of passive and active elements of the facility fire protection systems and barriers during planned facility transitions?
11M 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.
11M-40 Which technical safety requirements could be impacted by fire protection organization activities?
11M-41 Are all required fire protection system surveillance activities in place and scheduled for performance during the post-operational period? Are the surveillance results available for review?
11M-42 Are spare parts readily available for critical fire protection system components? Where are they located?
11M-43 Are there procedures and plans in place to formally take fire protection systems and related equipment out of service on a permanent basis? Are these plans and procedures available for review?
11N A program to identify and address unreviewed safety questions will be maintained on a continuing basis.
11N-44 For unreviewed safety questions related to fire protection, what compensatory measures have been taken?
11O Personnel training and qualifications will be maintained on a continuing basis.
11O-45 What is the process for identifying fire protection training requirements and conducting the associated training on a continuing basis during the post-operational period?
11O-46 What are the unique or unusual fire protection training requirements for the post-operational period?
11O-47 Are the current and planned fire protection training requirements adequate for general plant workers and for the fire protection staff? What was the basis for this conclusion?
11P 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.
11P-48 Is there complete and up-to-date documentation on containment barriers, and are the potential impacts of fire protection and life safety activities on containment barriers during the post-operational period identified, evaluated, and addressed systematically? Is this documentation available for review?
11P-49 What fire protection and life safety improvements have been or will be implemented to increase facility access without reducing containment barrier effectiveness?
11Q Emergency response capabilities commensurate with the potential accidents that could reasonably occur at the facility will be available on a continuing basis.
11Q-50 What additional or special fire fighting or life safety equipment is needed to support early response to potential emergencies during post-operational activities?
11.3 Surveillance Activities
DOE post-operational nuclear facility assessments will normally include three complementary components: document reviews, physical plant inspections, and personnel interviews. Each of the fire protection 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 51, an additional question should be entered under the applicable principle, and the number 51 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.
11.3.1 Fire protection -Related Document Review
11.3.1.1 Safety and Hazards Analysis Reports
Questions: 1 3 4 5 11 13 18 19 21 22 23 25 28 29 30 31 34 35 36 37 38 40 42 43 45 46 48
11.3.1.2 Fire Protection Procedures and Plans
Questions: 1 2 5 6 7 8 9 10 11 13 14 15 17 18 19 20 21 23 24 25 26 27 28 29 30 33 35 36 38 39 40 41 42 43 44 45 46 47 48 49
11.3.1.3 Fire Protection Records
Questions: 3 7 10 11 12 15 20 21 23 24 26 27 36 41 42 45
11.3.2 Fire Protection-Related Interviews
11.3.2.1 Fire Protection Manager
Questions: 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 34 35 36 37 38 39 40 41 42 43 44 45 46 47 48 49 50
11.3.2.2 Facility Manager
Questions: 1 2 4 5 6 7 8 11 13 14 15 17 18 19 21 24 25 26 27 28 29 30 33 34 35 36 38 39 40 44 45 47 48 49 50
11.3.2.3 Fire Protection Staff
Questions: 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 32 33 34 35 36 37 38 40 42 45 46 47 49 50
11.3.2.4 Facility Stakeholders
Questions: 1 2 4 13 16 35
11.3.3 Fire Protection-Related Facility Inspections
11.3.3.1 Fire Barriers, Radiation Containment Barriers, and Boundaries
Questions: 3 4 5 8 10 13 14 20 21 22 33 34 36 37 39 46 48 49 50
11.3.3.2 Alarm, Indication, and Communications Systems
Questions: 3 21 26 28 29 30 34 36 38 39 46
11.3.3.3 Process and Safety Systems
Questions: 3 4 5 13 14 18 21 27 33 34 37 46
11.3.4.4 Fire fighting Equipment and Support Facilities
Questions: 3 4 5 8 10 16 20 21 22 23 26 28 29 30 32 33 34 35 36 37 38 39 42 46 50
12.0 SAFEGUARDS AND SECURITY
12.1 Introduction
Safeguards and security (S&S) measures at DOE sites and facilities are designed to protect government interests from theft or diversion of special nuclear material (SNM), sabotage, espionage, loss or theft of classified material or government property, and other hostile acts which could cause unacceptable adverse impacts on national security or on the health and safety of employees, the public, or the environment. The level of protection at a site should be appropriate to that site's security interests as reflected in a formal, up-to-date security vulnerability assessment report. These interests include protection of SNM (physical and material accountability), protection of property, and protection of information (classified and/or sensitive).
During the performance of the range of facility deactivation, decommissioning, and decontamination activities, it is expected that the level of protection to be afforded to a facility will change as the security interests change. Following facility transition, some activities may result in increased security risks if compensatory measures are not taken. For instance, during facility deactivation, a facility may have to remove security barriers or disconnect security alarms prior to removing piping or systems containing significant quantities of SNM. If classified documents or equipment or special nuclear materials can be removed from the facility early in the decontamination and decommissioning process, the need for security or safeguards activities and equipment can be reduced.
An effective S&S program in the post-operational environment must also include an awareness of when certain S&S activities or requirements can be relaxed or no longer apply. For example, when a production facility is taken out of operation, the associated routine access to classified materials or SNM vaults is no longer needed, and continuing, mandatory access is generally reduced to accountability inventory requirements and container inspections. Since the increased radiological exposure and security risks associated with such access may be inconsistent with continuing S&S needs, a risk-based review of S&S requirements should be undertaken to determine the post-operational S&S needs and procedures. Once a facility completes the deactivation process, it is anticipated that all significant quantities of SNM will have been removed. At that point, the facility should be primarily protected against industrial sabotage and loss or theft of classified material and government property.
Independent oversight of a post-operational nuclear facility S&S program will normally involve determining whether an adequate S&S program is in place and planned for the rest of the facility life cycle. Facility managers must demonstrate that they have identified and planned for any unique S&S requirements, have identified any additional S&S equipment or resources that may be needed to accomplish facility deactivation, decontamination, and decommissioning; and have planned to have appropriate resources available to meet routine S&S surveillance requirements during the post-operational period.
12.2 Safeguards and Security-Related Nuclear Safety Principles and Question Sets
Question sets for assessing the safety related aspects of S&S programs during the post-operational period are presented below for each of the Nuclear Safety Principles. The evaluator should determine whether a principle is understood and being implemented in a positive manner from a safeguards and security 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.
* * * *
Caution shall be exercised in recording responses to the questions in this section as the answers to the questions may involve classified, sensitive security, or safeguards information that must be protected from release to unauthorized persons. Responses that could contain such information should be avoided wherever possible. If a response must contain such information, the documentation of the response shall be appropriately classified.
* * * *
12.2.1 Nuclear Safety Principles and Key Questions for Post-Operational Safeguards and Security at All Nuclear Facilities
12A Facilities will meet applicable federal, state, and local health and safety laws and regulations, including those identified by contract or other form of agreement.
12A-1 Which post-operational S&S requirements have been derived from applicable federal, state, and local health and safety laws and regulations? Have the actual systems been verified to meet those requirements? What requirements in DOE S&S Orders (5630 series) are not being met? Is S&S program compliance verification documentation available for review?
12A-2 Has a formal assessment determined which current and planned activities at the post-operational facility are impacted by DOE S&S requirements and what modifications might be needed? What are they? Is the assessment documented and available for review? What are the ongoing S&S requirements?
12A-3 What administrative procedure ensures continuing reviews of conformance with S&S requirements during the post-operational period?
12A-4 Do managers, supervisors, and workers know who is responsible for providing guidance on S&S requirements for post-operational activities and how to obtain that guidance in their areas of responsibility? Who are they? Do these persons acknowledge their responsibilities?
12A-5 What is the phased plan and budget to increase or decrease S&S capabilities as needed to meet the changing requirements in the post-operational environment? Is the current and planned staffing of the S&S organization sufficient to keep up with work requirements? What is the backlog of work?
12A-6 At what point in the post-operational period will security and safeguards no longer be required? What is the basis for each termination? Is the basis documented and available for review?
12A-7 What actions have been taken by facility managers to minimize the need for security and safeguards activities during the post-operational period (e.g., [1] determination that certain buildings, areas, equipment, or systems no longer require physical protection, [2] removal of SNM, classified equipment, or documents from the facility)?
12B The exposure of any person to radiation will be kept as low as is reasonably achievable (ALARA) under a systematic program.
12B-8 During security response activities, how will personnel exposures to potential airborne and surface contamination or equipment that is otherwise radioactive be minimized? What protective equipment is provided? How will it be provided, and where will it be kept? What remotely operated security equipment is available to help keep exposures down during emergency response activities?
12B-9 How does each individual involved with S&S activities know the facility radiation levels and understand his or her personal role in minimizing exposure? Where are security posts located relative to the lowest radiation areas?
12B-10 What routine radiation exposures are associated with inspecting and maintaining S&S systems and equipment and performing S&S-related functions? How can such exposures be reduced?
12C No person will receive doses of ionizing radiation in excess of the statutory dose limits during post-operational S&S activities.
12C-11 Do S&S personnel dose records show that any security or safeguards personnel are approaching administrative dose limits or a statutory dose limit? Under what conditions might exceeding one of these limits occur?
12C-12 How are S&S personnel made aware of plant radiation levels, areas where radiation levels might change, and their own cumulative radiation exposure?
12C-13 Are security and safeguards training exercises planned and conducted in such a way to minimize doses to exercise participants? What is done to minimize doses during exercises?
12D All practical steps will be taken to prevent radiological accidents during post-operational activities.
12D-14 How are S&S response plans and training exercises assessed in terms of the possibility that they could contribute to changes in the severity of accidents? Are these assessments documented and available for review?
12D-15 What can safeguards and security personnel do to prevent radiological accidents? Have radiological accidents occurred (or could they occur) at this or similar facilities as a result of inadequate S&S procedures? If they have, what preventive measures have been put in place in response?
12E Post-operational activities involving exposure or potential exposure to ionizing radiation will result in benefits commensurate with the safety risks resulting from that exposure.
12E-16 What criteria are in place under which a determination might be made that an S&S inspection or response activity should be terminated due to the potential for receiving significant levels of exposure to ionizing radiation? Who is responsible for making this decision?
12F Post-operational activities and related systems will be adequate to compensate for safety vulnerabilities resulting from age-related degradation, including an appropriate margin to accommodate uncertainties in material status.
12F-17 What compensatory actions or system upgrades are planned to support S&S protection equipment availability and reliability during the post-operational period?
12F-18 What periodic S&S inspections of facilities and tests of S&S equipment and systems have been performed, and how do the inspections include assessments of the effects of age-related degradation? Is the assessment documented and available for review? Are written procedures used for these inspections and tests? Are these procedures controlled by the facility configuration management program?
12G The generation of radioactive waste during post-operational activities will be minimized to the extent feasible.
12G-19 How will routine and response exercises be conducted so as to minimize the generation of radiological waste (e.g., minimize or not require use of disposable protective clothing for routine or exercise activities).
12.2.2 Nuclear Safety Principles and Key Questions for Post-Operational Activities at Nuclear Facilities Where a Nuclear or Radiological Hazard of Concern Exists
12H S&S work activities will be performed in a formal and controlled manner on a continuing basis.
12H-20 Is there an up-to-date and comprehensive S&S system and equipment list available to the S&S staff? Is it controlled by the facility's configuration management system? Is it available for review?
12H-21 How are S&S system modifications, surveillance, and maintenance procedures that impact system or security barrier availability included in the centrally controlled maintenance program?
12I The configuration and status of the physical plant will be documented and controlled on a continuing basis.
12I-22 Are S&S system configuration changes and temporary modifications reviewed and authorized by appropriate S&S personnel? Please provide a documented example.
12I-23 How are other process and safety system work packages and system configuration changes formally controlled in a manner that ensures coordination with S&S interests?
12J Positive control of nuclear processes and their safety systems, including communications and instrumentation systems, will be maintained.
12J-24 How are S&S personnel notified of plant process system problems. Are important nuclear safety and environmental instrumentation system alarms or indications provided at security and command posts? Are they in good condition and understood by security personnel? On what basis were your conclusions reached?
12J-25 How are the instrumentation and communications systems important to nuclear and environmental safety response provided with backup or alternative circuits or power supplies?
12K 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 activities potentially impacting the safety risks addressed in the document.
12K-26 How does the approved safety or hazards analysis document that addresses S&S communications interfaces, accident response requirements, and plant evacuation support procedures across security boundaries as they may apply for unique activities during the post-operational period?
12K-27 Have routine S&S equipment, system requirements, and related procedures been assessed for changes needed during post-operational activities? Is this assessment included in the facility's safety or hazards analysis documentation? Is it available for review?
12M-28 When will each S&S related communications and instrumentation system be taken out of service, and what criteria provide a basis for those actions? Is this basis consistent with and included in the facility's safety or hazards analysis documentation?
12L 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.
This principle is not related to the S&S program.
12M 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.
12M-29 What technical safety requirements could be impacted by S&S organization activities?
12M-30 What S&S surveillance activities are in place and scheduled for performance during the post-operational period?
12M-31 Where are spare parts for S&S system components kept and how are they controlled?
12M-32 What procedures and plans are in place to formally take S&S systems and related equipment out of service on a permanent basis? Are there records of equipment that has been removed from service and the disposition of that equipment? Are these records available for review?
12N A program to identify and address unreviewed safety questions will be maintained on a continuing basis.
12N-33 What unreviewed safety questions are related to S&S?
12N-34 For unreviewed safety questions related to S&S, have compensatory measures been needed? Are they in place? Please provide examples.
12O Personnel training and qualifications will be maintained on a continuing basis.
12O-35 What is the process for identifying S&S training requirements and conducting the associated training on a continuing basis during the post-operational period?
12O-36 What are the unique or unusual S&S training requirements for the post-operational period?
12O-37 Are the current and planned S&S training requirements adequate for general plant workers and for the S&S staff? What is the basis for your conclusion?
12O-38 Has the effectiveness of the S&S training been assessed? Is the assessment documented and available for review?
12P 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.
This functional area is not related to the S&S program.
12Q Emergency response capabilities commensurate with the potential accidents that could reasonably occur at the facility will be available on a continuing basis.
12Q-39 Have S&S activities been coordinated with emergency response activities to ensure that they do not conflict with each other? What conflicts were found? What is being done to resolve these conflict[s]?
12.3 Evaluation Approach for Post-operational Safeguards and Security
DOE post-operational nuclear facility assessments will normally include three complementary components: document reviews, physical plant inspections, and personnel interviews. Each of the S&S 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 40, an additional question should be entered under the applicable principle, and the number 40 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.
12.3.1 S&S-Related Document Review
12.3.1.1 Security Vulnerability Analyses; Safety and Hazards Analysis Reports
Questions: 1 2 6 8 9 14 16 26 27 28 24 25 26 29 39
12.3.1.2 S&S Procedures and Plans
Questions: 2 3 4 5 6 7 8 9 10 13 14 15 16 17 18 19 21 22 24 25 26 27 29 30 31 32 34 35 38 39
12.3.1.3 S&S Records
Questions: 6 11 15 18 20 22 32 38
12.3.2 S&S-Related Interviews
12.3.2.1 S&S Manager
Questions: 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 34 35 36 37 38 39
12.3.2.2 Facility Manager
Questions: 1 2 4 5 6 7 8 10 14 15 16 19 22 23 24 25 26 28 29 32 33 34 39
12.3.2.3 S&S Staff
Questions: 4 8 9 10 11 12 13 18 19 20 21 22 24 25 31 32 35 36 37
12.3.2.4 Facility Stakeholders
Questions: 1 15 24 26
12.3.3 S&S-Related Facility Inspections
12.3.3.1 S&S Barriers and Boundaries
Questions: 1 7 8 12 13 14 18 20 21 22 24 25 28 31 32
12.3.3.2 S&S Alarm, Indication, and Communications Systems
Questions: 20 24 25 28 32
12.3.3.3 S&S Systems and Equipment and Support Facilities
Questions: 2 7 8 9 10 17 18 19 20 21 22 24 25 28 31 32
INDEX
abandon in place 117, 120
access routes 136, 143
accidents 25, 26, 30, 37, 39, 45, 48, 57, 62, 70, 71, 75, 84, 87, 95, 98, 116, 121, 123, 138, 149
administrative control limits, radiation exposure 44, 57, 70, 83, 95, 115, 138, 149
administrative controls 60, 96
age-related degradation 26, 37, 46, 58, 72, 84, 95, 117, 128, 139, 150
ALARA 24, 35, 44, 56, 69, 83, 94, 115, 127, 137, 148
alarm systems 33, 53, 62, 80, 91, 111, 125, 135, 140, 145, 146, 151, 155
annual surveillance plan 7
approval process 61
as-built configurations 107
automatic controls 120, 130, 141
auxiliary systems, support facilities 33, 42, 53, 66, 67, 68, 80, 92, 102, 111, 125, 135, 145, 155
back-up systems 67, 68, 75, 83, 87, 88, 130, 141, 151
benefits, for radiation exposure 26, 37, 45, 58, 71, 84, 95, 116, 139, 149
beyond design basis 132
budget 31, 107, 148
calibration program 74, 86, 108, 115, 118, 119
cathodic protection 72, 85, 139
change controls 106
changes in procedures 45
changes in structures, systems, and components 47, 106
characterization 60
chemical composition 60
chemical hazards 2
chemistry 49, 76, 88, 99
classified documents or equipment 146
common-cause failures 29, 131
communication 46, 73, 118, 126, 129
communication systems 33, 47, 53, 60, 74, 80, 86, 91, 96, 97, 111, 119, 125, 130, 131, 135, 140, 141, 145, 151, 152, 155
compensatory measures 107, 139, 146, 150, 153
conduct of operations 46, 59, 73, 96
configuration management 27, 47, 60, 73, 81, 86, 97, 103 - 111, 119, 140, 150, 151
containers 54, 59, 62
containment barriers 30, 40, 42, 49, 50, 52, 54, 57, 63, 65, 67, 75, 77, 80, 88, 89, 91, 98, 100, 121, 122, 125, 126, 135, 136, 143, 145
contamination 34, 56, 61, 70, 72, 75, 87, 115, 121, 123, 136, 138, 148
contractors 50, 77, 99, 115, 116, 118, 121, 123
control of facility processes 130
control room 53
control room manager 42, 52
controlled documents 27, 107
controls and instrumentation 48, 50, 67, 68, 77, 87, 89, 100, 122, 130, 139, 141, 144
cooling of electronics 141
corrosion prevention 49, 59, 67, 72, 85, 99, 139
costs 26, 107
criticality safety 34, 60, 61, 87, 126
custody transfers 117
cutting torches 136
deactivation, def: 12
decommissioning, def: 12
decommissioning plan 105, 107
decontamination, def: 12
defense-in-depth 28, 39, 43, 48, 62, 75, 87, 98, 120, 121, 141
design basis 81, 84, 85, 103, 104, 106, 107, 112, 113, 117, 120, 121, 129, 132, 141
design controls 60, 116, 123
disconnections, out-of-service equipment 119
dismantlement, def: 12
document control system 27, 103, 104, 106
document review 8
documentation 47, 73, 97, 105, 107
DOE Order 5480.22, Technical Safety Requirements 28, 49, 62, 76, 88, 98, 108, 131, 142, 152
DOE Order 5480.7A, Fire Protection 136 -145
DOE Order 5700.6C, Quality Assurance
112 - 125
DOE Orders 1, 112, 127
DOE Orders 5630 series, Safeguards and Security 146 - 155
dose reduction 44, 56, 69, 83, 94
dosimetry 25, 36, 57, 70, 115
double-walled containments 87, 120
drawings 27, 73, 104, 105, 107, 110, 119, 130
drills 31, 130, 132
EH Deputy Assistant Secretary for Independent Oversight and Appraisals 5
EH Office of Independent Oversight and Appraisals 2
EH Residents 6
electrical power 87
emergencies 88, 130
emergency drills 31, 130, 132
emergency exposures 128
emergency information 133
Emergency Planning 126 - 135
emergency plans and procedures 129, 130, 132, 133
emergency power supply 130
emergency response 31, 41, 50, 63, 78, 100, 110, 123, 126 - 135, 136, 137, 153
emergency response equipment 130, 131, 132, 135
emergency response personnel and resources 131
engineered safety systems 60, 87, 120, 122
Engineering 81 -92
engineering features 63
engineering managers 91
engineering procedures and plans 90
engineering records 90
engineering requirements 83
engineering reviews 84
engineering staff 91
entombment, def: 12
environmental protection 1, 2, 25, 107, 118, 119, 128
equipment information 47, 72, 73, 85, 86, 89, 93, 96, 108, 119, 122, 140, 143, 150
equipment isolation and removal 49, 68, 76, 88, 99, 106, 119, 120, 121, 142, 152
equipment mockups 69, 83, 94
equipment performance 121
equipment problems 37, 46, 49, 58, 67, 70, 71, 96, 99, 104, 120, 137, 148
evacuation 51, 100, 151
exercises 31, 130, 132
exposure to radiation 25,, 34, 36, 37, 45, 56, 58, 70, 83, 84, 94, 95, 105, 115, 117, 123, 127, 138, 149
facility, def: 12
facility managers 33, 42, 52, 65, 79, 91, 101, 111, 124, 144, 155
facility transitions 1, 88, 103, 121, 142
fire barriers 135, 140, 145
fire fighting equipment 145
fire hazards 136
fire main distribution system 139
fire protection 59, 60, 63, 72, 85, 87, 136-145
fire protection engineer 137
fire protection manager 144
fire protection procedures and plans 144
fire protection records 144
fire protection staff 144
fire protection systems and equipment 136, 138, 140
fire watches 140
fissionable materials 34, 61, 87
flammable materials 137
flooding 63, 87
floors 117
formality 38, 46, 59, 73, 85, 116, 118
handling equipment 81, 108
hazard, def: 12
hazardous materials 114, 136
hazards and safety analysis documentation 26, 28, 32, 41, 48, 51, 61, 64, 74, 78, 86, 90, 98, 101, 104, 105, 107, 108, 110, 120, 121, 122, 124, 127, 128, 130, 131, 134, 141, 144, 151, 154
hazards of concern, 2
health physics manager/supervisor 42
high radiation areas 83
high level waste storage 60
high-risk facilities 7
holdup 34
hot spots 36, 57, 70
hot work 140
independent verifications 48, 61, 75, 88, 98, 113
industrial accidents 126
industrial hazards 2, 3
industry operating experience 96
initiation of activities 48
inspections 8, 42, 43, 52, 62, 72, 81, 84, 104, 116, 123, 136, 139, 149, 150
instrumentation 39, 47, 48, 50, 67, 68, 74, 77, 87, 89, 100, 119, 122, 128, 130, 140, 141, 144, 151, 152, 33, 53, 74, 80, 86, 88, 91, 97, 111, 119, 125, 135, 141, 145, 155
interagency communications 126, 129
interfaces 82, 93
internal oversight 27, 115, 117, 121
interviews 8
intra-building movement 57
inventory checks 116, 146
laws and regulations 23, 35, 44, 55, 68, 82, 94, 104, 114, 127, 137, 147
lay-up requirements 49, 76, 88, 99
lesson plans 94
lessons-learned program 50, 77, 89, 96, 99, 109, 122
life safety 136, 141
lighting 48, 74, 83, 86, 140
load testing records 108
local community, stakeholders 33, 35, 39, 42, 52, 54, 55, 58, 65, 80, 102, 105, 111, 114, 125, 134, 141, 144, 155
lockout/tagout 47, 73, 97, 119
log taking 53, 121
low-level waste 55
maintenance history 104, 107
maintenance and surveillance 1, 35, 67 - 80, 103, 140, 151
maintenance and surveillance procedures and plans 78
maintenance and surveillance records 79
maintenance manager/supervisor 79, 134
maintenance workers 79
maintenance-related exposures 35
management 22 - 33, 93, 120
master equipment list 72, 85
material accountability, SNM 146
material degradation 46, 71, 96, 120
material history 104, 107
material movements 60
mission of the facility 105
mixed wastes 60
mockups 69, 83, 94
modifications 86, 103, 119, 140, 151
monitoring instruments 128
monitoring performance 22
neutron moderation 34, 60, 61, 87, 126
non-radioactive hazardous material 114, 136
non-reactor facilities 126
nuclear hazards of concern, def: 12
nuclear or radiological hazards of concern 2
nuclear processes 47, 97
nuclear safety principles 2, 19
obsolete plant equipment 119
onsite transfers 57
operability 49, 67, 76
operating experience 96
operating personnel 74
operating stations 48, 53
operational exposures 35
operating records 51
operations 43 - 53
operations manager/supervisor 52, 134
operators 43, 49, 52, 87, 98
out of service facilities and equipment 49, 76, 88, 99, 121, 142, 152
oversight 27, 115, 117, 121
packaging and shipping personnel 65
packaging and storage-related structures, systems, and components 66
packaging and transportation 54 - 66, 72, 85
packaging and transportation managers/supervisor 65
packaging and transportation procedures and plans 64
packaging and transportation records 64
passive barriers 67
passive engineering controls 63, 87, 120
personnel accounting procedures 51, 100, 151
physical plant condition 43, 104
physical protection 148
pipes 87, 120
planning 7, 25, 26, 31, 35, 36, 55, 56, 57, 63, 68, 69, 82, 93, 104, 114, 126, 137, 140
plans 32, 39, 51, 67, 83, 107, 110, 124, 128, 129, 142
plant status 47, 72, 73, 85, 86, 96, 108, 119, 140, 143, 150
plant walk downs 81
population centers 39
portable structures, standards (DOE/EV-0043) 137
power supplies 67, 68, 83, 151
preservation of plant equipment 49, 59, 67, 70, 72, 85, 99, 139
preventive maintenance 76
preventive measures 149
principles 2, 19
procedural formality 38, 46, 59, 73, 85, 116, 118
procedures 27, 31, 32, 36, 39, 43, 44, 46, 49, 51, 56, 59, 60, 62, 67, 68, 69, 71, 73, 82, 83, 88, 96, 99, 105, 106, 107, 110, 124, 128, 129, 130, 141, 146, 149, 151, 152
process and safety systems 53, 80, 92, 111, 125, 135, 145
process safety management 25
procurement 118, 119
Project Coordinator for EH D&D Oversight and Technology Review Activities 5
project management plans 107
protective action guides (PAG) 126
protective coatings 70
protective equipment 137, 148
qualification requirements 50, 62, 77
qualified personnel 48
quality assurance 112 - 125
quality assurance manager 124
quality assurance program staff 125
question sets 4, 22 - 155
radiation containment barriers and boundaries 63, 111
radiation detection equipment technicians 40, 42
radiation detection systems 39, 41, 63
radiation exposure 25, 34, 35, 36, 37, 38, 45, 56, 57, 58, 70, 83, 84, 85, 94, 95, 105, 115, 117, 123, 127, 128, 138, 148, 149
radiation hot spots 36, 57, 70
radiation levels 36, 57, 69, 70, 83, 95, 115, 138, 148, 149
radiation monitoring programs 25, 115
radiation protection organization 38
radiation survey exposures 35
radiation survey point maps 38
radiation survey report 107
radiation workers 42
radioactive liquids 85
radioactive material, def: 13
radioactive materials 34, 114, 138
radioactive waste, def: 13
radioactive waste 38, 46, 59, 72
radiological accidents 25, 37, 45
radiological consequences 39, 75, 87
radiological control procedures 41
radiological controls 34 - 42
radiological controls records 42
radiological controls-related facility inspections 42
radiological hazard of concern, def: 13
radiological or nuclear hazards of concern 2
radiological safety managers 134
radiological vulnerabilities 37
receipt inspections 118
records 47, 50, 60, 73, 81, 86, 97, 105, 107, 108, 112, 114, 115, 117, 118, 119, 124, 152
reference material 53
regulations and laws 23, 35, 44, 55, 68, 82, 94, 104, 114, 127, 137, 147
releases 38, 128
reliability 29, 40, 48, 67, 74, 121, 132, 139, 150
remotely controlled equipment 36, 44, 56, 69, 83, 94, 127, 138, 148
reports 6, 9, 14
repository 34, 60
required-reading 50, 77, 89, 99, 122
rescue support 141
resources 22, 31, 34, 43, 58, 71, 81, 84, 93, 116, 126, 133, 138, 146
response plans 149
responsibilities 5, 22, 24, 28, 105, 129, 132, 137, 148
retired equipment 49, 68, 76, 88, 99, 106, 119, 120, 121, 142, 152
risk 26, 29, 37, 58, 71, 84, 95, 113, 116, 120, 122
roofs 117, 128
root causes 24
safeguards and security 146 - 155
safeguards and security barriers and boundaries 155
safeguards and security manager 154
safeguards and security procedures and plans 154
safeguards and security records 154
safeguards and security staff 155
safeguards and security systems and equipment 155
sabotage 146
safe shutdown 43, 139
safe storage, def: 13
safe storage 56, 57, 60, 63, 87
safety and hazard analysis documentation 28, 32, 41, 48, 51, 61, 64, 74, 78, 86, 90, 98, 101, 104, 105, 107, 108, 110, 120, 121, 122, 124, 127, 128, 130, 131, 134, 141, 151, 144, 154
safety categorizations 40, 49, 62, 76, 109, 121
safety concerns raised by workers 30
safety culture 30, 36, 44, 46, 56, 60, 69, 73, 83, 94, 96, 115
safety features 60
safety margin 122
safety risks 26, 29, 37, 58, 71, 84, 95, 113, 116, 120, 122
safety significance 29
safety system requirements 47, 97
safety systems 47, 98, 121, 139
safety and process systems 39, 41, 53, 63, 80, 92, 111, 125, 135, 139, 145
safety vulnerabilities 43
safety-related systems 68
schedule 6, 7
scope of the surveillance 2, 7
security boundaries 135, 151
security posts 148
security risks 146
security vulnerability analyses 154
seismic events 87
senior managers 33
shielding 38, 60, 83
shift turnover 47, 73, 96
significant quantity of fissionable material, def: 13
significant quantity of radioactive material, def: 13
site entry 56
site final condition 112, 114
site radiological characterization 119
source term 128
spare parts 67, 88, 142, 152
special equipment 63, 89, 100, 123
special nuclear material (SNM) 146
sprinkler systems 87, 141
staff personnel 33, 137, 148
stakeholders, local community 33, 35, 39, 42, 52, 54, 55, 58, 65, 80, 102, 105, 111, 114, 125, 134, 141, 144, 155
status information 47, 50, 74, 86, 107, 129
statutory dose limit 44, 57, 70, 83, 95, 115, 138, 149
stop work 114, 115
storage 56, 57, 60, 63, 87
structural members 117
subcontractor 116, 123
subcontractor manager 33, 124
subcontractors 33, 116, 123, 124, 94, 115, 118, 119, 120, 121
support facilities, auxiliary systems 33, 42, 53, 66, 67, 80, 92, 102, 111, 125, 135, 145, 155
surveillance and maintenance, def: 13
surveillance, conducting 8
surveillances 1, 3, 6, 8, 35, 49, 62, 67, 88, 98, 117, 121, 142
surveillance activity exposures 35
survey records 105
system descriptions 104
systems approach 82
tanks 87, 120
team coordination 5
technical safety requirements 28, 49, 62, 76, 88, 98, 108, 131, 142, 152
technical skills 22, 130
technical standards program 11
telephone system 131
temporary systems 43, 67, 121
termination of configuration management requirements 119
test procedures 112, 116
training 30, 35, 40, 50, 62, 63, 77, 89, 93-102, 116, 118, 121, 122, 126, 129, 132, 136, 138, 142, 149, 153
training manager/supervisor 101
training procedures and plans 101
training records 101
training staff 102
transitions, facility 1, 88, 103, 121, 142
transportation safety manual 57
treatment systems 85
trends 6, 25, 27, 35
Type A quantity 57
uncertainties 46, 59, 71, 84, 96, 103, 107
unreviewed safety questions 30, 40, 49, 62, 76, 88, 99, 109, 122, 142, 153
upgrades 93, 136, 150
ventilation 48, 67, 74, 82, 86, 137, 141
ventilation filters 137
video systems 140
vulnerability assessment 146
walls 117
waste acceptance criteria 55
waste management 26, 34, 46, 55, 59, 63, 72, 81, 85, 87, 93, 114, 117, 118, 126, 129, 150
waste storage 56, 57, 60, 63, 87
watchstander turnover 47, 73, 96
water sources 139
work packages 151
workarounds 46, 59, 72, 84, 96, 139
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